# Privacy Policy

### Introduction

Predium is the operator of the prediction platform accessible at predium.finance (“Platform”, “we”, “us”) and acts as data controller for purposes of applicable data protection law.

This Privacy Policy explains how we collect, use, and protect information when you use the Platform. It forms part of our Terms of Use available at predium.finance/terms.

By accessing or using the Platform, you agree to this Privacy Policy. If you do not agree, do not use the Platform.

Contact: <legal@predium.finance>

### Information We Collect

A) Information you provide voluntarily

* Account identifiers (optional): email address, phone number (if you choose email or SMS login), username or display name, profile image
* Security data: two-factor authentication configuration data
* Support communications: messages, tickets, and correspondence with our support team
* Affiliate data (if applicable): referral identifiers, performance metrics, payout wallet address (processed solely for commission payouts and not shared with third parties except as required for settlement), and traffic information you provide
* Referral data (if applicable): referral code used at registration and referral relationship identifier, used solely for the purpose of calculating and crediting referral commissions.

B) Wallet and blockchain information

* Public blockchain wallet address
* Transaction hashes, timestamps, amounts, and settlement outcomes
* Prediction history linked to your wallet or account

*We do not collect, store, or have access to private keys or seed phrases.*

C) Automatically collected information

* Usage data: pages visited, features used, session duration, interactions
* Device data: browser type, operating system, language, timezone
* IP address: processed on the basis of our legitimate interests in platform security and fraud prevention, and is not used for targeted advertising

### Cookies and Analytics

We use cookies and similar technologies as follows:

* Essential cookies: required for authentication and platform security. These are set automatically and cannot be disabled without affecting Platform functionality.
* Preference cookies: UI settings and language preferences.
* Analytics cookies: used to understand aggregated Platform usage and improve the service. Analytics cookies are set only following your explicit consent provided through our cookie consent mechanism. You may withdraw consent at any time via your browser settings or our cookie controls.

*Analytics data processed by third-party services such as Google Analytics may be transferred outside the European Economic Area under appropriate safeguards including Standard Contractual Clauses.*

### How We Use Information

We process information to:

* Operate and maintain the Platform
* Process Prediction Events, settlements, and withdrawals
* Provide customer support
* Detect fraud, abuse, and security threats
* Improve Platform performance, stability, and user experience
* Manage the affiliate program
* Comply with lawful requests where applicable
* Manage the referral program and track referral relationships between users

### Legal Basis for Processing (GDPR — where applicable)

Where GDPR applies, processing is based on:

* Contractual necessity: to provide the services you have requested
* Legitimate interests: platform security, fraud prevention, and service improvement. Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms.
* Consent: analytics and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
* Legal obligations: where required by applicable law

### Data Sharing

We may share limited data with the following categories of recipients:

Service providers (data processors)

* Authentication and wallet infrastructure: Privy
* Analytics: Google Analytics
* Customer support and ticketing tools
* Cloud infrastructure providers

*These providers are bound by their own terms and privacy policies and process data only as necessary to provide their respective services to us.*

Legal requirements

Information may be disclosed if required by applicable law, valid legal process, or to protect the rights, property, or safety of the Platform, its users, or the public.

Public blockchain

Blockchain transactions are public and immutable by design. We do not control or modify blockchain records.

We do not sell personal data.

### Data Retention

We retain personal data for no longer than necessary for the purposes described in this Privacy Policy. The following retention periods apply:

<table data-header-hidden><thead><tr><th valign="top"></th><th valign="top"></th><th valign="top"></th></tr></thead><tbody><tr><td valign="top">Data Category</td><td valign="top">Retention Period</td><td valign="top">Basis</td></tr><tr><td valign="top">Account and profile data</td><td valign="top">3 years after account closure</td><td valign="top">Dispute resolution, legal obligations</td></tr><tr><td valign="top">Transaction and prediction data</td><td valign="top">5 years</td><td valign="top">AML and compliance requirements</td></tr><tr><td valign="top">Support communications</td><td valign="top">2 years after resolution</td><td valign="top">Quality assurance, legal claims</td></tr><tr><td valign="top">Affiliate records</td><td valign="top">5 years after final settlement</td><td valign="top">Accounting and settlement purposes</td></tr><tr><td valign="top">Analytics data</td><td valign="top">26 months</td><td valign="top">Google Analytics default retention</td></tr><tr><td valign="top">Blockchain data</td><td valign="top">Indefinitely (public ledger)</td><td valign="top">Immutable by design</td></tr></tbody></table>

*Retention periods may be extended where required by law or where data is necessary for ongoing legal proceedings.*

### Security

We apply reasonable technical and organizational safeguards, including:

* Encrypted connections (TLS)
* Access controls and activity logging
* Monitoring for abuse and suspicious activity<br>

No system is completely secure. You use the Platform at your own risk.<br>

Your responsibility:

* Never share private keys or seed phrases
* Enable two-factor authentication where available
* Verify official domains and links to avoid phishing

### Your Rights

Depending on your jurisdiction, you may have the right to:

* Access your personal data
* Request correction of inaccurate data
* Request deletion (where technically and legally possible)
* Object to or restrict processing
* Withdraw consent (for analytics and non-essential cookies)
* Data portability (where applicable under GDPR)<br>

*Blockchain data cannot be deleted due to its immutable nature. Rights requests relating to on-chain data cannot be fulfilled.*<br>

To exercise your rights, contact: <legal@predium.finance>. We will respond within 30 days.

### International Data Transfers

Your data may be processed by our service providers in multiple jurisdictions. Where data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission. By using the Platform, you acknowledge that your data may be transferred internationally subject to such safeguards.

### Children’s Privacy

The Platform is not intended for users under 18 years of age, consistent with the eligibility requirements in our Terms of Use. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

### Governing Law

This Privacy Policy is governed by general principles of international data protection law. Where GDPR applies, it takes precedence. Disputes relating to this Privacy Policy shall be resolved through the same mechanism described in the Terms of Use.

### Policy Updates

We may update this Privacy Policy from time to time. Material changes will be communicated via the Platform. Continued use of the Platform after publication of changes constitutes acceptance of the updated Privacy Policy.

### Contact

For questions, requests, or complaints relating to this Privacy Policy or the processing of your personal data, contact: <legal@predium.finance>


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