Introduction

At Phoenix Engine, we take your privacy seriously. This Privacy Policy outlines how we collect, use, store, and protect your personal information when you engage with our website, communicate with us, use our services, or interact with us in any other way.

This policy applies to all personal data collected and processed by Phoenix Engine Ltd. and is designed to meet the standards of the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.

Note: Our services are not intended for individuals under the age of 16. If you are under 16, please do not provide any personal data without parental or guardian consent.

Who We Are

This website is operated by Phoenix Engine Ltd., a company registered in George Town, Cayman Islands. For the purposes of data protection law, Phoenix Engine Ltd. is the “Data Controller,” which means we determine the purposes and methods of processing your personal data.

If you have questions about this policy or wish to exercise your data rights, please contact us at: 📧 marketing@phoenixengine.io

Legal Basis for Processing

Depending on your interaction with us, we may rely on one or more of the following legal grounds to process your data:

• Legal obligation: Where processing is necessary for compliance with legal requirements.
• Contractual necessity: When processing is required to fulfill a contract with you or to take steps before entering into a contract.
• Legitimate interests: Where we process data to pursue our legitimate business interests (e.g. improving our services, securing our website), as long as your rights and freedoms are not overridden.
• Consent: In cases where your permission is required, we will only process your data if you have given us clear consent. You can withdraw your consent at any time.

Data We Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

• Contact Details: Your name, email address, company, phone number, and job title – typically provided through contact forms, inquiries, or job applications.
• Identity Information: Includes your name, gender, or company affiliation – used to verify your identity or personalize communications.
• Employment Data: Such as your CV, professional background, education, and relevant qualifications – if you apply for a job with us.
• User Activity Data: Pages visited, interactions, or clickstream data – used to understand how users engage with our site.
• Technical Data: Your IP address, browser type, operating system, device info, and approximate location – used for security and analytics.
• Any Other Information: Information you choose to submit voluntarily through communications with us.

We do not use your data for automated decision-making or profiling.

Your Rights

As a data subject under the GDPR, you have the following rights:

• Right to be informed: You have the right to know how we use your data.
• Right of access: You can request a copy of the data we hold about you.
• Right to rectification: You can ask us to correct inaccurate or incomplete data.
• Right to erasure: You may request that we delete your data under certain conditions.
• Right to restrict processing: You may request limited use of your data.
• Right to object: You can object to our use of your data based on legitimate interest or direct marketing.
• Right to data portability: You can request your data in a portable format.
• Rights regarding automated decisions: You can request human review of any automated decisions (though we currently do not use such methods).

To exercise these rights, contact us at marketing@phoenixengine.io

Data Security

We implement industry-standard security measures to prevent unauthorized access, disclosure, alteration, or loss of your personal data. All information is stored on secure servers, and access is limited to authorized personnel.

Please be aware that no method of online transmission or storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

Data Retention

We keep your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law.

Generally, we retain personal data for the duration of our business relationship and for up to one (1) year after its conclusion, unless legal obligations require a longer period.

Sharing Your Data

We do not sell your personal data. We may share it in the following circumstances:

• With legal or regulatory authorities where required by law.
• With affiliated entities within our corporate group, for operational purposes.
• With trusted third-party service providers such as hosting, analytics, or recruitment platforms, who support us under strict confidentiality agreements.
• With advisors (e.g., legal or accounting firms) as necessary.
• With third parties if you have given your explicit consent or if it is necessary to fulfill a service request.

If your data is transferred outside the European Economic Area (EEA), we ensure that proper safeguards (such as Standard Contractual Clauses) are in place.

Business Transfers

If Phoenix Engine Ltd. is involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. Any new entity will continue to use your information only in accordance with this Privacy Policy unless you consent to other use.

Updates to This Policy

We may revise this Privacy Policy periodically to reflect changes in the law, technology, or our practices. Updates will be posted on this page with the revised effective date. We recommend reviewing it regularly.

Your continued use of our website or services after updates are posted means you accept the revised policy.

Contact Us

For questions, concerns, or data requests, you can reach us at: 📧 marketing@phoenixengine.io

📍 Phoenix Engine Ltd., George Town, Cayman Islands

Key Definitions

• Personal Data: Any information that identifies or can be used to identify a person.
• Data Controller: The entity that determines how and why personal data is processed.
• Processing: Any action performed on personal data, including collection, storage, use, or deletion.
• GDPR: The General Data Protection Regulation (EU 2016/679), a legal framework that sets guidelines for the collection and processing of personal data of individuals within the EU.