PHLYXR Privacy Notice

Last updated: 04.06.2026

1. Introduction

1.1 PHLYXR ("we" / "us" / "our") recognises the importance that individuals place on their privacy when they provide us with personal data. As we are active in the medical and technology sectors, we are committed to protecting and respecting the privacy of any personal data we process.

1.2 This policy ("Privacy Notice") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, including where such personal data is collected via phlyxr.com (the "Site").

1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.5 For the purposes of this Privacy Notice, "UK GDPR" means Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018. The terms "consent", "controller", "personal data", "process", "processing", and "third party" shall have the definitions prescribed to them under the UK GDPR.

1.6 For the purpose of the UK GDPR, PHLYXR acts as the controller of the personal data we process.

1.7 If you have any questions, comments, or complaints regarding this Privacy Notice or how we process your personal data, please contact us at hello@phlyxr.com.

2. Information We May Collect From You

2.1 As we currently only process personal data for marketing and website administration purposes, the data we collect is strictly limited. We may collect the following types of personal data about you:

• Personal Identification & Contact Information: Your name and e-mail address (provided voluntarily when you sign up for our marketing communications or contact us).
• Log Data and Computer Information: Technical data created and logged automatically when you access the Site, including your Internet Protocol ("IP") address and device information.

2.2 We may collect the above-mentioned personal data from you in the following ways:

• Direct Interactions: Where you contact us directly (e.g., via email, website forms, or subscribing to our newsletters).
• Automated Technologies: As you interact with our Site, we automatically collect "log data." This includes technical information (device type, browser type and version, time zone setting, operating system) and information about your visit (URL clickstream to, through, and from our Site, pages viewed, page response times, and length of visits).
• Third-Party Sources: We may receive technical data about you from analytics providers and search information providers.

2.3 We do not collect any special categories of personal data (including data regarding health, ethnic origin, political opinions, or religious beliefs) or data relating to criminal convictions.

3. How We Use Your Information

3.1 We will only use your personal data in connection with our marketing activities and the running of our Site, and at all times in compliance with applicable data protection laws, including the UK GDPR. Specifically, your personal data is only collected and processed by us where:

• You have consented to the processing of your personal data;
• It is necessary for our legitimate business interests (e.g., when it is essential for us to process your data to enable us to operate the Site effectively or grow our business); or
• We are required to process your personal data to comply with legal obligations.

3.2 We may use your personal data in the following ways:

3.3 We do not use your personal data as part of any automated decision-making or profiling which produces legal or similarly significant effects concerning you.

4. How We Disclose Your Information

4.1 We do not sell, share, or transfer your personal data except as set out in this Privacy Notice and as permitted by law.

4.2 We may share your personal data with our selected partners and third-party service providers, limited to:

• Our IT and technology support partners, including cloud storage providers.
• Our email processing, marketing automation, and business software suppliers (e.g., platforms used to send our newsletters).
• Analytics and search engine providers that assist us in the improvement and optimisation of the Site.

4.3 Examples of other situations where we may disclose your personal data include:

• If we buy or sell any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.
• If PHLYXR, or substantially all of its assets, are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce our Terms of Use, or to protect the rights, property, or safety of PHLYXR or others.

5. Where and How We Store Your Information

5.1 All information you provide to us is stored directly with reputable third-party cloud storage providers. While the transmission of information via the internet can never be completely secure, we use strict procedures and security features, including appropriate technical and organisational measures, to secure your personal data from accidental loss, damage, destruction, or unauthorised access.

5.2 During the course of the activities of our support partners (such as marketing platforms), your personal data may be transferred to and stored at a destination outside the UK and European Economic Area ("EEA"). Any personal data transferred internationally will be subject to appropriate legally recognised safeguards.

5.3 We will store your personal data for as long as is necessary to fulfil the purposes for which it was originally collected.

• Marketing Data: Where personal data is processed pursuant to your consent for marketing, we will retain it until you withdraw your consent (unsubscribe), after which time such personal data shall be permanently deleted.
• Technical Data: Log data and technical information are typically held for a shorter duration, in line with standard industry practices for website security and analytics.

6. Third-Party Websites

6.1 The Site may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that those websites have their own privacy policies and privacy practices. We do not control such third parties' websites and do not accept any responsibility or liability for how they process your personal data. Please check these websites' policies before you submit any personal data to them.

7. Your Rights

7.1 Under certain circumstances and in accordance with the UK GDPR or other applicable data protection laws, you may have the right to require us to:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request that we correct or complete your personal data if it is inaccurate or incomplete.
• Right to Erasure (Right to be Forgotten): Request that we erase your personal data where we have no legal basis to continue processing it.
• Right to Restrict Processing: Request that we restrict how we process your personal data.
• Right to Object: Object to any processing that is based on our legitimate interests.
• Right to Withdraw Consent: Withdraw your consent for future processing at any time (e.g., clicking "unsubscribe" at the bottom of our marketing emails).

7.2 Further details about these rights can be found at the ICO's individual rights guidance.

7.3 If you withdraw your consent for us to process your personal data (such as for marketing), you will simply no longer receive our newsletters or updates.

8. Complaints

8.1 You have the right to make a complaint at any time regarding how we process your personal data to the Information Commissioner's Office (ICO), the UK's data protection regulatory authority:

9. Changes to this Policy

9.1 We may revise this Privacy Notice from time to time to reflect changes in our data processing practices as our startup grows. Please check this page regularly to take notice of any changes we may have made.