Kickr Legal

C3 Labs Ltd

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Data and privacy

Privacy Policy

Last updated: July 17, 2026

This Privacy Policy explains how C3 Labs Ltd, a British Virgin Islands company (“C3 Labs”, “Kickr”, “we”, “us”, or “our”), collects, uses, discloses, and protects personal data when you use the Kickr mobile application, kickr.fun, or related services (collectively, the “Services”). C3 Labs is the controller of personal data it determines how and why to process.

1. Personal Data We Collect

Information you provide

  • account and authentication data, such as your email address, social-login identifier, and information returned by your chosen sign-in provider;
  • public wallet addresses and an app-linked wallet identifier;
  • profile details or notification preferences you choose to add; and
  • support requests, legal requests, feedback, and other communications you send us.

Activity and technical data

  • markets viewed, orders initiated, positions, transaction status, and interactions with features;
  • public blockchain information, including wallet activity and transaction identifiers;
  • network and log data reasonably generated when you use the Services, such as IP address, timestamps, app version, error and security logs, device or browser type, and approximate location inferred from an IP address; and
  • push-notification tokens or device registrations if you enable notifications.

Information from other sources

We may receive information from Privy and other authentication or wallet providers, Polymarket and other market infrastructure, public blockchain networks, service providers, and publicly available sources. Those providers process information under their own policies.

2. Why We Use Personal Data

We use personal data to:

  • create and maintain your account and app-linked wallet;
  • provide market discovery, transaction routing, position tracking, notifications, and customer support;
  • authenticate users, protect accounts, detect abuse, troubleshoot errors, and secure the Services;
  • understand performance and improve the reliability and usability of the Services;
  • enforce our Terms, comply with sanctions and other legal obligations, and respond to lawful requests; and
  • communicate service, security, legal, and, where permitted, product updates.

Depending on the context, we process personal data with your consent, as necessary to provide the Services or take steps at your request, to comply with legal obligations, or on another basis permitted by applicable law. Where processing depends on consent, you may withdraw it at any time, without affecting earlier processing.

3. Wallets and Public Blockchains

C3 Labs does not store or control your private key. Privy or another wallet provider may process information to provide wallet creation, authentication, recovery, or export features.

Public blockchain records are visible to anyone, may reveal activity associated with a wallet address, and generally cannot be changed or deleted by C3 Labs. Do not include personal or sensitive information in a public transaction memo or other on-chain field.

4. How We Disclose Personal Data

We do not sell personal data. We may disclose personal data to the following classes of recipients for the purposes described above:

  • authentication and wallet providers, including Privy, when you use their features;
  • market, order-routing, blockchain, and infrastructure providers, including Polymarket, when needed to display or carry out an interaction you request;
  • hosting, database, security, communications, notification, support, and analytics providers acting for us;
  • professional advisers, auditors, insurers, and corporate service providers under appropriate duties of confidentiality;
  • courts, regulators, law-enforcement bodies, or other parties when required by law or reasonably necessary to protect rights, safety, and the integrity of the Services; and
  • a buyer, investor, or successor in connection with a financing, reorganisation, merger, sale, or transfer, subject to appropriate safeguards.

A third party acting as an independent controller handles personal data under its own privacy policy. A provider processing personal data for C3 Labs is permitted to use it only for the contracted service and subject to applicable safeguards.

5. International Transfers

C3 Labs and its providers may process personal data in the British Virgin Islands, the United Arab Emirates, and other countries where we or our providers operate. Those countries may have different data protection laws. Where required, we use contractual, organisational, or other safeguards, or obtain consent, before transferring personal data outside the British Virgin Islands.

6. Data Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including to provide the Services, protect security, resolve disputes, and meet legal, accounting, and recordkeeping obligations. Retention periods vary by data type and context. When data is no longer required, we delete or anonymise it, subject to limited backup cycles and legal holds.

We cannot delete public blockchain records. Third-party providers may also retain information under their own policies and legal obligations.

7. Your Rights and Choices

Depending on applicable law, you may ask us to:

  • confirm whether we process your personal data and provide access;
  • correct inaccurate, incomplete, or misleading personal data;
  • delete personal data that is no longer required, subject to legal and operational exceptions;
  • stop direct marketing or withdraw consent for consent-based processing; and
  • exercise any additional objection, restriction, portability, or complaint right available in your jurisdiction.

Submit a request to gm@kickr.fun or follow our account-deletion instructions. We may request information reasonably necessary to verify your identity and locate the relevant data. We will tell you within 30 days whether access will be provided where the BVI Data Protection Act, 2021 requires that timeframe, subject to lawful extensions.

If applicable, you may complain to the British Virgin Islands Information Commissioner or the data protection authority where you live. We encourage you to contact us first so we can address the issue.

8. Security

We use reasonable technical and organisational measures designed to protect personal data against loss, misuse, unauthorised access, alteration, and disclosure. No system is completely secure, and we cannot guarantee absolute security. You are responsible for securing your device, account credentials, recovery methods, and exported private keys.

9. Cookies, Local Storage, and Analytics

The Services and their providers may use cookies, local storage, SDKs, or similar technologies that are necessary for sign-in, security, preferences, performance, and basic measurement. We do not use personal data for third-party targeted advertising. If we introduce non-essential tracking that requires consent, we will provide an appropriate choice and update this Policy.

10. Children’s Privacy

The Services are not intended for anyone under 18 or under the age of legal majority where they live. We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us so we can investigate and take appropriate action.

11. Third-Party Services and Links

The Services link to or interact with independent services. Their privacy practices are not controlled by C3 Labs. Review the relevant provider’s privacy policy before using its service, including the Privy Privacy Policy and Polymarket Privacy Policy.

12. Changes to This Policy

We may update this Policy to reflect changes in the Services, our practices, or law. We will post the revised Policy and update the date above. If a change materially affects your rights, we may provide additional notice or request consent where required.

13. Contact

C3 Labs Ltd

Privacy requests: gm@kickr.fun