When we refer to “The Phemi”, we mean the The Phemi entity that acts as the controller of your information.
By using the Services, you accept the terms of this Policy and our Terms of Service, and consent to our initial collection, use, disclosure, and retention of your information as described in this Policy and Terms of Service.
Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message or offline.
If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us. Information we collect from you includes:
Contact information, such as your email address and telephone number;
Information Automatically Collected. We may automatically record certain information about how you use our Site (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, and operating system. We use this information to administer and provide access to the Services
Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
USE OF PERSONAL INFORMATION
To provide our service we will use your personal information in the following ways:
- To enable you to access and use the Services
- To comply with law
- We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
- For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
SHARING OF PERSONAL INFORMATION
Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes.
We may share information to comply with laws.
We may share information to respond to lawful requests and legal processes.
Professional Advisors and Service Providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
Other. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.
We may also share aggregated and/or anonymized data with others for their own uses.
The Company has offices outside of the EU and has affiliates and service providers in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
EU users should read the important information provided below about transfer of personal information outside of the European Economic Area (EEA).
HOW INFORMATION IS SECURED
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services.
INFORMATION CHOICES AND CHANGES
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to privacy@The Phemi.com. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences. We may require that you are the you are the user who you say you are by proving that you have control of your posting key via our conveyor API.
We welcome your comments or questions about this Policy, and you may contact us at: privacy@The Phemi.com.
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.
NOTICE TO EU DATA SUBJECTS
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at legal@The Phemi.com.
- Legal Basis
- For compliance, fraud prevention, and safety
- To provide our service
These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
With your consent
Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at email@example.com
Use for New Purposes
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at email@example.com or submit a complaint to the data protection regulator in your jurisdiction.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.