PM US TECH PRIVACY POLICY

Effective date: July 16, 2026

1) Introduction

This Privacy Policy explains how PM US Tech (QC Tech LLC), Polymarket US (QCX LLC), and Polymarket Clearing (QC Clearing LLC) (collectively, “Polymarket” “Company,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information of users of the Polymarket US trading application (the “App”). We encourage you to carefully and regularly review this Privacy Policy.

Your use of the App is subject to the Terms & Conditions, the Polymarket US Rulebook, the Polymarket Clearing Rulebook, the Participant Agreement, and the Risk Disclosure (collectively, “Terms”). If you do not agree with the Terms, or the collection and use of your personal information as described in this Privacy Policy, please do not access or use the App.

2) Applicability

This Privacy Policy applies to all information we collect from you in connection with your use and our provision of the App. This Privacy Policy does not apply to information collected on any other application or website made available by us that does not display this Privacy Policy or on any other websites offered by any third party (including our affiliates and subsidiaries).

Throughout this Privacy Policy, we use the term “personal information” to describe information that we collect, process, use, and disclose. “Personal information” includes any information that, alone or in combination with other information, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. It generally means the same as the terms “personally identifiable information,” or “personal data,” as defined under applicable data protection laws.

Please note, however, that under applicable state-level privacy laws, personal information does not include certain information, including:

de-identified or aggregated information;
publicly available information, such as public records held by the government or data made publicly available by you or with your permission;
protected health information handled by a covered entity or business associate and/or governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the Health Information Technology for Economic and Clinical Health Act (HITECH);
medical information protected under state law; or
personal information protected by federal laws such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the Driver’s Privacy Protection Act of 1994 (DPPA) and the Family Educational Rights and Privacy Act (FERPA).

3) Sources of Information

We collect personal information from various sources, including:

directly from you when you provide it to us,
automatically when you use the App,
from third parties, such as our business partners, third party service providers, advertising partners, affiliates, and social media platforms or networks,
from DCMs, futures commission merchants (“FCMs”) / clearing members, other intermediaries, independent software vendors (“ISVs”), and from public or governmental sources, and
publicly available sources.

4) Personal Information Collection

We may collect information about you and your use of the App, including:

Personal information, such as full name, date of birth, government-issued identifiers, profile picture, email address, physical address, and phone number.

Derivative information, such as device and usage data (IP, device/OS/browser, unique IDs, logs, duration, activity); location data; communications (support tickets, recordings, emails/chats); technical and usage data; and data collected automatically via cookies and other tracking technologies.

Financial information and information required for regulatory compliance, such as wallet ID, bank/payment information, balances, transactions; account and trading data (credentials, orders, executions, positions, balances, audit metadata); know your customer (“KYC”) / anti-money laundering (“AML”) data (verification results, sanctions/politically exposed person checks).
Mobile Device Information, such as device type, mobile device identification number, geolocation information, time zone, language setting, and browser type.
Geolocation Information. We collect information that identifies, with reasonable specificity, your location by using certain longitude and latitude coordinates obtained through GPS (for Android users), Wi-Fi, IP-based estimation, or other locational data. We may collect this data for fraud prevention and risk management purposes, among other reasons identified in this Privacy Policy.
Correspondence and Recordkeeping. We will retain records and copies of your correspondence (including e-mail addresses) if you contact us. We will retain all records for such time period as may be required or permitted by applicable law.
Surveys. If you decide to participate in surveys available via the App, you may be asked to provide certain information in your responses, which may include personal information. We may store such responses.

We may collect other information, including personal information, with your consent.

5) Use of Tracking Technologies

We and our partners may use various technologies—including your device’s mobile advertising ID and embedded software development kits (“SDKs”)—to gather personal information about your use of and engagement with the content on the App. This information may be combined with other data we collect and store about you and/or transmitted to third parties, such as our advertising partners. We and our partners may collect your personal information about your online activities over time and across different websites when you use the App. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third-party websites within their networks.

Your device may permit you to control these technologies. For instance, you may be able to opt-out of having your mobile advertising identifiers used for certain types of targeted or personalized advertising by accessing the settings in your mobile device.

6) How We Use Personal Information

We use personal information collected about you for various purposes, including:

To provide, operate, customize, personalize, measure, and improve the App, and the content and layout of the App;
To process transactions (including payments and refunds) and send notices about your transactions or your network activity;
To contact you regarding your use of the App, including responding to questions or requests you may have with respect to the App;
To measure interest and engagement in the App and short-term, transient use, such as contextual customization of ads;
To market to you and provide targeted advertising, coupons, newsletters, and other promotional information regarding the App (including marketing conducted by our business partners and affiliates);
To compile statistical data and analysis for our use internally or by third parties;
To ensure internal quality control, including to debug, identify and repair errors that impair intended functionality or improvements to the App;
To safeguard the App, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
To verify your identity, and prevent fraud, market abuse, prohibited or illegal activities, including through the use of our risk and fraud tools;
To offer certain features or functionalities through the App, which may involve interacting with artificial intelligence technology or tools;
To enforce our Terms, and protect the rights, property, or safety of us or others;
To respond to lawful requests by public authorities, or where otherwise required by law, court order, or other law enforcement or regulatory authority;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer or some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred;
To comply with legal/regulatory obligations (including Commodity Futures Trading Commission (“CFTC”), AML / KYC / counter-terrorism financing (“CTF”), sanctions, surveillance, audit trail, and recordkeeping requirements); and
As otherwise described to you when collecting your personal information, for any other purpose for which you provide consent, or as otherwise required or permitted by law.

We may aggregate, anonymize, and/or de-identify information such that it cannot be used to identify you and is not considered personal information under applicable laws. We use this information for product development and improvement, and other business activities.

7) To Whom We Disclose or Share Personal Information

Some personal information is public information (this may include your web3-enabled wallet’s public address, username, profile photo, profile first and last name, month, and year of account creation, and public transactions in which you have been involved) and may be seen by anyone on the Internet due to the nature of the blockchain and Internet, whether or not they have an account with us. Public information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party services that integrate with our App.

With respect to other personal information, we may disclose your personal information to:

Third-party service providers, including artificial intelligence tool providers and those that assist us in fraud detection, KYC/AML/CTF obligations, and prevention or otherwise assist in providing the App to you, such as DCMs, DCOs, FCMs, brokers, ISVs, surveillance providers, KYC/AML/CTF vendors, cloud and infrastructure providers, payment partners, banks, and other third-party service providers.
Our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control or related by common ownership or control that assist us with providing the App.
Successor(s) of our business, relating to all or part of the business, to evaluate a proposed transaction or sale, reorganization, merger, acquisition, or other change of control.
Other individuals who have referred you to our App.
Other third parties or nonaffiliates as permitted by law or contract, to provide the App, or to protect our or other’s rights, property, or safety.
Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity or other unfair trading practices, to investigate violations of the Terms, as otherwise required by law; the CFTC in accordance with regulatory requirements; or whenever we believe in good faith that disclosing such information is necessary or advisable.
If you authorize an account connection with a third-party account or platform, we may disclose your personal information to such third-party account or platform:

For the purposes of this Privacy Policy, an “account connection” with such a third party is a connection you authorize or enable between your account and a payment instrument, or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal information directly with such third-party. Examples of account connections include, without limitation: linking your account to a social media account or social messaging services; connecting your account to a third-party data aggregation or financial services company, if you provide such company with your account log-in credentials; or using your account to make payments to a merchant or allowing a merchant to charge your account.
If you connect your account to other financial accounts, directly or through a third-party services provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party’s services. For example, if you connect your account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Policy.
Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection.

We may also share or license your personal information with business partners and other third parties so that those third parties can offer you certain products, services, and promotions. Additionally, we may also use third-party advertising companies to serve ads when you visit the App, and those advertising companies may use information about your visits to the App and other websites that are contained in tracking technologies in order to provide advertisements about goods and services of interest to you. You may be entitled to prevent us from sharing and/or licensing your personal information to other companies under applicable law. If you wish to exercise this right, please send an e-mail to legal@polymarket.com.

We may disclose your personal information for additional purposes and/or to other third parties with your consent or at your direction. We may also disclose aggregated or de-identified data with third parties who may use that information for other purposes.

8) Data Retention

We will keep your personal information for as long as necessary for the purposes identified in this Privacy Policy or to fulfill the purpose(s) for which it was collected, or as permitted or required by applicable law or our legal obligations.

9) Security

We implement administrative, technical, and physical safeguards that are designed to help protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security, and no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we urge you to take adequate precautions to protect your personal information as well, including by not re-using or sharing your password. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.

10) Transfer of Data

Your personal information may be transferred to—and maintained on—servers located outside of your state, province, country or other governmental jurisdiction where data protection laws may differ from those of your jurisdiction. By using the App, you consent to the transfer of your information outside of your country of residence, which may have data protection rules that are different from those of your country. For example, we may store, process, use, and disclose personal information in the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities may be entitled to access your personal information.

11) Your Rights and Choices

Subject to certain exemptions under applicable law, you may have certain rights related to your personal information.

Right to access. You have the right to access, know about, or confirm the processing of your personal information, including the categories of, and sources of, personal information that we collect about you, the business or commercial purpose(s) for collecting, selling, or sharing your personal information, the categories of third parties to which your personal information is disclosed, and the specific pieces of personal information we have collected about you.
The right of correction or rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to certain processing of your personal information, such as processing for direct marketing purposes.
The right of restriction. You have the right to request that we restrict the processing of your sensitive personal information.
The right to data portability. You have the right to be provided with a copy of your personal information in a structured, machine-readable and commonly used format, to the extent technically feasible.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.
The right to erasure. If you wish to discontinue the use of the App, you have the right to request that we delete your personal information.
The right to opt-out of the “sale” or “sharing” of your personal information, or the use of your personal information for “targeted advertising” (as these terms are defined under applicable privacy laws). Please note that we may disclose your personal information to individuals who have referred you to the App, to our third-party business partners for their marketing purposes, and as otherwise described in this Privacy Policy. The information we may disclose may include your personal information and information about your use of the App. To opt out of the sale or sharing of your personal information, please contact us.

You will not be discriminated against for exercising any of these rights. To exercise your choices and rights, please contact us using the contact information provided in this Privacy Policy. We may request or require additional information to verify your identity to fulfill your request.

However, we may deny certain requests: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and property; or (d) where the request is frivolous or vexatious, or for other reasons permitted by law.

You may designate an authorized agent to make a request on your behalf. Authorized agents will be required to provide proof of their authority to act on your behalf by providing relevant documentation. We may contact you to confirm an authorized agent’s representation and to verify your identity.

12) Children Under the Age of 18

The App is not intended for individuals under the age of 18, and we do not knowingly collect, sell, share, or disclose the personal information of minors under the age of 18. If you are aware of an instance in which we have collected a minor’s personal information, please report it to legal@polymarket.com; we will delete the personal information where required, subject to regulatory retention obligations.

13) Third-Party Links and Services

The App may contain links to (or allow you to link to) unaffiliated third-party services, applications, or websites. We do not control information collection of any third-party services, applications, or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personal information. Any information you provide to any third party is not covered by this Privacy Policy and we cannot guarantee the safety and privacy of any information you provide to such third parties.

14) Personal Communication Preferences

If required by law, we will request your consent to send you marketing text messages and phone calls. You may manage your receipt of marketing and non-transactional communications from us by clicking on the “Unsubscribe” link located on the bottom of any marketing communication, replying STOP to a marketing text message, changing your settings on the App, or by sending us an email at support@polymarket.us with the subject line, “Unsubscribe from Marketing.” Registered users cannot opt out of receiving transactional or administrative emails related to their account. We will use commercially reasonable efforts to process such requests in a timely manner, in compliance with applicable laws.

15) Automated decision-making and profiling

We may use automated tools for fraud detection, sanctions/KYC/AML/CTF screening, surveillance, and risk controls. These automated tools may include artificial intelligence tools.

16) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about our information practices. You acknowledge that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the App following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

17) Contact us

For questions or concerns about our privacy practices, please contact:

PM US Tech
Attn: Privacy
169 Madison Ave, STE 16385

New York, NY 10016
Email: legal@polymarket.com

Phone Number: +1 201-293-6079

18) CFTC/DCM-specific disclosures

We and connected DCMs/FCMs/ISVs/market-surveillance providers collect and retain order, trade, and other audit-trail data to meet CFTC and exchange obligations. Certain personal information cannot be deleted until legal retention periods expire. We may monitor activity for abusive trading patterns and disclose data to regulators as required.

19) State-Specific Privacy Notice

U.S. state laws, including the California Consumer Privacy Act, require us to disclose the following additional information with respect to our privacy practices. If you are a California resident or a resident of a state that requires use to provide certain privacy-related disclosures, this section applies to you in addition to the rest of the privacy policy.

California Shine the Light Disclosure

We will provide information about the types of personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) that we may share with or disclose to third parties, other than our affiliates, for their direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light Law by contacting us. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.

Categories of Personal Information that We Collect and Disclose

You can find a list of the categories and examples of personal information that we collect in the “Personal Information Collection” section above. For details regarding the sources from which we obtain personal information, please see the “Sources of Information” section above. We collect and use personal information for the business or commercial purposes described in the “How We Use Your Personal Information” section above.

In the last 12 months, we have disclosed the following categories of personal information to various third-party recipients:

Category of Personal Information	Examples	Purpose of Use	Disclosure	Sold or Shared?
Identifiers	Name, email address, Social Security number, physical address, IP address, device identifiers	Site functionality, analytics, responding to requests, legal obligations (e.g., KYC/AML/CTF requirements and reporting unfair trading practices), marketing	Service providers Government entities and market integrity third-party entities Social media and marketing partners Affiliates and business partners	Yes
Internet or electronic network activity information	Browsing paths, clicks, session data on the App, automatically collected information about your use of the App	Site operation, analytics, App improvement, compliance with legal obligations, marketing	Service providers Government entities and market integrity third-party entities Social media and marketing partners Affiliates and business partners	Yes
Any personal information described in subdivision (e) of Section 1798.80	Name, Social Security number, government identification cards	KYC/AML/CTF requirements, compliance with legal obligations	Service providers (e.g., KYC/AML/CTF vendors, such as Socure) Government entities and market integrity third-party entities	No
Professional or employment-related information	Resume, employment history	To assess employment applications	Service providers	No
Protected demographic information	Age, sex, date of birth	KYC/AML/CTF Requirements, compliance with legal obligations	Service providers (e.g., KYC/AML/CTF vendors, such as Socure) Affiliates and business partners Service providers	No
Sensory information (e.g., audio, visual, olfactory information)	Not intentionally collected	N/A	N/A	No
Geolocation	IP-derived country/region	Fraud detection, localization, compliance with legal obligations	Service providers Government entities and market integrity third-party entities	No
Commercial Information	Services purchased, trades made	Responding to inquiries, requests and customer support, compliance with legal obligations, marketing	Service providers Government entities and market integrity third-party entities Social media and marketing partners Affiliates and business partners	Yes
Biometric Data	Not intentionally collected	N/A	N/A	No
Health Data	Not intentionally collected	N/A	N/A	No
Sensitive personal information	Social Security number	KYC/AML/CTF requirements, compliance with legal obligations	Service providers (e.g., KYC/AML/CTF vendors, such as Socure) Government entities and market integrity third-party entities	No
Inferences drawn from the categories described above	Not intentionally collected	N/A	N/A	No

Sensitive Personal Information

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Rights Available under California Law

For information about the rights that may be available to you under California law and how to exercise those rights, please see the “Your Rights and Choices” section above.

Appeals

Depending on applicable law, you may have the right to appeal our decision to deny your request or a request submitted by an authorized agent on your behalf. To submit an appeal, please contact us.

Notice of Financial Incentives

From time to time, we may offer financial incentives in connection with the collection or use of personal information. For example, we may provide financial incentives to you if you refer other individuals to the App using a unique website URL provided to you. To the extent that you provide this URL to other individuals, you agree and understand that you must have the consent of the individual to provide this referral, and you must provide the individual with a link to this privacy policy along with the URL. We may also provide credits for services on the App in exchange for you registering for an account on the App. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by contacting us. However, if you ask us to withdraw any financial incentive, we may be unable to return previously provided incentives at a later time.