> For the complete documentation index, see [llms.txt](https://usefantasy.gitbook.io/rules/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://usefantasy.gitbook.io/rules/terms/privacy-policy.md). # Privacy Policy ## 1. INTRODUCTION This Privacy Policy explains how Felix Labs, INC, a Delaware C-corp with a registered address at 131 Continental Drive, Newark, DE, USA, 19713, USA (“Fantasy”, “we”, “us”, or “our”), collects, uses, discloses, and safeguards information about users (“Users” or “you”) who access or use the Platform located at usefantasy.xyz (the “Platform”). We respect your privacy and are committed to protecting your Personal Data and Blockchain Data in accordance with applicable data protection laws. Unless otherwise defined in this Privacy Policy, capitalised terms have the meanings given to them in the Fantasy Terms and Conditions (the “Terms”). By accessing or using the Platform, you confirm your understanding of, and consent to, the data practices described in this Privacy Policy. If you disagree with this Privacy Policy, please discontinue use of the Platform. ## 2. DEFINITIONS * “Platform” means Fantasy’s website, dashboards, and related infrastructure through which Users purchase Evaluation Accounts, trade on simulated Accounts, and request Payouts. * “Personal Data” means information that can identify an individual, either alone or in combination with other data, as defined under applicable data protection law. * “KYC Data” means identity information collected to verify a User’s identity ahead of Funded Account access or a Payout, including government-issued identification documents and a live selfie. * “Blockchain Data” means information related to on-chain transactions, including wallet addresses, transaction identifiers, and timestamps, that is recorded on a public blockchain in connection with a Payout. * “Third-Party Wallet Providers” means independent wallet services (such as MetaMask or a Hyperliquid-compatible wallet) that allow Users to receive Payouts from the Platform. * “Trading Data” means information generated by a User’s activity on an Account, including orders, positions, Equity, Balance, and performance history. These definitions are aligned with the Terms, ensuring consistency across all documents governing your use of the Platform. ## 3. INFORMATION WE COLLECT Fantasy collects several categories of information necessary to operate the Program, verify eligibility, process Payouts, comply with legal obligations, and maintain the security of the Platform. ### 3.1 Information You May Provide * Registration Information: your name, email address, and password or authentication credentials when you create an account. * KYC Data: a government-issued passport, national ID, or driver’s licence, together with a live selfie for identity matching, collected before Funded Account access or a Payout, as described in Section 8 of the Terms. * Payout Wallet Information: the blockchain wallet address you designate to receive Payouts. We do not store private keys or seed phrases and cannot access the contents of your wallet. * Payment Information: information necessary to process your Evaluation fee, which may be collected and processed directly by our third-party payment processors rather than stored by us. * Support Communications: the content of any message, together with your name and email address, when you contact our support team. ### 3.2 Information Collected Automatically * Trading Data: orders, positions, Equity, Balance, and other performance data generated by your use of an Account, which we use to enforce the Equity Limits and Profit Target described in the Rulebook and to detect Prohibited Conduct. * Blockchain Data: wallet addresses, transaction identifiers, and timestamps associated with a Payout are recorded on the applicable public blockchain once a Payout is sent. This record is immutable and outside the Platform’s control. * Usage Data: technical information such as browser type, device type, operating system, IP address, page views, and timestamps, collected automatically when you access the Platform. * Device and Fingerprinting Data: device and browser fingerprints, session identifiers, and related signals, which we use to detect Account sharing, multiple-identity registration, and other anti-farming violations described in Section 9.3 of the Terms. * Cookies and Similar Technologies: we use cookies and similar technologies to operate the Platform, remember preferences, and analyse usage trends. You may adjust your browser settings to manage cookies, though doing so may affect certain Platform features. ### 3.3 Information From Third-Party Sources * Payment Processors: our payment processors provide us with confirmation of payment and limited billing information necessary to reconcile Evaluation fee payments. * Third-Party Wallet Providers: when you designate a wallet to receive a Payout, limited data (such as your wallet address) is shared with us to facilitate the transfer. We are not responsible for the data-handling practices of Third-Party Wallet Providers and encourage you to review their privacy policies. * Sanctions and Screening Databases: we may screen Users against sanctions and watch-list databases maintained by OFAC and other competent authorities to comply with Applicable Law. ## 4. HOW WE USE YOUR INFORMATION ### 4.1 Operating the Program * Account Administration: to create and administer Evaluation and Funded Accounts, calculate Equity and Balance, and enforce the applicable Equity Limits and Profit Target. * Processing Payouts: to verify eligibility for, calculate, and deliver Payouts to the wallet address you designate. * Customer Support: to respond to inquiries, resolve technical issues, and improve the overall User experience. * Platform Improvement: to analyse Usage Data and Trading Data in aggregate to improve Platform performance and inform new features. ### 4.2 Compliance, Security, and Integrity * AML and Sanctions Compliance: to verify identity, screen for Restricted Persons and Sanctioned Persons, and comply with anti-money laundering and counter-terrorist financing obligations. * Detecting Prohibited Conduct: to detect Account sharing, opposite hedging, coordinated trading, latency arbitrage, and other Prohibited Conduct described in Section 9.3 of the Terms, using correlation analysis, device and IP fingerprinting, and trade pattern analysis across Accounts. * Security: to detect and mitigate unauthorised access, fraud, and other malicious activity. * Legal Obligations: to comply with Applicable Law, respond to lawful requests from regulators or law enforcement, and manage legal and reputational risk. ### 4.3 Research and Analytics We may aggregate and de-identify data for research, trend analysis, and internal reporting purposes. Aggregated data cannot be used to identify an individual User. ## 5. INFORMATION DISCLOSURE ### 5.1 Public Disclosure of Blockchain Data Once a Payout is sent, the transaction is recorded on the applicable public blockchain and is inherently visible to any network participant, including the destination wallet address, transaction amount, and timestamp. This transparency is inherent to blockchain networks, and Fantasy does not control or have the ability to modify this public record. ### 5.2 Service Providers We share limited data with third-party service providers who perform services on our behalf, including KYC and identity-verification providers, payment processors, cloud-hosting and analytics providers, customer-support platforms, and fraud-detection and security vendors. These providers are contractually restricted from using your data for any purpose other than providing services to us. ### 5.3 Legal and Regulatory Disclosure We may disclose Personal Data, KYC Data, or Trading Data where required to comply with a legal process, court order, or regulatory obligation, or in response to a lawful request from a law enforcement or regulatory authority. ### 5.4 Business Transactions In the event of a merger, acquisition, financing, or sale of some or all of Fantasy’s assets, User data may be transferred to the acquiring or surviving entity as part of that transaction. We will provide notice of any material change in ownership or in the applicable Privacy Policy. ### 5.5 With Your Consent We may disclose your information for any other purpose with your consent. ## 6. DATA RETENTION We retain Personal Data, KYC Data, and Trading Data only for as long as necessary to fulfil the purposes described in this Privacy Policy, to satisfy our legal, tax, and regulatory record-keeping obligations (which, for KYC and AML records, is typically a period of at least five years following the end of the relationship, or such other period required by Applicable Law), or to resolve disputes and enforce our agreements. Blockchain Data associated with a Payout remains permanently recorded on the applicable public blockchain, consistent with the design of blockchain networks, and cannot be deleted by Fantasy. Support communications are retained for reference and quality-control purposes for a reasonable period, after which they may be anonymised or deleted. ## 7. SECURITY MEASURES We implement technical and organisational measures designed to protect User data from unauthorised access, disclosure, alteration, or destruction, including: * Encryption: sensitive data is encrypted in transit and, where applicable, at rest. * Access Controls: access to User data is limited to authorised personnel on a need-to-know basis. * Monitoring and Audits: we conduct periodic security reviews and monitoring to identify and address potential vulnerabilities. * User Responsibility: you are responsible for safeguarding your account credentials and your Payout wallet’s private keys and recovery phrase, which Fantasy cannot recover or restore. No method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security of your information. ## 8. INTERNATIONAL DATA TRANSFERS Fantasy is based in the United States, and your information may be processed on servers located in the United States or other jurisdictions that may not have data protection laws equivalent to those in your home jurisdiction. Where we transfer Personal Data internationally, we take steps designed to ensure the data remains protected in accordance with this Privacy Policy and Applicable Law. By using the Platform, you consent to the transfer of your information to, and its processing in, jurisdictions other than your own. ## 9. YOUR RIGHTS AND CHOICES Depending on Applicable Law and your jurisdiction of residence, you may have some or all of the following rights in respect of your Personal Data: * Right of Access: to request confirmation of whether we process your Personal Data, and to request a copy of that data. * Right to Correction: to request correction of inaccurate or incomplete Personal Data. * Right to Deletion: to request deletion of your Personal Data, subject to our legal and regulatory record-keeping obligations (including in respect of KYC Data) and subject to the immutability of Blockchain Data described in Section 6. * Right to Data Portability: to request a copy of your Personal Data in a structured, machine-readable format. * Right to Withdraw Consent: where our processing is based on your consent, to withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal. To exercise any of these rights, please contact us through the channels published on the Platform. We may need to verify your identity before responding to your request and may decline requests that are manifestly unfounded, excessive, or that conflict with our legal or regulatory obligations. ## 10. CHILDREN’S PRIVACY The Platform is not directed to, and is not intended for use by, individuals under the age of 18. We do not knowingly collect Personal Data from minors. If we become aware that we have collected Personal Data from a minor without appropriate consent, we will take steps to delete that information. ## 11. THIRD-PARTY LINKS AND SERVICES The Platform may contain links to, or integrate with, third-party websites, wallet providers, payment processors, or KYC providers that are not owned or controlled by Fantasy. This Privacy Policy does not apply to those third-party services, and we encourage you to review their privacy policies before providing them with any information. ## 12. CHANGES TO THIS PRIVACY POLICY We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or technology. When we make material changes, we will update the “Effective Date” date at the top of this Privacy Policy and, where appropriate, provide additional notice through the Platform or by email. Your continued use of the Platform following any update constitutes your acceptance of the revised Privacy Policy. ## 13. CONTACT US If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through the support channels published on the Platform, or in writing to Felix Labs, INC, 131 Continental Drive, Newark, DE, USA, 19713.