Privacy Policy

1. INTRODUCTION

This Privacy Policy explains how Plucasa Innovation Hub Ltd (“Plucasa,” “we,” “our,” or “us”) collects, uses, processes, stores, discloses, and protects personal data when users access or use the Plucasa platform (the “Platform”). By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. Plucasa acts as the data controller for personal data processed through the Platform unless otherwise stated.

2. SCOPE OF POLICY

This Policy applies to:

• Account registration and management
• Use of Predictions and escrow transactions
• Disputes and moderation processes
• Communications with support
• Security and fraud prevention activities

This Policy does not apply to third-party services or external websites not controlled by Plucasa.

3. INFORMATION WE COLLECT

We collect information in the following categories: 3.1 Information You Provide Directly

• Username
• Email address
• Encrypted password credentials
• Profile information you voluntarily submit
• Communications with support or administrators
• Dispute submissions and evidence

3.2 Transactional and Blockchain Metadata

• Cryptocurrency transaction identifiers
• Escrow creation and settlement records
• Wallet addresses used in connection with the Platform
• On-chain transaction hashes and timestamps

Plucasa does not collect or store private keys, seed phrases, or custodial wallet credentials. 3.3 Automatically Collected Information

• IP address
• Device type
• Browser type
• Operating system
• Session data
• Interaction logs
• Error reports
• Usage metrics

3.4 Security and Compliance Data

• Fraud detection signals
• Account activity logs
• Login timestamps
• IP consistency monitoring

3.5 User-Generated Content

• Predictions
• Comments
• Reviews
• Dispute notes and supporting materials

4. PURPOSES OF PROCESSING

We process personal data for the following purposes:

• Operating and maintaining the Platform
• Facilitating escrow transactions and settlement logic
• Enforcing platform rules and resolving disputes
• Detecting fraud and preventing abuse
• Complying with legal obligations
• Communicating with Users
• Improving platform performance and security
• Establishing, exercising, or defending legal claims, including

arbitration proceedings We do not use personal data for advertising resale purposes.

5. LEGAL BASIS FOR PROCESSING

We process personal data based on:

• Performance of a contract (providing the Platform)
• Legitimate interests (fraud prevention, security, dispute resolution,

and platform integrity)

• User consent (where required)
• Compliance with legal obligations
• Establishment, exercise, or defense of legal claims

6. DATA SHARING AND DISCLOSURE

We may share personal data with:

• Cloud hosting providers
• Infrastructure and security providers
• Blockchain analytics services
• Legal advisors and compliance consultants
• Law enforcement or regulatory authorities where required

We do not sell personal data to advertisers. We may disclose personal data where necessary to:

• Comply with legal processes
• Enforce our Terms
• Protect the safety of Users
• Prevent fraud or unlawful conduct

7. INTERNATIONAL DATA TRANSFERS

Data may be processed in multiple jurisdictions. By using the Platform, you acknowledge that your information may be transferred to and processed in jurisdictions that may not have the same data protection laws as your country of residence. Plucasa implements reasonable safeguards to protect such transfers.

8. DATA RETENTION

We retain personal data only as long as reasonably necessary for:

• Operational purposes
• Dispute resolution
• Fraud prevention
• Legal compliance
• Audit requirements
• Regulatory obligations
• Establishment, exercise, or defense of legal claims

Transactional records, dispute evidence, administrative determinations, and audit logs may be retained beyond account deletion where necessary for compliance, arbitration, legal defense, or fraud prevention. Blockchain transaction data is permanently recorded on public distributed ledgers and cannot be deleted, altered, or modified by Plucasa.

9. ACCOUNT DELETION AND DATA REQUESTS

Depending on jurisdiction, Users may request:

• Access to their data
• Correction of inaccurate data
• Deletion of personal data
• Restriction of processing
• Data export

Requests may be submitted to legal@plucasa.com or support@plucasa.com. Plucasa may deny or limit deletion requests where data retention is necessary for:

• Legal compliance
• Fraud prevention
• Dispute resolution
• Arbitration proceedings
• Regulatory defense
• Protection of Platform integrity

Deletion of an account does not remove or alter historical transaction data recorded on public blockchain networks.

10. DATA SECURITY

We implement technical and organizational safeguards including:

• Encryption in transit
• Access controls
• Secure hosting infrastructure
• Role-based administrative access
• Monitoring for suspicious or abusive activity

However, no system is completely secure. Users acknowledge that internet transmission and blockchain systems involve inherent risks. Plucasa cannot guarantee absolute security.

11. REGULATORY AND LAW ENFORCEMENT COOPERATION

Plucasa may preserve and disclose data where required by law, regulation, court order, arbitration proceedings, or valid legal process. We may also disclose data where reasonably necessary to:

• Protect the rights, property, or safety of Plucasa or its Users
• Enforce our Terms
• Prevent fraud, abuse, or unlawful conduct
• Comply with regulatory inquiries

Plucasa may retain data beyond standard retention periods where necessary for legal defense or compliance obligations.

12. CHILDREN’S PRIVACY

The Platform is intended only for individuals aged 18 or older. We do not knowingly collect data from minors. If we become aware of data collected from a minor, we may delete it.

13. COOKIES AND TRACKING

We use cookies and similar technologies to:

• Maintain sessions
• Enhance security
• Improve usability
• Support fraud prevention and system integrity

Disabling cookies may impair functionality. For detailed cookie information, please refer to the Cookie Policy.

14. THIRD-PARTY LINKS

The Platform may contain links to third-party websites. We are not responsible for the privacy practices of external sites.

15. AUTOMATED DECISION-MAKING

Plucasa does not use fully automated decision-making systems that produce legal or similarly significant effects without human review. Administrative determinations involve human oversight.

16. DATA BREACH RESPONSE

In the event of a material data security incident affecting personal data, Plucasa may take appropriate remedial measures and provide notice where required by applicable law.

17. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Material changes may be communicated via Platform notice or email. Continued use of the Platform constitutes acceptance of updates.

18. CONTACT

For privacy-related inquiries: legal@plucasa.com support@plucasa.com End of Privacy Policy