Privacy Policy for Phoenix Market

Last Updated: September 25, 2025

Phoenix Market (“we,” “our,” “us”) respects your privacy. This Privacy Policy describes our data practices for our website, mobile applications, and related services (“Services”), in compliance with applicable laws and Apple App Store requirements.

Our guiding principle: we do not collect, store, or share any personal information.

1. Categories of Data Collected

We do not collect or request the following types of personal information:

  • Identifiers: No names, email addresses, phone numbers, postal addresses, or government IDs.

  • Financial Information: No credit/debit card numbers, bank account details, Zelle login credentials, or cryptocurrency private keys/seed phrases.

  • Health or Sensitive Data: None.

  • Contacts or Calendar Information: None.

  • User Content: We do not collect messages, photos, files, or media.

  • Location Data: We do not track or store your location.

  • Advertising Data: We do not track you for marketing or advertising purposes.

2. Automatically Processed Technical Data

When you use our Services, limited technical information is automatically processed in order for the app and website to function:

  • Device & App Data: Device type, OS version, app version, and crash/error logs.

  • Network Data: IP addresses and connection logs that are automatically generated by standard internet protocols. These are ephemeral and not linked to identity.

  • Blockchain Transactions: If you interact with smart contracts, your transactions are publicly recorded on the blockchain. This is by design of blockchain networks and outside our control.

This information is not stored in a way that identifies you and is not combined with any personal data.

3. How Data Is Used

The limited technical data described above is used only for:

  • Operating and maintaining our Services

  • Fixing bugs, troubleshooting, and improving performance

  • Preventing abuse and ensuring security

  • Complying with applicable legal obligations

We do not use this data for analytics, profiling, or marketing.

4. Data Retention

  • We do not retain personal information because we do not collect it.

  • Technical logs (e.g., crash reports) may be stored temporarily (7–30 days) for troubleshooting, then automatically deleted.

  • Blockchain data is permanent and public by nature of the technology.

5. Sharing of Data

We do not sell, rent, or share personal information.

We may use infrastructure providers (e.g., cloud hosting, error monitoring services) that temporarily process non-identifying technical data necessary to deliver the Service. These providers are contractually bound to strict confidentiality and security standards.

We may also disclose technical data if required by law, regulation, or valid legal process.

6. Data Security

We take steps to safeguard the minimal technical data that is processed, including:

  • TLS/SSL encryption for all communications

  • Encryption at rest for any stored logs

  • Strict internal access controls and monitoring

  • Regular security audits of infrastructure and smart contracts

7. International Use and Transfers

Our Services are global. Since we do not collect personal information, we do not transfer personal data cross-border. If any technical data is routed or hosted internationally, the same security and privacy standards described here apply.

8. Your Rights and Controls

Because we do not collect personal information, there is no personal data to access, modify, or delete.

However, if you believe we have inadvertently processed information that could be personal, you may request:

  • Confirmation of processing

  • Correction or deletion

  • Restriction of processing

Contact details are provided in Section 12.

9. Children’s Privacy (COPPA Compliance)

Our Services are not directed to children under 13 (or the age of digital consent in your jurisdiction). We do not knowingly collect any data from children. If we discover unintentional collection, we will delete it immediately.

10. Regulatory Frameworks

While we do not collect data, this Privacy Policy is written to align with:

  • Apple App Store Review Guidelines (Sections 5.1.1–5.1.2)

  • General Data Protection Regulation (GDPR)

  • California Consumer Privacy Act (CCPA)

  • Children’s Online Privacy Protection Act (COPPA)

11. Policy Changes

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the “Last Updated” date above and, where appropriate, via an in-app notice.

12. Contact Information

If you have questions, concerns, or believe we may have inadvertently collected personal information, please contact us:

Phoenix Market

Email: main@phoenix.market

You may also have the right to lodge a complaint with your local data protection authority.

13. Dispute Resolution

If you have an unresolved privacy concern that we have not addressed satisfactorily, you may escalate it by contacting:

  • Your local data protection authority (for GDPR jurisdictions)

  • The California Attorney General’s Office (for CCPA)

  • The Federal Trade Commission (FTC) in the United States