Privacy Policy

Last Updated: January 2026

Solstice Technologies S. de RL. (to be formed / in formation), 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 that enables users to interact directly with a decentralized perpetuals protocol on the Solana blockchain (the "Interface"). This Privacy Policy explains what information we collect through the Interface 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, 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 and to users who connect a compatible wallet to interact with the Interface. By visiting the Site or connecting a wallet, you consent to the data practices described in this Privacy Policy.

Summary of Our Approach

The Interface is 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, 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 and the Interface:

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 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.
Usage data. We may collect information about your interactions with the Site and Interface, 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, 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 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 our third-party infrastructure and analytics providers may use cookies, pixels, web beacons, and similar technologies (collectively, "Cookies") to collect and store the types of information described above. 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.

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 and Interface, including enabling wallet connectivity and core functionality and tailoring features and content to you.
To secure the Interface, 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 and Interface.
To communicate with you about the Site or Interface if you contact us directly.

We do not sell your information. We do not use information collected through the Interface 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, 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.
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, 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 or Interface, 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.
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 and Interface 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.

External Websites and Third-Party Links

The Site 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 was last changed. Your continued use of the Site or Interface 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.com with "Privacy Policy" in the subject line.

Jurisdiction-Specific Notices

If you access the Site or Interface 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

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.
Indexing and display. To display balances, positions, fills, and related activity, we 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 and the Interface.