Convictions — Privacy Policy

Version 6 | Last updated: 23 July 2026

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. 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: info@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. This is our field-level inventory; the retention period for each category is described in Section 9.

Identity data: username, display name, email address, and date of birth. We retain your email address for the life of your account so that we can authenticate you, secure your account, 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 your birth month and year, which we retain solely to verify age eligibility; we do not collect or retain the day of your birth.
Device and usage data: device type, operating-system version, App version, and session events (screens viewed, Convictions created, Cred staked).
Analytics data: a Mixpanel-generated anonymous user identifier, your email domain where applicable, approximate location derived from IP address, and cohort and accuracy statistics.
Content data: Conviction statements, group memberships, Cred balance and staking history, and prediction outcomes.
Referral data: the referral code used at signup, if applicable.
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, create Convictions, stake Cred, join Groups, or contact us for support.
Automatically: when you use the App, we collect usage events (for example, screens viewed and stakes placed) via the Mixpanel SDK.
From third parties: if you sign up via a referral link, we receive the referral code used.

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 analyze usage and improve the App (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: Our Use of Mixpanel

We use Mixpanel, Inc. (USA) as our analytics provider, acting as our service provider under a data-processing agreement that prohibits Mixpanel from using the data for its own purposes. Mixpanel receives:

A Mixpanel-generated anonymous user identifier (not your name or email);
Event data such as screens viewed, Convictions created, and stakes placed;
Your email domain, where applicable, used to optionally associate you with a school community — not your full email; and
Device type and approximate location derived from IP address.

We call mixpanel.identify() once at login to link your in-app activity to your account. We never pass your full email or password as a Mixpanel event property. 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): analytics data as described in Section 5, 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 all data collected by the App and by Mixpanel in our App Privacy details, and those disclosures are kept consistent with this Policy.

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 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.
Analytics data: event data in Mixpanel is retained for 24 months and then deleted; analytics data associated with your account is purged on the same cycle as your account deletion.
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. 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.