Legal & Compliance

Terms of Service

Effective 06/01/25 · Last updated 06/30/25

Company: DoorDex Labs LLC, doing business as Phosphor (“Phosphor”, “we”, “us”, “our”)

1. Acceptance of Terms

By accessing or using the Phosphor Platform, including but not limited to phosphor.finance, app.phosphor.finance, and all services provided by DoorDex Labs LLC, you (“User”, “you”) agree to be legally bound by these Terms of Service (“Terms”). If you do not agree to these Terms, do not use the Platform.

These Terms form a legally binding agreement between you and DoorDex Labs LLC, a registered Money Services Business (MSB) with FinCEN.

2. Eligibility

You may use the Platform only if you:

• Are at least 18 years old and have the legal capacity to enter into a binding agreement;
• Are not a citizen or resident of a jurisdiction sanctioned by OFAC or otherwise prohibited by U.S. law;
• Will comply with all applicable laws, rules, and regulations.

We reserve the right to decline or terminate service to anyone at our sole discretion.

3. Account Registration and Verification

To use most features of the Platform, you must create an account and complete Know Your Customer (KYC) verification. You agree to:

• Provide truthful, accurate, and complete information;
• Maintain and promptly update your information;
• Not impersonate any person or use another user’s account.

You are solely responsible for maintaining the confidentiality of your credentials and for any activity under your account.

4. Services Provided

Phosphor provides services including:

• Cryptocurrency sales and purchases via express delivery;
• Managed access to decentralized finance (DeFi) strategies;
• Stablecoin liquidity services;
• User subscriptions for crypto services;
• Wallet integrations and transaction tracking.

Phosphor does not custody user funds. You remain in full control of your digital assets unless explicitly stated otherwise.

5. Compliance and AML/KYC

Phosphor is a licensed MSB and complies with all relevant AML/KYC obligations, including FinCEN regulations and state MSB laws.

You agree to:

• Complete identity verification prior to using our services;
• Cooperate with compliance reviews and submit requested documents;
• Refrain from using the Platform for any illegal or unauthorized purpose.

We may suspend or terminate your account at any time if you are suspected of violating our compliance policies.

6. Risk Disclosures

You acknowledge and accept the following risks:

• Cryptocurrency volatility: Prices can fluctuate significantly and are not guaranteed.
• Regulatory risk: Laws governing cryptocurrencies are evolving and may affect service availability.
• DeFi risk: Participation in DeFi strategies involves smart contract risk, market risk, and protocol failure risk.
• Technology risk: The Platform may experience outages, bugs, or third-party service disruptions.

Phosphor does not guarantee profits or returns and is not liable for losses from market movements or third-party failures.

7. Prohibited Activities

You agree not to use the Platform to:

• Violate any law, regulation, or third-party right;
• Commit fraud or misrepresentation;
• Evade AML/KYC processes;
• Use automated systems (bots, scrapers) without consent;
• Transact on behalf of prohibited or sanctioned entities.

We reserve the right to investigate and take legal action for any prohibited activity.

8. Fees

All applicable fees are clearly disclosed before you confirm any transaction. Fees may include:

• Service fees
• Spread or markup (where applicable)
• Subscription fees (if enrolled in recurring plans)

Phosphor reserves the right to adjust fee structures at any time with reasonable notice.

9. Intellectual Property

All content, branding, trademarks, and software on the Platform are owned by Phosphor or its licensors. You may not copy, modify, distribute, or reverse-engineer any part of the Platform without our prior written permission.

10. Limitation of Liability

To the fullest extent permitted by law:

• Phosphor is not liable for any indirect, incidental, punitive, or consequential damages arising from your use of the Platform;
• Our total aggregate liability will not exceed the greater of $100 or the fees paid to us in the past 6 months.

You agree to indemnify Phosphor from any claims, losses, or liabilities resulting from your violation of these Terms or applicable law.

11. No Financial Advice

Phosphor is not a registered broker-dealer, investment advisor, or tax advisor. All information provided is for educational or informational purposes only and should not be construed as financial or legal advice.

You are solely responsible for your investment decisions.

12. Termination

We may suspend or terminate your access at any time if:

• You violate these Terms;
• We are required to do so by law or regulation;
• You fail to pass KYC, trigger a sanctions match, or pose a compliance risk.

Upon termination, you are responsible for any outstanding obligations.

13. Changes to These Terms

We may update these Terms from time to time. If material changes are made, we will provide notice (e.g., via email or website notification). Your continued use of the Platform constitutes acceptance of the updated Terms.

14. Governing Law & Dispute Resolution

These Terms are governed by the laws of the State of California (or your state of residence, if required by law), without regard to conflict-of-law principles.

You agree to resolve disputes through binding arbitration, waiving class actions and jury trials, except where prohibited by law.

15. Contact Us

For questions, feedback, or legal notices:

DoorDex Labs LLC
Email: support@phosphor.finance
Website: https://staging.phosphor.finance

Privacy Policy

Effective 06/01/25 · Last updated 06/30/25

This Privacy Policy explains how DoorDex Labs LLC (“Phosphor”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal information through our websites and platforms: phosphor.finance, app.phosphor.finance, and all associated services and content (collectively, the “Platform”).

By accessing or using our Platform, you agree to the terms of this Privacy Policy.

1. Information We Collect

We collect personal information in the following ways:

a. Information You Provide

• Contact details: Name, email address, phone number
• Account data: Login credentials, profile info, communications
• Payment data: Wallet addresses, transaction history, payment method (if applicable)
• Support interactions: Feedback, support requests, survey responses

b. Information Collected Automatically

• Device data: IP address, browser type, operating system
• Usage data: Pages visited, clicks, time spent on site
• Cookies and tracking: As described in our Cookie Policy

c. Third-Party Sources

We may receive information from third-party partners (e.g., analytics tools, marketing services, or financial institutions).

2. How We Use Your Information

We use personal data for purposes including:

• To provide, maintain, and improve our services
• To personalize your experience and remember preferences
• To communicate with you about your account or support requests
• To detect and prevent fraud or unauthorized activity
• To comply with legal and regulatory requirements
• To market our services (with your consent, if required)

3. Sharing Your Information

We do not sell your personal information for monetary compensation.

We may share your data with:

• Service Providers: For hosting, analytics, payment processing, marketing, or support
• Legal Authorities: When required by law or to protect our rights and users
• Business Transfers: In case of merger, acquisition, or asset sale

Any third party receiving your data is contractually bound to use it only for the services they perform for us.

4. Your Privacy Rights

a. California Residents (CCPA/CPRA)

If you reside in California, you have the following rights:

To make a request, email us at support@phosphor.finance with the subject line “California Privacy Rights”. You may also authorize an agent to act on your behalf.

b. Other U.S. States (VA, CO, CT, UT)

Residents of these states may also have:

• The right to access or delete their data
• The right to opt out of targeted advertising and profiling
• The right to correct inaccurate personal data

To exercise these rights, contact support@phosphor.finance with your state of residence clearly stated.

5. Data Security

We implement reasonable technical and organizational measures to protect your personal information. While we strive to protect your data, no method of transmission over the internet or storage is 100% secure.

6. Data Retention

We retain your personal data only as long as necessary for the purposes stated in this policy, or as required by law.

7. International Data Transfers

DoorDex Labs LLC operates in the United States. If you access our Platform from outside the U.S., you consent to transferring your data to and processing it in the U.S., where privacy laws may differ from your country of residence.

8. Children’s Privacy

Our services are not intended for children under 18. We do not knowingly collect personal data from children. If we learn that we have collected data from a minor without parental consent, we will delete it promptly.

9. Updates to This Policy

We may revise this policy to reflect legal, technical, or operational changes. Updates will be posted on this page with a revised “Effective Date.” Continued use of our Platform after changes implies consent.

10. Contact Us

For questions, requests, or complaints regarding this Privacy Policy, contact:

DoorDex Labs LLC
Website: https://staging.phosphor.finance
Email: support@phosphor.finance

Cookie Policy

Effective 06/01/25 · Last updated 06/30/25

This Cookie Policy explains how DoorDex Labs LLC (“Phosphor”, “we”, “us”, or “our”) uses cookies and similar tracking technologies on phosphor.finance and app.phosphor.finance (the “Platform”). It also describes your rights in certain jurisdictions, including California.

By continuing to use our Platform, you consent to the use of cookies as described below.

1. What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow us to recognize your browser, remember preferences, understand how users interact with our services, and improve your overall experience.

2. Why We Use Cookies

We use cookies for the following purposes:

• Essential Cookies: Necessary to provide core functionalities such as secure login, account access, and fraud prevention.
• Performance & Analytics Cookies: Help us measure and improve Platform performance by understanding user behavior.
• Functionality Cookies: Store user preferences (e.g., language, region).
• Marketing Cookies (if applicable): Provide tailored ads and measure campaign effectiveness.
• Third-Party Cookies: Used by partners (e.g., analytics providers, embedded content tools).

3. Types of Cookies We Use

4. Your Choices

You have the right to control cookies:

• Cookie Banner: On your first visit, a banner allows you to accept or reject optional cookies.
• Browser Settings: Most browsers let you block, delete, or alert you about cookies.
• Do Not Track: We currently do not respond to DNT browser signals.
• Google Opt-Out: For Google Analytics, visit https://tools.google.com/dlpage/gaoptout

Disabling some cookies may affect Platform functionality.

5. Cookie Retention

• Session Cookies: Deleted when the browser closes.
• Persistent Cookies: Remain until expiration or user deletion.

We retain cookie data for only as long as necessary to fulfill their purposes.

6. California Consumer Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) regarding your personal information collected through cookies:

a. Right to Know

You may request that we disclose the categories and specific pieces of personal information we collect through cookies and third-party tools.

b. Right to Opt-Out of Sale/Sharing

While Phosphor does not sell personal data for monetary value, we may share data for analytics or advertising, which could be considered a “sale” or “sharing” under CCPA/CPRA. You may opt out by:

• Adjusting cookie settings via our banner or preference center.
• Sending an email to support@phosphor.finance with “Do Not Sell or Share My Personal Information” in the subject line.

c. Right to Delete

You may request that we delete personal data obtained via cookies (subject to exceptions).

d. Authorized Agent

California residents may designate an authorized agent to make privacy-related requests on their behalf.

To exercise these rights, please contact us using the information below.

7. State-Specific Notices

We recognize that other U.S. states — such as Virginia, Colorado, Connecticut, and Utah — have enacted or are enacting their own consumer privacy laws. Residents of these states may also have rights to:

• Access their personal data;
• Delete or correct that data;
• Opt out of processing for targeted advertising or profiling.

DoorDex Labs will comply with applicable state laws and will honor your privacy choices wherever required.

8. Updates to This Policy

We may revise this policy to reflect changes in technology, law, or our business practices. When we do, we will update the “Effective Date” and post the revised version on this page.

9. Contact Us

If you have any questions, or if you wish to exercise your rights, please contact:

DoorDex Labs LLC
Email: support@phosphor.finance
Website: https://staging.phosphor.finance

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Effective 06/01/25 · Last updated 06/30/25 · MSB Registration Number: 31000260888724

Company: DoorDex Labs LLC, doing business as Phosphor (“Phosphor”)

1. Introduction

DoorDex Labs LLC, doing business as Phosphor (“Phosphor”) is a registered and licensed Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) in the United States. As a crypto-focused financial services platform, we are committed to complying with all applicable Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) laws and regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and relevant state and federal guidance.

This policy outlines our approach to identifying, mitigating, and reporting risks related to money laundering, terrorist financing, and other illicit activity.

2. Legal Compliance

Our AML/KYC Program is designed to meet the requirements of:

• FinCEN regulations for MSBs
• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• OFAC Sanctions Compliance
• State MSB licensing rules
• FATF Recommendations (international best practices)

3. Know Your Customer (KYC) Procedures

a. Customer Identification Program (CIP)

Before providing services, Phosphor verifies the identity of all customers. Required information includes:

• Full legal name
• Date of birth
• Residential address
• Government-issued photo ID
• Selfie or biometric verification (when applicable)
• Additional documentation for business accounts

We use reputable third-party KYC providers to ensure document authenticity and biometric matches.

b. Ongoing Monitoring

We continuously monitor user accounts for behavioral anomalies and changes in risk profile. Periodic re-verification may be required in line with our risk-based approach.

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence to:

• High-volume users
• Politically Exposed Persons (PEPs)
• Users in high-risk jurisdictions
• Accounts linked to suspicious behavior

EDD may require supporting documents such as source of funds, occupation, business details, or video interviews.

5. Transaction Monitoring

Phosphor monitors all transactions using automated systems and human review to detect:

• High-risk patterns (e.g., layering, structuring, or rapid cycling of assets)
• Unusual blockchain activity
• Use of mixers, tumblers, or privacy coins
• Transfers to or from high-risk or sanctioned jurisdictions

We employ blockchain analytics tools and third-party screening to assist with these processes.

6. Sanctions Screening

We screen all users and transactions against:

• OFAC SDN and sanctions lists
• UN, EU, and other international watchlists
• PEP databases and adverse media sources

We prohibit access to our services from individuals or entities on these lists and from restricted jurisdictions.

7. Recordkeeping

In compliance with FinCEN regulations, we retain the following for at least 5 years:

• KYC documents and verification data
• Transaction logs and audit trails
• Communications and user activity logs
• Internal reviews and compliance actions

All data is securely stored with restricted access.

8. Suspicious Activity Reporting

As a licensed MSB, Phosphor is obligated to file Suspicious Activity Reports (SARs) with FinCEN when we suspect:

• Use of our platform for illegal or fraudulent activity
• Structuring or attempts to evade controls
• Use of accounts without an apparent lawful purpose
• Refusal to cooperate with compliance requests

Note: We do not process physical cash. Therefore, Currency Transaction Reports (CTRs) — which apply to cash transactions over $10,000 — are not applicable to our operations.

9. User Responsibilities

By using Phosphor, users agree to:

• Provide accurate and complete KYC information
• Not engage in prohibited or unlawful activity
• Cooperate with any compliance reviews or requests

Failure to comply may result in account restriction, suspension, or termination.

10. Compliance Oversight

Our AML program is overseen by a dedicated Compliance Officer, who is responsible for:

• Managing and updating policies
• Ensuring staff training and regulatory awareness
• Conducting internal audits and risk assessments
• Liaising with regulators and law enforcement when necessary

11. Policy Review

This policy is reviewed and updated at least annually, or more frequently as needed based on regulatory changes or risk environment shifts.

12. Contact Us

For questions or to report a concern, contact:

Compliance Department
DoorDex Labs LLC
MSB Registration #: 31000260888724
Email: support@phosphor.finance