Privacy Policy

Last Updated: May 2026

Solstice Technologies S. de RL., a company organized under the laws of the Republic of Panama and its affiliates ("Company," "we," "us," or "our") operate a non-custodial web-based user interface and mobile application that enable users to interact directly with a decentralized perpetuals protocol on the Solana blockchain (the "Interface" and "App," respectively). This Privacy Policy explains what information we collect through the Interface, the App, and our associated website (collectively, the "Site"), how we use and share that information, and the choices you have regarding the foregoing.

BY ACCESSING THE SITE, CONNECTING A WALLET, DOWNLOADING OR USING THE APP, OR OTHERWISE USING THE INTERFACE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY AND OUR TERMS OF USE LOCATED AT phoenix.trade/terms-of-service.

Scope and Acceptance

This Privacy Policy applies to visitors to the Site who view publicly available content, users who connect a compatible wallet to interact with the Interface, and users who download or use the App in any form, including any beta or pre-release version. By visiting the Site, connecting a wallet, or downloading or using the App, you consent to the data practices described in this Privacy Policy.

Summary of Our Approach

The Interface and the App are non-custodial and on-chain. We do not require account registration and do not ask you to provide traditional personal identifiers such as your name, email address, or government-issued identification to use core functionality. We collect limited data as set forth herein to operate, secure, and improve the Interface and the App, enforce geographic restrictions, and comply with applicable law.

Information We Collect

We collect the following categories of information in connection with your use of the Site, the Interface, and the App:

Wallet connection information. When you voluntarily connect a publicly available blockchain wallet address to the Interface, we process that public address to enable wallet connection, surface on-chain positions and activity, and facilitate on-chain interactions you initiate. We do not have access to your private keys or seed phrase and cannot initiate transactions on your behalf.
Technical and device information. We and/or our service providers may automatically collect limited technical information when you access the Site, such as IP address (which may be truncated or anonymized where configured), browser type, operating system, device type, language preferences, referring URLs, and diagnostic information. We use this information to maintain security, prevent fraud and abuse, measure performance, and debug issues.
Mobile device and App information. If you access the Services through the App, we and/or our service providers may collect additional technical information specific to your mobile device, including device model, operating system version, unique device identifiers, mobile network information, crash logs, and diagnostic data. During beta, we may collect enhanced diagnostic and performance data to identify bugs and improve App stability. We do not collect precise geolocation data. Any permissions the App requests (such as camera or biometric access for wallet authentication) are used solely for the stated purpose and are not shared with third parties for marketing purposes.
Usage data. We may collect information about your interactions with the Site, the Interface, and the App, such as pages viewed, features used, links clicked, time and duration of visits, and referral sources. We use this information to operate, maintain, and improve the Interface and the App, including user experience and performance.
Approximate location data. We may derive coarse location information from IP address or similar signals to enforce geographic restrictions, such as blocking access from jurisdictions where use of the Interface or the App is not permitted under our Terms of Use.
On-chain data. We may surface publicly available on-chain information associated with your connected wallet, including transaction hashes, amounts, timestamps, positions, and funding or fee activity. On-chain data is public by design and is not controlled by us.
Cookies and similar technologies.We and/or our third-party infrastructure and analytics providers may use cookies, pixels, web beacons, mobile software development kits (SDKs), and similar technologies (collectively, "Cookies") to collect and store the types of information described above. On the App, we may use mobile analytics SDKs to collect crash reports and performance data. Cookies help us authenticate requests, remember preferences, enhance performance and security, and understand how the Site is used. You can manage Cookies through your browser settings; however, disabling certain Cookies may impair Site or Interface functionality. On the App, you may manage tracking preferences through your device's privacy settings.

We do not request or collect from you: name, email address, mailing address, telephone number, date of birth, government ID, proof of address, payment card details, or other traditional personal identifiers to use core Interface features. We do not target or knowingly collect information from individuals under the age of 18.

How We Use Information

We use the information described above for the following purposes:

To operate, maintain, and improve the Site, the Interface, and the App, including enabling wallet connectivity and core functionality and tailoring features and content to you.
To monitor App performance, diagnose crashes, and improve the stability and functionality of the App, including during beta testing.
To send you push notifications related to the Services if you have enabled them on your device. You may disable push notifications at any time through your device settings.
To secure the Interface and the App, detect, prevent, and mitigate fraud, abuse, and security incidents, and protect the integrity of our systems and users.
To enforce geographic restrictions and comply with applicable sanctions and other legal requirements.
To comply with legal obligations, respond to lawful requests, and exercise or defend legal claims.
To generate aggregated, de-identified insights and statistics about usage of the Site, the Interface, and the App.
To communicate with you about the Site, the Interface, or the App if you contact us directly.

We do not sell your information. We do not use information collected through the Interface or the App for targeted advertising or direct marketing.

How We Share Information

We share the information we collect only as described below:

Service providers. We engage reputable third-party service providers to support hosting, content delivery, analytics, mobile analytics, security, performance monitoring, blockchain indexing, and related services. These providers are permitted to process information solely on our behalf and under appropriate confidentiality and security obligations.
Legal and compliance. We may disclose information if required by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, users, the public, or the security and integrity of the Interface and the App.
Corporate transactions. We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, sale of assets, insolvency, or similar corporate transaction. If such a transaction occurs, we will require the recipient to honor this Privacy Policy with respect to any information transferred or provide you with notice of material changes.
Aggregated and de-identified information. We may share aggregated or de-identified information that cannot reasonably be used to identify you, for lawful purposes such as analytics, research, and improving our services.

We do not sell personal information as defined by applicable law.

International Data Transfers

The Site, the Interface, the App, and our service providers may process information in jurisdictions outside your country of residence, and the Interface is operated from servers located in multiple jurisdictions (including possibly the United States and Europe). Data protection laws in those jurisdictions may differ from those in your home jurisdiction. By using the Site, the Interface, or the App, you acknowledge that information about you may be transferred to and processed in jurisdictions outside of your jurisdiction that may have different data protection rules and laws.

Data Retention

We retain analytics, logs, and related information only for as long as necessary to fulfill the purposes described in this Privacy Policy, including security, legal, and operational needs, or as required by law. On-chain data persists on and is permanently stored on the underlying blockchain and is outside our control.

Your Choices

You have the following choices regarding your information:

Cookies. You may block or delete Cookies through your browser or device settings. Some features of the Site or Interface may not function properly without certain Cookies.
Wallet connection. You can disconnect your wallet at any time. Disconnecting a wallet may limit your ability to use certain Interface features.
App permissions.You may manage permissions granted to the App (such as notifications or biometric access) at any time through your device's settings. Revoking certain permissions may limit App functionality.
Push notifications. If you have enabled push notifications from the App, you may disable them at any time through your device settings. Push notifications are informational only and do not constitute financial advice.
Beta participation. If you are accessing the App in its beta or pre-release form, beta access may be revoked at any time. Enhanced diagnostic data collected during beta will be used solely to improve the App and will be subject to the same retention and sharing practices described in this Privacy Policy.
Communications. If you contact us and subsequently wish to opt out of non-transactional communications, you may follow any unsubscribe instructions provided or contact us using the information below.

Please note that attempts to use VPNs or similar tools to circumvent geographic restrictions violate our Terms of Use and may result in access being blocked.

Children's Privacy

The Site, the Interface, and the App are not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18. If you believe that an individual under the age of 18 has provided us with personal information, please contact us, and we will take appropriate steps to delete such information where feasible.

Security

We implement commercially reasonable technical and organizational measures designed to protect information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security of information.

Do Not Track

We do not currently respond to browser "Do Not Track" signals because there is no industry standard for how to interpret such signals. We will update this section if standards are adopted. The App does not respond to equivalent mobile opt-out signals, such as iOS App Tracking Transparency prompts or Android advertising ID opt-outs, beyond what is required by applicable platform policies or law.

External Websites and Third-Party Links

The Site and the App may contain links to third-party websites or services that we do not operate or control. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party sites or services you visit.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this Privacy Policy indicates when it last changed. Your continued use of the Site, the Interface, or the App after any changes are effective indicates your acceptance of the updated Privacy Policy.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at notices@phoenix.trade with "Privacy Policy" in the subject line.

Jurisdiction-Specific Notices

If you access the Site, the Interface, or the App from outside the jurisdiction where our servers are located, you consent to the transfer and processing of your information in accordance with this Privacy Policy and at your own risk, recognizing that the level of protection in such jurisdictions may be different from that of your home jurisdiction.

Additional Disclosures for an On-Chain, Non-Custodial Interface, and App

No custody; no private key access. We do not control, hold, or have access to your private keys, seed phrase, or funds. You are solely responsible for securing your wallet and private keys. Transactions you initiate are authorized by you and are broadcast to and settled by the relevant blockchain network.
Public nature of blockchains. Transactions on public blockchains are inherently transparent and may be viewed by anyone. Please carefully consider what information you choose to associate with your public wallet address.
Beta App data. During the beta period, the App may collect enhanced diagnostic, performance, and crash data to support testing and development. This data is used solely to identify and resolve issues and improve the App, and is subject to the same confidentiality and security standards as all other information described in this Privacy Policy. Beta access does not create any right to continued access or to a production release.
App store platforms. If you download the App through a third-party platform such as the Apple App Store or Google Play Store, that platform may collect information about your download and usage independently and subject to its own privacy policy. We are not responsible for data collected by app store platforms. Please review the applicable platform privacy policy before downloading the App.
Indexing and display. To display balances, positions, fills, and related activity, we and/or our service providers may query public blockchain data or indexers associated with your connected wallet address. This information is already publicly available and is surfaced to you for convenience.

Please review our Terms of Use for additional disclosures and conditions relevant to your use of the Site, the Interface, and the App.