Privacy Policy

1. Introduction and Notice at Collection

This section elaborates on the scope and applicability of this Policy. The "Platform" refers to our online crypto lending and yield generation platform. As a company incorporated and operating under the laws of the Republic of Panama, we are committed to protecting your privacy while providing our services.

We collect, and in the past 12 months have collected, the following categories of information from and about you: identifiers; commercial information; internet or similar network activity; government-issued identifiers; financial account numbers; and inferences drawn from other personal information. We collect these categories of information from you in order to provide our services to you, to run our business, to communicate with you, and as required by law. We may have disclosed each of these categories of personal information for a business purpose as described below. We have not "sold" or "shared" personal information in the past 12 months, as those terms are defined by the CCPA.

We will retain each of these categories of personal information based on several factors, including as reasonably necessary to (i) provide our products and services or administer our relationship with a consumer; (ii) protect our business, employees, organization, and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

This Policy governs all aspects of information collection, processing, and protection across our Platform's services, including but not limited to account creation, market participation, transaction processing, and user interactions. It applies to all users accessing our Platform, whether as registered members or visitors.

By using our Platform, you acknowledge that you have read and understood this Policy and agree to be bound by its terms. If you do not agree with any aspect of this Policy, you should immediately discontinue use of our Platform. We recommend reviewing this Policy periodically as it may be updated from time to time in accordance with Section 9 of this document.

For purposes of this Policy, any capitalized terms not defined herein shall have the meanings assigned to them in our Terms of Service. This Policy should be read in conjunction with our Terms of Service and any other agreements between you and us governing your use of the Platform.

We are aware of our responsibilities to handle your personal data with care, to keep it secure, and comply with privacy and data protection laws applicable to our company and your personal information, including Law 81 of March 26, 2019, on the Protection of Personal Data and its Regulations, the Executive Decree 285 of May 28, 2021 ("Data Protection Laws").

2. Information We Collect

We collect and process two main categories of information about you when you use our Platform:

"Personal Information" refers to information that can directly or indirectly identify you as an individual. This includes your full name, email address, postal address, phone number, date of birth, government-issued identification documents, banking and financial information, and account login credentials. We may collect some or all of this information when you use the Platform, make transactions, or otherwise communicate or interact with us in any way.

"Usage Data" encompasses information about how you interact with our Platform. This includes your IP address, browser type and version, device information, operating system, time zone setting, access times and duration, pages viewed, features used, transaction history, and other diagnostic data. We, or our third-party vendors, collect this information automatically when you access and navigate our Platform through cookies, pixels, web beacons, and similar tracking technologies.

We maintain detailed records of all Platform transactions, including stakes placed, outcomes, and associated timestamps. Your IP address and device identifiers are logged for security purposes and to comply with our legal obligations regarding market integrity and fraud prevention.

Please note that certain features of the Platform may not be accessible if you choose not to provide some of the requested information. Any personal information you provide will be processed in accordance with this Policy and applicable data protection laws.

2.1. Consent for Information Collection and Processing

In accordance with the Data Protection Law, by using the Platform you explicitly consent to us collecting, using and/or processing your Personal Information for:

• Collection and processing of basic account information necessary for Platform functionality;
• Processing of identity verification documents as required by applicable laws;
• Use of your financial information for transaction processing;
• Collection and analysis of Usage Data to improve our services; and
• Sharing your information with third parties as outlined in Section 4 of this Policy.

Where we collect sensitive personal data (including but not limited to government-issued identification documents, or financial information), we may implement additional security measures and obtain separate explicit consent for such collection and processing.

You have the right to withdraw your consent at any time by contacting us. Please note that withdrawal of consent for certain essential processing activities may impact our ability to provide you with access to some or all of the Platform features.

We maintain records of all consent provided by users in accordance with the Data Protection Law and make these records available to regulatory authorities upon legitimate request.

3. How We Use Your Information

We process the personal information we collect about you for the following purposes:

• Account Management and Platform Operations: We use your information to create and maintain your account, process your transactions, provide customer support, and ensure the proper functioning of our prediction market platform. This includes verifying your identity, processing payments, and communicating with you about your account activities.
• Platform Improvement and Analytics: We analyze user behavior and platform performance to enhance our services, develop new features, and optimize user experience. This includes conducting statistical analyses, performing market research, and generating aggregated insights about platform usage patterns. Such processing is conducted using industry-standard analytics tools with appropriate safeguards in place.
• Marketing and Communications: We use your information to send you promotional materials, newsletters, product updates, and other marketing communications that may be of interest to you. This includes personalized recommendations based on your Platform activity and preferences. You may opt out of marketing communications at any time as described in this Policy.
• Legal Compliance and Risk Management: We process your information to comply with applicable laws, regulations, and legal obligations, including anti-money laundering requirements, tax reporting, and response to legal requests from authorities. We also use your information to detect and prevent fraud, unauthorized access, and other prohibited activities on our Platform.

The processing of your personal information is necessary for the performance of our contract with you, compliance with our legal obligations, and our legitimate interests in operating, improving, and protecting our Platform. We retain your information only for as long as necessary to fulfill these purposes or as required by applicable law.

4. Information Sharing and Disclosure

We may share your personal information with third parties and service providers in the following circumstances:

• With our affiliated companies and subsidiaries who assist in operating our Platform and providing services to you, subject to confidentiality obligations consistent with this Policy. These affiliates may be located in jurisdictions outside Panama.
• With third-party service providers who help us operate, maintain, and enhance our Platform, including payment processors, cloud storage providers, analytics services, and customer support services.
• When required by law, regulation, or legal process, including to respond to court orders, subpoenas, or government requests. We may also share information when we believe disclosure is necessary to protect our rights, investigate fraud, or enforce our Platform's terms of service.
• In connection with a merger, acquisition, bankruptcy, dissolution, reorganization, or similar corporate event. If we are involved in such a transaction, you will be notified via email and/or a prominent notice on our Platform of any change in ownership or uses of your personal information.

We do not sell, rent, or lease your personal information to third parties for their marketing purposes without your explicit consent.

5. Data Security

We implement and maintain appropriate technical and organizational security measures to protect your Personal Information from unauthorized access, disclosure, alteration, and destruction. These measures include industry-standard encryption protocols for data in transit and at rest, secure socket layer (SSL) technology, firewalls, and restricted access controls to our data centers and information systems.

Access to Personal Information is strictly limited to authorized employees, agents, and service providers who require such access to perform their assigned duties. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of personal information to and from our Platform is at your own risk.

6. Your Rights and Choices

Depending on your state or country of residence, you may have certain rights regarding your personal information that we collect and process. You may exercise these rights by contacting our Data Protection Officer using the contact information provided in Section 10 of this Policy.

Your rights include: (a) the right to access your personal information and request details about how we process it; (b) the right to request correction of inaccurate personal information; (c) the right to request deletion of your personal information, subject to our legal obligations and legitimate business interests; (d) the right to object to or restrict certain processing activities; (e) the right to data portability; (f) the right to limit the use of disclose of your sensitive personal information; and (g) the right to opt out of the sale or sharing of your personal information.

Please note that we do not collect or process sensitive personal information, as defined by applicable Data Protection Laws, except as necessary to perform our services. We also do not knowingly "sell" or "share" any personal information, including any personal information relating to consumers under the age of 16, as we understand those terms to be defined under applicable Data Protection Law.

Agents that you have authorized to act on your behalf may also submit requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

You may opt-out of receiving marketing communications from us at any time by: (i) clicking the "unsubscribe" link in any marketing email we send; or (ii) contacting our Data Protection Officer. Please note that even if you opt-out of marketing communications, we may still send you important Platform-related notifications and updates.

If you wish to delete your account, you may do so through your account settings or by contacting us. Please note that some information may be retained in our records to comply with legal obligations, resolve disputes, enforce our agreements, or protect our legitimate business interests.

We will respond to all legitimate requests within ten (10) business days from the date of submission. For requests to modify data, we will process these within five (5) business days.

If you would like to adjust your cookie settings, you can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.

Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

7. International Data Transfers

We may transfer, store, and process your personal information in countries other than Panama. By using the Platform, you acknowledge and consent that your personal information may be transferred to and processed in countries that may have different data protection rules than your country of residence.

For transfers of personal data to countries outside the European Economic Area (EEA), we implement appropriate safeguards and mechanisms to ensure adequate protection of your personal information. These safeguards include entering into Standard Contractual Clauses approved by the European Commission with our service providers and partners.

We maintain appropriate technical and organizational measures to protect your personal information during international transfers, including encryption of data in transit and storage. Where we engage third-party service providers who may access your personal information from other countries, we require them to provide at least the same level of privacy protection as required under applicable data protection laws.

If you are located in the European Union, you have the right to obtain information about the safeguards we use for transferring your personal information outside the EEA. You may contact our Data Protection Officer using the contact information provided in Section 10 to request such information.

8. Children's Privacy

The Platform is not directed to, designed for, or intentionally targeted at children under the age of 18. We do not knowingly collect personal information from children under 18 years of age. If you are under 18, you may not use or provide any information on the Platform, register an account, make any predictions, or engage in any transactions.

If we become aware that we have inadvertently collected personal information from a child under the age of 18, we will take steps to delete such information from our records as soon as possible. If you believe we might have any information from or about a child under 18, please contact our Data Protection Officer immediately at the contact information provided in Section 10 of this Policy.

Parents and legal guardians who believe their child has submitted personal information to our Platform without their consent should contact us to request the deletion of that information. We reserve the right to request proof of identity and/or legal guardianship to process such requests.

9. Changes to This Policy

We reserve the right to update or modify this Policy at any time and from time to time without prior notice. We will post any revised version of the Policy on the Platform and update the "effective date" referenced at the beginning of this Policy. If we make any material changes to this Policy, we will notify you through a prominent notice on our Platform, by sending you an email to the last email address you provided to us, or through other appropriate communication channels.

Your continued use of the Platform following the posting of changes to this Policy will constitute your acknowledgment and acceptance of such changes. We encourage you to periodically review this Policy to stay informed about how we collect, use, and protect your personal information. If you do not agree with any changes to this Policy, you must discontinue using our Platform.

Any changes or modifications will be effective immediately upon posting the revised Policy on the Platform. These changes will apply to all information we have about you, as well as any information we may receive in the future.

10. Contact Us

For any questions, concerns, or requests related to your personal information or this Policy, you may contact us through the website.

We will endeavor to respond to your inquiries within 10 days of receipt. If you are exercising any of your data protection rights, we may need to request specific information from you to verify your identity. This is a security measure to ensure that personal information is not disclosed to unauthorized persons.

You may exercise your rights of access, rectification, cancellation, or opposition ("ARCO Rights") concerning your personal data, as well as request the withdraw of consent, by sending a request through the website.

11. Governing Law and Dispute Resolution

This Policy shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to its conflict of law provisions. To the extent permitted by applicable law, any dispute, controversy or claim arising out of or relating to this Policy, or the breach, termination or invalidity thereof, shall be settled by binding arbitration in Panama City, Panama, in accordance with the Rules of Arbitration of the International Chamber of Commerce by one or more arbitrators appointed in accordance with said Rules.

The arbitration shall be conducted in the English language. The arbitral tribunal shall consist of three arbitrators, with each party appointing one arbitrator and the two party-appointed arbitrators selecting the third arbitrator who shall serve as the presiding arbitrator. The award rendered by the arbitrators shall be final and binding on the parties, and judgment upon the award may be entered in any court having jurisdiction thereof.

Nothing in this Policy shall limit your rights under the Data Protection Law, including your right to file complaints with the National Authority for Transparency and Access to Information (ANTAI) for matters related to personal data protection. However, disputes arising from other contractual matters shall be resolved through arbitration.