Privacy Policy

This Privacy Policy explains how Phoenix Veritas Ventures Ltd. (the Company, "we", "us", or "our") collects, uses, shares, and protects information in connection with this website and the features made available through it (the "Website"). It forms part of, and is incorporated by reference into, our Terms & Conditions.

"Personal Information" means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household.

By using the Website you acknowledge this policy. If you do not agree with it, please do not use the Website. This policy does not apply to any third-party website, exchange, wallet, or application that you reach from the Website, each of which has its own privacy practices.

We take commercially reasonable physical, electronic, and administrative steps to protect the information we hold from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Those measures include encryption of traffic in transit, restricting access to systems to those who need it, and applying authentication controls to administrative access.

No method of transmission over the internet and no method of electronic storage is completely secure, however, and we cannot guarantee absolute security. We are not responsible for any unauthorised access, disclosure, or loss arising from causes beyond our reasonable control, including hacking, exploitation of a third-party vulnerability, interception in transit, sabotage, or terrorism. Any transmission of information to us is at your own risk.

Phoenix Veritas Ventures Ltd. will never call, text, email, direct-message, or otherwise contact you to request your private keys, seed phrase, passwords, or other sensitive information. Anyone who does so is attempting to defraud you. Please be careful.

We collect information in two ways: information that you provide to us voluntarily, and information collected automatically by technology when you visit the Website. Each is described below. We do not operate user accounts, we do not process payments, and we do not ask you to identify yourself in order to browse the Website.

You may choose to provide us with:

• your email address and any name or handle you give, when you write to us or subscribe to updates;
• the contents of your message, including anything you choose to include in it;
• a public wallet address, where you voluntarily supply one — for example in connection with an airdrop claim, a community activity, or a support request; and
• your communication preferences.

Providing this information is entirely voluntary. If you do not provide it, you can still browse the Website; we may simply be unable to respond to you or to include you in the activity concerned.

We ask that you do not send us sensitive personal information — such as government identification numbers, financial account details, health information, or information revealing racial or ethnic origin, religious belief, or political opinion — and we do not request it. Please do not send us your private keys or seed phrase under any circumstances.

When you visit the Website, our hosting, security, and analytics providers automatically record certain technical information, including:

• your IP address and the approximate geographic region derived from it;
• your browser type and version, operating system, device type, and screen characteristics;
• your language preference;
• the website or source that referred you to us;
• the pages you view, the links you follow, and actions you take on the Website; and
• the date, time, and duration of your visit.

This information is used in aggregate to operate, secure, and improve the Website and to understand traffic patterns. We do not use it to build a profile of you or to identify you personally.

Most browsers accept cookies automatically but allow you to refuse or delete them through their settings. Refusing cookies may affect the operation of parts of the Website. See "Tracking tools" below.

Transactions involving the token are recorded on a public blockchain by the network itself. That ledger is public, permanent, and outside our control. We do not write to it on your behalf, we cannot amend or erase anything recorded on it, and no request under this policy can require us to do so.

We do not attempt to link wallet addresses to identities. Where you connect a wallet to a third-party exchange, marketplace, or application reached from the Website, that connection and any information it discloses are governed by that service's own privacy policy, not by this one.

We do not engage in automated decision-making that produces legal or similarly significant effects. We use the information described above to:

• operate, maintain, host, secure, and improve the Website;
• respond to your messages, requests, and questions;
• send you updates you have asked to receive, and administer any community activity you take part in;
• measure and understand aggregate traffic and how the Website is used;
• detect, investigate, and prevent security incidents and malicious, deceptive, fraudulent, or illegal activity, and protect the rights, property, and safety of any person;
• debug and repair errors that impair intended functionality;
• perform our obligations under, and enforce, our Terms & Conditions; and
• comply with applicable law, regulation, and legal process.

Where we rely on consent — for example to send you marketing updates — we obtain it by affirmative action, such as your ticking a box or clicking a button, and you may withdraw it at any time. Withdrawing consent does not affect communications that are necessary rather than promotional, such as a notice about a security incident or a material change to this policy.

We do not sell your Personal Information, and we do not share it with third parties or affiliates for their own direct marketing purposes.

We share information only in the following circumstances:

• with service providers who host the Website, deliver content, protect against abuse, distribute email, or provide analytics — each acting on our instructions, for the limited purpose of performing that service for us, and under an obligation to protect the information;
• where required by applicable law, regulation, subpoena, court order, or other valid legal process, or in response to a lawful request by a public or governmental authority;
• where we believe in good faith that disclosure is necessary or appropriate to investigate or prevent fraud, misrepresentation, improper or illegal conduct, infringement of intellectual property rights, a violation of our Terms & Conditions, or any activity that exposes us or any person to liability or harm;
• to establish, exercise, or defend legal claims; and
• to a successor or acquirer in connection with a merger, acquisition, financing, reorganisation, or sale of assets, in which case this policy will continue to apply to the information transferred until the recipient provides notice of a different policy.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you, for any purpose.

Where you take part in a community activity, campaign, or airdrop claim connected with the Website, we may collect the information necessary to administer it — typically an email address, a handle, and a public wallet address — and use it to verify eligibility, prevent abuse and duplicate entry, administer the activity, and confirm your participation.

We may use your contact details to confirm your participation, send reminders and updates about the activity, notify you of changes, and provide related information. Communications are normally sent by email. Where you provide a telephone number and opt in to messages, standard message and data rates set by your carrier may apply, and you may stop them at any time by replying with the stop keyword indicated or by contacting us.

We do not operate targeted advertising or remarketing campaigns, we do not use advertising cookies, and we do not participate in advertising co-operatives or cooperative databases. We do not permit third-party advertising networks to collect information about you through the Website for interest-based advertising.

Should that change, we will update this policy before doing so and, where consent is required, obtain it. For your general awareness, if you wish to limit interest-based advertising across the web more broadly, industry opt-out tools are available from the Network Advertising Initiative at networkadvertising.org, the Digital Advertising Alliance at optout.aboutads.info, and, for mobile applications, the DAA's AppChoices tool. Those opt-outs are cookie- and device-based, so you must apply them on each browser and device you use, and they do not stop all data collection — operational and fraud-prevention collection may continue.

A cookie is a small text file placed on your device by a website, which may contain an identifier, your preferences, and a record of activity. The Website uses only the following categories:

• Strictly necessary cookies, which enable core functions such as security, network management, and remembering choices required for the Website to work. These cannot be switched off in our systems without the Website ceasing to function properly.
• Performance cookies, which collect aggregated and anonymous information about how the Website is used — such as browser and operating system, pages viewed, and time on page — so that we can improve it. They do not identify you individually.
• Functionality cookies, which remember choices you make, such as language or region, in order to provide a more consistent experience. They do not track your activity across other websites.

We may also encounter or use web beacons — also called clear GIFs or pixel tags — which are small embedded graphics used to understand whether a page or an email has been viewed, and simple analytics that record aggregate interaction such as page depth and navigation. We do not use session-replay tools that record your keystrokes or the contents of what you type.

You can control cookies through your browser settings, which usually allow you to see what cookies are stored, delete them individually or entirely, and block them from some or all sites. Blocking cookies may cause parts of the Website to stop working. Browser help pages explain how to do this for each browser.

We use privacy-respecting analytics to understand aggregate traffic. Where a service such as Google Analytics is used, it sets cookies or similar identifiers that record information about your visit, including the frequency and timing of visits, the pages viewed, the approximate region, and your IP address.

Where Google Analytics is in use we enable IP anonymisation, so that your IP address is truncated before storage and is not retained in full. We do not enable Google Analytics advertising features, audience remarketing, or the association of analytics data with advertising identifiers.

You can prevent analytics cookies through your browser settings as described above, or by installing the Google Analytics opt-out browser add-on available from Google. That add-on prevents Google Analytics from collecting data about your visit; it does not prevent other analytics services or our own server logs from operating. Analytics providers may transfer information to third parties where required to do so by law.

If you have asked to receive updates from us, you may stop them at any time by clicking the unsubscribe link in any message we send, or by writing to [email protected]. Please allow up to ten business days for your request to take effect, during which messages already in process may still reach you.

Opting out of updates does not stop communications that are necessary rather than promotional — for example, a reply to a question you asked us, a notice of a material change to this policy, or a notification required by law such as a data breach notice.

We will not deny you access to the Website, charge you a different price, or provide you with a different level of service because you decline to provide Personal Information or exercise a privacy right.

Some browsers transmit a "Do Not Track" or global privacy control signal. Because we do not track users across third-party websites or serve interest-based advertising, our practices are consistent with those signals by default, and we honour a recognised opt-out preference signal where one is received and applicable.

The Website links to third-party websites, exchanges, wallets, applications, and social media platforms that we do not own or control. This policy does not apply to them, and we are not responsible for their content or their information practices. If you reach the Website through a third-party platform, or interact with our content there, that platform's own privacy policy governs, and it may differ significantly from this one. We encourage you to read the privacy policy of every site you visit.

You authorise us to disclose Personal Information as required in connection with any judicial, administrative, arbitral, or law enforcement proceeding, or in response to a lawful request by a governmental or regulatory authority. You further authorise disclosure where we believe in good faith that it is necessary or appropriate to investigate or take action regarding improper or illegal conduct, fraud, misrepresentation, infringement of intellectual property rights, a threat to the security or integrity of the Website, or any activity that may expose us or any other person to liability or harm.

The Website is not directed to children. We do not knowingly permit anyone under 18 years of age to use the Website, and we do not knowingly collect Personal Information from anyone under that age. If we learn that we have collected such information without verified parental or guardian consent, we will make reasonable efforts to delete it from our records promptly.

If you believe that a child has provided us with Personal Information, please write to [email protected] so that we can delete it. If you provide information about another person, you represent that you are authorised to do so and to consent on their behalf to the handling described in this policy.

Please do not send us confidential or proprietary information, ideas, suggestions, or creative materials. Any such information you do send will be treated as non-confidential and non-proprietary, and by sending it you grant us an unrestricted, irrevocable, worldwide, royalty-free right to use, modify, reproduce, transmit, display, and distribute it for any purpose whatsoever, without any payment, attribution, or other compensation to you. This does not apply to Personal Information, which is handled as described elsewhere in this policy.

This section applies only to residents of California and supplements the rest of this policy. It is provided under California Civil Code sections 1798.83 to 1798.84 and the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA").

Categories of information. In the preceding twelve months we have collected the following categories of Personal Information: identifiers (such as an email address, an IP address, and any name, handle, or public wallet address you provide); internet or other electronic network activity information (such as browsing and interaction data on the Website); and approximate geolocation derived from an IP address. We collect this from you directly and from our hosting, security, and analytics providers. We do not collect sensitive personal information as the CCPA defines it, and we do not use or disclose any such information beyond the purposes the CCPA permits without a right to limit.

Purposes. We collect, use, and disclose Personal Information for the business purposes described in "How we use Personal Information" above, including legal compliance and auditing, detecting security incidents and malicious, deceptive, fraudulent, or illegal activity, debugging and repairing errors, performing and improving the Website, internal operations, and short-term transient use.

We have not sold or shared Personal Information, as those terms are defined by the CCPA, in the preceding twelve months, and we do not sell or share the Personal Information of consumers we know to be under sixteen years of age. We do not disclose Personal Information to third parties for their direct marketing purposes.

Subject to verification and to the limits the CCPA allows, California residents have the following rights:

• the right to be informed, at or before the point of collection, of the categories of Personal Information collected and the purposes for which they are used;
• the right to know and access the specific pieces and categories of Personal Information collected, the categories of sources, the business or commercial purposes for collection, and the categories of third parties to whom it is disclosed;
• the right to delete Personal Information we have collected from you, subject to statutory exceptions;
• the right to correct inaccurate Personal Information;
• the right to limit the use and disclosure of sensitive personal information;
• the right to opt out of the sale or sharing of Personal Information — noting that we do neither;
• the right to access information about, and to opt out of, automated decision-making technology — noting that we do not use it; and
• the right to be free from unlawful discrimination or retaliation for exercising any of these rights.

To exercise any of these rights, write to [email protected]. We will need to verify your identity before acting, which normally means confirming control of the email address associated with the information, and we may ask for further detail where a request is broad or the information is sensitive. An authorised agent may submit a request on your behalf with sufficient written proof of authorisation, and we may still require you to verify your own identity. We will respond within the period the CCPA requires, ordinarily forty-five days, and may extend that once where reasonably necessary, telling you if we do.

You may visit the Website without identifying yourself, though technical information such as an IP address may still be collected through the tools described above. A link to this policy appears in the footer of every page.

We retain Personal Information only for as long as is necessary for the purpose for which it was collected — for example, for as long as you wish to receive updates, or for as long as needed to answer and follow up on a message you sent us — and for such longer period as is required or permitted to comply with legal obligations, resolve disputes, prevent fraud and abuse, and enforce our agreements. When information is no longer needed, we delete it or retain it only in de-identified or aggregated form, which we may keep indefinitely.

We may assign or transfer this policy, and the information covered by it, to any successor or acquirer in connection with a merger, acquisition, reorganisation, financing, or sale of assets. The recipient will be bound by this policy in respect of the information transferred until it provides notice of a different policy. Where the law applicable to you requires advance notice of such a transfer, we will provide it.

We may update this policy from time to time by posting the revised version on this page and updating the date shown above. Where a change is material we will make it prominent on the Website. Your continued use of the Website after a change takes effect constitutes your acceptance of the revised policy, so please review this page periodically.

Any dispute arising out of or relating to this policy is governed by the laws of the British Virgin Islands, without regard to its conflict of laws principles, and is subject to the dispute resolution, binding arbitration, jury trial waiver, and class action waiver provisions set out in our Terms & Conditions, which you should read alongside this policy.

Questions about this policy, about the information we hold, or about updating that information, along with any general enquiries, may be sent to [email protected].