POLYMARKET APP — TERMS & CONDITIONS (ISV FRONT END)

Effective Date: September 25, 2025

Provider: PM US Tech (a/k/a QC Tech Limited Liability Company) (“Company,” “we,” “us,” or “our”)

App: The Polymarket App, including related websites, portals, and APIs (the “App”).

1) What these Terms cover; our role

These Terms & Conditions (“Terms”) govern your access to and use of the App, an independent software vendor (ISV) front end that enables order entry/routing, market-data display, and account operations to connect you to Polymarket US (a/k/a QCX Limited Liability Company), a CFTC-registered designated contract market (“DCM”), and Polymarket Clearing (a/k/a QC Clearing Limited Liability Company), a CFTC-registered derivatives clearing organization (“DCO”). The App is not itself a DCM, DCO, FCM, broker, adviser, custodian, or investment service, and it does not list, clear, or settle contracts. Your use of the App is also subject to our Privacy Policy, which is incorporated herein by reference.

These Terms, along with our Privacy Policy, constitute a legally binding agreement between you and the Company that conditions your use of the App. By using or accessing the App, you signify your acceptance of these Terms and the terms of our Privacy Policy. If you do not agree to these Terms or the terms of our Privacy Policy, you should not access or use the App.

2) Relationship to DCM/DCO/FCM; controlling documents

Your trading privileges, market access, contract terms, clearing, and surveillance obligations are governed by the DCM Rulebook, DCO Rulebook, and any member/customer agreements (including with a futures commission merchant (“FCM”) or clearing member) that apply to you. You acknowledge that these documents have been made available to you, and you are fully aware of the content therein.  Those documents are incorporated by reference and control to the extent they conflict with these Terms on exchange/clearing matters.

3) Eligibility & account paths

You must be at least 18 years old (or the higher age required in your jurisdiction) and legally permitted to access the DCM. Access may require KYC/AML and sanctions screening and ongoing eligibility reviews. You may connect directly (if eligible) or via an FCM/clearing member; venue rules apply.  The Company does not represent that the App is appropriate or available for use in any specific location. Access to the App from locations where its contents are illegal is prohibited.  By using the App, you are confirming that you satisfy the foregoing conditions.

4) License to use the App

We grant you a limited, revocable, non-exclusive, non-transferable license to use the App solely to access the DCM/DCO (directly or via an FCM) for your own trading and account administration. You may not copy, modify, reverse engineer, or create derivative works of the App except to the extent a restriction is prohibited by law.  These Terms will survive any termination or expiration of your access to the App.

5) Market data & content

Market data, reference data, analytics, and documentation presented in the App are licensed to you for personal, non-commercial use in connection with your trading and remain the property of the venue/licensors. Redistribution, resale, scraping, bulk downloads, and commercialization of derived works are prohibited unless expressly licensed. Venue notices and contract terms shown in the App are informational; the official DCM Rulebook/contract terms control.

6) Front-end audit trail, user IDs & surveillance

To support exchange obligations for electronic trading, the App may: (i) assign/manage user IDs; (ii) capture front-end audit-trail events (timestamps, order messages, device/OS/browser and IP metadata); (iii) implement risk/surveillance controls (including self-match prevention and other venue-required controls); and (iv) share relevant logs with the DCM/DCO/FCM and regulators as required. Misusing IDs, evading controls, or disabling telemetry is prohibited.

7) Acceptable use

You agree not to: (a) access or use the App in violation of these Terms, venue rules or any applicable law, statute, court order, regulation or ordinance; (b) interfere with or bypass security/surveillance features; (c) use bots or automation except through authorized APIs; (d) engage in market manipulation or abusive trading (e.g., spoofing, layering, wash trades, disallowed self-trades); (e) infringe intellectual property or violate export/sanctions laws; (f) provide false information or take any action that attempts to impersonate, deceive, or defraud any person or entity; (g) abuse, defame, harass, libel, disparage or threaten another user of the App or any other third party; (h) harvest, otherwise collect, store, post or share personal information about users or any other third parties, or otherwise attempt to gain unauthorized access to any network, system, or personal information of anyone; and (i) introduce or attempt to introduce software viruses, Trojan horses, worms, backdoors or any other malicious files or computer codes, or take any action that imposes or may impose an unreasonable or disproportionately large load on our technical infrastructure.

8) Fees & taxes

We may charge App access or feature fees; we will disclose fees before you incur them. Venue and FCM fees (e.g., execution, clearing, regulatory pass-through) may also apply under their terms. You are responsible for taxes on your activity.

9) Mobile and internet usage

By using the App from your mobile phone, you understand that your wireless or internet services provider’s standard SMS, MMS and/or data rates will apply to your use of the App.  By using the App, you agree to be responsible for any fees that are incurred as a result of your use of the App.  You hereby represent and warrant that you are the owner or authorized user of any mobile or other wireless device that you use to access the App, and that you are authorized to approve all associated SMS, MMS and data charges.

10) Third-party services & integrations

The App may integrate third-party services (e.g., identity verification, cloud hosting, security logging, optional SSO/OAuth, mapping/location, analytics). Those providers may process data under their policies.

11) Privacy

Your use of the App is subject to our Privacy Policy (incorporated herein by reference), which describes data categories (including KYC/AML, device/usage, and—where permitted—location), purposes (including recordkeeping and market surveillance), sharing (including with DCM/DCO/FCM and regulators), and rights/choices.

12) Security

Certain sections of the App may prompt you for login information for access, which may include a user name or other registration identifier, and a password (“Login Credentials”).  You are responsible for maintaining the confidentiality of your Login Credentials, and you are responsible for all uses of your Login Credentials, and any and all related charges incurred, if any, whether or not authorized by you.

13) No advice; risks

By accessing the App, you acknowledge and agree that the information made available to you through the App is for general, informational purposes only. The Company makes no representations that any information provided via the App is accurate, current, or complete, and you are solely responsible for evaluating the risks and merits regarding the use of the App and any information or services provided herein. Nothing on the App is intended to be, and you should not consider anything on the App to be, investment, legal, tax, or accounting advice. Educational content, FAQs, or analytics are informational only. Event-contract trading involves risk of loss; review venue rules and contract specifications before trading.

14) Past Performance

Past performance is not indicative of future results and no representation or warranty is made that any transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that losses will be avoided. In addition, through various portions of the App, you may access historical documents or information that was published in the past. Please be advised that these documents and information may reflect information that, with the passage of time, has since changed. The Company does not undertake any obligation to update any such document or information.

15) Forward-Looking Statements

The contents of the App may contain forward-looking statements. These statements are based on certain beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, and other factors. You can identify these forward-looking statements by the use of words such as “outlook,” “indicator,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “anticipate,” “optimistic,” “intend,” “plan,” “estimate,” “aim,” “will” or the negative version of these words or similar expressions. These statements are not guarantees of future performance and involve certain risks, uncertainties and assumptions that are difficult to predict with regard to timing, extent, likelihood and degree of occurrence. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward-looking statements. Furthermore, the Company undertakes no obligation to update, amend or clarify forward-looking statements, whether as a result of new information, future events or otherwise.

16) Sources of Information

Certain information contained on the App was obtained from published and nonpublished sources. Such information may not have been, and in many cases, has not been, independently verified by the Company. The Company does not assume responsibility for the accuracy of such information (or for updating the App based on facts learned following its publication).  References on the App to any names, marks, products or services of third parties who may or may not be affiliated with the Company, or hypertext links to third party sites or information or content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply the Company’s endorsement, sponsorship, referral or recommendation of the third party, its information, materials or services. The Company does not control and is not responsible for any third-party content on the App or on other third-party sites that may be linked to the App. Such third-party content or sites should not be presumed to reflect the view of the Company. The Company is not responsible for the ramifications of your use of such third-party content or sites, or for any third party’s policies or practices regarding security, privacy, use or other matters.

17) Availability; changes; upgrades

Features may vary by jurisdiction, access path (direct vs. FCM), or user status. We may modify, suspend, or discontinue features at any time. We do not guarantee uninterrupted or error-free operation.

We may from time to time in our sole discretion develop and provide updates to the App, which may include upgrades, bug fixes, patches, other error corrections, and/or new features (collectively, including related documentation, “Updates”).  You shall promptly download and install all Updates and acknowledge and agree that the App or portions thereof may not properly operate should you fail to do so.

18) Termination & remedies

Notwithstanding any of these Terms, we reserve the right, without notice and in our sole discretion, to suspend or terminate your license to use the App, and to block or prevent future your access to and use of the App, including for suspected violations of these Terms, the DCM or DCO Rulebook, law, or risk/surveillance alerts. Termination of App access does not necessarily terminate your venue account; venue rules govern trading privileges. The Company reserves the right to seek all remedies available at law and in equity for any such violations.  The failure of the Company to act with respect to any such violation by you or others does not constitute a waiver and will not limit the Company’s rights with respect to such violation or any subsequent violations.

You further acknowledge that a violation or attempted violation of any of these Terms will cause irreparable damage to the Company, the exact amount of which would be difficult to ascertain and for which there will be no adequate remedy at law. Accordingly, you agree that the Company will be entitled as a matter of right to an injunction issued by any court of competent jurisdiction, restraining such violation or attempted violation of these Terms by you, or your affiliates, partners, or agents, as well as recover from you any and all costs and expenses sustained or incurred by the Company in obtaining such an injunction, including, without limitation, reasonable attorney’s fees. You agree that no bond or other security will be required in connection with such injunction.

19) Intellectual property; feedback

We and our licensors retain all rights in the App and content (excluding your data). All content included on the App, such as text, images, graphics, logos, articles and other materials, is the property of the Company or others, as applicable, and is protected by United States and international copyright and other laws. All trademarks and logos displayed on the App are the property of their respective owners, who may or may not be affiliated with the Company. Nothing contained on the App should be construed as granting, by implication, estoppel or otherwise, any license or right to use any content or trademark displayed on the App without the express written permission of the Company or such other third party that may own the content or trademark displayed on the App. Nothing in these Terms shall constitute a waiver of any trademark or other intellectual property rights concerning name, logo or trademark. You may download or copy content on the App only to the extent such download is expressly permitted in writing on the App. No right, title or interest in any downloaded materials or software is transferred to you as a result of any such downloading or copying. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the App, any content thereof, or any related software. You must retain all copyright and trademark notices, including any other proprietary notices, contained in the materials, and you must not alter, obscure or obliterate any of such notices. The use of such materials on any other website or in any environment of networked computers is prohibited.

All feedback regarding our services that you provide by email or any other medium to us (“Feedback”), will, to the maximum extent permissible under applicable laws, automatically become our sole property, and you hereby assign to us, exclusively and throughout the world, all rights, title, and interests in such Feedback, all intellectual property rights embodied therein, and otherwise, you hereby grant us a perpetual, irrevocable, worldwide, fully-paid up, royalty free, assignable, sublicensable license to use, reproduce, display, create derivative works of, make, sell, have made, have sold, import, export or otherwise exploit any such Feedback.  You are not entitled to any acknowledgment, compensation or reimbursement in connection with such Feedback or grant of rights to same.  By providing such Feedback, you acknowledge and agree that: (a) your Feedback does not contain confidential or proprietary information; (b) we are not under any obligation of confidentiality, express or implied, with respect to the Feedback; (c) we will be entitled to use or disclose (or choose not to use or disclose) any Feedback for any purpose, in any way, in any media worldwide; and (d) we may have something similar to the Feedback already under consideration or in development.

20) Disclaimers

THE APP AND ALL CONTENT ON THE APP IS PROVIDED TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTY OF ANY KIND EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, AND NON-INFRINGEMENT.  THE COMPANY MAKES NO WARRANTY AS TO THE ACCURACY, COMPLETENESS, CURRENCY, OR RELIABILITY OF ANY CONTENT AVAILABLE THROUGH THE APP.  YOU ARE RESPONSIBLE FOR VERIFYING ANY INFORMATION BEFORE RELYING ON IT.  USE OF THE APP AND THE CONTENT AVAILABLE ON THE APP IS AT YOUR SOLE RISK.  THE COMPANY MAKES NO REPRESENTATIONS OR WARRANTIES THAT USE OF THE APP WILL BE UNINTERRUPTED, SECURE OR ERROR-FREE.  YOU ARE RESPONSIBLE FOR TAKING ALL NECESSARY PRECAUTIONS TO ENSURE THAT ANY CONTENT YOU MAY OBTAIN FROM THE APP IS FREE OF VIRUSES.

21) Limitation of liability; release

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE (ON BEHALF OF OURSELVES AND OUR AFFILIATES, LICENSORS, OR OUR OR THEIR RESPECTIVE DIRECTORS, MEMBERS, EMPLOYEES OR AGENTS) WILL NOT BE LIABLE FOR AND SPECIFICALLY DISCLAIM INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, LOST PROFITS, LOSS OF DATA, OR TRADING LOSSES.

YOU HEREBY AGREE TO RELEASE AND FOREVER DISCHARGE THE APP, THE COMPANY, AND OUR AFFILIATES, LICENSORS, DIRECTORS, SHAREHOLDERS, OFFICERS, EMPLOYEES, REPRESENTATIVES, AGENTS, AND SUPPLIERS, AND THEIR RESPECTIVE SUCCESSORS AND ASSIGNS, AND ALL OTHER RELATED PERSONS OR ENTITIES, FROM ANY AND ALL MANNER OF RIGHTS, CLAIMS, COMPLAINTS, SUITS, DEMANDS, CAUSES OF ACTION, PROCEEDINGS, LIABILITIES, OBLIGATIONS, LEGAL FEES, COSTS, AND DISBURSEMENTS OF ANY NATURE WHATSOEVER, WHETHER KNOWN OR UNKNOWN, WHICH NOW OR HEREAFTER ARISE FROM, RELATE TO, OR ARE CONNECTED WITH YOUR USE OF OR INABILITY TO USE THE APP OR ANY CONTENTS HEREUNDER.

IF YOU ARE A CALIFORNIA RESIDENT, YOU WAIVE CALIFORNIA CIVIL CODE SECTION 1542, WHICH STATES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH, IF KNOWN BY HIM MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR” (OR ANY EQUIVALENT STATUTORY PROVISION WITH A SIMILAR IMPORT OR INTENT).  IF YOU ARE A RESIDENT OF A STATE OTHER THAN CALIFORNIA, YOU EXPLICITLY WAIVE THE TERMS AND PROTECTIONS OF ANY STATUTE OF YOUR OWN STATE THAT HAS A SIMILAR IMPORT OR INTENT.

22) Indemnification

 You agree to indemnify, defend and hold us, our affiliates, and our and their respective independent contractors, service providers, consultants, directors, officers, employees and agents, and applicable third parties (such as licensors, partners and advertisers) (collectively, the “Indemnified Parties”) harmless from and against any actual or threatened suit, demand or claims, damages, costs, liabilities and expenses (including, but not limited to, damage awards, settlement amounts, and reasonable attorneys’ fees) brought against any Indemnified Parties, arising out of or relating to: (a) your use of the App, the contents therein or any other information (including Feedback as defined above) available through the App; (b) your conduct; (c) your failure to perform your obligations under these Terms (including, but not limited to, your violation of these Terms); and/or (d) your violation of the rights of any third party.

23) Dispute resolution

Any dispute arising from or relating to these Terms or the App (any “Dispute”) will be resolved by confidential, binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules (as modified by these Terms) before a single arbitrator seated in New York County, New York.

You and the Company agree that any Dispute is personal to us, and that any such Dispute shall only be resolved by an individual arbitration and shall not be brought as a class arbitration, a class action, or any other representative proceeding.  Neither you nor the Company agrees to class arbitration, or an arbitration where a person brings a dispute as a representative of any other person or persons. Neither you nor the Company agrees that a dispute can be brought as a class representative action whether inside or outside of arbitration, or on behalf of any other person or persons.

As limited by the Federal Arbitration Act and the provisions of these Terms, the arbitrator will have the exclusive power and jurisdiction to (a) make all procedural and substantive decisions concerning the Dispute, including the power to determine the question of arbitrability; and (b) grant all rights and remedies that would have been available to you or the Company in a court of law, including the power to permit discovery as would have been available in a court of law; provided, however, that the arbitrator shall not have the power to conduct a class arbitration or representative action, which is prohibited by these Terms as stated above.

In making any award, the arbitrator will be subject to the provisions of these Terms, including the “Limitation of liability; release” provision above, and will not have jurisdiction to make an award to any party to the arbitration contrary to that provision; provided, however, that if the enforceability of any of these restrictions is limited by the applicable substantive law, that restriction will only be enforced to the extent permitted by such law or rules.

The cost of the arbitration proceeding shall be borne by the unsuccessful party, as determined by the arbitrator.

24) Governing law; venue; jury waiver

These Terms are governed by New York law (without regard to its conflict of laws provisions). Subject to Section 17, you consent and submit to the exclusive jurisdiction of the state and federal courts located in New York County, New York for any permitted court action, and you and the Company each waive jury trial to the fullest extent permitted by law.  25) Export & sanctions

You may not use the App if you are subject to U.S. sanctions or located in a restricted or embargoed jurisdiction. You must comply with export control and sanctions laws (e.g., EAR, OFAC).

26) Changes to these Terms

We may modify the App and the rules and regulations governing its use, at any time.  Modifications may be posted through the App, and any such changes or modifications will be effective immediately upon posting of the revisions through the App.  By continuing use of the App after such changes are made you will be accepting such changes.  If you do not agree to any changes or modifications to these Terms, your sole recourse is to stop using the App.

27) Miscellaneous

These Terms (together with the Privacy Policy and any legal notices or other terms or conditions published through the App) form the entire agreement between you and us regarding the App. If any provision is found to be void or unenforceable, then the remainder will remain in full force and effect, and the invalid provision will be partially enforced to the maximum extent permitted by law to effectuate the purpose of these Terms. You may not assign any of your rights or obligations under these Terms without our consent. We reserve the right to assign or transfer our rights and obligations under these Terms. We are not liable for delays/failures due to events beyond our reasonable control. We may deliver notices electronically via the App or email.

28) Communications

When you use the App or send emails to us, you communicate with us electronically and consent to receive communications from us electronically.  We may communicate with you by: (a) email to your email address indicated in your communications with us, (b) posting general notices on the App, or (c) posting messages that are displayed to you when you log in to or access the App.  You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

29) Contact

All notices to us of a legal nature shall be in writing and shall be sent by both email and certified first-class U.S. mail, return receipt requested, to:

PM US Tech (QC Tech LLC)
Attn: Legal
7251 W Palmetto Park Rd, Suite 102
Boca Raton, FL 33433
legal@polymarket.com

29) User Submissions

Certain areas of the App enable you to access online forums and to submit emails, or otherwise provide feedback to the Company.  We provide the App solely as a service provider, as such term is defined by various laws, including the Digital Millennium Copyright Act of 1998 (“DMCA”) and Section 230 of the Communications Decency Act (“CDA”).  As such, although we prohibit certain activities in these Terms, we do not control and take no responsibility or liability for any content posted, stored, allowed access to or uploaded by you or any third party, including a list of connections (“User Content”), or for any loss or damage thereto, nor are we liable for any mistakes, defamation, slander, libel, omissions, falsehoods, obscenity or profanity you may encounter by use of the App.  Your use of the App is at your own risk.  As a provider of interactive services, we are not liable for any statements, representations or content provided by our users in any gallery, forum, personal home page or other interactive area.  We have no obligation to screen, edit or monitor any User Content posted on the App.  We also do not endorse, support, represent, approve, sponsor, or guarantee the completeness, truthfulness, accuracy, or reliability of any User Content or Feedback (as defined below).  In addition, the Company reserves the right, but not the obligation, to monitor, delete, move or edit content, in whole or in part, submitted to the forums that it, in its sole discretion, deems abusive, defamatory, obscene, in violation of intellectual property, privacy, or other proprietary rights, in violation of these terms and conditions, or for any other reason.

29) License to Company

By submitting User Content, you hereby grant to the Company an irrevocable, sublicensable, perpetual, royalty-free, worldwide license to use, copy, translate, modify, publish, perform, transmit and display User Content via any media in accordance with our Privacy Policy, and waive any moral rights you may have in such content.  Subject to our Privacy Policy, the Company shall be free to use such content, including any ideas, concepts, know-how, or techniques contained in User Content. This is a license only – your ownership in your User Content is not affected.