Privacy Policy

1. About Kelvon

Kelvon, Inc. (“Kelvon,” “we,” “us,” or “our”) is a Delaware corporation that operates the AI-powered prediction market research and analytics platform available at kelvon.com and through our associated services (collectively, the “Service”).

This Privacy Policy (“Policy”) describes: what personal information we collect from you when you visit our website, create an account, or use the Service; why we collect it; how we use, store, and share it; the lawful basis on which we process it; how long we retain it; and the rights you have regarding your personal information.

By accessing or using the Service, or by submitting your personal information to us, you acknowledge that you have read this Policy and agree to the collection, use, and disclosure of your personal information as described herein. If you do not agree to this Policy, please do not access or use the Service.

2. Personal Information We Collect

We collect personal information in the following ways:

2.1. Account Information.

If you create an account, you will provide us with certain information required to register and access the Service. Depending on how you register, this includes:

• Email registration: your email address and a password you create;
• Google Sign-In: your name, email address, and profile image, as provided to us by Google at your direction when you choose to authenticate using your Google account; and
• Subscription and billing status, including your current plan tier.

You are not required to provide information beyond what is necessary to create and maintain your account.

2.2. Platform Behavior Data.

When you use the Service, we automatically collect information about how you interact with the platform. This may include:

• Markets, market categories, and topics you search for, browse, or view within the Service;
• Markets you add to or remove from your watchlists;
• Trading history, watchlists, active positions, risk profile, AI query patterns;
• Queries, prompts, and questions you submit to our AI research assistant;
• Features, tools, and content you access and how frequently you use them;
• Risk profile preferences and settings as you configure them within the Service; and
• Other behavioral interactions with Service features and content.

This platform behavior data is used to personalize your experience, including personalized market recommendations, AI research tailored to your interests, and adaptive analytics aligned to your trading activity and profile, and to power the AI features described in this Policy. Important limitation: other than publicly available information from on-chain prediction markets (such as Polymarket) that Kelvon connects with and analyzes, Kelvon does not collect, access, or receive information about actual trades, order history, account balances, or positions held on third-party prediction market platforms, unless you explicitly connect an external account through a future feature that expressly enables such a connection, in which case separate and specific notice will be provided at that time.

2.3. Contact Data.

We process personal information you voluntarily provide, including email address, when you contact us for support, submit product feedback, or otherwise correspond with us by email or through the Service.

2.4. Log Files.

Like most web services, we automatically collect information recorded in server log files when you access the Service. This includes internet protocol (IP) addresses, browser type, internet service provider, referring and exit pages, platform type, and date and time stamps. We use log data to administer the Service, analyze traffic patterns, troubleshoot issues, and ensure compliance with our Terms of Service. IP addresses may be considered personal information in certain jurisdictions and are treated in accordance with this Policy.

2.5. Device Information.

We collect information about the device and software you use to access the Service, including device type, operating system and version, browser type and version, and unique device identifiers. We use this information to optimize the Service for your device, detect abuse, and maintain security.

2.6. Analytics.

We use proprietary analytics tools to collect information about how the Service is accessed and used. This information is collected in pseudonymous form and may include feature usage patterns, interaction events, session duration, and error rates. We use analytics data to analyze and improve the performance and functionality of the Service. We do not use third-party advertising analytics providers.

2.7. Third-Party Sign-In Data.

If you choose to register or sign in using Google Sign-In, Google will provide us with certain information from your Google account, specifically your name and email address, to create and authenticate your Kelvon account. We do not receive additional Google account data, and we do not share your information back with Google beyond what is inherent in the standard OAuth authentication flow. Your use of Google Sign-In is subject to Google’s Privacy Policy, available at policies.google.com/privacy. We neither control nor take any responsibility for how Google collects, stores, or processes your personal information.

2.8. Payment Information.

Payment transactions for paid subscriptions are processed by Link, a payment service provided by Stripe, Inc. (“Link”). When you subscribe to a paid plan, Link collects and processes your payment card information directly such as your method of payment and payment card information (including payment card number, delivery address, and billing address). Kelvon does not store or have access to your raw payment card information at any time.

2.9. Cookies and Tracking Technologies.

We use cookies and similar technologies to operate the Service. The types of cookies we use include (which list is not exhaustive):

• Strictly Necessary Cookies: required for the Service to function, including session management, authentication tokens, and security features. These cannot be disabled.
• Analytics Cookies: help us understand how users interact with the Service, including features accessed, session behavior, and error rates.
• Preference Cookies: remember your settings, customization choices, and display preferences across sessions.

We do not use advertising cookies or third-party tracking technologies for advertising or remarketing purposes. You may control non-essential cookies through your browser settings; however, disabling certain cookies may affect Service functionality.

Our websites are not designed to respond to “do not track” signals from browsers.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1. Account Operations. We use your account information, including your email address, authentication credentials, and subscription status, to: authenticate and secure your account and prevent unauthorized access; acknowledge, confirm, and manage your account; send you a welcome email upon registration to verify your email address; notify you of subscription and billing matters, including payment failures; and respond to account-related requests.

3.2. Personalization. We use your platform behavior data, including markets you view, watchlists you maintain, queries you submit, and preferences you configure to personalize your experience. This includes tailoring AI research outputs, surfacing relevant markets, and adapting the Service to your trading profile and usage patterns. See Section 4 for details specific to AI assistant interactions.

3.3. AI Research Features and Analytics. We process the queries and prompts you submit to our AI assistant to generate research responses, market analysis, probability estimates, and other outputs in real time. We retain your conversation history to enable continuity across your sessions. See Section 4 for our AI training and data usage commitments.

3.4. Marketing. Where permitted by applicable law or with your consent, we may send you marketing communications about Kelvon products, features, and updates that are similar to those you use or subscribe to. You may opt out of marketing emails at any time by clicking the unsubscribe link in any such email or by adjusting your notification preferences in account settings.

3.5. Service Announcements. We may send you service-related announcements when necessary, for instance, to notify you of significant Service changes, security issues, planned downtime, or material updates to our policies. These operational communications are not subject to opt-out, as they are necessary to maintain your access to the Service.

3.6. Customer Support. We use your contact information, account data, device information, server logs, and any other details you provide to diagnose and resolve support requests and improve Service reliability.

3.7. Security and Fraud Prevention. We process personal information as necessary to detect, investigate, and prevent fraudulent transactions, unauthorized access, abuse of the Service, and other harmful or illegal activities.

3.8. Legitimate Interests. We may process your personal information as necessary for the following legitimate business interests: administering and improving the Service; conducting internal research, analytics, and testing; complying with legal obligations and responding to lawful requests; enforcing our Terms of Service and other agreements; and protecting the rights, property, and safety of Kelvon, our users, and the public. When we process your personal information based on legitimate interests, we consider and balance any potential impact on your rights under applicable data protection law. Our legitimate interests do not override your interests where the impact on you would be disproportionate.

4. AI Assistant and Conversation Data

When you interact with our AI research assistant, your queries are processed by our AI systems in real time to generate responses and provide the research functionality you have requested. This section describes how conversation data is specifically handled.

4.1. Conversation Retention. We retain the content of your conversations with the AI research assistant for a limited period that varies by your subscription tier. After that period, the conversation can no longer be recovered. Following an additional period after a conversation expires or you delete it, we sever the link between the conversation and your account, and the resulting de-identified content may be retained as described in Section 6. De-identification removes structured identifiers but does not scrub information you elect to include in the free-text of your conversations.

4.2. AI Model Improvement. We may use de-identified or anonymized and aggregated platform behavior data and usage patterns, such as aggregate feature adoption rates, error rates, and anonymized query topic distributions, to train, evaluate, and improve our AI systems. We do not use the identifiable content of your individual conversations or queries to train our AI models. We do not share identifiable conversation content with any third party for AI training purposes. Any use of data to improve our AI systems is limited to data that has been de-identified and aggregated such that it cannot reasonably be used to identify you as an individual.

5. When We Share Your Information

We share your personal information in the following circumstances. We do not sell your personal information.

5.1. Service Providers. We may transfer personal information to service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders, and that provide website and application functionality, hosting, infrastructure, analytics, customer support, advertising and marketing services, support tooling and security services.

5.2. Payment Processing. Payment transactions for paid subscriptions are processed by Link, a payment service provided by Stripe, Inc. (“Link”). When you subscribe to a paid plan, Link collects and processes your payment card information directly. Kelvon does not store or have access to your raw payment card information at any time. Link’s handling of your payment data is governed by the Stripe Privacy Policy, available at stripe.com/privacy. If there are any issues processing your subscription payment, we will contact you using the email address associated with your account.

5.3. Google Sign-In. If you authenticate using Google Sign-In, Google provides us with your name and email address for the purpose of creating and authenticating your account. We do not receive additional data from your Google account beyond what is necessary for authentication, and we do not share your Kelvon data with Google for its own independent use beyond what is inherent in the authentication flow. Your use of Google Sign-In is governed by the Google Privacy Policy.

5.4. Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy or insolvency proceeding, your personal information may be transferred to a successor entity or acquirer as part of the transaction. We will notify you of any such transfer and of any changes to this Policy that result from it.

5.5. Legal and Administrative Reasons. We may disclose your personal information when we believe in good faith that disclosure is necessary to: (i) comply with applicable law, regulation, legal process, or enforceable governmental request; (ii) enforce our Terms of Service or other applicable agreements; (iii) detect, prevent, or address fraud, security issues, or technical problems; or (iv) protect the rights, property, or safety of Kelvon, our users, or the public. This may include exchanging information with law enforcement authorities, courts, or government agencies as required or permitted by law.

6. User Account and Deletion

You may request deletion of your Kelvon account at any time by visiting your account settings. Upon receiving a deletion request, we will process the deletion of your personal information in accordance with applicable laws as follows:

• Account information (email, credentials, profile data);
• AI conversation history; and
• Platform behavior data associated with your account.

During the deletion period you may cancel your deletion request and restore your account. After the deletion period expires, deletion is final.

Certain data may be retained in accordance with and where required by applicable law or necessary for legitimate business purposes. Transaction records, financial records, and related compliance data may be retained in accordance with applicable laws for tax, accounting, fraud prevention, and audit purposes, in accordance with applicable law. After the applicable retention period, such data is securely deleted or de-identified.

De-identified and aggregated data, that is, data from which you cannot be identified, is no longer considered personal information and is not subject to the deletion timelines above. Such data may be retained for research, analytics, and AI improvement purposes.

7. Security of Personal Data

We implement appropriate technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. You must not share your login information with any other person. Please notify us immediately at support@kelvon.com if you suspect any unauthorized access to your account or any other security breach.

No method of electronic transmission or storage is completely secure. While we work to implement commercially reasonable security measures, we cannot guarantee the absolute security of your personal information.

8. Data Retention

We retain personal information in accordance with applicable laws and for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal obligations.

9. Your Rights and Choices

Subject to applicable law, you may have the following rights regarding your personal information:

• Access: the right to request a copy of the personal information we hold about you and confirmation of whether we process it;
• Correction: the right to request correction of inaccurate or incomplete personal information;
• Deletion: the right to request deletion of your personal information, subject to certain legal exceptions (see Section 6);
• Restriction: the right to request that we limit or restrict processing of your personal information in certain circumstances;
• Portability: the right to receive your personal information in a structured, commonly used, and machine-readable format;
• Objection: the right to object to our processing of your personal information where we rely on legitimate interests as the legal basis, including for direct marketing; and
• Withdrawal of Consent: where we rely on your consent to process personal information, the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

To exercise any of these rights, please contact us at support@kelvon.com or through your account settings. We will verify your identity before fulfilling any request and will respond in accordance with applicable law within the applicable timeframe. We will not discriminate against you for exercising your privacy rights.

Again, you may opt out of marketing emails at any time by clicking the unsubscribe link in any such email or by adjusting your notification preferences in account settings.

10. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, additional rights apply under the General Data Protection Regulation, the UK GDPR, and equivalent local laws. This section supplements the rights described in Section 9.

Legal Basis for Processing

We process your personal data on the following legal bases:

• Contract Performance: processing necessary to provide the Service you have requested, including account management, AI research functionality, and personalization features;
• Legitimate Interests: processing necessary for our legitimate interests in operating and improving the Service, maintaining security, preventing fraud, and conducting analytics — where those interests are not overridden by your fundamental rights and freedoms;
• Consent: processing based on your freely given, specific, and informed consent, such as for marketing communications or non-essential cookies. You may withdraw consent at any time by contacting us or adjusting your account settings, without affecting the lawfulness of processing that occurred before withdrawal; and
• Legal Obligation: processing necessary to comply with a legal obligation to which we are subject.

We do not generally rely on consent as the lawful basis for processing your personal data where another lawful basis is available. Where we do rely on consent, we will make this clear to you at the point of collection.

Your GDPR Rights

In addition to the rights described in Section 9, you have the right to lodge a complaint with your national data protection supervisory authority if you believe our processing of your personal data violates applicable law. Contact information for EU supervisory authorities is available at edpb.europa.eu. UK residents may contact the Information Commissioner’s Office (ICO) at ico.org.uk.

You also have the right to object at any time to our processing of your personal data for direct marketing purposes, which includes profiling to the extent that it relates to direct marketing. If you object, we will cease processing your data for that purpose.

To exercise any of your GDPR rights, please contact us at support@kelvon.com. We will respond to your request within thirty (30) days, extendable by an additional two months in complex cases where we will notify you.

11. International Data Transfers

Kelvon, Inc. is based in the United States. Personal information we collect may be transferred to, stored, and processed in the United States or other countries where our service providers maintain facilities. These countries may have data protection laws that differ from those in your jurisdiction.

If you are located in the EEA, United Kingdom, or Switzerland, we rely on appropriate safeguards for international data transfers, for example, Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your personal information receives an adequate and consistent level of protection wherever it is processed. By using the Service, you acknowledge that your personal information may be processed in the United States.

If you would like more information about the safeguards we implement for international transfers, please contact us at support@kelvon.com.

12. Third-Party Links and Prediction Market Platforms

The Service may display links to and information derived from third-party websites, applications, and prediction market platforms, including Kalshi, Polymarket, and various news, sports, economic, and data sources. This Policy does not apply to, and we are not responsible for, the privacy practices of any third-party sites or platforms.

Kelvon does not control how third-party prediction market platforms collect, store, or use your personal information. Any information you provide to, or any activity you conduct on, those platforms is governed by their own respective privacy policies. We encourage you to review the privacy policy of each third-party site or platform you visit or use.

13. Children’s Privacy

The Service is not directed to individuals under the age of eighteen (18) and we do not knowingly collect personal information from anyone under 18. If you believe that we may have inadvertently collected personal information from a person under 18, please contact us immediately at support@kelvon.com and we will take prompt steps to delete such information from our records.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make changes to this Policy, we will notify you by posting the revised Policy on this page, updating the effective date. Your continued use of the Service following the effective date of any revised Policy constitutes your acceptance of the changes. If you do not accept the revised Policy, please discontinue use of the Service.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: