Privacy Policy

Last updated: May 9, 2026

This Privacy Policy explains how Predictable Reality, Inc. (“Predictable Reality”, “we”, “us”, or “our”) handles information in connection with (i) the website located at oddmaki.com and any associated subdomains (the “Site”) and (ii) the OddMaki protocol web application (the “App”, and together with the Site, the “Services”).

This Privacy Policy is incorporated into and forms part of our Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

We have designed the Services to collect as little information about you as practical. This Policy describes what little we do.

1. Scope — What This Policy Covers, and What It Does Not

1.1 What this Policy covers. This Policy describes how Predictable Reality processes personal information that we collect through the Site and the App.

1.2 What this Policy does not cover.

• The Protocol. “OddMaki” or the “Protocol” refers to a set of smart contracts deployed to public blockchain networks. Once deployed, those contracts execute autonomously. Data written to a public blockchain — including wallet addresses, transactions, and smart-contract state — is public, immutable, and outside our control. We do not “process” on-chain data in the sense contemplated by data-protection laws; we are not a controller or processor of that data. We cannot delete, rectify, or restrict access to information recorded on a blockchain.
• Venues. Independent third parties operate prediction-market platforms (“Venues”) on top of the Protocol. We are not a Venue operator. This Policy does not cover any Venue. Each Venue is responsible for its own privacy practices.
• Third-party services. This Policy does not cover the privacy practices of third-party services that you may interact with in connection with the Services, including wallet providers, RPC providers, oracles, indexers, blockchain explorers, or any website or service that links to or from the Services. Their practices are governed by their own policies.

2. Information We Collect

The Services do not require an account, and we do not collect names, email addresses, phone numbers, or other contact information through any form on the Services. The categories of information we do collect are limited to the following.

2.1 Information collected automatically by our hosting and analytics infrastructure

The Services are hosted on Vercel. When you access the Services, our hosting and analytics infrastructure automatically receives technical information that is standard for any modern website:

• Server logs generated by Vercel — including IP address, user agent, request URL, referrer, response status, and timestamp — used for operational, security, and abuse-prevention purposes.
• Vercel Web Analytics, which we use to understand aggregate usage of the Services. Vercel Web Analytics is designed to be privacy-respecting: it does not set cookies and does not track users across websites. It generates a pseudonymous visitor identifier by hashing your IP address and user agent with a daily-rotating salt, and that identifier resets every 24 hours. We use the resulting aggregate metrics — page views, referrers, countries, device categories — to understand how the Services are used. We do not receive your raw IP address through Vercel Analytics.

We do not run any advertising, retargeting, social-media tracking, or session-replay tools. We do not use Google Analytics, Meta Pixel, or similar third-party trackers.

2.2 Wallet connection and on-chain interaction

The App allows you to connect a self-custodial wallet using RainbowKit, a third-party wallet-connection library, which uses the WalletConnect protocol (operated by Reown, formerly WalletConnect Inc.) to support mobile and cross-device connections. When you connect a wallet:

• The App receives your public wallet address and the network identifier of the chain you are connected to. This information is processed in your browser to display on-chain state relevant to your address.
• A small amount of data is stored in your browser’s local storage so that the App can remember your wallet-connection preference between visits. This storage is strictly necessary to deliver the wallet-connection feature you requested. It is not a cookie, is local to your device, and can be cleared at any time through your browser settings.
• For mobile and cross-device connections, the WalletConnect protocol routes session-establishment messages through a relay operated by Reown. As part of that routing, Reown’s relay infrastructure necessarily receives your IP address, user-agent, connection metadata, and the Project ID associated with the App. The contents of messages exchanged between your wallet and the App over the relay are end-to-end encrypted; Reown is the relay operator, not a counterparty to your transactions. Reown’s processing of this information is governed by its own privacy notice, available at https://reown.com/privacy-policy (and historically at https://walletconnect.com/privacy).
• Through the Reown Dashboard, we receive aggregate analytics about connection activity associated with our Project ID — including counts of sessions, wallet types used, chains connected to, and similar usage metrics. We use these metrics to understand and improve the App.
• We do not receive, store, or transmit your private keys or seed phrase.
• Transactions you sign are sent to public blockchain networks through one or more RPC providers. Those RPC providers, your wallet provider, and the blockchain itself may receive your IP address, wallet address, and transaction payload independently of us. We do not control their practices, and we encourage you to review their privacy policies.
• A public wallet address, when combined with on-chain activity, may be considered personal information in some jurisdictions (including under GDPR). Even where it is, the underlying on-chain data is public and outside our control.

2.3 If you contact us

We do not solicit personal information through the Services, but if you choose to contact us by email or another channel, we receive whatever information you choose to send. We use that information only to respond to your inquiry and to maintain a reasonable record of the correspondence.

2.4 Sensitive information

We do not collect government-issued identifiers, financial-account information, biometric data, precise geolocation, or other categories of sensitive personal information. The Services are not a Know-Your-Customer (“KYC”) interface.

3. How We Use Information

We use the limited information described above to:

1. operate, maintain, and secure the Services;
2. understand aggregate usage of the Services through privacy-respecting analytics;
3. detect, prevent, and respond to abuse, fraud, and security incidents;
4. respond to inquiries you send us;
5. comply with legal and regulatory obligations and respond to lawful requests; and
6. establish, exercise, or defend legal claims.

We do not sell personal information, and we do not use personal information for advertising or cross-context behavioral tracking. See Section 8 for California-specific disclosures.

4. Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases under Article 6 of the GDPR (and equivalent UK / Swiss provisions):

• Legitimate interests (Art. 6(1)(f)) — for operating, securing, and understanding aggregate usage of the Services, and for protecting our rights. We balance these interests against your rights and freedoms; given the limited nature of the data we process, we believe that balance is appropriate.
• Performance of a contract (Art. 6(1)(b)) — to provide the Services you have requested under our Terms of Service.
• Legal obligation (Art. 6(1)(c)) — to comply with applicable law and respond to lawful requests.

5. Cookies and Similar Technologies

The Services do not use cookies.

• Vercel Web Analytics is cookieless.
• RainbowKit stores a small amount of wallet-connection state in your browser’s local storage. This storage is strictly necessary to deliver the wallet-connection functionality you have requested.

Because we do not set cookies and the only browser storage we rely on is strictly necessary for functionality you have requested, we do not display a cookie consent banner. If we ever introduce non-essential cookies or similar technologies, we will update this Policy and provide an appropriate consent mechanism in advance.

You can clear your browser’s local storage and any other site data at any time through your browser settings.

6. How We Share Information

We share personal information only as described below.

• Vercel. Our hosting and analytics provider. Information necessary for delivering and securing the Services flows through Vercel’s infrastructure under its terms and privacy practices.
• Reown (WalletConnect). When you connect a wallet using the WalletConnect protocol — required for most mobile and cross-device connections — session-establishment data is routed through Reown’s relay infrastructure as described in Section 2.2.
• Wallet and RPC infrastructure. When you connect a wallet or submit a transaction through the App, information about your interaction is necessarily transmitted to the wallet provider you choose, the RPC provider(s) used to broadcast transactions, and ultimately the public blockchain network. These third parties act independently and have their own privacy practices.
• Legal and protective disclosures. We may disclose information when we believe in good faith that disclosure is required or permitted by law, including in response to subpoenas, court orders, or other legal process; to protect the rights, property, or safety of Predictable Reality, our users, or others; or to investigate or prevent suspected fraud, abuse, or violations of our Terms of Service.
• Corporate transactions. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to standard confidentiality protections.

We do not sell personal information to third parties, and we do not share personal information with third parties for advertising purposes.

7. International Data Transfers

Predictable Reality is incorporated in the United States, and our service providers (including our hosting provider and the operator of the WalletConnect relay) operate infrastructure in the United States and other countries whose data-protection laws may differ from those of your country.

Where required by law, transfers of personal information from the EEA, UK, or Switzerland to a country not recognized as providing an adequate level of protection are made under appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable). You may request information about the relevant safeguards by contacting us.

8. Your Rights

8.1 EEA, UK, and Switzerland

Subject to applicable law, you have the right to:

• access the personal information we hold about you;
• rectify inaccurate or incomplete information;
• erase personal information in certain circumstances;
• restrict or object to our processing of your information;
• portability — receive your information in a structured, commonly used format;
• withdraw consent at any time, where processing is based on consent; and
• lodge a complaint with your supervisory authority.

To exercise any of these rights, contact us at the address in Section 12.

Note that on-chain data is, by the nature of public blockchains, not within our control: we cannot rectify, erase, or restrict information recorded on a blockchain.

8.2 California (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended (“CCPA”), provides you with specific rights regarding your personal information.

• Right to know. You may request information about the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for which we collected it, and the categories of third parties with whom we shared it.
• Right to delete. You may request that we delete personal information we have collected from you, subject to exceptions.
• Right to correct. You may request that we correct inaccurate personal information.
• Right to opt out of sale or sharing. We do not “sell” personal information and we do not “share” personal information for cross-context behavioral advertising as those terms are defined under the CCPA.
• Right to limit use of sensitive personal information. We do not collect or use sensitive personal information in ways that would trigger this right.
• Right to non-discrimination for exercising your rights.

The categories of personal information we collect are described in Section 2; the purposes are described in Section 3; the categories of recipients are described in Section 6. We retain personal information for the periods described in Section 9.

To exercise your CCPA rights, contact us at the address in Section 12. We will verify your request consistent with CCPA requirements. You may designate an authorized agent to make a request on your behalf, subject to verification.

8.3 Other jurisdictions

Residents of other U.S. states (including Virginia, Colorado, Connecticut, Utah, and others that have enacted comprehensive privacy laws) and of other countries may have similar rights under applicable law. You may exercise those rights by contacting us at the address in Section 12.

9. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Retention periods depend on the type of information:

• Server logs are retained for the period set by our hosting provider’s defaults and our own operational and security needs, and then deleted or aggregated.
• Vercel Web Analytics data is retained according to Vercel’s analytics retention practices and is, by design, pseudonymous and reset on a rolling daily basis.
• Email correspondence, if you choose to contact us, is retained for as long as reasonably necessary to address the matter and for a reasonable period thereafter.

We cannot delete on-chain data.

10. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. No system is perfectly secure, however, and we cannot guarantee the security of any information you provide. You are responsible for the security of your wallet, devices, and credentials.

11. Children

The Services are not directed to children under 18, and we do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

12. Changes to This Policy and Contact

We may update this Privacy Policy from time to time. The updated Policy will be effective when posted, and the “Last updated” date above will reflect the change. If we make material changes, we will provide additional notice as required by applicable law (for example, by posting a notice on the Site). Your continued use of the Services after the updated Policy takes effect constitutes acceptance of the updated Policy.

For privacy-related questions or to exercise your rights, contact us at:

Predictable Reality, Inc.
131 Continental Dr, Suite 305
Newark, DE 19713, U.S.A.
Email: privacy@oddmaki.com