Privacy Policy

Effective Date: November 23, 2025

This Privacy Policy describes how FLICK ("Company," "we," "us," or "our") collects, uses, and shares your personal information when you use our event prediction market service and related features (the "Service").

1. Introduction

Your privacy is important to us. This policy applies to all information collected through our Service, as well as any related services, sales, marketing, or events. By using the Service, you consent to the data practices described in this policy.

2. Information We Collect

We collect information that falls into the following categories:

2.1 Information You Provide Directly

This includes personal data you voluntarily provide to us when you register for the Service or participate in prize redemptions:

Data Category

Purpose

Mandatory?

Account Information

Email address, unique username, encrypted password.

Yes

Wallet Information

Your public cryptocurrency wallet address.

Yes (For Payout)

Optional KYC/AML Data

Full legal name, date of birth, residential address, government-issued ID (e.g., passport, driver’s license), and potentially biometric data (e.g., facial scan for liveness checks).

Only required for payouts above certain thresholds or when mandated by law.

2.2 Information Automatically Collected (Usage Data)

We automatically collect certain information when you access or use the Service. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:

Log Data: IP address, browser type, device information (OS, unique device IDs), referral source, pages viewed, and the time and date of your use.

Tracking Technologies: We may use cookies and similar tracking technologies to track activity on our Service and hold certain information (e.g., session state).

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Manage the Service

To create and manage your account and user profile.

To enable you to participate in prediction markets and track your scores (Points).

To perform internal analytics and improve the quality of the Service.

3.2 For Legal Compliance and Security (KYC/AML)

To verify your identity when required for prize payouts (via KYC process).

To comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws and regulations globally.

To detect and prevent fraudulent, manipulative, or unauthorized activity on the Service.

To enforce our Terms of Service.

3.3 To Process Payouts

To send cryptocurrency prizes to the public wallet address you provide. We only use your public wallet address for the sole purpose of sending the prize.

4. Sharing Your Information

We only share your information with third parties in the following situations:

With KYC/AML Verification Providers: If you request a prize payout that triggers mandatory verification, we share necessary identity and document data with reputable third-party identity verification services to ensure legal compliance. These providers are bound by strict data processing agreements.

Affiliates and Service Providers: We may share data with vendors, consultants, and other third-party service providers (e.g., cloud hosting, analytics, bug tracking) who need access to that information to perform work for us.

Legal Obligations: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation; (b) protect and defend our rights or property; or (c) protect the personal safety of users or the public.

Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

5. Data Security and Retention

5.1 Security

We implement technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, we cannot guarantee that the internet or the Service will be 100% secure.

5.2 Data Retention

We retain personal information, including mandatory KYC/AML records, for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

KYC/AML Records: Verification documents and associated personal data are typically retained for a minimum of five (5) years after the termination of the business relationship, as mandated by international anti-money laundering regulations.

6. Your Privacy Rights

Depending on your jurisdiction, you may have the right to request access to, correction of, or deletion of the personal information we hold about you. Please note that we may not be able to fulfill requests to delete KYC/AML documentation until the legally mandated retention period expires.

7. Contact Information

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) at: support@flickai.io