Privacy Policy
This Privacy Policy explains how ConvictionMarkets, Inc. (“ConvictionMarkets,” “we,” “us,” “our”), a Delaware corporation, collects, uses, shares, and protects personal information when you use the Takes mobile app (the “App”). This Policy also covers our websites at trytakes.app and try-takes.com (together, the “Site”). We are committed to transparency and to complying with applicable U.S. privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Delaware Personal Data Privacy Act, the Children’s Online Privacy Protection Act (COPPA), and the Federal Trade Commission Act. We do not sell or share your personal information, and we never will. We collect and retain the information described in this Policy to operate the App and improve your experience, and we do not track you across other companies’ apps or websites. Your use of the App is also governed by our Terms of Service, and this Policy should be read alongside them.
1. Who We Are and How to Contact Us
ConvictionMarkets, Inc. is responsible for the personal information processed through the App.
Mailing address: 855 Flathead Creek Road East, Wilsall, MT 59086
Privacy enquiries, data requests, safety and all other questions: support@conviction-markets.com
We respond to general privacy enquiries within 30 days. For verifiable consumer rights requests under state privacy laws, we respond within 45 days, which we may extend by a further 45 days where reasonably necessary, with notice to you.
2. Personal Information We Collect
We collect the following categories of personal information. The retention period for each category is described in Section 9.
Identity and profile data: your Takes account identifier, name, username, and profile photo if you add one; your mobile phone number if you sign up or sign in with it; and, if you sign in with Apple or Google, the account identifier and any email address that provider gives us.
Content and activity data: the takes you post, the picks you make, the results of those takes, your record and streaks, and the screens and features you use.
Social graph data: your friends, friend requests, and invites you send or accept.
Contact matching data: if you use Find Friends and allow access to your contacts, the App turns each phone number in your contacts into a one-way hashed code on your device and sends only those codes to us, to find friends who already use Takes. We do not upload or store your contacts’ names or numbers.
Device and diagnostics data: your device type and operating system, App version, a push notification token if you allow notifications, and crash and error reports (including the screen and the steps leading up to an error), linked to your account identifier so we can find and fix problems.
Source and test data: the invite, link, or community that brought you to the App, and which version of a product test you are part of.
Moderation data: reports submitted or received, block relationships, and moderation actions taken and their outcomes (see Section 7).
We do not collect: precise GPS location, financial or payment data, health data, biometric identifiers, or government-issued identification numbers.
3. How We Collect Personal Information
Directly from you: when you register, set up your profile, post takes, make picks, add friends, send invites, or contact us for support.
Automatically: when you use the App, we collect activity and usage events (for example, screens viewed and picks made) via the Mixpanel SDK, and crash and error reports via Sentry.
From third parties: if you sign in with Apple or Google, we receive the information described in Section 2; if you arrive through an invite, we receive the invite used and the account that sent it.
4. How and Why We Use Your Information
We use your personal information only for the following purposes:
To create and authenticate your account and provide core App functionality (takes, picks, results, records, and friends);
To check and settle takes, including using automated systems as described in Section 5;
To understand how the App is used, including by comparing versions of our products in product tests (you can opt out of analytics at any time; see Section 5);
To comply with our legal obligations, including responding to data-rights requests;
To keep the App safe, prevent fraud and abuse, and operate our content-moderation system; and
To send you service-related messages, such as sign-in codes, notifications you have allowed, and security and support messages. We do not currently send marketing or promotional communications; if we introduce them, we will do so only on an opt-in basis, and you will be able to unsubscribe at any time.
We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you. Automated settlement affects only results and records inside the App.
5. AI, Analytics, and Product Measurement
AI settlement. The text of a take is sent to artificial-intelligence service providers, who process it for us to check that the take can be settled, to suggest rewording, and to decide its outcome from public sources. Please do not include private information about yourself or anyone else in a take.
We use Mixpanel, Inc. (USA) as our analytics provider. Mixpanel acts as our service provider under a data-processing agreement that prohibits it from using your data for its own purposes. We use analytics to understand how the App is used. We do not use it to advertise to you.
Mixpanel receives:
Your account identifier, so activity can be understood as belonging to one person over time.
Your activity in the App, such as screens you view, takes you post, picks you make, results, invites, and friends you add. The text of your takes is not included.
Source and test data, such as the invite, link, or community that brought you to the App, and the version of a product test you are part of.
Technical and approximate location data: your App version, device type, and the approximate city or region Mixpanel derives from your IP address.
Crash and error reports. We use Sentry (Functional Software, Inc., USA) to receive crash and error reports from the App, including your account identifier, App version, device type and the steps leading up to an error. Sentry processes this data only to help us fix problems, under a data-processing agreement.
Our websites. On the Site, Mixpanel collects the pages you view, the page or link that sent you to the Site, and the buttons you click, along with your browser and device type and the approximate city or region Mixpanel derives from your IP address. Mixpanel keeps a random identifier in your browser’s storage so repeat visits can be counted. We do not ask for your name or contact details on the Site, we do not record your session there, and we do not use this data for advertising. If your browser sends a Do Not Track or Global Privacy Control signal, the Site does not load Mixpanel at all. Sentry receives error reports from the Site, including the page, your browser and device type, and the steps leading up to the error, only to help us fix problems. Our hosting provider processes standard server logs, including IP addresses, to deliver and secure the Site. If you follow a link on the Site that sends visitors to different apps as part of a product test, a small cookie may remember which app you were sent to.
We never send your phone number to Mixpanel or Sentry. Mixpanel processes data on servers in the United States. For more information, see Mixpanel’s privacy policy at mixpanel.com/legal/privacy-policy.
You can opt out of Mixpanel analytics at any time by contacting support@conviction-markets.com. Opting out will not affect your ability to use the App.
6. How We Share Information: We Do Not Sell or Share Your Data
We do not sell your personal information, and we do not share it for cross-context behavioral advertising or any other purpose, for money or any other valuable consideration. We do not disclose your personal information to data brokers. Your name, username, photo, takes, picks, and record may be visible to other users of the App. Beyond that, we share personal information only with the limited service providers listed below, who process data on our instructions, and only as required to operate the App or comply with law:
Analytics provider (Mixpanel): the data described in Section 5.
AI service providers: the text of takes, as described in Section 5.
Cloud and hosting providers: our backend database and infrastructure providers host the App’s data and process it only on our instructions.
Messaging providers: Twilio sends sign-up and sign-in codes to your phone number.
Error monitoring (Sentry): the crash and error reports described in Section 5.
Push notifications: Expo and Apple’s Push Notification service deliver notifications to your device using your push token.
Apple (App Store): Apple receives the limited data required for app distribution; see Apple’s privacy policy.
Legal and safety: we may disclose information if required by law, subpoena, or court order, or where necessary to protect the rights, property, or safety of our users, the public, or ConvictionMarkets.
Business transfers: if we merge with or are acquired by another company, your information may be transferred as part of that transaction; we will notify you beforehand and give you the opportunity to delete your account, and any successor will remain bound by this Policy or provide equivalent protection.
We may create and use truly de-identified or aggregated statistics that cannot reasonably be used to identify you. We will maintain such information in de-identified form, will not attempt to re-identify it, and do not sell it.
7. User-Safety Data
The App provides Report and Block features to help keep the platform safe. When you use these features, we process the following personal information.
7.1 Report Submissions
When you submit a report about another user’s take or profile, we record the identity of the reporting user, the reported content or profile, the reason selected, the date and time, and the outcome of our review. An automated notification is sent to our moderation team at support@conviction-markets.com upon submission. We do not disclose the identity of the reporting user to the reported user.
7.2 Block Relationships
When you block another user, we store the block relationship so the blocked user cannot access your profile, view your takes, or interact with you within the App. This data is retained for as long as the block is active and for a reasonable period afterward to maintain safety records.
7.3 Moderation Records
We retain moderation records, including reports filed, content removed, warnings issued, suspensions, and ban history, for up to 24 months for safety, appeals, legal-compliance, and audit purposes. We may share moderation data with law enforcement where required by law or where necessary to prevent or respond to imminent harm.
8. Apple App Tracking Transparency
We do not track you across apps or websites owned by other companies. We do not use Apple’s Identifier for Advertisers (IDFA) for cross-app tracking, and we do not share your data with data brokers. As a result, we do not present an App Tracking Transparency (ATT) prompt for tracking purposes. If this ever changes, we will update this Policy and implement the ATT permission prompt before any tracking begins. In App Store Connect, we disclose the data collected by the App and by our service providers in our App Privacy details. We review those disclosures whenever this Policy is updated so that they remain consistent with it.
9. Data Retention
We keep personal information only for as long as necessary for the purposes described in this Policy, and then delete or de-identify it. Retention by category:
Account, profile, and content data: retained while your account is active. You can delete your account at any time at Settings → Delete Account within the App. Upon deletion, your account and associated personal information are permanently removed within 30 days. If you need assistance, contact support@conviction-markets.com.
Analytics data: event data held by Mixpanel is retained for up to 24 months and then deleted.
Moderation records: retained for up to 24 months after the relevant moderation action, as described in Section 7.3.
Backups: encrypted backups are retained for up to 90 days after deletion from live systems, then overwritten.
Legal holds: we may retain information longer where required by law or for ongoing legal proceedings.
10. Security and Breach Notification
We implement appropriate technical and organizational measures to protect your personal information, including encryption of data in transit (TLS) and at rest, access controls limiting who can view personal information, and regular review of our data inventory and security practices. Access to directly identifying information is limited to a small number of authorized personnel who need it to operate the App. No system is completely secure. If we become aware of a data breach affecting your personal information, we will notify affected users and the appropriate authorities as required by applicable state breach-notification laws, without unreasonable delay. If you become aware of a security issue, please contact support@conviction-markets.com immediately.
11. Children’s Privacy
The App is not directed to children under 13, and we do not knowingly collect personal information from anyone under 13. We will delete any account we discover belongs to a child under 13. If you believe we have inadvertently collected information from a child under 13, contact us immediately at support@conviction-markets.com and we will delete it.
Users aged 13 to 17 may use the App only with the consent and supervision of a parent or legal guardian. We do not sell or share the personal information of any user, and we never sell or share the personal information of minors for any purpose. We encourage parents and guardians to contact us with any concerns at support@conviction-markets.com.
12. Your Privacy Rights
Depending on where you live, you may have some or all of the following rights regarding your personal information. We honor these rights for all users, regardless of state of residence:
The right to know or access the categories and specific pieces of personal information we have collected about you;
The right to delete your personal information;
The right to correct inaccurate personal information;
The right to obtain a portable copy of your personal information;
The right to opt out of the sale or sharing of your personal information and of targeted advertising: note that we do not sell or share your personal information and do not process sensitive personal information beyond what is necessary to provide the App; and
The right not to receive discriminatory treatment for exercising any of these rights.
To submit a request, email support@conviction-markets.com with the subject line “Privacy Request.” We will verify your request using information associated with your account and respond within the timelines in Section 1. You may use an authorized agent to submit a request on your behalf, subject to verification.
12.1 California Residents (CCPA/CPRA)
California residents have the rights described above, including the right to know, delete, correct, opt out of sale or sharing, limit the use of sensitive personal information, and not be discriminated against. We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we do not use or disclose sensitive personal information for purposes that would trigger the right to limit. Under California’s “Shine the Light” law, we do not disclose personal information to third parties for their own direct-marketing purposes. To exercise your rights, email support@conviction-markets.com with the subject line “California Privacy Request.”
12.2 Delaware Residents (DPDPA)
We comply with the Delaware Personal Data Privacy Act. Delaware residents have the right to access, correct, delete, and obtain a portable copy of their personal data, and to opt out of targeted advertising and the sale of personal data (we do not sell personal data). You also have the right to appeal a decision on your request; to appeal, reply to our response or email support@conviction-markets.com with the subject line “Privacy Appeal.”
12.3 Residents of Other States
If you live in another state with a comprehensive privacy law, you have substantially the same rights described in this Section 12, and you may exercise them using the same contact method.
13. Third-Party Services and Links
The App may reference or display information from third-party services (for example, sports results and public news sources). These services have their own privacy policies, and we are not responsible for their practices.
14. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of changes via in-app notice, and the “Last updated” date above reflects the most recent revision. For material changes, such as changes to how we collect, use, or share your personal information, we will request your affirmative acceptance via an in-app prompt before the changes take effect. You may request prior versions of this Policy by contacting support@conviction-markets.com.
15. Contact Us
For any privacy questions, data requests, or complaints:
ConvictionMarkets, Inc.
Mailing address: 855 Flathead Creek Road East, Wilsall, MT 59086
Email: support@conviction-markets.com
This Privacy Policy is accessible within the App at Settings, and at a public URL on our website so that it can be reviewed before downloading the App.