Privacy Policy

This website-hosted user interface and the related applications (together, the “Interface”) are made available by PredictGlobe (“PredictGlobe”, “us”, “we” or “our”).

This Privacy Policy (the “Policy”) governs the manner in which we make the Interface available and how we collect, use, maintain and disclose information collected from our users (each, a “user”, “you” or “your”) through our websites, including the Interface, web applications, mobile applications and all associated sites linked thereto by the Interface or by us (the “Site”). This Policy further applies to all information we collect through our Site and otherwise obtain in connection with the products, services, content, features, technologies and functions we provide to you or to which we provide access (collectively with the Site, the “Services”).

Please read this Policy carefully. We are committed to protecting your privacy through our compliance with the terms of this Policy.

We understand that you may have questions regarding this Policy, including your personal information, how it may be collected and how it may be used. You may email us at support@predictglobe.com with any privacy-related questions or concerns.

Our Terms of Use (the “Terms”) govern all use of our Services and, together with this Policy, constitute your agreement with us (the “Agreement”). If you do not agree with the terms of this Policy, please do not access our Site.

By accessing or using our Services, you acknowledge that you have read and understood this Policy. Specifically, by (i) using, visiting or accessing the Services, (ii) establishing an account through the Services, and/or (iii) clicking “accept”, “agree” or “OK” (or a similar term) with respect to any of our Terms or similar policies, you acknowledge the practices described in this Policy. Where applicable law requires your consent for a particular processing activity, we will request that consent separately and you may withdraw it at any time.

In operating the Site and providing the Services we collect and/or receive certain information about you and your activities, as described below.

This Policy applies to all information we collect from you in connection with the Site and the Services. This Policy does not apply to information collected by us offline or through any other means, including on any other website made available by any third party. Throughout this Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymised so that it no longer identifies a specific user.

This Policy does not apply to information recorded on public blockchain networks. Such information is public, permanent and outside our control. Please see Public information below.

When you visit the Site and use the Services, we collect your IP address and standard web log information, such as your browser type and the pages you accessed on our Site. We also derive approximate geolocation information from your IP address, as described below. If you do not agree to our collection of this information, you will not be able to use the Services, because we rely on it to enforce geographic restrictions and to secure the Interface.

We collect information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Site, which may include usage details, IP addresses and information collected through Cookies and other tracking technologies.
• In certain instances, from third parties, such as our infrastructure, wallet, payment and fraud-prevention providers, and from publicly available blockchain data.

If you create an account with us, we collect the following information from you:

• Account information. Your email address, which we verify using a one-time code, together with your account identifier and the date and time of registration. If you choose to sign in with Google, we receive the email address and account identifier that Google provides. We do not currently require you to provide your name, postal address, telephone number or date of birth in order to create an account. Where you choose to provide additional information, for example when contacting support, we will retain it as described in this Policy.
• Derivative information. Information our servers collect automatically when you access the Site, such as your IP address, browser type and version, operating system, device type, language settings, screen resolution, access times, referring source, the pages you viewed directly before and after accessing the Site, and details of your interaction with the Services. This also includes security-related information such as login timestamps, session identifiers, failed authentication attempts and signals indicating the use of a virtual private network, proxy or similar technology.
• Wallet and transaction information. The blockchain wallet address associated with your account; the addresses, assets, networks and amounts involved in your deposits and withdrawals; your orders, executions, positions, balances and settlement records; blockchain transaction identifiers; and records of fees charged. Our wallet-infrastructure and payment providers collect, process and store certain of this information in accordance with their own privacy policies.
• Geolocation information. We derive your approximate location (country, region and, where available, city) from your IP address each time you access the Services. We do not currently collect precise GPS-based location. We use this information to determine whether access to the Services is permitted in your location under our Restricted Countries and Regions Policy, to detect attempts to circumvent those restrictions, and for fraud-prevention and risk-management purposes. Location determinations are approximate and may occasionally be incorrect. If you believe you have been restricted in error, please contact us.
• Responsible participation information. Any deposit limits, loss limits, time-outs, self-exclusions or similar controls you set, together with the dates on which they were set and any related correspondence.
• Correspondence and recordkeeping. We retain records and copies of your correspondence, including email addresses, if you contact us. We retain all records for such period as may be required by applicable law or as described under Retention below.
• Surveys and feedback. If you decide to participate in surveys or provide feedback, you may be asked to provide certain information, which may include personal information. We may store such responses.

We are committed to providing a safe and secure customer experience. We do not currently require government-issued identity documents from all users. However, before permitting you to use, or continue to use, certain Services, we may require additional information from you, which may in future include government-issued identity documents, that we can use to verify your identity, age or location, prevent fraud, comply with sanctions requirements or manage risk and compliance throughout our relationship. If we introduce such requirements, we will update this Policy before collecting that information.

Finally, we may collect additional information from or about you in other ways not specifically described here, for example in connection with your contact with our support team.

Our Site is not intended for persons under 18 years of age, or the higher age of majority in your jurisdiction. No one under that age may provide any personal information to or on the Site. If we obtain actual knowledge that we have collected personal information from a person under 18, we will close the relevant account and promptly delete the information, unless we are legally obligated to retain it. If you believe we may have collected information from or about a person under 18, please contact us using the contact information below.

A cookie is a small file placed on your device. When you visit our Site or use our Services, we and certain service providers may use cookies, local storage, pixels and similar technologies (collectively, “Cookies”). We use Cookies to recognise you as a user, to keep you logged in, to secure the Interface, to store the result of the geographic access check, to remember your preferences, to perform analytics, to mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.

Strictly necessary Cookies are required for the Services to function and are used without consent. Where required by applicable law, including for visitors from the European Economic Area, the United Kingdom and Switzerland, we obtain your consent before setting any non-essential Cookies, and you may withdraw that consent at any time by contacting us at support@predictglobe.com. We do not currently use advertising or retargeting Cookies.

Most browsers are set to accept cookies by default. You can remove or reject cookies through your browser settings. However, certain Services are only available through the use of Cookies. If you choose to disable or decline strictly necessary Cookies, your use of the Services may be limited or not possible.

Global Privacy Control. We honour the Global Privacy Control browser signal as an instruction to reject non-essential Cookies.

Further detail, including a list of the Cookies we set, is provided in our Cookie Notice.

Having accurate information about you permits us to provide you with a secure, efficient and compliant experience. Specifically, we use information collected about you via the Site to:

• Create and manage your account and authenticate you when you log in.
• Deliver the Services, execute your instructions and process transactions, including deposits, orders and withdrawals, and send notices about your transactions.
• Determine whether access to the Services is permitted in your location and detect attempts to circumvent geographic restrictions.
• Comply with sanctions requirements and other legal obligations, and respond to lawful requests from public authorities.
• Detect security incidents; protect against malicious, deceptive, fraudulent, manipulative or illegal activity; and investigate and act on violations of our Terms.
• Apply the responsible-participation controls you have set.
• Contact you regarding your account, your use of the Services, and material changes to our Terms, fees or policies.
• Provide customer support and respond to your enquiries and complaints.
• Debug, identify and repair errors that impair intended functionality.
• Monitor and analyse usage and trends, compile aggregated and anonymised statistics, and improve, upgrade and enhance the Services.
• Research and develop new products, services and security procedures.
• Ensure internal quality control.
• Send you marketing communications where you have consented to receive them.
• Resolve disputes, collect fees and troubleshoot problems.
• Enforce our Terms and policies and protect our rights, property and safety and those of our users and others.
• Fulfil any other purpose for which you provide us with your information, or as otherwise disclosed to you at the time of collection.

Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases: performance of our contract with you (account operation, transaction execution, support); compliance with our legal obligations (sanctions screening, geographic restrictions, responding to lawful requests, record-keeping); our legitimate interests (security, fraud and manipulation prevention, service improvement, enforcing our Terms), which we have assessed as not being overridden by your rights and interests; and your consent (non-essential Cookies, marketing emails), which you may withdraw at any time.

We use automated processing to enforce geographic restrictions. If you are blocked and believe this is incorrect, you may contact us to request human review.

We do not sell your personal information and we do not share it with third parties for their own direct-marketing purposes. If we intend to use your information in any manner that is not consistent with this Policy, you will be informed of such use before or at the time the information is collected.

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We use administrative, technical and physical security measures to help protect your personal information, including encryption in transit, encryption at rest for sensitive data stores, firewalls, logging and monitoring, and access controls that limit access to personal information to those who require it. Despite our efforts, we cannot guarantee that personal information will not be accessed, disclosed, altered or destroyed by breach of our safeguards.

We urge you to take adequate precautions to protect your own information, including keeping the email account associated with your PredictGlobe account secure, as anyone with access to that email account may be able to access your PredictGlobe account. We will never ask you for your seed phrase, private keys or one-time codes.

In the event of a personal-data breach affecting you, we will notify you and the relevant supervisory authority where required by applicable law.

We retain personal information for as long as reasonably necessary to fulfil the purposes described in this Policy, to comply with legal, regulatory, accounting and reporting obligations, to resolve disputes and to enforce our agreements. Indicatively:

• Account and email information: for the life of the account and 5 years after closure.
• IP address and geolocation logs: 12 months on a rolling basis, except where retained as evidence of a compliance or security event.
• Transaction, order and settlement records: 5 to 7 years from the transaction.
• Responsible-participation and self-exclusion records: for the duration of the control and 5 years thereafter, so that it can be honoured.
• Support correspondence: 3 years.
• Security and authentication logs: 12 months.
• Analytics information: up to 26 months, after which it is aggregated or deleted.
• Cookie-consent records: 12 months from the last consent decision.

These periods may be extended where information is subject to a legal hold, investigation or dispute. Information recorded on a blockchain cannot be deleted by us.

Some information is public by nature of the technology on which the Services rely. Your wallet’s public address and the transactions in which it has been involved are recorded on public blockchain networks and may be seen by anyone on the Internet, whether or not they have an account with us. Such information may also be seen, accessed, reshared or downloaded through APIs, block explorers, analytics tools or third-party services that interact with those networks. You should not assume that on-chain activity is private.

We share your information only as described below and only to the extent necessary for the relevant purpose:

• Service providers. We employ other companies to perform functions on our behalf, including wallet-infrastructure providers; providers of the market, order-book and settlement infrastructure through which your orders are executed; payment, bridging and fiat on-ramp providers; cloud hosting and content-delivery providers; email delivery, analytics, error-monitoring and customer-support tooling; and IP-geolocation, fraud-detection and sanctions-screening services. These providers are bound by contractual obligations of confidentiality and data protection and may use your information only to provide the relevant service. Payment and on-ramp providers may conduct their own compliance checks under their own terms and privacy policies. A list of our current sub-processors is available on request.
• Affiliates. We may share information with any of our parent companies, affiliates, subsidiaries or other companies under common control with us, for the purposes described in this Policy.
• Professional advisers. Lawyers, accountants, auditors and insurers, under obligations of confidentiality.
• Legal and safety. Law enforcement, government officials, regulators or other third parties if we are compelled to do so by a subpoena, court order or similar legal process; when necessary to comply with law; or where disclosure is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, to investigate violations of our Terms, or to protect the rights, property or safety of us, our users or others.
• Corporate transactions. As we develop our business, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, financing, sale of assets, dissolution, liquidation or bankruptcy, your information may be part of the transferred assets, subject to appropriate confidentiality obligations.
• Aggregated information. We may analyse your information in anonymised and/or aggregated form to operate, maintain and improve the Services, and may share such anonymised information with partners and other third parties. This information does not identify you personally.
• With your consent or at your direction.

The Services may contain links to, or integrate with, unaffiliated third-party services, applications, protocols or websites, including blockchain networks, wallet providers, fiat on-ramps and block explorers. We do not control the information-collection practices of any such third party. We encourage you to be aware when you are interacting with a third party and to read the privacy statement of any third party that collects personal information. Any information you provide to a third party is not covered by this Policy and we cannot guarantee the safety and privacy of that information.

We may use third-party analytics providers to evaluate your use of the Services, compile reports on activity, analyse performance metrics and collect other information relating to the Services. These providers use Cookies and related technologies to help analyse and provide us the data. Analytics Cookies are set only with your consent where consent is required, and you may withdraw that consent at any time by contacting us at support@predictglobe.com. Where practicable we configure analytics to pseudonymise IP addresses and to disable data sharing for the provider’s own purposes. Please be advised that if you opt out of analytics, this will not affect your ability to use the Services.

To the extent you have registered for the Services, you may access, review, make changes to and request deletion of your personal information by following the instructions found on the Site or by sending an email to us at support@predictglobe.com from the email address associated with your account with the subject line “Privacy Policy”. We reserve the right to ask for information verifying your identity before we comply with a request.

In addition, you may manage your receipt of marketing communications by clicking the “Unsubscribe” link located at the bottom of any marketing email, or by sending us an email at support@predictglobe.com with the subject line “Unsubscribe from Marketing”. Registered users cannot opt out of receiving transactional, security or administrative emails related to their account, such as one-time login codes, transaction notices and notices of changes to our Terms or fees.

Your personal information may be transferred to, and maintained on, computers located outside your state, province, country or other governmental jurisdiction, where the data-protection laws may differ from those of your jurisdiction. In certain circumstances, courts, law-enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Where personal information originating in the European Economic Area, the United Kingdom or Switzerland is transferred to a country that has not been recognised as providing an adequate level of protection, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or another lawful transfer mechanism. Further information about these safeguards is available on request. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Depending on the applicable law where you reside, you may be able to exercise the rights described below in relation to your personal information. Your rights are not absolute: depending on applicable law, a request may be refused in whole or in part (a) where refusal is required or authorised by law; (b) where granting the request would adversely affect the rights or privacy of another person; (c) to protect our legal rights and property; (d) where the request is manifestly unfounded or excessive; or (e) where the information must be retained to satisfy a legal obligation. We may ask you to verify your identity before responding. We will respond within one month, or such longer period as applicable law permits for complex requests, in which case we will inform you of the extension. We will not discriminate against you for exercising these rights.

To exercise any right, email us at support@predictglobe.com from the email address associated with your account, using the subject line indicated:

Right of access

To obtain confirmation of whether we process your personal information and a copy of it. Subject line: "Access Request".

Right of correction or rectification

To have inaccurate or incomplete information corrected. Subject line: "Correction or Rectification".

Right to object

To object to processing based on our legitimate interests, and to object at any time to direct marketing. Subject line: "Object to Processing".

Right of restriction

To request that we restrict processing of your personal information in certain circumstances. Subject line: "Restrict Processing".

Right to data portability

To receive the personal information you provided to us in a structured, commonly used and machine-readable format. Subject line: "Portability / Personal Information".

Right to withdraw consent

Where we rely on your consent, to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. Subject line: "Withdraw Consent".

Right to erasure

To have your personal information deleted, subject to our legal retention obligations and the permanence of blockchain records. Subject line: "Erasure / Personal Data Deletion". Upon receipt we will confirm receipt and will confirm once deletion has been completed. Please note that it is not possible to remove information recorded on a blockchain, and that certain records must be retained for the periods set out under Retention.

Where applicable, we will ensure that corrections, restrictions and deletions are communicated to the service providers with whom the relevant information has been shared.

If you are located in the European Economic Area, the United Kingdom, Switzerland or Brazil, you also have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law. In the European Union, this is the data-protection authority of your member state; in the United Kingdom, it is the Information Commissioner’s Office. We would appreciate the opportunity to address your concerns before you approach a supervisory authority, and you may contact us at any time at support@predictglobe.com.

We may update this Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. Where changes are material, we will provide notice by email or through the Site before the changes take effect, where required by applicable law. We encourage you to review this page periodically to stay informed about our information practices. Your continued use of the Site following the effective date of any changes will be deemed your acceptance of those changes, to the extent permitted by applicable law. If you do not agree to this Policy, please do not use our Site.

If you have any comments or questions about this Policy, please contact us by email at support@predictglobe.com.