PHOCIS Tech© — Privacy Policy

Comprehensive Privacy Policy

Effective Date: July 9, 2026

1. Introduction

PHOCIS Tech© ("Company," "we," "our," or "us") is committed to safeguarding the privacy and security of your non-public personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our services or access our platform. It applies to current and former customers, users accessing the Service on behalf of a business, and visitors of www.phocistech.com.

By accessing the Service, you consent to the practices described herein. This policy is constructed in accordance with U.S. federal and state privacy regulations, including but not limited to: GDPR, CCPA, GLBA, FIPA, and the California Shine the Light law. PHOCIS Tech© maintains the right to alter this policy and update compliance language at any time to align with evolving technologies, regulations, or operational standards. We may notify users via email, in-platform notices, or website updates.

2. Definitions

• Account: A unique record allowing access to PHOCIS Tech© services, which may include user-specific credentials, access levels, transaction logs, and system interaction data.
• Consumer: A natural person who interacts with the platform for personal or household purposes, as defined under CCPA.
• Data Controller: PHOCIS Tech© determines the purpose and means of processing personal data under GDPR.
• Device: Any hardware/software (e.g., mobile, desktop, tablet, kiosk) used to access the Service.
• Personal Data: Identifiable information such as name, contact data, account numbers, and biometric data.
• Service: The PHOCIS Tech© website, mobile apps, APIs, portals, and proprietary systems.
• Usage Data: Automatically collected data such as browser type, device info, interaction timestamps, and diagnostics.

3. Personal Information Collected

PHOCIS Tech© collects data from users, affiliated institutions, and automated systems during registration, onboarding, service use, or third-party integrations.

Examples of Data We Collect:

• Identifiers: Name, DOB, government-issued ID (license, passport).
• Contact: Address, email, phone, emergency contact.
• Transactional: Bank details, wire logs, ACH records, cash flow.
• Employment: Job title, employer, income verification.
• Sensitive: SSN, biometrics, authentication data.
• Behavioral: Heatmaps, clickstream, user interaction trends.

4. Data Collection Methods

Information may be collected via:

• Online forms & applications
• Uploaded documentation
• Financial integrations
• Support tickets
• Cookies & tracking scripts
• Session monitoring & screen recording

Third-party providers must meet PHOCIS Tech©'s privacy and security standards.

5. Cookies & Tracking Technologies

PHOCIS Tech© uses cookies, pixels, and tracking tools to:

• Maintain session stability
• Authenticate users
• Detect fraud/bot activity
• Improve navigation and platform UX
• Analyze user behavior

Tracking is anonymized unless tied to a logged-in session. Users can adjust settings via their browser.

6. Use of Information

PHOCIS Tech© uses your data to:

• Perform AML/KYC onboarding
• Enable secure account access & fund movement
• Meet legal/compliance reporting obligations
• Prevent fraud
• Optimize the platform via analytics
• Provide support & updates
• Develop new features & services
• Monitor and respond to security threats

AI and ML tools are used to detect anomalies, guide security alerts, and protect user data.

7. Disclosure of Information

PHOCIS Tech© does not sell or lease personal data. We may disclose information only when necessary, such as to:

• Regulators (SEC, FINRA, OFAC, FDIC)
• Legal entities under subpoena or court order
• Contracted service providers (under strict privacy terms)
• Auditors and compliance reviewers
• Data analytics vendors (anonymized use only)

8. International Data Transfer

While PHOCIS Tech© operates in the U.S., some data may be processed internationally under:

• Standard Contractual Clauses (SCCs)
• U.S.-EU Privacy Shield (legacy)
• Approved cross-border agreements

9. Data Security Measures

PHOCIS Tech© employs robust protection standards:

• AES-256 encryption (in transit + at rest)
• SOC 2 Type II certified systems
• Zero Trust access validation
• Regular 3rd-party penetration testing
• MFA on all access portals
• EDR systems and tamper-proof audit logs
• A defined Incident Response Plan (IRP)

10. Data Retention & Storage

We retain data in line with U.S. financial law:

• Customer Data: ≥ 7 years post account closure
• Communications: Indefinitely
• Transaction Records: Immutable for 7+ years
• Backups: Rotated & encrypted based on internal policy

Expired records are destroyed or anonymized per NIST 800-88 standards.

11. Customer Rights

Users may:

• Request a copy of stored data (Access)
• Request corrections (Rectification)
• Limit data use (Restrict Processing)
• Object to AI-based decisions
• Transfer data to another platform
• File complaints via support@phocis.tech

Requests can be submitted through our site's privacy section.

12. GDPR-Specific Disclosures

PHOCIS Tech© processes EU/EEA data under:

• Consent
• Contractual necessity
• Legal obligation
• Legitimate interest

Users can withdraw consent at any time, pending compliance requirements.

13. CCPA-Specific Disclosures

California residents may:

• Request disclosures of data from the past 12 months
• Request deletion (except when required by law)
• Exercise non-discrimination rights in pricing or access

Submit CCPA requests via our Data Access Portal or by calling 877.679.6879.

14. Minors & Children's Privacy

PHOCIS Tech© does not permit access by users under 18. We do not knowingly collect data from minors. Any such data will be deleted immediately.

15. Policy Updates

This Privacy Policy may be updated to reflect changes in law or operations. Updates will be communicated via:

• Our website
• Email (to registered users)
• In-platform notifications

16. SMS / Text Messaging & Mobile Information

If you provide your mobile phone number and opt in to receive text messages (SMS/MMS) from PHOCIS Capital Inc., d/b/a PHOCIS Tech©, we collect and store your phone number and your opt-in consent records solely for the purpose of sending you the messages you have agreed to receive, such as account notifications, security alerts, transaction confirmations, and, where separately elected, marketing messages.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted only as necessary to deliver those services. All other use cases and categories described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with, or sold to, any third parties.

You may withdraw your consent and stop receiving text messages at any time by replying STOP to any message. Reply HELP for assistance, or contact us at support@phocis.tech or 877-679-6879. Message and data rates may apply. For full details, see our SMS Messaging Policy.

17. Contact Information

For privacy questions or rights requests:

Schedule Onboarding Appointment →

Questions about this policy? Email support@phocis.tech or call 877.679.6879.

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