Privacy Notice

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect when you:

• make an enquiry
• sign up for marketing emails and alerts
• create an account with us
• enrol in the Phoenix Labs (Credi Limited) staking pool
• place an order for merchandise from the Swag Store
• communicate with us about your order
• swap your tokens
• browse our website

References to we, our or us in this privacy notice are to Phoenix Labs Ltd.

Phoenix Labs Limited is registered in the British Virgin Islands under company number 2103539 and our registered office is at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands

1. PERSONAL INFORMATION

   • When you browse our website, we may collect certain personal information about you, such as your IP address and the pages that you visit.
   • If you register to use our website, you will need to provide us with additional personal data, including your email address and password.
   • Depending on how you use our website, you may need to provide us with further personal data. For example, if you use our website to stake your tokens, you will need to connect your wallet which will provide us with details of the tokens you own and wish to stake.
   • If you are required to complete KYC checks, you will need to provide information and documentation to our third-party KYC provider to verify your identity, such as photographic ID. Our KYC provider will share this with us.
   • If you make a purchase from our Swag Store, you will need to provide your postal address for delivery and payment details.
   • Depending on the nature of our interactions with you, there may be certain essential personal information that we have to collect from you so that we can provide you with the information, goods, or services that you have requested. This will vary depending on the relationship we have with you.
   • We may also ask you for additional personal information which it is optional for you to provide but which will allow us to improve the service that we provide. For example, if you make an enquiry, we may ask for more information about you to enable us to provide the most appropriate response.
   • We will always aim to make it clear which personal information it is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any particular piece of personal information please contact us.

2. USES MADE OF THE INFORMATION

   • We are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018.
   • Specifically, we may use your personal information as follows:
     1. To perform our obligations to you, including:
        • handling any request that you make in respect of the staking of your tokens or a token swap, including creating any smart contract required to give effect to this request
        • fulfilling any order that you place at our Swag Store, including authorising payments, dispatching the ordered merchandise and handling any returns
     2. Where you have expressly consented to us doing so, including:
        • where you have requested that we keep you up-to-date with news and updates, to provide you with the types of news and updates that you have asked to receive by the types of communication that you have asked us to use
        • where you make an enquiry or request any particular information, to respond to that enquiry and provide the requested information.
   • Where it is necessary for compliance with legal obligations, including:
   • for record keeping and regulatory compliance purposes
   • for carrying out checks to prevent money laundering
   • Where we otherwise have a legitimate interest in doing so, including:
     • Where we otherwise have a legitimate interest in doing so, including:
       • carrying out checks to prevent fraud to protect us from dishonest activity
       • undertaking surveys or market research to enable us to improve the service we offer
       • ensuring that our website is presented in an effective manner for you and your computer
       • tracking your use of our website to help us provide a positive user experience and improve and increase usage of our website
   • Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, you may do so by contacting us as described in paragraph 11. Please note however that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent.

3. SHARING OF YOUR PERSONAL INFORMATION WITHIN OUR GROUP

   • Our group consists of various Affiliates.
   • In this notice, the term “Affiliate” means a person that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with Phoenix Labs.
   • Where you provide personal information to one company within our group, it may be shared with one or more Affiliates. This is in our legitimate interests to enable us to operate our group effectively and to provide you with an efficient service.
   • All Affiliates are bound by this privacy notice.

4. OTHER CIRCUMSTANCES IN WHICH WE MAY SHARE YOUR PERSONAL INFORMATION

   • We may share your personal information with:
     1. Providers of outsourced services, such as hosting and IT support or maintenance services (to the extent necessary for the provider to provide those outsourced services to us)
     2. The provider of your cryptocurrency wallet
     3. Providers of our know-your-customer / anti-money-laundering checks
     4. The prospective seller or buyer of any business or assets in the event that we sell or buy any business or assets
   • We may also share your personal information with third parties if we are under a duty to share your personal information in order to comply with any legal obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, or safety of our customers, ourselves or others.
   • We may share anonymised and aggregated information about our customers to third parties, such as advertisers, to allow them to select and send relevant adverts to our customers. We may also use such anonymised aggregate information to help advertisers reach the kind of audience they want to target.

5. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

   • We will not transfer any of your personal data outside of the UK or EEA.

6. RETENTION, UPDATING AND REMOVAL OF YOUR PERSONAL INFORMATION

   • Where you provide us with personal information we may retain this information for future use, including providing you with news and updates of a type you have asked to receive; monitoring fraud and other illegal or unlawful activity; and record keeping purposes.
   • The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
   • It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your email address. You may be able to update some of the personal information we hold about you through the “Your Account” section of the website. Alternatively, you can contact us using the details in paragraph 11.
   • If you want to stop receiving any information from us, such as news and updates, please let us know by contacting us using the details in paragraph 11. It may take up to one month to unsubscribe you from marketing.
   • Your decision to stop receiving information from us may result in the deletion of some of the personal information that we hold about you, but we may still retain personal information we require for other purposes, including where it is required for record keeping purposes.
   • In certain circumstances you may be entitled to request the erasure of personal information that we hold about you. To make a request of this nature, please contact us, providing full details of the personal information you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request.

7. COOKIES AND LOG FILES

   • When you browse our website, we may use "cookies" to keep track of your visit and give you a better browsing experience. Where required by law, we will request your consent or offer an opt-out.
   • In common with most websites, our website logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp. We may use this information to analyse trends, administer the website, track your movement around the website and gather broad demographic information.

8. SECURITY

   • The protection of your personal information is very important to us and we have in place various security measures to ensure that your personal information is kept secure.
   • However, you should be aware that the method you use to get in contact with us, such as email or post, may not be entirely secure and your personal information may be susceptible to being intercepted in transit. Equally, your personal information is at risk if a malicious third-party gains access to your account on our website or to any other place where your personal information is stored, such as your email account.
   • You should therefore take all reasonable steps to keep your personal information secure, including choosing a secure password for your customer account on our website and your email account and not disclosing your passwords to anybody else. You should use a unique password for every account.

9. ENQUIRIES, ISSUES AND COMPLAINTS

   • You are entitled by law to ask for a copy of your personal information at any time. Please contact us using the details in paragraph 11.

   In the unlikely event that you have any concerns about how we use your personal information, please contact us as described in paragraph 11. This includes situations where you want to request the rectification or erasure of your personal information, restrictions to be placed around how we use your personal information, or to object to a particular use.

   You can also send a complaint to the ICO if you are unhappy with how we have used your data.

10. CHANGES TO THIS PRIVACY NOTICE

    • We reserve the right to alter this privacy notice at any time. Such alterations will be posted on our website. You can also obtain an up-to-date copy of our privacy notice by contacting us as described in paragraph 11. Should you object to any alteration, please contact us.

11. CONTACTING US

    • If you have an enquiry, concerns or wish to make a complaint in respect of our use of your personal data please contact us.

12. FURTHER INFORMATION

    • We hope that the contents of this privacy notice address any queries that you may have about the personal information we may hold about you and what we may do with it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 11 above.
    • Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. For example, more information about your legal rights can be found on the Information Commissioner"s website at link.

Disclaimer

Phoenix Labs, and its shareholders, directors, officers, Affiliates, employees, contractors, agents, partners, insurers and lawyers do not provide any investment, legal, accounting or other advice. Nothing on this website should be considered advice and you should always consider taking independent advice before utilising any of the functions of this website.