Effective Date: April 21, 2026
This Privacy Policy (“Policy”) is effective as of the date hereof, and outlines how Prophecy S.A., a company incorporated under the laws of the Republic of Panama (“we”, “us”, or “our”) and the operator of a social predictions platform and related services (collectively, the “Platform”) collects, uses, and processes Personal Information of users (“you” or “users”) who interact with our Platform.
We do not own, operate, or control the underlying decentralized prediction protocol (“Protocol”) that supports the Platform and, accordingly, this Policy does not apply to such Protocol, which operates independently of us as detailed further below. We collect, use, and process Personal Information based on applicable lawful bases including contractual necessity, legitimate interests, and consent as detailed herein. The Platform is a social predictions market designed to provide users with an interactive, community-driven environment for making predictions about real-world events for social, entertainment, and educational purposes only. By accessing or using the Platform, you agree to the terms of this Policy.
The Platform is a social predictions market designed to provide users with an interactive, community-driven environment for making predictions about real-world events, including but not limited to sports outcomes, political developments, entertainment results, and other topics of public interest. The Platform operates exclusively for social, entertainment, and educational purposes. All predictions, outcomes, and activities on the Platform are simulated and involve only Prophecy Social Tokens or PSTs. PSTs have no monetary value, cannot be exchanged for real money or any item of value, and cannot be transferred, sold, or redeemed other than with us as the operator of the Platform. The Platform does not involve, facilitate, or permit any form of financial transaction, monetary exchange, or transfer of real assets. We are incorporated under the laws of the Republic of Panama and are committed to transparency regarding data handling practices in social prediction environments.
We may collect the following categories of information from and about you to the extent it has been provided or made available to us: identifiers (including IP addresses, email addresses, and usernames); internet or similar network activity; User Content (including predictions, comments, messages, and other materials you submit); account registration information; and inferences drawn from other Personal Information. We collect these categories of information from you in order to operate the Platform, improve user experience, comply with legal obligations, and communicate with users who voluntarily provide contact information. We do not collect government-issued identifiers or financial account numbers as the Platform operates for social, entertainment, and educational purposes only. We may have disclosed each of these categories of Personal Information for a business purpose as described below.
We will retain various categories of Personal Information based on several factors, including with respect to:
Retention periods may be extended where reasonably necessary to:
This Policy governs all aspects of information collection, processing, and protection across our Platform’s services, including but not limited to market participation, transaction processing, and user interactions. It applies to all users accessing our Platform. 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.
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 us 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”).
This Policy applies exclusively to our Platform and does not extend to the Protocol. The Protocol operates as an autonomous, decentralized system deployed on public blockchain networks, functioning independently of our control or governance.
We operate the Platform that provides user interface and related services to facilitate interaction with the Protocol, but do not control, operate, or govern the Protocol itself. The Protocol’s smart contracts execute autonomously according to their programmed logic, and all on-chain activities occur directly between users and the Protocol without us acting as an intermediary.
We do not assert or claim data controller status over Protocol transactions, on-chain data, or blockchain-recorded activities. Such activities are governed by the decentralized nature of blockchain technology and applicable blockchain network protocols, not by this Privacy Policy.
We collect and process three 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. Given the nature of the Platform, we collect minimal (if any) Personal Information. This may include your email address if you voluntarily subscribe to communications, User Content you submit through the Platform (including predictions, comments, messages, and other materials), and any information you provide when contacting support. We do not require or collect full names, postal addresses, phone numbers, dates of birth, government-issued identification documents, banking information, or account passwords. Access to the Platform requires only a compatible blockchain wallet, which you control independently. We may collect some or all of this information when you use the Platform or voluntarily provide it through communication channels.
“Usage Data” encompasses information about how you interact with the 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, and other diagnostic data. We, or our third-party vendors, collect this information automatically when you access and navigate the Platform through cookies, pixels, web beacons, and similar tracking technologies.
“Rewards Program Data” includes information collected in connection with promotional or incentive programs we may operate from time to time. This may include your participation status, qualifying activities, reward calculations, distribution records, and compliance verification data. Rewards Program Data is collected to administer program eligibility, calculate and distribute rewards, prevent fraud and abuse, and ensure compliance with program terms and applicable laws.
We do not maintain centralized records of your prediction activity. All predictions and outcomes occur directly on the blockchain through smart contract execution and are recorded immutably on the public ledger. Blockchain prediction data (including wallet addresses, prediction details, prediction amounts, timestamps, and settlement events) is publicly accessible to anyone and is not under our control or custody. Your IP address and device identifiers are logged by the Platform for security purposes and to improve Platform functionality. This Platform-level data is separate from on-chain prediction data.
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.
In accordance with the Data Protection Laws, we process your Personal Information based on the following lawful bases for Platform operation:
You have the right to withdraw your consent at any time by contacting us where consent is the lawful basis for processing. Please note that withdrawal of consent for marketing communications will not affect other processing activities that rely on different lawful bases such as contractual necessity or legitimate interests. Withdrawal of consent for certain Platform-related data collection may impact our ability to provide you with certain Platform features such as personalized predictions, community interactions, and social engagement tools, but will not affect your core ability to participate in prediction activities.
We maintain records of all lawful bases provided by users in accordance with the Data Protection Laws. We may make these records available to regulatory authorities when compelled by applicable law.
Your explicit consent serves as the lawful basis for processing Personal Information for marketing communications, promotional materials, newsletters, and personalized recommendations related to Platform features, prediction markets, community events, and social engagement opportunities. This consent is separate from and independent of other lawful bases we rely on for Platform operation and security. You may withdraw your marketing consent at any time without affecting our ability to process your information for other purposes based on alternative lawful bases such as contractual necessity or legitimate interests.
The processing of your Personal Information is based on the following lawful bases: (i) contractual necessity for Platform operation and performance; (ii) compliance with applicable legal obligations; and (iii) our legitimate interests in operating, improving, and protecting the Platform, except where marketing communications require your explicit consent as specified above. You should assume that Platform activity may be analysed and potentially linked to you at your own risk.
The Platform is a social predictions market designed to provide users with an interactive, community-driven environment for making predictions about real-world events, including but not limited to sports outcomes, political developments, entertainment results, and other topics of public interest. The Platform serves as an interface to interact with the underlying Protocol, an autonomous blockchain-based system that operates independently of our control. The Platform operates exclusively for social, entertainment, and educational purposes.
When you interact with the Platform it automatically processes and records the following interaction data:
This data processing occurs through our Platform systems to facilitate social predictions and community engagement. We process this data according to our platform logic to enable prediction markets, user interactions, and community features. As the Platform operator, we serve, unless stipulated otherwise, as the data controller for all Platform processing activities. Platform data is stored on our servers and processed through our systems to provide the social, entertainment, and educational services described in our Terms of Service. We maintain control over Platform functionality, user data processing, and system operations. The Platform may integrate with third-party services to enhance user experience, including analytics providers, content delivery networks, and communication tools. These service providers process data according to their respective privacy policies and our data processing agreements with them.
The Platform is designed to process only the minimum data necessary for Platform functionality. Personal identifying information may be required for account creation and Platform interaction, including email addresses and account credentials. Platform data is stored in our systems and can be modified or deleted in accordance with applicable data protection laws and your rights as described in this Policy. Users may request deletion of their personal data subject to legal retention requirements and legitimate business interests. The Platform may be updated through standard software development processes. Any updates that affect data processing will be announced through appropriate channels. Historical activity data may be retained in accordance with our data retention policies outlined herein. All Platform features and data processing practices are described in this Policy and our Terms of Service.
To access certain features of the Platform, you may be required to create an account. You agree to provide accurate, current, and complete information during the registration process and to update such information as necessary to maintain its accuracy. We collect and process account registration data including email addresses, usernames, and profile information you voluntarily provide. Account activity data such as prediction participation, PST balances, community interactions, and platform usage patterns are recorded in our systems. Unlike blockchain-based systems, this information is stored in our controlled databases and is subject to our data protection practices outlined in this Policy.
While wallet addresses do not inherently contain personal identifying information, they are pseudonymous, not anonymous. Blockchain analysis techniques, transaction pattern analysis, IP address correlation, exchange KYC data, and other methods may be used by third parties to link wallet addresses to real-world identities. We have no control over such analysis conducted by third parties.
We do not require or conduct identity verification (KYC) for use of the Platform. However, if you have provided Personal Information to us through other channels (such as email communications or account registration), third parties may be able to link your Platform activity to your identity.
Users should be aware that:
Using the same wallet address for multiple transactions increases the risk of identity correlation. Users concerned about privacy should consider their account privacy practices, though we provide no guarantees regarding on-chain privacy.
Blockchain analytics companies, regulators, researchers, and other third parties may monitor Platform transactions and attempt to identify users. We have no control over such activities and cannot prevent third parties from analysing publicly available blockchain data.
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 us.
Under applicable data protection laws, you may have the right to access, correct, delete, or object to the processing of your Personal Information that we collect through the Platform, subject to applicable legal limitations. Due to the nature of Platform data storage and processing systems, certain data may be retained for operational continuity and legal compliance purposes.
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 18, 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 may be asked to 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 us and requesting to opt-out. Please note that even if you opt-out of marketing communications, we may still send you important Platform-related notifications and updates.
You may close your account and cease using the Platform at any time by contacting us or by following the account closure procedures available on the Platform. 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.
When you disconnect your wallet from the Platform, 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. Importantly, you do not have an “account” with us in the traditional sense as you interact with the Platform using your self-custodied wallet. We cannot delete blockchain transaction data, which is permanently recorded on the public ledger. Deleting Platform-collected data will not affect your on-chain transaction history or your ability to interact with the Platform through other means.
We will respond to all legitimate requests as soon as practicable and generally within ten (10) business days from the date of submission. For requests to modify data, we will process these as soon as practicable and generally 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. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform and may not be implemented. We do not currently respond to “Do Not Track” or “DNT” signals from browsers, as there is no uniform standard for how such signals should be interpreted or implemented. However, you can control tracking through the cookie settings described above and by adjusting your browser privacy settings. If you block cookies, certain features of the Platform may not work. If you block or reject cookies, not all of the tracking described here will stop.
The Platform may allow you to submit, post, or share content, including predictions, comments, messages, and other materials (collectively, “User Content”). You retain ownership of any intellectual property rights in your User Content, but you grant the Company a worldwide, non-exclusive, royalty-free, transferable, sublicensable license to use, reproduce, modify, adapt, publish, translate, distribute, and display your User Content in connection with the operation and promotion of the Platform.
You are solely responsible for your User Content and the consequences of posting or sharing it on the Platform. You represent and warrant that you own or have the necessary rights to your User Content and that your User Content does not violate any third-party rights or applicable laws.
We reserve the right, but have no obligation, to monitor, review, or remove User Content that we determine, in our sole discretion, violates our Terms of Service or is otherwise objectionable. We do not endorse any User Content or any opinion, recommendation, or advice expressed therein.
We may transfer, store, and process your Personal Information collected through the Platform 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. Additionally, blockchain data is distributed across a global network of nodes and validators operating in multiple jurisdictions. We have no control over the geographic location of blockchain data or the nodes that process Platform transactions.
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 European Economic Area. You may contact us to request such information.
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 the 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.
This Policy does not apply to third-party websites, services, or applications that may be linked from or accessible through the Platform. We are not responsible for the privacy practices or content of such third-party sites or services. We encourage you to review the privacy policies and terms of service of any third-party sites or services before providing any Personal Information or using their services. Your interactions with third parties are governed solely by their respective privacy policies and terms of service.
If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
You may exercise your rights by contacting us through our website. We may need to verify your identity before processing your request. You may also designate an authorized agent to act on your behalf, subject to applicable verification requirements.
We will respond to verifiable requests within 45 days, which may be extended once by an additional 45 days where reasonably necessary.
We use cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and improve our services. This section explains what cookies are, how we use them, and your choices regarding their use.
Cookies are small text files stored on your device when you visit the Platform. They contain information that helps us recognize your browser and remember certain information about your preferences or past actions.
Cookies may be either “session cookies” (which expire when you close your browser) or “persistent cookies” (which remain on your device for a set period or until you delete them). The retention period for each cookie depends on its purpose and your browser settings.
You can control cookies through your browser settings. Most browsers allow you to:
Please note that disabling certain cookies may affect the functionality of the Platform. Essential cookies cannot be disabled without impacting core Platform operations.
Do Not Track (DNT):Some browsers include a “Do Not Track” feature that signals websites not to track users. Currently, there is no universally accepted standard for how websites should respond to DNT signals. We do not currently respond to DNT signals, but we provide you with choices about cookie usage as described above.
This section serves as our cookie policy and is updated from time to time. You can manage your cookie preferences at any time using the “Cookie Settings” link in the site footer. For more information about cookies, visit www.allaboutcookies.org or your browser’s help section.
For any questions, concerns, or requests related to your Personal Information or this Policy, you may contact us through our website.
The governing law, force majeure and arbitration provisions of the Terms of Service apply to this Policy and are incorporated herein by reference, mutatis mutandis.
