Fantom Privacy Policy

Last updated 10 May 2023
Thank you for choosing to be part of our community at Fantom Foundation Ltd (“Fantom”, “Company,” “we,” “us,” or “our“). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us at legal@fantom.foundation.

1. Our Role In Your Privacy

This privacy policy applies to you if you:

  • Visit our website at https://fantom.foundation
  • Engage with us in other related ways ― including any sales, marketing, or events.

In this privacy policy, if we refer to:

  • “Website,” we are referring to any website of ours that references or links to this privacy policy.
  • “Services,” we are referring to our Website, and other related services, including any sales, marketing, or events.

The purpose of this privacy policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy policy carefully, as it will help you understand what we do with the information that we collect.

2. Your Responsibilities

  • Read this privacy policy
  • If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information you confirm that you have the right to authorise us to process it on our behalf in accordance with this privacy policy.

3. What Information Do We Collect?

From the first moment you interact with Fantom we are collecting data. Sometimes you provide us with data, sometimes we collect data about you, either automatically or from other sources, like publicly available on websites or from a trusted data supplier.

Here’s what data we collect:

  • a. Personal information you disclose to us
  • We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.
  • The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products, Services, and features you use. The personal information we collect may include the following:
    • Contact details – We may collect names; phone numbers; email addresses; mailing addresses; contact preferences; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

  • b. Information automatically collected/ collected by u
  • We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include the following:
    • Device and usage information – Your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use) and device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
    • Location data – Country, location, information about how and when you use our Website and other technical information such as device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information. The amount of information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your ‘location setting’ on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
  • This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

4. How Do We Use Your Information?

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We may use your information which we collect or receive for the purposes set out below:

  • To send administrative information to you – to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services – as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies – for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
  • To respond to legal requests and prevent harm – If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • Fulfill and manage your orders – to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
  • Administer prize draws and competitions – to administer prize draws and competitions when you elect to participate in our competitions.
  • To deliver and facilitate delivery of services to the user – to provide you with the requested service.
  • To respond to user inquiries/offer support to users – to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications – We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, provided this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR CHOICES AND PRIVACY RIGHTS?” – see section 11 below).
  • Deliver targeted advertising to you – to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness
  • Responding to Job Applications – to respond to an employment or independent contractor application you may have submitted with Fantom.

5. Will Your Information Be Shared With Anyone?

We may process or share your data that we hold based on the following legal basis:

  • Consent – if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests – when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract – Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations – where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests – where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business Transfers – We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Vendors, Consultants, and Other Third-Party Service Providers – We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this privacy policy , we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Affiliates – We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business Partners – We may share your information with our business partners to offer you certain products, services, or promotions.

6. Who Will Your Information Be Shared With?

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in section 14 below “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?”.

  • Data Analytics Service Providers
  • Data Storage Service Providers
  • Cloud Computing Service Providers
  • Communication & Collaboration Tools
  • Performance Monitoring Tools
  • Product Engineering & Design Tools
  • Social Networks
  • Sales & Marketing Tools
  • Testing Tools
  • Website Hosting Service Providers

7. Do We Use Cookies And Other Tracking Technologies?

We do not use cookies or tracking technologies. Rather, we utilise anonymous page view tracking information provided by third-party analytics provider Fathom (https://usefathom.com) which does not collect or store any personal data. As such, we make no use of cookies.

8. Is Your Information Transferred Internationally?

Our servers are located in the Cayman Islands. If you are accessing our Website from outside the Cayman Islands, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” – see section 5 above), in Australia, India, United States, United Kingdom, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable laws.

  • European Commission’s Standard Contractual ClauseWe have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this privacy policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How Do We Keep Your Information Safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we collect and process.

However, please remember:

  • Despite our safeguards and efforts to secure your information, unfortunately no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information.
  • Transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
  • You are responsible for your username and password and should keep them safe.
  • If you believe your privacy has been breached, please contact us immediately on legal@fantom.foundation.

11. What Are Your Privacy Choices And Rights?

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right to :

  • Request access and obtain a copy of your personal information.
  • Request rectification or erasure.
  • Restrict the processing of your personal information and, if applicable, to data portability.
  • In certain circumstances, you may also have the right to object to the processing of your personal information.
  • If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you believe we are unlawfully processing your personal information, you have the right to complain to the Cayman Islands data protection supervisory authority. You can find their contact details here: https://ombudsman.ky/data-protection

12. Controls For Do-not-track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. Do We Make Updates To This Privacy Policy?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Privacy Policy?

If you have questions or comments about this privacy policy, you may email us atlegal@fantom.foundation or by post to:

15. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, have any inaccurate information corrected or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us on the above provided details.