This Privacy Policy explains how ConvictionMarkets, Inc. (“ConvictionMarkets,” “we,” “us,” “our”), a Delaware corporation, collects, uses, shares, and protects personal information when you use the Convictions app (“App”). We are committed to transparency and to complying with applicable U.S. privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Delaware Personal Data Privacy Act, the Children’s Online Privacy Protection Act (COPPA), and the Federal Trade Commission Act. We do not sell or share your personal information, and we never will. We collect and retain the information described in this Policy to operate the App and improve your experience, and we do not track you across other companies’ apps or websites. Your use of the App is also governed by our Terms of Service, which you accepted when creating your account, and this Policy should be read alongside them.
1. Who We Are and How to Contact Us
ConvictionMarkets, Inc. is responsible for the personal information processed through the App.
Mailing address: 855 Flathead Creek Road East, Wilsall, MT 59086
Privacy enquiries and data requests: privacy@conviction-markets.com
General and legal enquiries: legal@conviction-markets.com
Content moderation and safety: security@conviction-markets.com
We respond to general privacy enquiries within 30 days. For verifiable consumer rights requests under state privacy laws, we respond within 45 days, which we may extend by a further 45 days where reasonably necessary, with notice to you.
2. Personal Information We Collect
We collect the following categories of personal information. The retention period for each category is described in Section 9.
Identity and profile data: your Convictions account identifier, username, display name, email address, the month and year of your birth, and your gender if you choose to provide one. We retain your email address for the life of your account so that we can authenticate you, secure your account, contact you about the App, and help you regain access if you are locked out. We do not currently use your email address to send marketing or promotional messages; if we choose to do so in the future, we will update this Policy and give you the ability to opt in to, and to unsubscribe from, marketing emails at any time. We collect only the month and year of your birth, which we retain to verify age eligibility and to understand the age composition of our user base; we never collect or retain the day of your birth.
Activity and usage data: the screens you view and the time you spend on them, the Convictions you create or interact with, the stakes you place, and your Cred balance, streaks, and accuracy record.
Social graph data: the Groups you belong to, the accounts you follow, and the accounts that follow you.
Content data: the text of the Convictions you create, your comments, your staking history, and your prediction outcomes. The text of a Conviction is transmitted to our analytics provider together with the events describing it (see Section 5). The contents of private messages are not transmitted to our analytics provider.
Technical and approximate location data: the App version; the Internet Protocol (IP) address from which your account was created, which we record and retain on your user profile; and the approximate city and region derived from that IP address.
Referral data: the referral or promotional code you signed up with, if any, and the account that referred you.
Moderation data: reports submitted or received, block relationships, and moderation actions taken and their outcomes (see Section 7).
We do not collect: precise GPS location, financial or payment data, health data, biometric identifiers, or government-issued identification numbers.
3. How We Collect Personal Information
Directly from you: when you register, set a username and display name, provide your birth month and year and your gender if you choose to, create Convictions, stake Cred, join Groups, follow other accounts, or contact us for support.
Automatically: when you use the App, we collect activity and usage events (for example, screens viewed and stakes placed) via the Mixpanel SDK. We also automatically record the IP address from which your account was created, and we derive your approximate city and region from it.
From third parties: if you sign up via a referral link, we receive the referral or promotional code used and the account that referred you.
4. How and Why We Use Your Information
We use your personal information only for the following purposes:
To create and authenticate your account and provide core App functionality (Convictions, Cred, Groups, and Leaderboards);
To understand how the App is used — which features people reach, where they get stuck, and whether the changes we make improve the experience (you can opt out of analytics at any time — see Section 5);
To verify age eligibility and to comply with our legal obligations, including responding to data-rights requests;
To keep the App safe, prevent fraud and abuse, and operate our content-moderation system; and
To send you service-related messages, such as account, security, and support notifications. We do not currently send marketing or promotional communications; if we introduce them, we will do so only on an opt-in basis, and you will be able to unsubscribe at any time.
We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you.
5. Analytics and Product Measurement
We use Mixpanel, Inc. (USA) as our analytics provider. Mixpanel acts as our service provider under a data-processing agreement that prohibits it from using your data for its own purposes.
We use analytics to understand how the App is used — which features people reach, where they get stuck, and whether changes we make improve the experience. We do not use it to advertise to you, and we do not sell or share your personal information for advertising or any other cross-context behavioural purpose.
Mixpanel receives:
Your account identifier. Your Convictions account ID, so activity can be understood as belonging to one person over time.
Your profile details. Your username, display name, email address, the month and year of your birth (never the day), and your gender if you chose to provide one. Your email address is used to identify your account within our analytics and to contact you about the App; it is not used for advertising and is not shared onward.
Your activity in the App. Screens you view and how long you spend on them, Convictions you create or interact with, stakes you place, groups you belong to, who you follow, and your Cred balance, streaks, and accuracy record.
Content you post. The text of a Conviction you create is included with the events describing it. We do not send the contents of your private messages.
Referral information. The referral or promotional code you signed up with, if any, and the account that referred you.
Technical and approximate location data. Your App version, the IP address your account was created from, and the approximate city or region Mixpanel derives from it. We do not collect precise GPS location.
We never send your password to Mixpanel. Mixpanel processes data on servers in the United States. For more information, see Mixpanel’s privacy policy at mixpanel.com/legal/privacy-policy.
You can opt out of Mixpanel analytics at any time by contacting support@conviction-markets.com. Opting out will not affect your ability to use the App.
6. How We Share Information — We Do Not Sell or Share Your Data
We do not sell your personal information, and we do not share it for cross-context behavioral advertising or any other purpose, for money or any other valuable consideration. We do not disclose your personal information to data brokers. We share personal information only with the limited service providers listed below, who process data solely on our instructions and under contractual confidentiality and data-protection obligations, and only as required to operate the App or comply with law:
Analytics provider (Mixpanel): the data described in Section 5, which includes directly identifying information such as your display name and email address, the text of the Convictions you create, and your social connections, under a data-processing agreement.
Cloud and hosting providers: our backend database and infrastructure providers host the App’s data and process it only on our instructions under data-processing agreements.
Apple (App Store): Apple receives the limited data required for app distribution; see Apple’s privacy policy.
Legal and safety: we may disclose information if required by law, subpoena, or court order, or where necessary to protect the rights, property, or safety of our users, the public, or ConvictionMarkets.
Business transfers: if we merge with or are acquired by another company, your information may be transferred as part of that transaction; we will notify you beforehand and give you the opportunity to delete your account, and any successor will remain bound by this Policy or provide equivalent protection.
We may create and use truly de-identified or aggregated statistics that cannot reasonably be used to identify you (for example, the total number of Convictions made in a category). We will maintain such information in de-identified form, will not attempt to re-identify it, and do not sell it.
7. User-Safety Data
The App provides Report and Block features to help keep the platform safe. When you use these features, we process the following personal information.
7.1 Report Submissions
When you submit a report about another user’s Conviction, comment, or profile, we record the identity of the reporting user, the reported content or profile, the reason selected, the date and time, and the outcome of our review. An automated notification is sent to our moderation team at support@conviction-markets.com upon submission. We do not disclose the identity of the reporting user to the reported user.
7.2 Block Relationships
When you block another user, we store the block relationship so the blocked user cannot access your profile, view your Convictions, or interact with you within the App. This data is retained for as long as the block is active and for a reasonable period afterward to maintain safety records.
7.3 Moderation Records
We retain moderation records — including reports filed, content removed, warnings issued, suspensions, and ban history — for up to 24 months for safety, appeals, legal-compliance, and audit purposes. We may share moderation data with law enforcement where required by law or where necessary to prevent or respond to imminent harm.
8. Apple App Tracking Transparency
We do not track you across apps or websites owned by other companies. We do not use Apple’s Identifier for Advertisers (IDFA) for cross-app tracking, and we do not share your data with data brokers. As a result, we do not present an App Tracking Transparency (ATT) prompt for tracking purposes. If this ever changes, we will update this Policy and implement the ATT permission prompt before any tracking begins. In App Store Connect, we disclose the data collected by the App and by Mixpanel in our App Privacy details. We review those disclosures whenever this Policy is updated so that they remain consistent with it.
9. Data Retention
We keep personal information only for as long as necessary for the purposes described in this Policy, and then delete or de-identify it. Retention by category:
Account, profile, and content data: retained while your account is active. This includes your email address, which we retain for the life of your account so we can log you in and help you recover access, and which is deleted when you delete your account. You can delete your account at any time at Settings → Account → Delete Account within the App. Upon deletion, your account and associated personal information are permanently removed within 30 days. If you need assistance, contact support@conviction-markets.com.
Technical identifiers: the IP address recorded when your account was created is retained on your user profile for the life of your account and is deleted when you delete your account.
Analytics data: event data held by Mixpanel is retained for up to 24 months and then deleted. The profile, content, social graph, and technical data held on your Mixpanel user profile, as described in Section 5, is deleted when your account is deleted.
Moderation records: retained for up to 24 months after the relevant moderation action, as described in Section 7.3.
Backups: encrypted backups are retained for up to 90 days after deletion from live systems, then overwritten.
Legal holds: we may retain information longer where required by law or for ongoing legal proceedings.
10. Security and Breach Notification
We implement appropriate technical and organizational measures to protect your personal information, including encryption of data in transit (TLS) and at rest, access controls limiting who can view personal information, and regular review of our data inventory and security practices. Access to directly identifying information is limited to a small number of authorized personnel who need it to operate the App. No system is completely secure. If we become aware of a data breach affecting your personal information, we will notify affected users and the appropriate authorities as required by applicable state breach-notification laws, without unreasonable delay. If you become aware of a security issue, please contact support@conviction-markets.com immediately.
11. Children’s Privacy
The App is not directed to children under 13, and we do not knowingly collect personal information from anyone under 13. We present a neutral age screen at registration and will delete any account we discover belongs to a child under 13. If you believe we have inadvertently collected information from a child under 13, contact us immediately at support@conviction-markets.com and we will delete it.
Users aged 13 to 17 may use the App only with the consent and supervision of a parent or legal guardian. We do not sell or share the personal information of any user, and we never sell or share the personal information of minors for any purpose. We encourage parents and guardians to contact us with any concerns at support@conviction-markets.com.
12. Your Privacy Rights
Depending on where you live, you may have some or all of the following rights regarding your personal information. We honor these rights for all users, regardless of state of residence:
The right to know or access the categories and specific pieces of personal information we have collected about you;
The right to delete your personal information;
The right to correct inaccurate personal information;
The right to obtain a portable copy of your personal information;
The right to opt out of the sale or sharing of your personal information and of targeted advertising — note that we do not sell or share your personal information and do not process sensitive personal information beyond what is necessary to provide the App; and
The right not to receive discriminatory treatment for exercising any of these rights.
To submit a request, email support@conviction-markets.com with the subject line “Privacy Request.” We will verify your request using information associated with your account and respond within the timelines in Section 1. You may use an authorized agent to submit a request on your behalf, subject to verification.
12.1 California Residents (CCPA/CPRA)
California residents have the rights described above, including the right to know, delete, correct, opt out of sale or sharing, limit the use of sensitive personal information, and not be discriminated against. We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we do not use or disclose sensitive personal information for purposes that would trigger the right to limit. Under California’s “Shine the Light” law, we do not disclose personal information to third parties for their own direct-marketing purposes. To exercise your rights, email support@conviction-markets.com with the subject line “California Privacy Request.”
12.2 Delaware Residents (DPDPA)
We comply with the Delaware Personal Data Privacy Act. Delaware residents have the right to access, correct, delete, and obtain a portable copy of their personal data, and to opt out of targeted advertising and the sale of personal data (we do not sell personal data). You also have the right to appeal a decision on your request; to appeal, reply to our response or email support@conviction-markets.com with the subject line “Privacy Appeal.”
12.3 Residents of Other States
If you live in another state with a comprehensive privacy law, you have substantially the same rights described in this Section 12, and you may exercise them using the same contact method.
13. Third-Party Services and Links
The App may reference or display data from third-party services (for example, sports-result APIs and public data providers). These services have their own privacy policies, and we are not responsible for their practices.
14. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of changes via in-app notice or email, and the “Last updated” date above reflects the most recent revision. For material changes — such as changes to how we collect, use, or share your personal information — we will request your affirmative acceptance via an in-app prompt before the changes take effect. You may request prior versions of this Policy by contacting support@conviction-markets.com.
15. Contact Us
For any privacy questions, data requests, or complaints:
ConvictionMarkets, Inc.
Mailing address: 855 Flathead Creek Road East, Wilsall, MT 59086
Privacy enquiries and data requests: support@conviction-markets.com
General and legal enquiries: support@conviction-markets.com
Content moderation, safety reports, and appeals: support@conviction-markets.com
This Privacy Policy is accessible within the App at Settings → Legal → Privacy Policy, and at a public URL on our website so that it can be reviewed before downloading the App.