Document Classification

This document is a legally binding Cookie & Tracking Technologies Policy. It governs the use of cookies, tracking tools and similar technologies on PhoenixX web properties and digital services.

Confidentiality Level: Public Legal Document
Applies To: Website Visitors, Registered Users, Clients and Platform Users
Status: Approved by PhoenixX Compliance & Risk Management

1. Purpose and Legal Effect

2. Scope and Applicability

This Policy applies to PhoenixX digital properties, including PhoenixX.one, www.PhoenixX.one and associated subdomains. It governs cookies used for functionality, analytics, performance optimization, session integrity, fraud detection and security enhancement.

3. Legal Basis for Cookie Use

PhoenixX processes cookie-related data based on the following legal bases under GDPR:

• Article 6(1)(a) – Consent for non-essential cookies
• Article 6(1)(f) – Legitimate interest for strictly necessary cookies PhoenixX adheres to Article 5(3) of the ePrivacy Directive, requiring consent before storing or accessing non-essential cookies on a user's device.

4. Cookie Categories Used by PhoenixX

PhoenixX uses a Consent Management Platform (CMP) consistent with GDPR requirements. Users may update cookie settings at any time.

5. Specific Cookies Used

PhoenixX may deploy the following cookies:

PhoenixX may add or remove cookies where necessary for legitimate business purposes, security compliance or service improvement.

6. Third-Party Tracking Tools

PhoenixX may use trusted third-party analytics and performance tools including Google Analytics 4, Microsoft Clarity and Zoho Analytics. These providers may process limited pseudonymized data on PhoenixX’s behalf under contractual Data Processing Agreements. PhoenixX prohibits the use of invasive cross-site tracking technologies and does not authorize third-party resale of PhoenixX user data.

7. Data Sharing and International Transfers

Some tracking tools may transfer pseudonymized or aggregated analytics data outside the European Economic Area (EEA). Where this occurs, PhoenixX ensures compliance with GDPR Chapter V by implementing Standard Contractual Clauses (SCCs) and applying appropriate safeguards consistent with Swiss FADP and the EU Schrems II ruling.

8. Cookie Retention Periods

PhoenixX retains cookie information only for as long as necessary for the purposes described in this Policy. Cookie retention periods vary depending on category but do not exceed two (2) years unless legally required for security, fraud prevention or compliance.

9. Managing Cookie Preferences

Users may modify or withdraw their consent at any time via the Cookie Settings panel. Withdrawal of consent disables corresponding cookie categories but will not affect data processed prior to withdrawal. Strictly necessary cookies cannot be disabled.

10. Browser-Level Cookie Control

Users may configure their browsers to block cookies or delete existing ones. However, restricting cookies may result in limited functionality of PhoenixX services. Browser-level controls do not override legitimate security and platform integrity cookies.

11. Security and Fraud Prevention Cookies

PhoenixX uses certain cookies and tracking technologies to detect fraud, prevent automation abuse, mitigate scraping activity and secure PhoenixX Systems. These technologies fall under legitimate interest under GDPR Article 6(1)(f) and may not be disabled where required to ensure cyber security and legal compliance.

12. Enforcement and Abuse Prevention

PhoenixX may restrict access to PhoenixX.one and www.PhoenixX.one when automated bot activity, scraping, credential abuse or malicious browser behavior is detected. PhoenixX enforces tracking protections consistent with PHX-REA-1.0 (Risk Enforcement & Account Actions Policy) and may block access to protect system integrity. Attempts to tamper with consent tools, evade cookie controls or bypass security tracking mechanisms constitute unauthorized use.

13. Your Rights Under GDPR and Swiss FADP

Users have the right to request access, rectification, restriction or deletion of personal data processed through cookies, subject to legal retention limits. Certain rights may be limited where data is retained for fraud prevention, compliance or evidence preservation under PHX-DREP-1.0 (Data Retention & Evidence Preservation Policy).

14. Contact and Complaints

For cookie and privacy-related inquiries, contact PhoenixX Compliance: PhoenixX LLC, 1309 Coffeen Avenue, STE 1200, Sheridan, WY 82801, USA
Email: compliance@PhoenixX.one
PhoenixX Data Protection Office (DPO): dpo@PhoenixX.one

Complaints may also be filed with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or an EU Supervisory Authority.

14. Contact and Complaints

For cookie and privacy-related inquiries, contact PhoenixX Compliance: PhoenixX LLC, 1309 Coffeen Avenue, STE 1200, Sheridan, WY 82801, USA
Email: compliance@PhoenixX.one
PhoenixX Data Protection Office (DPO): dpo@PhoenixX.one

Complaints may also be filed with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or an EU Supervisory Authority.