Subtick Markets · 3-102-066254 S.R.L. · subtickmarkets.com/privacy
Privacy Policy
How Subtick Markets collects, uses, shares and protects personal data when you use its services, on subtickmarkets.com or through a partner, or visit subtickmarkets.com.
1.About this policy
This Privacy Policy explains how 3-102-066254 S.R.L., trading as Subtick Markets (“Subtick”, “we” or “us”), handles personal data when you use Subtick’s esports prediction markets and perpetual futures, on subtickmarkets.com or through a partner (the “Services”), and when you visit subtickmarkets.com.
If you access the Services through a partner, the partner is a separate company with its own privacy policy. That policy covers your partner account and the partner’s own services. This policy covers only what Subtick does.
Words such as “App”, “partner”, “balance”, “deposit”, “on-ramp provider”, “committed funds” and “trading requirement” have the meanings given in our Terms of Service.
2.Who is responsible for your data
3-102-066254 S.R.L., a sociedad de responsabilidad limitada incorporated in Costa Rica with cédula jurídica 3102066254 and its registered office at Edificio Latitud Norte, 3rd floor, Oficinas de Quatro Legal, 400 m north of Construplaza, Guachipelín, San Rafael, Escazú, San José, Costa Rica, is responsible for your personal data as its controller.
You can contact us about privacy at privacy@subtickmarkets.com.
A partner is a separate and independent controller of the data it holds about you. A partner shares data with us at your request and with your consent, and is responsible for its own collection of that data. We are responsible for how we use the data once we receive it.
3.Data we receive from partners
If you register in the App through a partner, and only after you give your consent when you register, the partner shares with us the account and identity verification data it already holds about you under its own privacy policy, and no more. This includes:
- your partner account ID, username and avatar;
- your country of residence;
- your full name, date of birth, nationality and residential address;
- the type, number, issuing country and expiry date of your identity document, copies of the document, and the results of liveness and selfie checks, where the partner holds them;
- the results of the partner’s verification, sanctions and politically exposed person checks; and
- your verification and eligibility status, including whether the partner has banned or restricted you.
While you use the Services through the partner, it also tells us about any later change to your verification or eligibility status. Where we request it for anti-money laundering purposes, the partner may share information it holds about the source of your funds and wealth.
We never receive your partner account password or your payment card or bank account details. If we need more information, we may ask you or the partner for it and will handle it under this policy.
4.Data we share with the partner
If you access the Services through a partner, we share with that partner:
- whether you have registered with Subtick, and the documents and consents you accepted;
- your trading activity, as needed to calculate fees under our agreement with the partner and to prevent fraud and market abuse;
- any restriction, suspension, closure or self-exclusion of your Subtick account; and
- information about suspected fraud, market abuse, money laundering or sanctions breaches, where the law allows.
5.Data we collect
We also collect the following data ourselves.
- Account data: if you register on subtickmarkets.com, your email address, username and the sign-in details you choose. We store passwords only in a form we cannot read.
- Identity verification data: when you verify your identity with us, the data you give us and our identity verification provider, such as your name, date of birth, nationality, address, identity document and its details, selfie and liveness check results, and the results of sanctions and politically exposed person screening.
- Registration records: the version of our legal documents you accepted, the date and time, the partner you came through, if any, your IP address, your browser’s user agent, your language setting, the confirmations you gave (that you are 18 or older, not a US person and not in a restricted jurisdiction), and your separate consents, including any consent to a partner sharing your data with us.
- Wallet and transaction data: your deposit addresses, the wallet addresses you deposit from and withdraw to, transaction hashes, assets, networks, amounts and conversion rates, and the results of blockchain analytics on those addresses and transactions.
- Trading data: your balance, orders, trades, positions, margin, liquidations, funding payments, settlements and fees, and your progress towards the trading requirement.
- On-ramp data: if you buy crypto assets through an on-ramp provider from the App, the status, amount and asset of your purchase and the deposit address it was sent to. We do not receive your card or bank account details.
- Device and technical data: your IP address, the approximate location derived from it, browser and device type, user agent and language, and logs of requests, errors and security events.
- Communications: messages you send us, complaints, and requests such as trading limits or self-exclusion.
- Compliance data: the results of sanctions screening, monitoring for fraud and market abuse, and any information obtained in anti-money laundering checks, including about the source of your funds and wealth.
When you visit subtickmarkets.com, our hosting provider processes technical data such as your IP address and user agent to deliver the website and protect it from abuse. We do not use analytics or advertising tracking on the website.
6.How we use your data
We use personal data to:
- provide the Services: create and sign you in to your account, show your account, execute orders, run positions, apply liquidations and funding, and settle markets;
- verify your identity, including from data a partner shares with your consent, so that you do not have to verify again where we can rely on it;
- process your deposits and withdrawals, keep your balance and apply the trading requirement;
- check your eligibility, including your age, location and, where relevant, your status with the partner;
- keep evidence of your acceptance of our legal documents and of your consents;
- prevent and detect fraud, money laundering, terrorist financing, sanctions breaches, market manipulation, insider trading and other misuse, including by screening deposits, withdrawals and wallet addresses, and protect the integrity of our markets;
- keep the Services secure, detect attacks and investigate incidents;
- answer your questions, handle complaints, and apply trading limits and self-exclusion;
- meet our legal obligations, including record keeping and requests from authorities;
- meet the requirements of any licensing or supervisory authority;
- monitor trading for signs of harm and apply responsible trading measures, including limits and self-exclusion;
- run, maintain and improve the Services, for example by monitoring performance and fixing errors;
- tell you about changes to the Services and to our legal documents; and
- establish, exercise or defend legal claims.
We do not sell your personal data, and we do not use it for advertising.
7.Legal bases
Where a data protection law such as the EU General Data Protection Regulation (GDPR) applies and requires a legal basis, we rely on the following.
- Contract: to provide the Services, process your deposits and withdrawals, keep your balance and keep evidence of our agreement.
- Legal obligation: for identity verification, anti-money laundering, sanctions, record keeping, tax, the conditions of any licence we hold and requests from authorities.
- Legitimate interests: to keep the Services secure, prevent fraud and market abuse, improve the Services, share the information described in section 4 with the partner you came through, and establish or defend legal claims. We weigh these interests against your rights.
- Consent: where we ask for it, including for a partner sharing your identity verification data with us and for international transfers where the law requires consent. You give this consent separately when you register. You can withdraw consent at any time by emailing privacy@subtickmarkets.com. This does not affect what we did before you withdrew it. If you withdraw it, we may ask you to verify your identity with us directly or, where we cannot continue without your consent, close your Subtick account under our Terms of Service, and we may keep the data we need to meet our legal obligations.
8.Automated decisions
Some decisions are made automatically by our systems, following set rules. For example, we refuse orders from accounts that are not eligible or are located in a restricted jurisdiction, we liquidate a position when its margin falls below the maintenance level, and we hold deposits and withdrawals for review when our screening flags them. These decisions are needed to perform our contract with you and to meet legal requirements.
Where the law gives you this right, you can contact us to ask about a decision, give your point of view and ask for a person to review it.
10.International transfers
We are based in Costa Rica. We receive data from partners and providers that may be located in other countries. Our partners, service providers and any authority that licenses us may process personal data in other countries, including the United States and countries in the European Union, whose data protection laws may differ from those where you live.
When we transfer personal data to another country, we take the steps that applicable law requires to protect it, such as contractual safeguards, including standard contractual clauses where they apply, and checks on the recipient’s security.
11.How long we keep data
We keep personal data only as long as we need it for the purposes in this policy.
- Registration, trading, deposit, withdrawal, wallet and compliance records are kept for at least 5 years after our relationship with you ends, or longer where the law requires it or we need them for a legal claim or investigation.
- Identity verification data, whether we collect it or receive it from a partner, is kept for the same period as trading records.
- Communications are kept for as long as we need them to deal with your request and any follow-up, and for the same period as trading records where they concern your account.
- Technical and security logs are kept for a limited period, unless we need them to investigate an incident.
When we no longer need personal data, we delete it or make it anonymous.
12.Security
We protect personal data with technical and organisational measures suited to the risk, including encryption in transit, access on a need-to-know basis, monitoring and logging.
No system is completely secure. Keep your sign-in details secure, and your partner account if you use it to sign in, and tell us straight away if you suspect misuse. If a security breach affects your personal data, we will notify you and the authorities where the law requires.
13.Your rights
Depending on where you live, you may have the right to:
- access your personal data and get a copy of it;
- correct data that is inaccurate or incomplete;
- have your data deleted;
- object to, or ask us to restrict, some processing, including processing based on legitimate interests;
- receive your data in a portable format;
- withdraw your consent;
- not be subject to decisions based solely on automated processing that significantly affect you, and ask for a person to review them; and
- complain to a data protection authority.
To use these rights, email privacy@subtickmarkets.com. We will confirm your identity, usually through your Subtick account, and reply within the time set by applicable law.
Some rights have limits. For example, we cannot delete records that the law requires us to keep until the retention period ends, and no one can delete or change transactions recorded on a public blockchain. Data held by a partner is covered by the partner’s privacy policy, so ask the partner for it.
14.Costa Rican data protection law
We process personal data in line with Costa Rica’s Law 8968 on the Protection of Persons in the Processing of their Personal Data (Ley de Protección de la Persona frente al Tratamiento de sus Datos Personales) and its regulations.
Under Law 8968 you have the right to access, correct and delete your personal data, and to withdraw your consent. You can use these rights by emailing privacy@subtickmarkets.com.
Where Law 8968 requires your informed and express consent to process your data, or to transfer it to third parties, including abroad, you give it separately when you register. If you withdraw it, we may no longer be able to provide the Services to you.
You can also complain to the Agencia de Protección de Datos de los Habitantes (PRODHAB), Costa Rica’s data protection authority.
15.Children
The Services are only for people aged 18 or over. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will close the account and delete the data, unless the law requires us to keep it. If you believe someone under 18 is using the Services, contact privacy@subtickmarkets.com.
17.Changes to this policy
We may update this policy. The version and date are shown at the top of this page. When we publish a new version, the App asks you to review it, as described in our Terms of Service.
18.Contact us
- Privacy requests
- privacy@subtickmarkets.com
- Legal matters
- legal@subtickmarkets.com
- Post
- 3-102-066254 S.R.L., Edificio Latitud Norte, 3rd floor, Oficinas de Quatro Legal, 400 m north of Construplaza, Guachipelín, San Rafael, Escazú, San José, Costa Rica