Legal

Privacy Policy

Read the full Predict Bay™ privacy policy exactly as published below.

PredictBay Privacy Policy

Effective Date: December 21, 2025

Last Updated: July 1, 2026

This Privacy Policy explains how PredictBay Inc., a corporation incorporated under the laws of the Republic of Panama (“PredictBay,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with an identified or identifiable person (“Personal Data” or “Personal Information”), and the choices and rights available to individuals regarding such information.

By accessing the Platform or using the Services, you acknowledge and agree to the collection, use, and disclosure of your information in accordance with this Privacy Policy. The Platform operates on blockchain technology, where transaction data, wallet addresses, and other interactions are publicly accessible and immutable. By accessing or using the Platform or Services, you acknowledge and consent to the public nature of the blockchain data associated with your activities. If you do not agree with our practices, you must not use the Platform or Services.

This Privacy Policy applies to Personal Data processed in connection with PredictBay’s websites, web applications, interfaces, products, services, and related offerings (collectively, the “Services”), including when you create an account, participate in prediction markets, place orders, execute or settle transactions, interact with analytics features, undergo compliance checks, communicate with us, or otherwise interact with the Services.

This Privacy Policy does not apply to information processed by third parties under their own privacy policies, including third-party websites, applications, or services that may be linked to or integrated with the Services.

PredictBay is aware of its responsibilities to handle personal data with care, to keep it secure, and to comply with applicable privacy and data protection laws, including Law 81 of 2019 on “Personal Data Protection” and Executive Decree No. 285 of May 28, 2021, which regulates Law 81 of 2019 on Personal Data Protection, of the Republic of Panama.

In the event that PredictBay engages third-party service providers to support the Platform's operations, security, analytics, communications, and performance, these providers may process Personal Data on PredictBay's behalf, subject to appropriate contractual, technical, and organizational safeguards and as otherwise permitted by Applicable Data Protection Law.

THE USER UNDERSTANDS, ACKNOWLEDGES, AND AGREES THAT PREDICTBAY USES SERVICE PROVIDERS TO MAKE ITS SERVICES AVAILABLE TO THE USER, AND THAT THESE SERVICE PROVIDERS MAY INTERCEPT USER COMMUNICATIONS OR TRACK THEIR ACTIVITIES. BY USING PREDICTBAY'S SERVICES, THE USER SPECIFICALLY CONSENTS TO THIS INTERCEPTION, TRACKING, AND DATA COLLECTION BY THIRD-PARTY SERVICE PROVIDERS.

1. Definitions

For purposes of this Privacy Policy:

“Account” means a registered user profile used to access the Services.

“Applicable Data Protection Law” means all laws, regulations, directives, and binding guidance relating to the processing of Personal Data applicable to PredictBay or the Platform, including (to the extent applicable) Panama’s Law 81 of 2019 on Personal Data Protection, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK Data Protection Act 2018, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), and equivalent legislation in other jurisdictions. The rights, disclosures, and obligations described in this Policy may vary depending on the User’s location, the manner in which the Platform is made available to the User, and the data protection laws applicable to the relevant processing activity. Where jurisdiction-specific rules apply, PredictBay may provide supplemental disclosures or notices.

“Controller,” “Business,” “Processor,” “Service Provider,” “Third Party,” and similar terms have the meanings given under the Applicable Data Protection Law.

“Personal Data” / “Personal Information” means information about an identifiable individual, as defined under the Applicable Data Protection Law.

“Sensitive Personal Information” includes categories treated as sensitive under certain laws (e.g., precise geolocation, government identifiers, financial account credentials, biometric identifiers, and similar categories), and “Special Categories of Personal Data” has the meaning under the Applicable Data Protection Law (e.g., data revealing racial or ethnic origin, political opinions, religious beliefs, health, biometric data used to uniquely identify a natural person, etc.). PredictBay does not request or require Special Categories of Personal Data for ordinary use of the Services; however, such information may be included in documents you provide or may be inferred by third parties in limited contexts (e.g., identity verification workflows) depending on what you submit.

“De-Identified” or “Aggregated” information means information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular person, household, or device, subject to applicable legal requirements.

2. Scope and Role

2.1 Geographic Scope

The Services are offered to users in multiple jurisdictions, and PredictBay processes Personal Data in accordance with this Privacy Policy and Applicable Data Protection Law. Some features may be restricted or unavailable in certain jurisdictions due to legal, regulatory, or risk-based requirements.

2.2 PredictBay’s Role

Depending on the processing activity and Applicable Data Protection Law, PredictBay may act as a controller/business (determining the purposes and means of processing) or as a processor/service provider when processing on behalf of another entity in a limited context (e.g., enterprise features, if offered). Where required by law, additional disclosures may be provided at or before the point of collection.

2.3 Information about people under 18

The Platform is not intended for, directed at, or designed to be accessed or used by any person under the age of eighteen (18) years, or such higher age as may constitute the age of legal majority in the applicable jurisdiction of residence (a “Minor”). No Minor may access, use, register on, or interact with the Platform or any of its features, functionalities, or services in any capacity.

No Minor may provide any Personal Data to PredictBay, whether on or through the Platform, including through support communications, API interactions, or any other mechanism. This prohibition extends to names, email addresses, wallet addresses, and any other information that constitutes Personal Data under Applicable Data Protection Law.

PredictBay does not knowingly collect, solicit, or receive Personal Data from Minors. In the event that PredictBay becomes aware that it has collected Personal Data from a Minor, PredictBay shall take prompt steps to: (a) identify and isolate such data; (b) permanently delete or destroy such data; and (c) where technically feasible, terminate any access associated with such Minor.

Any User who believes that PredictBay may have inadvertently collected Personal Data from a Minor should promptly contact PredictBay at [email protected].

3. Categories of Personal Data We Collect

We collect Personal Data in the following categories. The specific data elements collected depend on how you use the Services, the features you access, your jurisdiction, and applicable legal requirements.

3.1 Identifiers and Contact Information

Full name

Email address

Telephone number

Mailing address and country/region of residence

Username/handle and account identifiers

Government-issued identifiers (where required for compliance), such as national ID numbers, tax identification numbers, and similar identifiers

Date of birth and age verification attributes

3.2 Account Credentials and Authentication Data

Multi-factor authentication data (e.g., authenticator configuration, phone-based verification)

Authentication tokens and session identifiers

Single sign-on data (e.g., identifiers received from an identity provider, depending on your authentication method and settings)

3.3 Identity Verification and Due Diligence Data (KYC/AML/Compliance)

When required or permitted by law, regulation, or risk controls, we may collect and process:

Identity document images and data (e.g., passport, national ID, driver’s license), including document numbers, issuance/expiration dates, and issuing authority

Selfies, liveness checks, and related verification outputs (including biometric-derived signals where used by verification vendors), to the extent permitted by law and your choices

Proof of address documents (e.g., utility bill, bank statement) and associated data

Tax residency and tax status information, where required for compliance

Source-of-funds/source-of-wealth information, where required for compliance or enhanced due diligence

Sanctions, politically exposed person (PEP), watchlist, and adverse media screening results (including risk indicators and match data)

Geolocation and jurisdictional eligibility signals used for access controls (see Section 3.7)

Internal compliance notes, investigation records, and case management artifacts related to legal obligations and platform integrity

3.4 Financial and Payment Information

Depending on the funding/settlement methods available in your jurisdiction and the Services you use, we may collect:

Payment card information and related metadata (typically processed by payment processors; we may receive limited data such as last four digits, card brand, and tokenized identifiers)

Bank account information (e.g., account and routing numbers) and account linking data where account linking is offered

Deposit/withdrawal records, payment confirmations, chargeback and dispute information

Billing address and transaction authorization details

Account balances and ledger entries maintained within the Services, where applicable

3.5 Transaction and Trading/Market Activity Data

We collect and generate data relating to your use of prediction markets and related activity, including:

Orders, trades, positions, settlement outcomes, timestamps, and related events

Market selections, quantities, pricing, fees, and other transaction attributes

Payouts, credits, debits, and adjustments

Trading limits, risk controls, and compliance flags applied to your activity

Market participation history and platform interactions relevant to the Services

3.6 Communications, Support, and Feedback

Messages you send to us (e.g., support tickets, emails, chat messages)

Customer service interactions, including call recordings or transcripts where permitted by law and disclosed at the time of recording

Survey responses, feedback, bug reports, and feature requests

Content you provide through the Services (e.g., if community, commentary, or dispute workflows are offered)

3.7 Device, Network, and Usage Data (Automatic Collection)

When you access or use the Services, we automatically collect:

IP address

Approximate location derived from IP address

Device identifiers and attributes (e.g., device type, operating system, browser type, language settings)

Application version, SDK versions, and configuration data

Log data (e.g., access times, pages viewed, actions taken, referring URLs)

Performance and diagnostic data (e.g., crash reports, latency, error logs)

Fraud and security signals (e.g., device fingerprinting elements, risk indicators, bot detection signals), to the extent permitted by law

Precise geolocation (e.g., GPS-level data) is collected only where a feature requires it and where you grant the relevant device permission or otherwise provide consent where required by law.

3.8 Cookies and Similar Technologies Data

We collect information through cookies, pixels, SDKs, local storage, and similar technologies, which may include:

Unique cookie identifiers and advertising identifiers (where applicable)

Analytics events, attribution data, and campaign interactions

Preferences and settings data

See Section 12 (Cookies and Tracking Technologies) for details.

3.9 Blockchain / Public Ledger Data (If Applicable)

If the Services involve interactions with public or permissioned blockchains, smart contracts, or wallet infrastructure, we may process:

Public wallet addresses and public keys

Transaction hashes, smart contract interactions, and on-chain event logs

Token transfers, timestamps, and related public ledger data

Wallet provider metadata and connection events

Wallet addresses provisioned for you through zero-knowledge login (zkLogin), which are derived from your third-party sign-in identity together with an independently held salt, and the resulting on-chain account, balance-manager, or position objects associated with your Account

Metadata relating to network-fee–sponsored ("Sponsored") transactions submitted on your behalf, including the operations requested, identity and origin signals, and rate-limiting and anti-replay records

Interactions with third-party on-chain order-book, pricing, and oracle infrastructure used to provision, open, price, or settle on-chain positions

Important: Public blockchains are generally accessible to anyone, independently of PredictBay. Information recorded on-chain (including wallet addresses, transaction hashes, amounts, timestamps, and smart-contract interactions) is typically public, permanent, and immutable — PredictBay may not be able to control, edit, delete, or restrict access to it once recorded, and erasure or "right to be forgotten" requests may not be technically possible for data already on a blockchain. Where an on-chain address is linked to your Account, your on-chain activity may be associated with you by PredictBay or by third parties (for example, through blockchain analytics). Users are advised to consider this immutability before initiating any on-chain transaction through the Platform.

3.10 Inferences and Derived Data

We may generate inferences and derived data, including:

Risk scores and trust/safety assessments

Eligibility determinations (e.g., jurisdictional access controls)

Fraud and abuse likelihood indicators

Analytics outputs (e.g., segmentation based on usage patterns)

Account integrity signals (e.g., suspected account takeover indicators)

3.11 Information About Others You Provide

If you provide information about other individuals (e.g., referrals, authorized representatives, beneficial owners for institutional accounts, or third-party payment account holders), we process that information as described in this Privacy Policy. You represent that you have appropriate authority to provide such information.

4. Sources of Personal Data

We collect Personal Data from the following sources:

Directly from you (e.g., account registration, identity verification submissions, support communications).

Automatically from your devices and browsers when you use the Services (e.g., logs, cookies, device signals).

From service providers and vendors that help us provide the Services (e.g., identity verification providers, payment processors, fraud detection vendors, analytics providers, cloud hosting providers).

From third-party identity providers (e.g., when you use single sign-on), subject to your settings and the provider’s policies.

From publicly available sources and commercial databases, where permitted by law (e.g., sanctions lists, PEP lists, adverse media sources).

From governmental, regulatory, or law enforcement authorities where required or permitted by law.

From other users or third parties where they provide information about you in connection with their use of the Services (e.g., referral programs, dispute submissions).

5. How We Use Personal Data

We use Personal Data for the purposes listed below. The purposes for which we use your Personal Data depend on the context of collection and the Services you use.

5.1 Providing and Operating the Services

Create, administer, and maintain Accounts

Authenticate users and manage sessions

Enable participation in prediction markets, including order placement, trade execution, settlement, and related account administration

Process deposits, withdrawals, fees, and related financial operations

Provide user-facing analytics and market insights features, where offered

Personalize functional aspects of the Services (e.g., language, region settings)

5.2 Customer Support and Communications

Respond to inquiries and support requests

Provide administrative messages (e.g., confirmations, notices, alerts)

Communicate about Account status, updates, or material changes to the Services

Collect feedback and conduct surveys

5.3 Compliance, Legal Obligations, and Regulatory Requirements

Conduct identity verification, eligibility checks, and due diligence processes

Perform AML/CFT, sanctions, and watchlist screening, transaction monitoring, and suspicious activity analysis

Enforce jurisdictional restrictions and other access controls

Maintain records as required by Applicable Data Protection Laws and regulations (including recordkeeping and reporting obligations)

Respond to lawful requests from regulators, law enforcement, courts, and other authorities

Conduct audits and demonstrate compliance with legal obligations

5.4 Fraud Prevention, Security, and Platform Integrity

Detect, investigate, prevent, and mitigate fraud, account takeover, unauthorized access, cheating, market manipulation, and other prohibited conduct

Secure Accounts and the Services (e.g., security monitoring, access controls, anomaly detection)

Verify identity and reduce risk of impersonation

Protect users, PredictBay, and third parties from harm, abuse, or illegal activity

5.5 Analytics, Research, and Product Improvement

Analyzing Platform usage patterns, user journeys, technical performance, and session-based interaction data to improve functionality, reliability, security, and user experience;

Conducting internal research and development;

Measuring the effectiveness of marketing campaigns and educational content; and

Aggregating and anonymizing data for statistical analysis, benchmarking, and reporting.

5.6 Marketing and Advertising (Where Permitted)

Send marketing communications where permitted by law and consistent with your preferences

Measure marketing effectiveness and attribution

Conduct interest-based advertising or cross-context behavioral advertising where offered and where permitted by law, subject to opt-out rights (see Section 13)

5.7 Corporate Operations and Business Administration

Manage corporate governance, reporting, and internal operations

Conduct risk management and business planning

Protect our legal interests, including establishing, exercising, or defending legal claims

Support mergers, acquisitions, reorganizations, financing, bankruptcy, or similar transactions (see Section 7.6)

6. Legal Bases for Processing

Depending on the context, PredictBay processes Personal Data on one or more of the following legal bases:

performance of a contract or pre-contractual steps requested by the User, including to provide the Platform, enable wallet connectivity, process transactions initiated by the User, and provide support;

compliance with legal and regulatory obligations, including sanctions screening, fraud prevention, security, audit, recordkeeping, and responses to lawful requests from competent authorities;

PredictBay’s legitimate interests, where permitted by Applicable Data Protection Law, including improving the Platform, maintaining security, preventing misuse, conducting internal analytics, and managing business operations, provided such interests are not overridden by the User’s rights and freedoms; and

the User’s consent, where required, including for certain marketing communications and certain cookies or similar technologies.

Where PredictBay relies on consent, the User may withdraw it at any time without affecting processing carried out before withdrawal.

7. Disclosures of Personal Data

We may disclose Personal Data to the following categories of recipients, subject to Applicable Data Protection Law and appropriate safeguards.

7.1 Service Providers and Vendors

We disclose Personal Data to third-party service providers that perform services on our behalf, such as:

Cloud hosting and infrastructure providers

Identity verification and due diligence providers

Payment processors, banking partners, and payout providers

Fraud prevention, risk scoring, and security vendors

Customer support platforms and communication tools

Analytics and performance measurement providers

Email delivery and messaging providers

Compliance, audit, and professional services providers (e.g., legal counsel, accountants)

For on-chain functionality: wallet-provisioning and zero-knowledge-proof (zkLogin) providers, transaction-sponsorship providers, blockchain node/RPC and indexing providers, and on-chain oracle and pricing providers

Service providers are contractually required (where applicable) to use Personal Data only as necessary to provide services to PredictBay and to implement reasonable safeguards, subject to legal requirements and permitted uses.

7.2 Affiliates and Entities Under Common Control

We may disclose Personal Data to our current and future parents, subsidiaries, affiliates, and other entities under common control, for purposes consistent with this Privacy Policy, including internal administration, compliance, security, and service delivery.

7.3 Counterparties and Market Participants (Limited Contexts)

Depending on how the Services are structured, limited information relating to market activity may be visible to other market participants (e.g., aggregated market depth or anonymized/obfuscated activity), subject to the design of the Services. PredictBay does not commit to any specific anonymity model and disclosures may vary by product configuration and legal requirements.

7.4 Blockchain Networks and Public Dissemination (If Applicable)

If transactions are executed or recorded on a blockchain or other distributed ledger:

Certain data (e.g., wallet addresses, transaction hashes, smart contract interactions) may be recorded on-chain and become publicly accessible.

PredictBay may disclose or broadcast transaction data to blockchain nodes, validators, or network participants as necessary to facilitate transactions.

PredictBay may not be able to remove or modify on-chain data once recorded.

PredictBay may share transaction-related data with third-party wallet-provisioning, proof-generation, and transaction-sponsorship providers, node/RPC and indexing providers, and on-chain oracle and pricing providers, in each case as necessary to provision wallets and to build, sponsor, broadcast, index, price, or settle on-chain transactions. These third parties operate the underlying protocols and infrastructure and are not controlled by PredictBay.

7.5 Governmental, Regulatory, and Law Enforcement Authorities

We may disclose Personal Data to regulators, law enforcement, courts, or other governmental authorities:

To comply with legal obligations or lawful requests

To respond to subpoenas, court orders, or similar legal processes

To report suspicious activity where required or permitted

To protect the rights, property, and safety of PredictBay, users, or others

7.6 Business Transfers and Corporate Transactions

We may disclose Personal Data in connection with, or during negotiations of, any merger, acquisition, financing, reorganization, sale of assets, bankruptcy, dissolution, or other corporate transaction or proceeding involving all or part of PredictBay. Personal Data may be disclosed to counterparties, advisors, and other participants, subject to confidentiality and legal requirements.

7.7 Professional Advisors

We may disclose Personal Data to professional advisors (e.g., lawyers, auditors, accountants, consultants) where necessary for legal, compliance, audit, or business purposes.

7.8 With Your Direction or Consent

We disclose Personal Data when you direct us to do so, when you use integrations, or when you otherwise consent to a disclosure.

8. International Data Transfers

PredictBay may process and store Personal Data in jurisdictions other than where you reside. These jurisdictions may have data protection laws that differ from your jurisdiction.

Where required by law, PredictBay implements lawful mechanisms for cross-border transfers, which may include:

Standard Contractual Clauses approved by the European Commission (and supplementary measures where appropriate)

The UK International Data Transfer Agreement (IDTA) or the UK Addendum to EU SCCs

Reliance on adequacy decisions where applicable

Other transfer mechanisms permitted by Applicable Data Protection Law

9. Data Retention

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect PredictBay’s legitimate interests.

Retention periods vary depending on the nature of the data and the context of processing, including:

Account data: typically retained for the duration of the Account and as needed thereafter for legitimate business purposes and legal compliance.

Transaction, financial, and compliance records: may be retained for extended periods as required by applicable financial, tax, AML, and recordkeeping laws and regulations, and for audit and dispute purposes.

Identity verification data: retained as required for compliance, fraud prevention, and auditability, subject to Applicable Data Protection Law and vendor arrangements.

Security logs and device data: retained for periods appropriate to security monitoring, incident investigation, and platform integrity.

Marketing data: retained until you opt out, your consent is withdrawn (where consent is required), or the data is no longer needed for the relevant purpose.

Where permitted, we may retain De-Identified or Aggregated data for longer periods. When Personal Data is no longer required, PredictBay will securely delete or anonymize it in accordance with its data retention and disposal procedures. Blockchain Data cannot be deleted or modified due to the immutable nature of blockchain technology.

10. Data Security

PredictBay implements and maintains administrative, technical, and physical safeguards designed to protect Personal Data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Safeguards may include, depending on risk and context:

Encryption in transit and, where appropriate, at rest

Access controls and least-privilege practices

Security monitoring, logging, and alerting

Network security controls and vulnerability management

Vendor security diligence and contractual protections

Incident response procedures and contingency planning

No method of transmission or storage is fully secure under all conditions. PredictBay does not represent that unauthorized access, disclosure, loss, or alteration will never occur.

11. Your Rights and Choices

Your rights depend on your jurisdiction and the nature of PredictBay’s processing. PredictBay may require identity verification to respond to requests and may deny or limit requests where permitted by law (including where compliance recordkeeping obligations apply).

11.1 Republic of Panama Rights

Subject to Applicable Data Protection Law, Users may have the following rights with respect to their Personal Data:

Right of Access: the right to request confirmation of whether Personal Data is being processed and to obtain a copy of such data;

Right of Rectification: the right to request correction of inaccurate or incomplete Personal Data;

Right of Erasure: the right to request deletion of Personal Data, subject to applicable legal retention obligations and the immutable nature of Blockchain Data;

Right to Restrict Processing: the right to request restriction of processing in certain circumstances;

Right to Data Portability: the right to receive Personal Data in a structured, commonly used, machine-readable format;

Right to Object: the right to object to processing based on legitimate interests or for direct marketing purposes; and

Right to Withdraw Consent: the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, Users may contact PredictBay at [email protected], providing their full name and sufficient detail to enable PredictBay to identify and process the request. PredictBay will respond within twenty (20) working days, in accordance with Law 81 of 2019. PredictBay reserves the right to retain Personal Data as permitted or required by Applicable Law.

11.2 EEA/UK (GDPR/UK GDPR) Rights

If you are located in the EEA or the UK (or where similar rights apply), you may have the right to:

Access your Personal Data

Rectify inaccurate or incomplete Personal Data

Delete your Personal Data (subject to legal obligations and exceptions)

Restrict processing in certain circumstances

Data portability (receive certain Personal Data in a structured, commonly used, machine-readable format)

Object to processing based on legitimate interests or direct marketing

Withdraw consent at any time where processing is based on consent (withdrawal does not affect prior processing)

Lodge a complaint with a supervisory authority (EEA) or the UK Information Commissioner’s Office (UK)

11.3 California (CCPA/CPRA) Rights

If you are a California resident, you may have the right to:

Know the categories and specific pieces of Personal Information we collected about you

Know the categories of sources from which Personal Information is collected

Know the business or commercial purposes for collecting, selling, or sharing Personal Information

Know the categories of third parties to whom we disclose Personal Information

Delete Personal Information, subject to exceptions

Correct inaccurate Personal Information, subject to exceptions

Opt out of the “sale” or “sharing” of Personal Information (as defined under California law)

Limit the use and disclosure of Sensitive Personal Information, where applicable

Not receive discriminatory treatment for exercising your rights

Exemptions: Certain data may be exempt from some CCPA/CPRA rights, including information subject to specific sectoral privacy laws, and data retained to comply with legal obligations (including compliance and recordkeeping requirements).

11.4 Other U.S. State Privacy Rights

If you are located in a U.S. state with an applicable privacy law (e.g., Colorado, Virginia, Connecticut, Utah, Texas, Oregon, Montana, and others), you may have rights similar to access, deletion, correction, portability, opt-out of targeted advertising, and opt-out of certain profiling. Where required, we provide an appeals process for denied requests.

11.5 Canada, Brazil, and Other Jurisdictions

You may have rights under other Applicable Data Protection Laws (e.g., Canada’s PIPEDA, Brazil’s LGPD, Switzerland’s FADP, and others), which may include rights of access, correction, deletion, portability, and objection, subject to legal exceptions.

11.6 Exercising Rights

To exercise applicable rights, submit a request using the contact method in Section 15. We may request additional information to verify your identity and the scope of your request. If you use an authorized agent (where permitted), we may require proof of authorization and may still request verification from you.

11.7 Marketing Preferences

You may opt out of promotional emails by using the unsubscribe mechanism provided in those messages. You may continue to receive non-promotional communications (e.g., security alerts, transactional notices, legal notices).

12. Cookies and Tracking Technologies

12.1 Types of Technologies

The Services may use:

Cookies (first-party and third-party)

Pixels/web beacons

SDKs and similar tracking code

Local storage and device identifiers

Session replay or interaction monitoring tools, where deployed and permitted by law (typically for debugging, fraud prevention, and product improvement), subject to configuration and jurisdictional requirements

12.2 Purposes

Tracking technologies may be used for:

Strictly necessary functions (e.g., session management, security)

Preferences (e.g., language, settings)

Analytics and performance measurement

Fraud detection and abuse prevention

Advertising, attribution, and cross-context behavioral advertising (where applicable and permitted)

12.3 Managing Cookies and Consent

You may manage cookie preferences through:

Any cookie consent tool or banner made available on the Services (where required)

Browser settings (which may limit functionality)

Platform-level controls (e.g., device advertising settings), where applicable

12.4 Do Not Track and Global Privacy Control

Some browsers transmit “Do Not Track” signals. Practices vary and not all systems respond to these signals. Where required by law, we honor recognized opt-out preference signals such as the Global Privacy Control (GPC) for certain opt-out requests.

13. “Sale,” “Sharing,” Targeted Advertising, and Opt-Outs (U.S. Privacy Laws)

PredictBay does not offer a commitment that data will never be disclosed in ways that could be interpreted as a “sale” or “sharing” under certain laws. Some disclosures to analytics or advertising partners (if used) may be considered a “sale” or “sharing” under CCPA/CPRA or “targeted advertising” under other state laws, depending on the context and configuration.

Where applicable, you may opt out by:

Using an in-product opt-out mechanism if provided

Using cookie preference controls (Section 12)

Submitting a request as described in Section 11.6

14. Third-Party Links, Integrations, and External Services

The Services may include links to, or integrations with, third-party services (e.g., identity providers, payment providers, blockchain explorers, analytics tools, social platforms). PredictBay does not control third-party privacy practices. Your use of third-party services is subject to their terms and privacy policies, and PredictBay is not responsible for their practices.

15. Contact Information and Privacy Inquiries

For questions, requests, or complaints regarding this Privacy Policy or our privacy practices, contact:

Email: [email protected]

If you are located in a jurisdiction that provides a right to lodge complaints with a regulator, you may also contact your local data protection authority. We encourage you to contact us first so we can attempt to address your concern.

16. Changes to This Privacy Policy

PredictBay reserves the right to modify or update this Policy at any time, and in its sole discretion, to reflect changes in data processing practices, legal requirements, or business operations.

Any material changes will be communicated by posting the revised Policy on the Platform with an updated “Last Updated” date.

Where a material change affects the purposes or lawful bases of processing, expands the categories of Personal Data collected, or introduces new categories of recipients, PredictBay shall endeavor to provide notice through the Platform, by email, or through other appropriate channels prior to the change taking effect. Where required by Applicable Data Protection Law, PredictBay shall obtain fresh consent before implementing such changes.

Continued access to or use of the Platform following the posting of a revised Policy constitutes acceptance of the revised Policy. Users who do not agree must immediately discontinue use of the Platform.

17. How to Complain

Users may exercise their rights of access, rectification, cancellation, or opposition concerning their personal data, as well as request the revocation of their consent, by sending a request to [email protected], providing their full name and address or any other data or document that allows their identification, including a legal document proving ownership, as well as the purpose of their request. The response time is twenty (20) working days.

If a User believes that their right to personal data protection, including ARCO rights, has been violated, they may also contact the National Authority for Transparency and Access to Information (“ANTAI”) of the Republic of Panama, whose website is https://www.antai.gob.pa/.

This Privacy Policy has been created in accordance with the rules issued under Law 81 of 2019 on “Personal Data Protection” and Executive Decree No. 285 of May 28, 2021, which regulates Law 81 of 2019 on Personal Data Protection.

18. Governing Law

This Policy is governed by the laws of the Republic of Panama, without prejudice to any mandatory rights or protections that may apply to a User under Applicable Data Protection Law. The dispute resolution provisions set forth in the PredictBay Terms of Service apply to any dispute arising out of or in connection with this Policy.