Privacy Policy

Last updated: 15 August 2026

Phantom is a project operated by [Registered operator name], registered under the laws of [Country of registration] (hereinafter "we", "us", "our", "Phantom"). We operate [your-domain.com] (the "Site") and provide software for players, news and entertainment related to game modification through the Site (the "Services").

We created this Privacy Policy to inform you of our policies regarding the collection, use and disclosure of data about individuals who can be identified from that data ("Personal Data") in the course of using the Services.

We use your data to provide and improve the Services. By using the Services, you consent to the collection and use of information in accordance with this Policy. Unless otherwise defined here, terms used in this Privacy Policy have the same meaning as in our Terms and Conditions.

We do not sell your Personal Data to third parties. "Sale" of Personal Data under the CCPA is defined broadly and includes the sale, lease, release, disclosure, dissemination, distribution, provision, transfer or other communication — whether oral, written, electronic or otherwise — of a consumer's Personal Data to another business or third party for monetary or other consideration. If we decide to sell the Site or our business, we will notify you so that you may prohibit us from transferring your Personal Data as part of that sale. In such an event, we will delete your data from our databases prior to the sale.

For the purposes of this Policy, "User" means an individual who uses the Site and has submitted a form or placed an order. "Visitor" means an individual who uses the Site to view the Services we offer or otherwise browse the Site. "You" refers to both where the information relates to both.

Our principles

We adhere to the following principles to protect your privacy:

  • Purposefulness — Personal Data is processed fairly and transparently, only to achieve specific and legitimate purposes, and is not processed in a manner inconsistent with those purposes.
  • Minimalism — Personal Data is collected only to the extent necessary to achieve the stated purposes, and we do not store Personal Data once it is no longer needed.
  • Limited use — Personal Data is used for other purposes only with the consent of the data subject or with the authorisation of a competent authority.
  • Data quality — Personal Data is kept up to date; it must be relevant, complete and necessary to achieve the purpose of processing.
  • Security — security measures are applied to protect Personal Data from unauthorised or unlawful processing and from accidental loss, destruction or damage, using appropriate technical and organisational measures.
  • Individual participation — individuals are notified of the data collected about them, are given access to it, and have the right to request correction of inaccurate or misleading data.

Data we collect

Visitor data. If the Site is used solely for information — that is, if a Visitor does not provide us with information in any way — we collect only the data provided by their browser to our server. This is necessary for technical purposes, to show the Site and ensure stable and secure access. The legal basis is our legitimate interest. That data is:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (the exact page accessed)
  • Access status / HTTP status code
  • The amount of data transferred in each case
  • The site generating the request (referrer)
  • Browser, browser version and language
  • Operating system and interface

We collect usage data in aggregate to assess the popularity of pages on the Site and how the Site delivers content to you. The processing of usage data is based on our legitimate interest in managing our business effectively, providing quality services, maintaining the Site, developing and improving products, and identifying who is interested in them.

User data. When you contact us through the request form on the Site, you provide us with your name or nickname, your e-mail address, the topic of the request, an optional order ID or transaction hash, and the content of your message. We use this Personal Data only to answer you, and we may keep a record of requests and responses to improve the quality of our support.

Order data. When you place an order on the Site, a contract is formed between you and us. To process the order we process the e-mail address you provide, the product ordered, and the blockchain transaction that paid for it. Payments are made in cryptocurrency: the transaction hash and the wallet address you paid from are visible to us and are recorded permanently on a public blockchain that we neither control nor can amend. We never ask for and never hold bank card details.

Support assistant. The Site offers an assistant that answers questions about the catalogue. Your messages to it are processed to generate a reply and are not used to build a profile of you.

Where possible we ask for your explicit consent to process your Personal Data — for example, consent to the use of cookies. You can control cookies at the browser level. If you do not consent to cookies you can still use the Site, but some features may be limited.

When we process Personal Data you send us in order to reply, we assume your consent to that processing. You may withdraw consent at any time by contacting us; Personal Data will be deleted within seventy-two (72) hours.

Communication

We collect any data you share with us — through the request form on the Site, by e-mail, through messaging platforms, or through any other communication you send us. We process this data to communicate with you, to maintain records, and to bring, pursue or defend legal claims. The legal basis for this processing is our legitimate interest in responding to communications sent to us and keeping records for the purposes of legal claims.

Additional terms of processing

We do not collect sensitive data about you. Sensitive data means details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic and biometric data. We do not collect information about criminal convictions or offences.

If we are required by law to collect Personal Data that you do not provide, we may be unable to fulfil the contract — for example, to provide you with the Services. If you do not provide the requested data we may have to cancel your order, and we will tell you if that happens.

We will only use your Personal Data for the purposes for which it was collected, or for reasonably compatible purposes. If we need to use your data for a new purpose we will inform you and explain the legal basis. We may process your Personal Data without your knowledge or consent where necessary or permitted by law.

We do not use automated decision-making or profiling.

Applicable law

  • For Users and Visitors located in the European Economic Area, Personal Data is processed in accordance with Regulation (EU) 2016/679 of 27 April 2016 — the General Data Protection Regulation (GDPR).
  • For Users and Visitors located in California, processing is carried out in accordance with the California Consumer Privacy Act (CCPA), Cal. Civ. Code § 1798.100 et seq.
  • For Users and Visitors located in the United Kingdom, processing is carried out in accordance with the Data Protection Act 2018.
  • For Users and Visitors located in Brazil, processing is carried out in accordance with the Lei Geral de Proteção de Dados (LGPD).

We process Personal Data as both Processor and Controller, as those terms are defined in the GDPR.

We may need to transfer your Personal Data to third-party service providers. Where Personal Data is transferred outside the European Economic Area, we require that appropriate safeguards are in place. We put Data Processing Agreements in place with our service providers requiring them to keep Personal Data confidential and to comply with the GDPR.

Your rights

You may review, correct, update, delete or transfer your Personal Data. To do so, contact us through the request form on the Site or by e-mail. We will acknowledge your request within seventy-two (72) hours and process it promptly and as required by law.

  • Right of access. You may ask whether we are processing your Personal Data. If we are, we will tell you which categories we process, the purposes, the categories of recipients it has been or will be disclosed to, and the expected retention period or the criteria used to determine it.
  • Right to withdraw consent. Where processing is based on your consent, you may withdraw it at any time by contacting us; your Personal Data will be deleted after seventy-two (72) hours. Withdrawal may reduce your ability to use the Services.
  • Right to object. Where processing is based on our legitimate interest in running and developing our business, you may object at any time. We will then stop processing your Personal Data unless it is needed to provide the Services, or unless we have compelling legitimate grounds that override your interests, rights and freedoms, or for legal claims.
  • Right to restrict processing. You may ask us to restrict processing as provided by applicable data protection law — for example, to let us verify accuracy after you challenge it, or to stop us deleting data you still need for legal claims. Restriction may reduce your ability to use the Services.
  • Right to data portability. You may receive your Personal Data from us in a structured, commonly used, machine-readable format, and transfer it to third parties, where our processing is based on your consent and carried out by automated means.

To exercise these rights, use the features offered through the Services first. If those are not sufficient, send us a request containing your name, contact details and a copy of valid proof of identity. We may request additional information to confirm your identity, and we reserve the right to reject unreasonably repetitive, excessive or manifestly unfounded requests.

If you are in California and are dissatisfied with how we have used your Personal Data, you may file a complaint with the California Department of Justice: https://www.oag.ca.gov/privacy/caloppa/complaint-form/privacy-notice. If you are in the UK, you may complain to the Information Commissioner's Office at casework@ico.org.uk. If you are in Brazil, you may complain to the National Data Protection Authority (ANPD) through its official channels.

Data storage

We retain Personal Data for as long as you use the Services or continue to communicate with our support team. Your information is deleted if you have not communicated with support for more than twelve (12) months.

When deciding how long to keep data we consider its quantity, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and legal requirements. For tax purposes we may be required to keep basic information about Users — contact, e-mail and transaction data — for twelve (12) months after they stop using the Services.

In some cases we may anonymise your Personal Data for research or statistical purposes, in which case we may use that information indefinitely without further notice to you. Data collected for analytics purposes is deleted twelve (12) months after collection.

Blockchain transactions are an exception we cannot control: once a payment is confirmed, the transaction record is public and permanent, and no party is able to erase it.

Information security

We apply generally accepted industry standards to protect the information you give us, both in transit and once we have received it. We maintain technical, physical and administrative measures so that your Personal Data is reasonably protected against unauthorised access, loss, manipulation, falsification, destruction or unauthorised disclosure.

No method of transmitting data over the Internet or storing electronic documents is 100% secure, so we cannot guarantee absolute security — but we do our best to keep transmission as secure as possible.

We do not process sensitive or criminal offence data as either Controller or Processor, and we do not carry out profiling.

Service providers

We employ third-party companies and individuals to operate the Site ("Service Providers"), to provide Services on our behalf, or to help us analyse how the Site is used. Third parties have access to your Personal Data only to perform those tasks on our behalf and are required not to disclose or use it for any other purpose.

  • Hosting. The Site and its data are hosted by our hosting provider, which supplies servers and related infrastructure.
  • Payments. Payments are accepted in cryptocurrency and settle on public blockchain networks. Where a payment processor is used to generate addresses and confirm transactions, that processor handles the transaction data under its own privacy policy. We do not store or collect bank card details at any point.
  • Support assistant. The assistant on the Site runs on our own infrastructure, so your conversations with it are not sent to a third-party AI provider.
  • Analytics. If we use a third-party analytics provider to monitor and analyse use of the Services, that provider processes usage data under its own privacy policy.

For a complete and current list of Service Providers, please contact us.

Age restrictions

We do not provide the Services to children. Users of the Services must be of legal age under applicable law.

The Site and Services are not intended for anyone under the age of 13. Minors may use the Site only with the assistance of a parent or guardian. Under no circumstances may anyone under the age of 13 use the Site.

We do not knowingly process the data of EU residents under the age of 16 without parental consent. If we become aware that we have done so, we will take reasonable steps to delete that Personal Data as soon as possible. Users must not provide us with the Personal Data of children.

Applicability

This Privacy Policy applies to the Site. The Site contains links to other websites; once you are redirected to another website, this Privacy Policy no longer applies.

Acceptance and updates

We assume you have read this document carefully and agree with its contents. If you do not agree with this Privacy Policy, you should refrain from using the Site.

We may need to share Personal Data with other parties: Service Providers who provide IT and system administration services; government authorities who require us to report processing activities; and third parties to whom we sell or transfer parts of our business or assets. We require all such third parties to respect the security of your Personal Data, to treat it in accordance with the law, and to process it only for specified purposes and on our instructions.

We may update this Privacy Policy from time to time, so we encourage you to review it periodically so that you always know what information we collect, how we use it, and with whom we share it.

Contact us

If you have any questions about how the Site works or about your dealings with it, send us a request through the Contact Us page — it is the fastest route and every request gets a reference number.

Operator: [Registered operator name] · E-mail: [support@your-domain.com] · Discord: [Discord handle]