1.   Scope of This Policy

This Policy applies to:

•        All users who visit, register on, or use the Platform;

•        Information collected through our website, mobile applications, APIs, and associated services;

•        Information collected in connection with our KYC/AML compliance obligations.

This Policy does not apply to third-party websites or services linked from the Platform. We encourage you to review the privacy policies of those third parties independently.

2.   Information We Collect

2.1    Information You Provide to Us 

 2.2    Information We Collect Automatically

 2.3    Information from Third Parties

We may receive personal information from:

•        KYC/AML verification partners: Identity verification providers who process identity documents and biometric data on our behalf;

•        Blockchain networks: Publicly available on-chain data associated with wallet addresses you connect to the Platform;

•        Sanctions and PEP screening databases: Third-party services that screen users against international sanctions lists;

•        Analytics providers: Aggregated and pseudonymised usage data from analytics platforms.

3.  How We Use Your Information 

 4.   KYC/AMLData—SpecialProvisions

4.1  Given the regulatory requirements applicable to prediction market and crypto asset platforms, identity verification is a mandatory condition of using the Platform's full functionality. We process identity documents and biometric data (including facial images and liveness verification) for this purpose.

4.2  Biometric and identity document data is processed by our third-party KYC provider in accordance with their privacy terms and is not retained by the Company beyond what is required for regulatory record-keeping.

4.3  KYC/AML records, including identity documents, transaction histories, and compliance review records, are retained for a minimum of 5 years from the date of account closure (or such longer period as required by applicable law).

4.4  We are required to report suspicious activity to relevant financial intelligence authorities. Making such reports is a legal obligation, and we are generally prohibited from informing you that a report has been made ("tipping off").

5.  DataSharingandDisclosure

We do not sell your personal information. We share your information only as follows:

5.1    Service Providers (Data Processors)

We engage third-party service providers who process data on our behalf, including:

•        KYC/AML providers (identity verification, sanctions screening)

•        Cloud infrastructure providers (hosting, storage)

•        Analytics providers (usage analytics — data is pseudonymised)

•        Customer support platforms

•        Blockchain analytics providers (on-chain transaction monitoring for AML purposes)

•        Email delivery services

•        Legal and professional advisers (subject to professional confidentiality obligations)

All service providers are engaged under data processing agreements and are required to implement appropriate security measures.

5.2    Legal and Regulatory Disclosure

We may disclose your information to:

•        Competent regulatory authorities, financial intelligence units, or law enforcement agencies where required by applicable law or a valid legal order;

•        Courts or dispute resolution bodies in connection with legal proceedings;

•        Any successor entity in the event of a merger, acquisition, or sale of all or part of our business (subject to the successor maintaining equivalent data protection standards).

 5.3    With Your Consent

We may share your information with third parties for other purposes where you have given your specific, informed consent.

6.  International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. Where such transfers occur, we implement appropriate safeguards, including:

•        Standard contractual clauses approved by relevant data protection authorities;

•        Processing only with countries that have been assessed as providing an adequate level of data protection;

•        Binding corporate rules where applicable.

By using the Platform, you acknowledge that your information may be transferred internationally as described above.

7.   Cookies and Tracking Technologies

7.1  We use cookies and similar tracking technologies (including pixels and local storage) to operate the Platform, analyse usage, and (where you consent) personalise your experience.

7.2  The types of cookies we use:

7.3  You can manage your cookie preferences through our Cookie Consent Manager, accessible in the Platform footer. You can also control cookies through your browser settings. Disabling strictly necessary cookies will affect Platform functionality.

7.4  We do not use tracking technologies to build advertising profiles for sale to third parties.

8.  Data Retention

We retain your personal information for as long as:

•        Your account remains active;

•        It is necessary to provide Platform services;

•        It is required to comply with applicable legal and regulatory obligations (including AML record-keeping requirements of a minimum of 5 years);

•        It is necessary for the establishment, exercise, or defence of legal claims.

Upon account closure, identifiable personal information will be deleted or anonymised within 90 days, except where longer retention is required by law. KYC/AML records are retained for the periods required by applicable regulation.

9.  Your Data Rights

Subject to applicable law, you may have the following rights in respect of your personal information:

To exercise any of these rights, please contact privacy@polytrade.live. We will respond within 30 days of receiving your request. We may require you to verify your identity before processing your request.

Limitations: Some rights may be limited or excluded where applicable law requires us to retain or process your information (for example, AML record-keeping obligations).

10. Security

10.1  We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:

•        Encryption of data in transit (TLS) and at rest (AES-256 or equivalent);

•        Multi-factor authentication for Platform accounts and internal systems;

•        Role-based access controls limiting employee access to personal data;

•        Regular security audits and penetration testing;

•        Incident response and business continuity procedures.

10.2  Notwithstanding the above, no system is entirely secure. We cannot guarantee absolute security and are not liable for unauthorised access that is beyond our reasonable control.

10.3  Data Breaches. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable data protection law.

11.  Children's Privacy

The Platform is not intended for, and we do not knowingly collect personal information from, individuals under the age of 18. If we become aware that we have collected personal information from a minor, we will promptly delete it. If you believe a minor has provided us with personal information, please contact privacy@polytrade.live.

12. Third-Party Links

The Platform may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing them with any personal information.

13. Blockchain Data

13.1  You acknowledge that data recorded on a public blockchain network is inherently public and immutable. Wallet addresses, transaction amounts, and timestamps associated with on-chain activity are publicly visible to anyone with access to the relevant blockchain.

13.2  We cannot delete or modify on-chain data. Requests for erasure of blockchain data cannot be fulfilled to the extent such data exists on a public ledger. Our obligations under data protection law apply only to personal data in our systems and control.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to you via email or a prominent notice on the Platform at least 14 days before the change takes effect. The date of the most recent revision is always indicated at the top of this Policy. Your continued use of the Platform after the effective date of a revision constitutes your acceptance of the updated Policy.

15. Supervisory Authority

If you are located in a jurisdiction with a data protection supervisory authority and you believe we have not handled your personal information in accordance with applicable law, you have the right to lodge a complaint with the relevant authority. Please contact us first so we have the opportunity to address your concern.

16. Governing Law

Any disputes arising under this Policy shall be subject to the dispute resolution provisions set out in our Terms and Conditions.

17. Contact Us

For all privacy-related queries: