1. Introduction and ApplicabilityThis Privacy Policy (“Policy”) explains how Conviction (“we,” “us,” or “our”), a company incorporated under the laws of the British Virgin Islands (“BVI”), collects, uses, discloses, and protects personal information in connection with your (“you” or “User”) access to and use of the Conviction Platform (the “Platform”).The Platform operates on ZetaChain and facilitates non-custodial, on-chain, opinion-based outcome market interactions, including asset movements across supported blockchain networks (such as EVM-compatible chains, Solana, and Bitcoin).User authentication and wallet connection are facilitated through our Wallet-as-a-Service (“WaaS”) provider, Dynamic.By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to this Policy. If you do not agree, you must discontinue use of the Platform.This Policy should be read together with our Terms of Service, which govern your use of the Platform.
2. Our Identity and Contact InformationData Controller: Conviction acts as the data controller for personal data processed under this Policy.Corporate Domicile: Incorporated under the laws of the British Virgin Islands.Contact for Privacy Matters:• Email (Privacy Inquiries): [email protected]• General Support: https://t.me/conviction_bet 3. Information We Collect
3.1. Information You Provide DirectlyWe may collect:• Contact Information: Email address (e.g., for WaaS authentication, communications, or support).• WaaS User Identifier: A unique identifier generated by Dynamic for authentication purposes.• Blockchain Identifiers: External Wallet Address connected via Dynamic. The Smart Account address deployed for you on ZetaChain.• Communication Records: Messages exchanged with us through official channels.We do not request or store private keys, seed phrases, or wallet signing credentials.
3.2. Usage and Technical InformationCollected automatically when you use the Platform:• IP address (used for security and jurisdictional compliance)• Browser type, operating system, and device information• Access timestamps and session durations• Platform interaction logs (pages accessed, features used)
3.3. On-Chain DataBlockchain transactions and interactions are public by design.We may process publicly available on-chain data such as transaction hashes and smart contract interaction records. We do not control, modify, or delete blockchain data.
4. Purpose, Legal Basis, and RetentionWe process personal information only for the purposes below and do not use it for third-party advertising.
4.1. Platform Access and Operation• Purpose: Authentication, account access, Smart Account linkage• Legal Basis: Performance of contract (Terms of Service)• Retention: For as long as you maintain an account
4.2. Transaction Records and Compliance• Purpose: Maintaining records of on-chain interactions and platform operations• Legal Basis: Performance of contract and compliance with applicable legal obligations• Retention: As required by applicable law or legitimate business needs
4.3. Security and Abuse Prevention• Purpose: Fraud prevention, security monitoring, geo-blocking enforcement• Legal Basis: Legitimate interests• Retention: Aggregated or anonymized once no longer necessary
5. Information Sharing and DisclosureWe do not sell or rent personal information. We may share information with:• WaaS Providers (e.g., Dynamic) for authentication purposes• Service Providers under contractual obligations (e.g., hosting, database services such as AWS or Supabase)• Legal or Regulatory Authorities, where required by law• Corporate Counterparties in the event of mergers, acquisitions, or restructuring
6. International Data TransfersConviction operates globally. Your personal information may be processed outside your country of residence, including in the United States or other jurisdictions where our service providers operate.Where required under applicable data protection laws (such as GDPR), we apply appropriate safeguards, including Standard Contractual Clauses (SCCs) or equivalent mechanisms.
7. Data SecurityWe apply reasonable technical and organizational measures to protect personal information, including:• Encryption in transit (TLS/SSL)• Access controls and role-based permissions• Infrastructure security practicesUser Responsibility: We do not store or access private keys or signing credentials. Users are solely responsible for securing their wallets and WaaS access credentials.
8. Your RightsDepending on your jurisdiction, you may have rights to:• Access or correct personal data• Request deletion (subject to legal obligations)• Object to or restrict processing• Request data portabilityHow to Exercise RightsContact us at [email protected].We will respond within 30 days, subject to lawful extensions. 9. Children's PrivacyThe Platform is not intended for individuals under 18.We do not knowingly collect personal data from minors.
10. Cookies and Similar TechnologiesWe use only strictly necessary cookies and storage technologies required for:• Platform functionality• Session management• Security and preference settingsWe do not use cookies for behavioral advertising or targeted marketing.
11. Governing LawThis Policy is governed by the laws of the British Virgin Islands, without regard to conflict of law principles.
12. Changes to This PolicyWe may update this Policy from time to time.Material changes will be posted on the Platform with an updated effective date. Continued use of the Platform constitutes acceptance of the revised Policy.