Privacy Policy

We collect information in three ways: information you provide, information collected automatically, and information from third parties.

Information you provide. When you sign up, we collect your email address, chosen display name, date of birth (to verify eligibility), and country of residence. If you enable paid prediction mode, we additionally collect identity verification data required by our regulated execution partners, including full legal name, residential address, government-issued identification, photographs for liveness checks, and (where required) tax identification numbers. We also collect any information you voluntarily submit through support requests, surveys, referrals, or social posts within the Services.

Information collected automatically. When you use the Services we automatically collect device and usage information, including IP address, device identifiers, device type, operating system, mobile network, browser type, time zone, referring URL, pages and screens viewed, features used, prediction activity (markets viewed, swipes, picks, outcomes, balances), session duration, crash logs, and approximate location derived from IP address. We use cookies, SDKs, pixels, local storage, and similar technologies to collect this data; see our Cookies Policy for details.

Information from third parties. We receive information from identity verification vendors, fraud and anti-money-laundering providers, payment processors, analytics providers, our prediction market execution partners (including Polymarket, Kalshi, and other regulated venues), advertising and attribution partners, and publicly available sources. If you sign up through a referral link, we record the referring user’s code to credit rewards.

We use the information described above to:

• Operate, maintain, and improve the Services, including debugging and optimizing performance.
• Create and manage your account, authenticate you, and keep your account secure.
• Process predictions, settle outcomes, pay winnings, handle referrals, and maintain accurate ledgers.
• Verify your identity, age, and eligibility, and to comply with anti-money-laundering, sanctions, and tax obligations.
• Detect, investigate, and prevent fraudulent, abusive, or unlawful activity, including market manipulation and multi-accounting.
• Personalize your feed, AI recommendations, and social features.
• Send transactional communications (receipts, account alerts, security notices) and, with your consent, marketing communications.
• Understand how the Services are used and develop new features through analytics and aggregated research.
• Enforce our Terms of Service and protect our rights, property, and users.
• Comply with applicable laws, regulations, and lawful requests from government authorities.

If you are located in the European Economic Area, United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR and equivalent laws:

• Contract performance — to provide the Services you request.
• Legitimate interests — to operate and improve the Services, protect against fraud, and communicate with you, where these interests are not overridden by your rights.
• Consent — for marketing communications, optional analytics cookies, and certain personalization features. You may withdraw consent at any time.
• Legal obligations — to comply with tax, financial-crime, and regulatory requirements.

We do not sell your personal information for money. We share information only as described below:

• Service providers. Vendors who process data on our behalf under written data processing agreements, including cloud hosting, database, analytics, customer support, KYC/AML, payment, and communications providers.
• Execution partners. Our regulated prediction market partners (for example, Polymarket, Kalshi) receive the minimum information necessary to route and settle your predictions and to comply with their own regulatory obligations.
• Other users. Information you choose to share publicly within the Services — such as your handle, predictions, badges, leaderboard position, and social posts — is visible to other users. Do not share what you wouldn’t want public.
• Legal and safety. Law enforcement, regulators, courts, and other authorities when we reasonably believe disclosure is required by law, to enforce our Terms, or to protect users or the public.
• Corporate transactions. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to confidentiality obligations and, where required, your consent.
• With your consent. Any other sharing you specifically authorize.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

We are headquartered in the United States and operate globally. Your information may be transferred to, stored in, and processed in countries other than your country of residence. Where we transfer personal data out of the EEA, UK, or Switzerland, we use legally recognized transfer mechanisms, including the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, and we apply supplementary safeguards where required.

We retain personal information for as long as needed to provide the Services, comply with our legal obligations (including financial record-keeping, which commonly requires five to seven years), resolve disputes, and enforce our agreements. When the data is no longer required, we delete or anonymize it. Aggregated, de-identified data may be retained indefinitely.

Depending on your location, you may have the following rights:

• Access — request a copy of personal data we hold about you.
• Correction — request correction of inaccurate or incomplete data.
• Deletion — request deletion of your data, subject to legal retention obligations.
• Portability — receive a machine-readable copy of data you provided to us.
• Objection and restriction — object to or restrict certain processing, including direct marketing.
• Withdraw consent — withdraw any consent you previously provided.
• No sale / no share (California residents) — we do not sell or share (as those terms are defined under the CCPA/CPRA) your personal information.
• Complaint — lodge a complaint with your local data protection authority.

To exercise your rights, email privacy@flicktrade.com. We may request information to verify your identity before acting on a request. We will respond within the time required by applicable law.

We use cookies and similar technologies to operate the Services, remember preferences, measure performance, and personalize your experience. See our Cookies Policy for categories, purposes, and how to manage your preferences. Most browsers allow you to refuse or delete cookies through browser settings; some features may not function properly if cookies are disabled.

We implement administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls, network segmentation, least-privilege policies, periodic penetration testing, and staff security training. No system is perfectly secure; we encourage you to use strong, unique passwords, enable multi-factor authentication, and notify us immediately at security@flicktrade.com if you suspect your account has been compromised.

The Services are not directed to individuals under 18, and we do not knowingly collect personal information from minors. If we learn we have collected data from a minor, we will delete it. Contact us if you believe a minor has provided us with personal information.

We may update this Policy from time to time. When we make material changes, we will notify you by email, in-app notice, or by updating the “Last updated” date above. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.

fliiick Labs, Inc.
Attention: Privacy Team
privacy@flicktrade.com