Last Updated: September 24, 2026

Introduction

This website-hosted user interface, located at Polymarket.com, (this “Site”) is made available by Adventure One QSS Inc., a corporation organized and existing under the laws of Panama (the “Company”, “us”, “we”, or “our”).

This Privacy Policy (the “Policy”) governs the manner in which we collect, use, maintain and disclose personal data from and about our users (each, a “user”, “you”, or “your”) through the Site or which we or our affiliates otherwise obtain in connection with products and services, content, features, technologies, functions and all related applications we may provide to you or to which we may provide access (collectively with the Site, the “Services”).

We are committed to protecting your privacy, and we encourage you to read this Policy carefully and to review it regularly. Our Terms of Use (“Terms”) govern all use of our Services and constitute your agreement with us (the “Agreement”). If you do not agree with the Terms, or the collection and use of your personal data as described in this Policy, please do not access our Site.

Applicability

This Policy applies to all information we collect from you in connection with your use and our provision of the Services. This Policy does not apply to information collected on any other website made available by us that does not display this Policy or on any other websites offered by any third party (including our affiliates and subsidiaries). Throughout this Policy, we use the term “personal data” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal data to include information that has been aggregated, de-identified, and/or anonymized so that it does not identify a specific user.

Information Collection

We collect personal data from various sources, including:

Directly from you when you provide it to us;

Automatically as you navigate through the Site;

In certain instances, from third parties, such as our business partners, third-party service providers and advertising partners, or other social media platforms or networks to which you have connected your account and provided authorization for the Services to access this information;

Publicly available sources; and

From third parties that refer you to our Services.

If you create an account with us or otherwise use our Services, we may collect the following information from you:

Personal data. Information by which you may be personally identified, such as your name, postal address, e-mail address, telephone number, date of birth, profile picture, digital wallet address, account username, social media accounts, and other demographic information, such as your age, gender, hometown, and interests that you voluntarily provide to us. Please note that, before permitting you to use the Services, we may require additional information from you (including, for instance, government-issued identity documents such as passport number, driver’s license details or national identity card details) that we can use to verify your identity, address or other information; prevent and respond to fraud or other misuse of the Services; or meet our compliance obligations.

Derivative Information. Information our servers may collect automatically when you access and use the Site, such as your IP address, browser type, operating system, access times, and pages you navigate through on our Site and pages viewed directly before and after accessing the Site. This may also include other information about your internet connection and the equipment you use to access our Site.

Financial Information. If applicable to your use of the Services, in order for us to process payments of any fees owed to us in connection with your use of the Services, you will be required to provide certain information relating to your digital wallet and the transactions you authorize through it, including your public wallet address and transaction records, and, where you elect to use a third-party payment method, data related to that payment method. You authorize our third-party payment vendors and wallet providers to collect, process, and store your Financial Information in accordance with their respective privacy policies.

Mobile Device Information. If you access the Site from a mobile device we may obtain information automatically about you from your mobile device such as your device type, mobile device identification number, geolocation information derived from IP addresses, time zone, language setting, and browser type.

Geolocation Information. We collect information that identifies, with reasonable specificity, your location by using certain longitude and latitude coordinates obtained through GPS, Wi-Fi, cell-site triangulation, or other locational data. We may collect this data for fraud prevention and risk management purposes, among other reasons identified in this Privacy Policy.

Correspondence and Recordkeeping. We will retain records and copies of your correspondence (including e-mail addresses) if you contact us. We will retain all records for such time period as may be required or permitted by applicable law.

Surveys. If you decide to participate in surveys available via the Services, you may be asked to provide certain information in your responses, which may include personal data. We may store such responses and use the information that you provide to improve the Services.

We may collect other information, including personal data, from you with your consent.

Use of Cookies and Other Tracking Technologies

When you use our Services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). A cookie is a small file placed on the hard drive of your computer. Cookies may automatically collect certain information, such as a website visitor’s device’s IP address, browser type, operating system, computer platform, web pages viewed, and/or the date and time of the website visit. We use Cookies to recognize you as a customer; to customize the Services, including advertising provided to you; to measure the effectiveness of our promotions; to support the functioning of the Site; to perform a wide range of analytics; to mitigate risk and prevent potential fraud; or otherwise as described in this Privacy Policy.

Most browsers are set to accept cookies by default, and you may be able to reject cookies through your browser settings. However, some of our Services are only available through the use of Cookies. Therefore, if you choose to disable or decline Cookies, your use of the Site and our Services may be limited or not possible.

Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics. You may not decline web beacons. However, you may be able to modify your web browser’s settings to render web beacons ineffective.

Third parties may use Cookies on the Site (either alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Services. This information may be associated with other personal data about your online activities over time and across different websites and online Services. Third parties may use this information to provide you with interest-based advertising or other targeted content.

This Site uses Google Analytics. For more information on Google Analytics and other Google tracking technologies, please visit the sites below:

For Google Analytics, visit: https://www.google.com/analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google Services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en. We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

For Google AdWords, you can set preferences for how Google advertises to you using the Google Ad Preferences page at: https://adssettings.google.com/authenticated.

Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. You can enable or disable DNT by visiting the preferences or settings page of your web browser. The Site does not respond to DNT signals.

Use of Your Information

We use personal data collected about you via the Services for various purposes, including:

To provide, customize, personalize, measure, and improve our Services, and the content and layout of our Services.

To process transactions (including payments and refunds) and send notices about your transactions or your network activity.

To contact you regarding your use of the Services, including responding to questions or requests you may have with respect to the Services;

To enable user-to-user communications;

To measure interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;

To market to you and provide targeted advertising, coupons, newsletters, and other promotional information regarding the Services (including marketing conducted by our business partners and affiliates);

To compile statistical data and analysis for our use internally or by third parties;

To ensure internal quality control, including to debug, identify and repair errors that impair intended functionality or improvements to the Services;

To safeguard the Services, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;

To verify your identity, and prevent fraud, prohibited or illegal activities, including through the use of our risk and fraud tools;

To offer certain features or functionalities, which may involve interacting with artificial intelligence technology or tools;

To enforce our Terms and policies, and protect the rights, property, or safety of us or others;

To comply with legal and regulatory obligations, including those related to market integrity;

To respond to lawful requests by public authorities, or where otherwise required by law, court order, or other law enforcement or regulatory authority;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer or some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred; and

As otherwise described to you when collecting your personal data, for any other purpose for which you provide consent, or as otherwise required or permitted by law.

Legal Bases for Processing

We may use your personal data for these purposes because one or more of the following legal bases applies:

We need to do so to perform our contractual obligations with you;

We have obtained your consent, unless an exemption provided under applicable law permits the use and disclosure of your personal data without your consent;

We have a legal or regulatory obligation that must be discharged;

We may need to do so to establish, exercise, or defend our legal rights or for the purpose of legal proceedings; or

The use of your personal data is necessary for our legitimate business interests or the legitimate interests of a third party, provided such interests are not overridden by your rights or interests.

To Whom We Disclose or Share Personal Data

Some personal data is public information (this may include your web3-enabled wallet’s public address, username, profile photo, profile first and last name, month and year of account creation, and public transactions in which you have been involved), and may be seen by anyone on the Internet due to the nature of the blockchain, whether or not they have an account with us. Public information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party services that integrate with our Services.

With respect to other personal data, we may disclose your personal data to:

Third-party service providers that assist us in fraud detection and prevention or otherwise assist in providing the Services to you, such as vendors, cloud and infrastructure providers, payment and wallet partners, and other third-party service providers.

Our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control or related by common ownership or control that assist us with providing the Services.

Successor(s) of our business, relating to all or part of the business, to evaluate a proposed transaction or sale, reorganization, merger, acquisition, or other change of control.

Other individuals who have referred you to our Services.

Other third parties or nonaffiliates as permitted by law or contract, to provide the Services, or to protect our or other’s rights, property, or safety.

Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal data is reasonably necessary to prevent physical harm or financial loss; to report suspected illegal activity or other unfair trading practices, to investigate violations of the Terms of Services, as otherwise required by law; or whenever we believe in good faith that disclosing such information is necessary or advisable.

If you authorize an account connection with a third-party account or platform, we may disclose your personal data to such third-party account or platform:

For the purposes of this Policy, an “account connection” with such a third party is a connection you authorize or enable between your account and a digital wallet, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal data and other information directly with such third-party. Examples of account connections include, without limitation: linking your account to a social media account or social messaging Services; connecting your account to a third-party data aggregation or financial Services company, if you provide such company with your account log-in credentials; or using your account to make payments to a merchant or allowing a merchant to charge your account.

If you connect your account to other financial accounts, directly or through a third-party Services provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party’s Services. For example, if you connect your account to a social media account, we will receive personal data from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Policy.

Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal data as part of the account connection.

We may also share or license your personal data with business partners and other third parties so that those third parties can offer you certain products, services, and promotions. Additionally, we may also use third-party advertising companies to serve ads when you visit the Site, and those advertising companies may use information about your visits to the Site and other websites that are contained in Cookies in order to provide advertisements about goods and services of interest to you. You may be entitled to prevent us from sharing and/or licensing your personal data to other companies under applicable law. If you wish to exercise this right, please send an e-mail to [email protected].

We may use your personal data and proprietary data for business or marketing purposes in addition to using such information for the purpose of complying with regulatory obligations, and we may disclose personal data and proprietary data to our affiliated entities for their business or marketing purposes. You may opt out of us using this information for business and marketing purposes by contacting us at [email protected]. We do not condition access to its trading facility on your consent to the use of personal information or other information for our business or marketing purposes. Where necessary, we may disclose personal information to one or more DCMs, swap execution facilities, or derivatives clearing organizations registered with the U.S. Commodity Futures Trading Commission.

We may disclose your personal data for additional purposes and/or to other third parties with your consent or at your direction. We may also disclose aggregated or de-identified data with third parties who may use that data for other purposes.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any personal data to us. If we obtain actual knowledge that we have collected personal data from a person under the age of 18, we will promptly delete the minor’s personal data, unless we are legally obligated to retain such data. If you believe we may have mistakenly or unintentionally collected any information from or about a person under 18, please contact us using the contact information provided below.

Third-Party Links

The Services may contain links to (or allow you to link to) unaffiliated third-party services, applications, or websites. We do not control information collection of any third-party services, applications, or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personal data. Any information you provide to any third party is not covered by this Policy and we cannot guarantee the safety and privacy of any information you provide to such third parties.

Personal Communication Preferences

You may manage your receipt of marketing and non-transactional communications from us by clicking on the “Unsubscribe” link located on the bottom of any marketing e-mail, or by sending us an email at [email protected] with the subject line, “Unsubscribe from Marketing.” Registered users cannot opt out of receiving transactional or administrative e-mails related to their account. We will use commercially reasonable efforts to process such requests in a timely manner, in compliance with applicable laws. In connection with our use of SMS messaging, we agree no mobile information will be shared with third parties or affiliates for their marketing or promotional purposes. Any sharing with third parties for any other purpose will not include your phone number and opt-in data, unless permitted or required by applicable law and for the purposes described in this privacy policy, such as fraud detection.

Transfer of Data

By using the Services, you consent to the transfer of your information outside of your country of residence, which may have data protection rules that are different from those of your country. For example, we may store, process, use, and disclose personal data in the United States, including personal data that is collected from individuals not residing in the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.

Financial Incentives

From time to time, we may offer financial incentives in connection with the collection or use of personal data. For example, we may provide financial incentives to you if you refer other individuals to our Services using a unique website URL provided to you. To the extent that you provide this URL to other individuals, you agree and understand that you must have the consent of the individual to provide this referral and you must provide the individual with a link to this privacy policy along with the URL. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by contacting us. However, if you ask us to withdraw any financial incentive, we may be unable to return previously provided incentives at a later time.

Personal Data Processing in Connection with Perpetual Futures Contracts

Our Services in connection with perpetual futures contracts may be accessed only through an application programming interface made available to certain website users, subject to applicable access controls and authorization requirements. In connection with perpetual futures contracts, we may process personal data in a manner similar to the processing activities described in this Privacy Policy, including to provide, operate, maintain, secure, monitor, and improve the Services; verify user eligibility; and detect, prevent, and investigate fraud, misuse, security incidents, and other potentially unlawful or prohibited activity. Personal data processed in connection with perpetual futures contracts may be stored and processed in jurisdictions other than that in which the individual providing such information resides.

How We Protect and Store Your Information

We strive to ensure security on our systems and use administrative, technical, and other physical security measures to help protect your personal data. Despite these efforts, we cannot guarantee the absolute security of your personal data, as no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we urge you to take adequate precautions to protect your personal data as well, including by not re-using or sharing your password. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures on the Services.

Your Data Protection Rights

Subject to certain exemptions under applicable law, you may have certain rights related to your personal data.

Right to access. You have the right to access, know about, or confirm the processing of your personal data, including the categories of, and sources of, personal data that we collect about you, the business or commercial purpose(s) for collecting, selling, or sharing your personal data, the categories of third parties to which your personal data is disclosed, and the specific pieces of personal data we have collected about you.
The right of correction or rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to certain processing of your personal data, such as processing for direct marketing purposes.
The right of restriction. You have the right to request that we restrict the processing of your sensitive personal data.
The right to data portability. You have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format, to the extent technically feasible.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data.
The right to erasure. If you wish to discontinue the use of our Services, you have the right to request that we delete your personal data.
The right to opt-out of the “sale” or “sharing” of your personal data, or the use of your personal data for “targeted advertising” (as these terms are defined under applicable privacy laws). Please note that we may disclose your personal data to individuals who have referred you to our Services, to our third-party business partners for their marketing purposes, and as otherwise described in this Privacy Policy. The information we may disclose may include your personal data and information about your use of our Services.
The right to opt out of certain automated decision-making. We do not make decisions that produce legal or similarly significant effects concerning you based solely on automated processing, except where required to comply with law (including sanctions and access restrictions). However, we use automated tools to generate risk scores and alerts for investigators, but any decision based automatically generated risk scores and alerts is made with human interaction, oversight, and intervention.

You will not be discriminated against for exercising any of these rights. To exercise your choices and rights, please contact us using the contact information provided in this Privacy Policy. We may request or require additional information to verify your identity to fulfill your request.

However, we may deny certain requests: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and property; or (d) where the request is frivolous or vexatious, or for other reasons permitted by law.

You may designate an authorized agent to make a request on your behalf. Authorized agents will be required to provide proof of their authority to act on your behalf by providing relevant documentation. We may contact you to confirm an authorized agent’s representation and to verify your identity.

If you are located in the European Economic Area, the UK, Switzerland or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law. Before doing so, we request that you contact us if you have questions or complaints about how we have processed your personal data. We are typically able to resolve privacy questions or concerns promptly and effectively.

Data Retention

We will retain your personal data for only as long as is reasonably necessary to fulfill the purpose(s) for which it was collected, as set out in this Privacy Policy or any other notice provided to you at the time your personal data is collected, or as otherwise required to meet our legal obligations.

Changes to Our Policy

We may update this Policy from time to time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about our information practices. You acknowledge that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

If you have any comments or questions about this Policy, please contact us by e-mail at [email protected].