Likely Markets – Privacy Policy

When you use Likely Markets, you may provide us with the following information:

• Telegram user ID and Telegram username — collected automatically when you access the Mini App;
• Telegram display name — used to identify you within the Platform;
• TON wallet address — provided by you when making deposits or withdrawals;
• Market content — titles, descriptions, and resolution decisions for markets you create as a Creator;
• Dispute submissions — information you provide when filing or responding to a dispute;
• Communications — messages you send to our support or legal email addresses.

When you use the Platform, we automatically collect certain technical and usage data:

• Platform activity logs — records of your buy orders, sell orders, market participations, and withdrawals;
• Transaction records — amounts, timestamps, and outcomes of all financial activity on the Platform;
• Device and access data — general information about the device and connection used to access the Platform (e.g. operating system type, access timestamps);
• IP address — collected for security, fraud prevention, and operational purposes;
• In-app behaviour — how you navigate and interact with the Platform, used for product improvement.

Likely Markets does not collect:

• Your real name, physical address, or government-issued identification (we do not perform KYC at this stage);
• Payment card details or bank account information;
• Biometric data of any kind;
• The content of your private Telegram messages;
• Data from your device beyond what is described in Section 3.2.

Because Likely Markets operates as a Telegram Mini App, your primary identity on the Platform is your Telegram account. We do not require you to create a separate account with a username and password.

We use your data to:

• Process your deposits, buy orders, sell orders, and withdrawals;
• Calculate and credit your earnings and platform Credits;
• Identify you within the Platform and attribute activity to your account;
• Resolve disputes and enforce the Creator bond and strike system;
• Process Creator applications and maintain Creator records.

• Detect and prevent fraudulent activity, market manipulation, and abuse of the Platform;
• Identify and investigate violations of the Terms of Service;
• Protect the integrity of the dispute resolution system;
• Monitor for unusual transaction patterns that may indicate account compromise.

• Analyse usage patterns to improve the Platform's features and user experience;
• Identify technical issues and bugs;
• Develop new features based on how Users interact with existing functionality.

• Comply with applicable laws and regulations;
• Respond to lawful requests from public authorities;
• Maintain records as required by applicable law;
• Enforce our Terms of Service, Creator Agreement, and other policies.

Under the GDPR, we process your personal data on the following legal bases:

• Contract performance — processing necessary to provide the Platform services you have requested;
• Legitimate interests — fraud prevention, security, and Platform improvement, where these interests are not overridden by your rights;
• Legal obligation — where processing is required by applicable law;
• Consent — where you have explicitly consented to specific processing activities.

Likely Markets does not sell, rent, or trade your personal data to any third party for commercial purposes. Full stop.

Certain information is visible to other Platform users by design:

• Your Telegram username — displayed as the Creator or participant in markets you are involved in;
• Your Creator markets, resolution decisions, and strike history — visible to maintain Platform transparency;
• Publicly visible market activity — buy and sell orders may be visible to other market participants.

We may share limited data with trusted third-party service providers who assist us in operating the Platform, subject to strict confidentiality obligations. This includes:

• Cloud infrastructure and hosting providers;
• Blockchain infrastructure providers for TON network interactions;
• Analytics tools for Platform usage analysis (anonymised data only).

We may disclose your data to law enforcement or regulatory authorities if:

• We are required to do so by applicable law or a binding court order;
• We believe disclosure is necessary to prevent fraud, illegal activity, or harm;
• Disclosure is necessary to protect the rights, property, or safety of Likely Markets, our users, or the public.

In the event of a merger, acquisition, or sale of all or part of Likely Markets, your data may be transferred to the successor entity. We will notify you of any such transfer and your options regarding your data.

You have the right to request a copy of the personal data we hold about you. We will respond to access requests within 30 days.

You have the right to request correction of inaccurate or incomplete personal data we hold about you.

You have the right to request that we restrict the processing of your data in certain circumstances, such as while a dispute about its accuracy is resolved.

You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to the following limitations:

• We may retain data where required by law or for legitimate legal defence purposes;
• Transaction and market records may be retained for audit and dispute resolution purposes;
• Blockchain data cannot be deleted (see Section 7).

You have the right to receive your personal data in a structured, machine-readable format and to transmit it to another service.

You have the right to object to the processing of your data where we rely on legitimate interests as our legal basis.

Where we process data based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact us at legal@likely.markets. We will respond within 30 days. We may request verification of your identity before processing your request.

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.