Unreviewed draft. This document has not been reviewed by a lawyer and describes services that may require regulatory authorisation. It is not in force and should not be relied on.

OddsFeed — Privacy Policy

Effective date: [EFFECTIVE DATE]

Last updated: [DATE]

DRAFT — NOT YET LEGALLY REVIEWED.

Review with a qualified lawyer before publication. Placeholders in [BRACKETS]

must be completed.

1. Who is responsible

[LEGAL ENTITY / NAME], [ADDRESS] is the controller of the personal data

described here. Contact: [CONTACT EMAIL].

2. The short version

OddsFeed is a free game with no money in it. We do not take payments, so we

collect none of what a payment service would: no identity documents, no bank or

card details, no proof of address, no wallet addresses.

What we hold is essentially: **who you signed in as, and what you did in the

game.**

3. What we collect

CategoryWhat it isWhere it comes from
Accountemail address, display name, profile picture, account identifieryour identity provider when you sign in
Game activitycredit balance, positions taken, outcomes, watchlist, leaderboard standingyour use of the Service
Usagepages viewed, stories opened, videos played, approximate countryyour device, automatically
TechnicalIP address, browser and device type, timestampsyour device, automatically

We do not collect: identity documents, biometric data, bank or card details,

proof of address, tax identifiers, source-of-funds evidence, or wallet addresses.

No feature of the Service requires them.

4. Why we use it, and on what legal basis

PurposeDataBasis (GDPR Art. 6)
Create and operate your accountaccountContract
Run the game — positions, settlement, balancesaccount, game activityContract
Show leaderboards and public standingsdisplay name, game activityContract
Restrict access where the Service is unavailableapproximate country, IPLegal obligation; Legitimate interests
Keep the Service secure and prevent abusetechnical, usageLegitimate interests
Understand and improve the productusageLegitimate interests
Email you about the ServiceaccountConsent, withdrawable at any time

Where we rely on legitimate interests, we have weighed those against your rights;

you may object at any time (section 8).

5. Approximate location

We derive an approximate country from your IP address, through the network in

front of the Service, in order to restrict access where the prediction markets we

display are blocked. We do not collect precise location and do not track your

movements.

6. Who else sees your data

  • [HOSTING PROVIDER] — hosting and content delivery.
  • [AUTH PROVIDER, e.g. Supabase] — sign-in and session management.
  • Google (YouTube) — video is embedded through YouTube's official player.

When a video loads, YouTube receives your IP address and may set cookies under

its own policy. We use the privacy-enhanced (youtube-nocookie) player, which

reduces but does not eliminate this.

  • Polymarket — we read their public API from our servers. **We do not send

them anything about you.**

We do not sell your personal data, and we do not share it for advertising.

7. Public information

Your display name and game standing may appear on public leaderboards.

Your email address is never shown publicly. If you would rather not appear,

change your display name or ask us to remove you (section 8).

8. Your rights

Under the GDPR you may request access, correction, erasure, restriction,

portability, and object to processing based on legitimate interests. You may

withdraw consent at any time.

Write to [CONTACT EMAIL]. We respond within one month.

You may also complain to your supervisory authority — in Slovenia, the

Informacijski pooblaščenec (ip-rs.si).

9. How long we keep it

DataRetention
Accountwhile your account exists, then [PERIOD]
Game activitywhile your account exists, then [PERIOD]
Usage and technical[PERIOD, e.g. 12 months]

Deleting your account deletes your credits, positions and history. Because

nothing of value is held, none of it can be restored afterwards.

10. Transfers outside the EEA

Some providers in section 6 may process data outside the EEA. Where they do, we

rely on the European Commission's standard contractual clauses or an adequacy

decision. [CONFIRM PER PROVIDER.]

11. Children

The Service is for adults aged 18 and over. We do not knowingly collect data from

children. If you believe a child has an account, contact us and we will delete

it.

12. Security

Access is restricted, traffic is encrypted in transit, and we hold no payment or

identity data that would be worth attacking. No system is perfectly secure, and

we cannot guarantee absolute security.

13. Changes

We will post any update here and, for significant changes, tell you in the

Service.