Privacy Policy

This Privacy Policy describes how Wire Markets Limited, a company registered in Gibraltar under company number 126927 ("Wire Markets," "we," "us," or "our"), acting as the group company supporting the operations of Wire Action Markets Ltd and Wire Alternative Markets Ltd (collectively, the "Wire Group"), collects, uses, discloses, and protects personal information when you use our websites, mobile applications, prediction market platforms, and related services (the "Services").

Wire Markets is part of a wider group whose ultimate parent is Wire Industries Inc. (USA), operator of the WagerWire brand. This Policy is drafted in accordance with the Gibraltar General Data Protection Regulation (the "Gibraltar GDPR") and the Gibraltar Data Protection Act 2004.

1. Controller and Contact Details

• Data controller: Wire Markets Limited (Gibraltar company no. 126927), Office 262, 1st Floor, World Trade Center, 6 Bayside Road, Gibraltar GX11 1AA
• Data Protection Officer / privacy contact: legal@wiremarkets.co
• Group entities: Wire Action Markets Ltd and Wire Alternative Markets Ltd process personal information in accordance with this Policy under intra-group data-sharing arrangements described in Section 5.

2. Information We Collect

a. Information you provide directly

• Account registration: name, email address, username, password, date of birth, and contact details.
• Identity verification (KYC): government-issued identification, proof of address, source-of-funds information, and other documentation required under Gibraltar licensing conditions and anti-money-laundering/counter-terrorist-financing (AML/CFT) obligations.
• Marketplace and trading activity: positions, orders, trades, listings, pricing, transaction history, deposits and withdrawals, and communications with other users where peer-to-peer features apply.
• Communications: support requests, surveys, feedback, complaints, and newsletter subscriptions.
• Payment information: processed by third-party payment providers; we do not store full card numbers.

b. Information collected automatically

• Device and usage data: IP address, browser type, operating system, device identifiers, pages viewed, session logs, and interaction data.
• Location data: approximate location from IP and, with your permission, precise geolocation, used to verify eligibility in permitted jurisdictions.
• Cookies and similar technologies (see our Cookies Policy).

c. Information from third parties

• Identity and screening providers: KYC/AML, sanctions, and politically-exposed-persons (PEP) screening results.
• Social login providers (e.g., Google, Apple): information you authorise them to share.
• Group companies and partners: including Wire Industries Inc. and WagerWire-affiliated services, where you link accounts or use integrated features.
• Market data and analytics providers.

3. Purposes and Lawful Bases for Processing

Where we process special category data (e.g., identification documents containing such data, or data relating to criminal convictions for screening), we do so under an applicable condition in Articles 9–10 of the Gibraltar GDPR, including substantial public interest in preventing unlawful acts and complying with regulatory requirements.

4. Data Retention

We retain personal information for as long as your account is active and thereafter as required by Gibraltar law and our licensing conditions, typically at least five (5) years after the end of the business relationship or transaction date for AML/CFT and regulatory records. Marketing data is retained until you withdraw consent or object. When retention periods expire, data is securely deleted or anonymised.

5. How We Share Your Information

• Within the Wire Group: Wire Action Markets Ltd and Wire Alternative Markets Ltd, for shared operations, compliance, risk, and customer service, under intra-group data-sharing agreements. Wire Markets remains responsible as controller for group processing under this Policy.
• Our parent company: Wire Industries Inc. (USA) and its affiliates (including WagerWire), for group administration, technology, product development, and analytics (subject to the transfer safeguards in Section 6).
• Service providers: hosting, cloud infrastructure, KYC/AML screening, geolocation, payment processing, customer support, email delivery, and analytics vendors acting as processors under data processing agreements.
• Regulators and authorities: the Gibraltar licensing authority, the Gibraltar Regulatory Authority, the Gibraltar Financial Intelligence Unit, courts, and law enforcement, where required by law or licence condition.
• Business partners and counterparties: where necessary to execute market transactions or promotions you request.
• Advertising and analytics partners: as described in the Cookies Policy; you may object or withdraw consent at any time.
• Corporate transactions: parties to a merger, acquisition, financing, or sale of assets, subject to confidentiality protections.

We do not sell your personal information.

6. International Transfers

Your information may be transferred to and processed in countries outside Gibraltar, the UK, and the EEA, in particular the United States, where our parent company and certain service providers are located. Where we make such transfers, we rely on:

• adequacy regulations recognising the destination as providing adequate protection; or
• the UK/Gibraltar International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (as recognised in Gibraltar), supplemented by transfer risk assessments and additional safeguards where required.

You may request a copy of the relevant safeguards by contacting us at the address in Section 1.

7. Data Security

We apply appropriate technical and organisational measures, including encryption in transit and at rest, access controls, network monitoring, vendor due diligence, and staff training. No system is completely secure; in the event of a personal data breach likely to result in a high risk to your rights, we will notify you and the GRA as required by law.

8. Your Rights

Under the Gibraltar GDPR, you have the right to:

1. Access your personal information and receive a copy;
2. Rectify inaccurate or incomplete data;
3. Erase your data ("right to be forgotten"), subject to our legal retention obligations (see Section 4);
4. Restrict or object to processing, including processing based on legitimate interests and direct marketing;
5. Data portability for data you provided under contract or consent;
6. Withdraw consent at any time where processing is based on consent, without affecting prior processing;
7. Not be subject to solely automated decisions with legal or similarly significant effects, subject to applicable exceptions.

How to exercise your rights: Email legal@wiremarkets.co with the subject "Data Protection Request". We respond within one month (extendable by two months for complex requests) and may need to verify your identity.

Right to complain: You may lodge a complaint with the Gibraltar Regulatory Authority (GRA), 2nd Floor, Eurotowers 4, 1 Europort Road, Gibraltar, gra.gi. We would appreciate the chance to resolve your concern first.

9. Age Restriction

The Services are intended only for persons aged 18 or older. We do not knowingly collect personal information from minors and will delete any such data promptly upon discovery, where allowed.

10. Third-Party Links and Social Features

The Services may link to third-party sites, sportsbooks, or partners (including WagerWire services operated by Wire Industries Inc.). Their privacy practices are governed by their own policies; we are not responsible for them.

11. Automated Decision-Making and Profiling

We use automated systems for identity verification, sanctions/AML screening, fraud detection, and jurisdiction checks. Decisions with legal or similarly significant effect are subject to human review where required, and you may request human intervention, express your point of view, and contest such decisions.

12. Changes to This Policy

We may update this Policy from time to time. The current version will be posted on the Services with an updated "Last Updated" date and any material changes will be notified by email or in-product notice where required. Continued use after posting constitutes acknowledgement.

13. Contact

Wire Markets Limited (Gibraltar company no. 126927)

Registered office: 262, 1st Floor, World Trade Center, 6 Bayside Road, Gibraltar GX11 1AA.

Email: legal@wiremarkets.co