PRIVACY POLICY

FENIX– data protection policy (hereafter, the “Privacy Policy”)

1. What is the scope of this document?

We, at Fenix, have defined this Privacy Policy to explain and describe the personal data we collect, for what purposes we do it, as well as your privacy rights and the way you can exercise them.

This Privacy Policy applies to our use of personal data collected by us or provided by you in relation to your use of our website (Fenix.life), (hereafter, the “Website”) and/or mobile application (hereafter, the “App”).

This Privacy Policy does not apply to our use of personal data about (i) individuals employed by Fenix and acting in the course of their employment or (ii) third parties providing services to Fenix and accessing our Website and/or our App in connection with the provision of such services. We have separate policies which we will make available to such persons.

We may revise this Privacy Policy from time to time to keep it in line with changes in our business, services or applicable law. All changes to this Privacy Policy will be published on our Website and App. In case of substantial changes, we will also notify Fenix users by email or other means.

This Privacy Policy forms part of the Agreement between us and users of our services. You should not enter into the Agreement with us and use our services if you do not want your data to be treated in accordance with this Privacy Policy.

2. Which types of personal data does Fenix collect about me?

Fenix collects personal data from you in two ways and processes such personal data:

  • The personal data that you communicate to us
  • We collect and process all personal data that you choose to communicate to us when you register to use our services, such as:

    (1) your name;

    (2) your mobile number;

    (3) your email address;

    (4) your birth date; and

    (5) your registration / login data, along with any other personal data which you communicate to us by other means from time to time.

  • The usage data that our systems collect
  • We also collect and process certain types of information automatically, whenever you interact with us, in order to allow you to use our services in accordance with the agreement between us (for example, tracking the location of your mobile device to validate your right to rent a vehicle and processing the data created when you start or end a ride).

    We collect and process data for the purposes of improving your experience on our Website and/or App. When you visit our Website and/or App, cookies may be installed on your browser software to obtain certain personal data when your web browser accesses our Website and/or App. We will also obtain certain usage data as other content served by and on behalf of Fenix on other websites. Most browsers allow you to change settings to disable or enable cookies.

    Those usage data that we collect are the following:

    (1) the Internet protocol (IP) address used to connect your computer or mobile device to the Internet;

    (2) the location of your computer or mobile device during the use of our Website or App;

    (3) language settings;

    (4) time zone;

    (5) interface controls;

    (6) system information; and

    (7) version used.

    3. For what purposes will Fenix collect and process my personal data?

    We collect and process personal data when it is necessary for operating, providing or improving our services offered to our users. In particular, we collect and process personal data in order to:

  • perform the agreement between us that enables you to use our services (including offering the service, managing your account, taking payment etc.);
  • improve your experience on our Website and App;
  • handle your requests about our services;
  • verify that your usage of our services does not infringe our Terms of Service or any laws or regulations;
  • Communicate to you regarding any important changes in the services or the Terms of Service (including this Privacy Policy).
  • Our grounds for performing this processing are one or more of the following:

    - it is necessary to ensure the performance of the contract between you and us;

    - it is in Fenix’s legitimate interests;

    - you have consented to the processing.

    We also process your personal data for marketing purposes which may include sending newsletters, marketing emails or SMS, push notifications to inform you about our services, to ask for feedback about our services or inform you of new services or features we are offering.

    You can opt out of receiving marketing communications at any time and we will communicate to you how you can do this.

    4. Who are the recipients of the personal data collected about me? Does Fenix share those data with third parties?

    Unless legally required or permitted, Fenix does not share your personal data except with specified and authorised recipients, i.e. its affiliate companies and service providers that are either subject to this Privacy Policy or follow privacy rules at least as protective as those stated therein.

    We will comply with any mandatory legal requests for your personal data that we receive from competent authorities.

    We do share data with third parties (such as regulators, real estate partners, technology partners etc.) relating to the use of our services, including use of our Website and App, however this data is aggregated and cannot be used to identify any person.

    5. How long does Fenix keep personal data?

    We will keep the personal data necessary for the management of your account for as long as you maintain an account with us and for a reasonable period thereafter in order for us to be able to manage any requests or issues which may arise after your account has been closed.

    We will keep the remaining personal data that we hold for marketing and other purposes for a reasonable period and, as noted above, you will always be able to tell us that you no longer wish to receive marketing communications and we will comply with your wishes.

    If we need to keep personal data for longer periods in relation to the exercise or defence of legal proceedings or in order to comply with any legal or regulatory obligations then we may do so.

    If we anonymise your personal data so that you can no longer be identified by reference to it, we may keep it indefinitely.

    6. Are my personal data safe with Fenix?

    Your personal data are stored securely. Fenix uses physical, administrative and software-based security safeguards to provide reasonable protection for your personal data. Personal data are not stored on paper. All electronic copies are encrypted and protected by firewall and information access authorisation controls.

    7. Who is responsible for processing personal data?

    The responsible party is FENIX TECHNOLOGIES LIMITED.

    If you have any question on our Privacy Policy or on our privacy practices that are not addressed in this Privacy Policy, please contact us care@fenix.life.