Introduction

This Privacy Policy explains how Juice Exchange, LLC (“JuiceX”), a designated contract market regulated by the U.S. Commodity Futures Trading Commission (“CFTC”), collects, uses, discloses, and protects personal information in connection with your use of our trading platform, websites, mobile applications, and related services (collectively, the “Services”).
Juice Exchange, LLC is located at 8400 NW 33rd Street, Suite 310, Doral, FL 33122.
JuiceX offers event-based derivatives markets. Access to the Services is provided to (1) individual Self-Clearing Members who access the platform directly through our user interface, and (2) Futures Commission Merchants (“FCMs”) and Introducing Brokers (“IBs”) and their customers, who generally access the platform via API. This Policy describes our handling of personal information across all of these relationships.
This Policy does not apply to information handled by an FCM or IB with respect to its own customers where that FCM or IB, rather than JuiceX, is responsible for collecting and screening customer information. Customers who access the Exchange through a Member FCM or IB should also review that Member’s own privacy policy.

Table of Contents

1. Important Information and Who We Are
2. The Information We Collect About You
3. How Your Personal Information Is Collected
4. How We Use Your Personal Information
5. Disclosures of Your Personal Information
6. Personal Information Security
7. Personal Information Retention
8. Your Legal Rights
9. Eligibility and Children’s Privacy
10. Notice to California Residents
11. GLBA Consumer Privacy Notice
12. USA PATRIOT Act Notice
13. Changes to This Policy
14. How to Contact Us
Addendum 1 — Biometric Information Privacy Policy

1. Important Information and Who We Are

JuiceX complies with applicable U.S. privacy and financial-services laws, including, as applicable, the Gramm-Leach-Bliley Act (“GLBA”) and the CFTC’s implementing privacy regulations, the Bank Secrecy Act and its implementing anti-money laundering (“AML”) requirements, applicable state consumer privacy laws such as the California Consumer Privacy Act (“CCPA”), and applicable state biometric information privacy laws (see Addendum 1).
This Policy should be read together with our Rulebook, Terms of Use, and any Member Agreement applicable to your relationship with the Exchange. By using the Services, you agree to this Policy and consent to the data practices described here. If you do not agree, please do not use the Services.
We review and update this Policy periodically. The “Last Updated” date above reflects the most recent revision. Notice of material changes will be posted to our company website in accordance with Section 13 below.

2. The Information We Collect About You

The specific information we collect depends on whether you are an individual Self-Clearing Member, or an FCM, IB, or a customer of an FCM/IB Member. Consistent with our Customer Onboarding Policy and Procedure, we collect the following categories of personal information:

Identity Data

Full legal name, date of birth, and citizenship
Government-issued identification (verified via our identity verification vendor, Persona)
Selfie / biometric liveness verification data used solely to confirm your identity (see Addendum 1 — Biometric Information Privacy Policy)
Taxpayer identification information (tax ID type and number, and tax forms such as Form W-9)

Contact Data

Current residential address (and length of time at that address)
Mailing address (if different)
Phone number and email address

Financial Data

Annual income and net worth (financial profile)
U.S. (or approved foreign) bank account information used for funding and withdrawals
Trading experience

Employment and Affiliation Data

Employer and employment information
Disclosed affiliations with sports leagues, teams, governing bodies, or other organizations relevant to insider-trading and conflict-of-interest screening on our event markets

Screening and Compliance Data

Know-Your-Customer (KYC) verification results and outcomes
Criminal background check results (including periodic rescreening checks)
Sanctions, watchlist (OFAC/UN), and Politically Exposed Person (PEP) screening results
Adverse media screening results
Affiliation and prohibited-trader screening results (via our vendor IC360’s ProhiTrade solution)
Self-exclusion / responsible-trading elections
Risk-rating and account-approval decisions

Trading and Account Data

Orders, trades, positions, and account activity on the Exchange
Account credentials (username; passwords are not retained in plain text)

Technical and Usage Data

IP address, device and browser information, log-in activity, and similar data collected automatically through our websites, applications, and APIs

Entity Data (FCM and IB Members only)

Ownership structure, beneficial owner and control person information
Entity tax documentation and registration status
Audited financial statements and required financial filings (e.g., FR-1)
Supervisory designee information and Business Continuity/Disaster Recovery plans
Executed Member Agreements

3. How Your Personal Information Is Collected

Directly from you

When you register for an account, complete identity verification, sign required disclosures and agreements, fund your account, or otherwise interact with our Services (including customer support).

Automatically

Through your use of our websites, applications, and APIs, we and our service providers may automatically collect technical and usage data using cookies, server logs, and similar technologies.

From third parties

Persona (identity verification, KYC/KYB, sanctions/PEP/adverse media screening, biometric liveness checks)
IC360 (affiliation and prohibited-trader screening via ProhiTrade)
Sponsoring FCMs or IBs, where you access the Exchange through one of our Members
QC Clearing, d/b/a Polymarket Clearing, our designated derivatives clearing organization (“DCO”), in connection with clearing and settlement
Publicly available sources and, where applicable, credit bureaus or fraud-prevention agencies

4. How We Use Your Personal Information

We use personal information to:
Onboard, verify, and approve your account in accordance with our Customer Onboarding Policy and Procedure
Provide the Services, including trade execution, clearing, and settlement
Comply with legal and regulatory obligations, including those of the CFTC, the National Futures Association (“NFA”), and the Bank Secrecy Act (KYC, AML, sanctions, and recordkeeping obligations)
Detect, prevent, and investigate fraud, money laundering, insider trading, prohibited trading affiliations, and other financial crime
Operate market surveillance, risk management, and regulatory reporting programs
Market JuiceX products and services to you, and communicate with you regarding your account, transactions, and changes to our Rulebook, Terms of Use, or this Policy
Maintain and improve the security, reliability, and performance of our Services

5. Disclosures of Your Personal Information

We may share personal information with the following categories of recipients:
Identity verification and screening vendors: Persona and IC360, to perform the KYC/AML/sanctions and affiliation screening described above
Our designated DCO, QC Clearing d/b/a Polymarket Clearing, for clearing and settlement of your transactions
Sponsoring FCMs or IBs, where relevant to your account relationship
Regulators and law enforcement, including the CFTC and NFA, where required or permitted by law
Professional advisers (legal, audit, banking) bound by confidentiality obligations
Affiliates, for the purposes described in Section 11 below (see note)
A successor entity in connection with a merger, financing, acquisition, or similar corporate transaction
We do not sell personal information to nonaffiliated third parties for their own marketing purposes.

6. Personal Information Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure, consistent with our internal Data Classification and Systems Categorization Policy, Data Loss Prevention Policy, and Access Control Policy. In particular:
Customer personal information and trade data are classified as Restricted, our highest sensitivity level, requiring encryption at rest and in transit, need-to-know access restrictions, and logging and monitoring of access
Access to systems containing personal information is granted on a least-privilege, role-based basis and is subject to periodic review
We employ data loss prevention tools that scan outgoing communications for personal information and block unauthorized external transmission of Restricted data
We maintain a written Security Incident Response Plan and will notify affected customers and, where required, regulators, in the event of a qualifying data security incident
While we maintain these safeguards, no system can guarantee absolute security. You are also responsible for safeguarding your own account credentials.

7. Personal Information Retention

We retain books and records containing personal information for a period of at least five (5) years from the date the record is created, and such records are readily accessible for prompt production during the first two (2) years of that period, in accordance with CFTC Regulation 1.31. Certain records may be retained longer where required by other applicable law (e.g., the Bank Secrecy Act) or where necessary to resolve disputes, enforce our agreements, or comply with legal process.

Biometric data collected as part of identity verification is subject to a separate, shorter retention and destruction schedule described in Addendum 1 (Biometric Information Privacy Policy).

8. Your Legal Rights

Subject to applicable law and to the exceptions described below, you may have the right to request access to, correction of, or deletion of your personal information. Because much of the information we collect is nonpublic personal information collected in our capacity as a CFTC-regulated entity, certain rights and exceptions under GLBA and CFTC recordkeeping rules may limit our ability to delete or restrict use of your information. To exercise your rights, please contact us using the information in Section 14.

9. Eligibility and Children’s Privacy

Our Services are intended only for individuals who have reached the legal age of majority and contractual capacity in their jurisdiction (generally 18 years of age in the United States). We do not knowingly collect personal information from individuals under this age, and registration requires confirmation that the applicant is a legal “person” of contract age. If we learn that we have inadvertently collected information from an individual who does not meet this eligibility requirement, we will take steps to delete that information.

10. Notice to California Residents

JuiceX will have Members and customers who are California residents. All personal information we collect about California residents falls within the categories described in Section 2 above, and is collected in JuiceX’s capacity as a CFTC-regulated financial institution for KYC, AML, sanctions, trading, and related regulatory compliance purposes. Nonpublic personal information collected for these GLBA/CFTC compliance purposes is generally exempt from the CCPA.
To the extent any portion of the information described in Section 2 is not subject to that exemption, California residents may have the right to know the categories of personal information we collect and disclose, to request correction or deletion of certain personal information, and to not receive discriminatory treatment for exercising these rights. To exercise these rights, contact us using the information in Section 14.

11. GLBA Consumer Privacy Notice

The following notice is provided in accordance with the Gramm-Leach-Bliley Act and the CFTC’s implementing privacy regulations.

Reasons We May Share Your Information	Does JuiceX Share?	Can You Limit This Sharing?
For our everyday business purposes – such as to process transactions, maintain your account, comply with regulatory reporting, or respond to legal process	Yes – with our screening vendors (Persona, IC360), our designated DCO, and regulators as required	No – this sharing is necessary to provide the Services and meet regulatory obligations
For our marketing purposes – to offer JuiceX products and services to you	Yes – JuiceX markets its own products and services directly to you	Yes, you can opt out of receiving marketing messages
For joint marketing with other financial companies	No – JuiceX does not currently engage in joint marketing	Not applicable at this time
For our affiliates’ everyday business purposes – information about your transactions and experiences	Not currently – JuiceX has no affiliates established as of this Policy’s effective date. JuiceX intends to share this information with affiliates in the future once established, at which point this notice will be updated	Not applicable at this time
For our affiliates’ everyday business purposes – information about your creditworthiness	JuiceX has no affiliates established as of this Policy’s effective date	Not applicable at this time
For our affiliates to market to you	Not currently – no affiliates are established yet. JuiceX intends to permit affiliate marketing in the future once affiliates exist, at which point this notice will be updated	Not applicable at this time
For nonaffiliates to market to you	No	We do not share information with nonaffiliates for their own marketing purposes

To limit sharing, or with questions about this notice, contact us using the information in Section 14.

12. USA PATRIOT Act Notice

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account. When you open an account with JuiceX, we will ask for information that allows us to identify you, consistent with our Customer Onboarding Policy and Procedure. If you are opening an account on behalf of a business entity, we may also request documents relating to that entity’s formation, existence, and authority.

13. Changes to This Policy

We may revise this Policy from time to time. Notice of material changes will be posted on the JuiceX company website prior to the changes taking effect. Your continued use of the Services after a revised Policy is posted constitutes acceptance of the changes.

14. How to Contact Us

If you have questions, comments, or requests regarding this Policy or our privacy practices, please contact us at:
Privacy@juicex.com

Addendum 1 — Biometric Information Privacy Policy

This Addendum applies to biometric data collected from users residing in the United States and supplements the main Policy above.

JuiceX uses Persona, an identity-verification vendor, to collect and process biometric data on our behalf as part of our Customer Onboarding Policy and Procedure (specifically, Persona’s Identity Verification service, not its separate Age Assurance service). Persona acts as our processor and maintains its own Processor Privacy Policy describing its handling of this data, available at https://withpersona.com/legal/privacy-policy. Persona’s default practice is to delete biometric scan data immediately upon completion of the verification process unless we instruct it to retain data longer, subject to the retention and destruction schedule in Section 5 below.

1. What Biometric Data We Collect

As part of identity verification during onboarding, our vendor Persona collects a selfie photo and a photo of your government-issued identification, and derives biometric identifiers from them (a scan of face geometry and related information) to confirm that you are the person depicted in your identification document (a “liveness” and identity match check).

2. Purpose

We use biometric data solely to verify or authenticate your identity, detect and prevent fraud, and satisfy AML/KYC and sanctions-screening obligations as described in Section 2 and Section 4 of the main Policy above. We do not use biometric data for any other purpose, such as advertising or profiling.

3. Consent

We collect biometric data only after you provide informed consent through the onboarding/identity-verification flow. We do not collect, use, or disclose biometric data without your consent.

4. Disclosure

We do not sell, lease, trade, or otherwise profit from biometric data. Biometric data is disclosed only to Persona (our identity-verification vendor, which processes it on our behalf) and otherwise only if required by law, court order, or subpoena, or if you or your authorized representative direct us to do so.

As disclosed in Persona’s Processor Privacy Policy, Persona may use secure cloud service providers — including Amazon Web Services, Google Cloud, and MongoDB — to process biometric data on our behalf as part of providing identity verification services.

5. Retention and Destruction

Biometric data (the facial-geometry scan data derived from your selfie and government identification) is retained only until the earlier of: (a) completion of the identity-verification process and determination of an outcome, or (b) three (3) years following your last interaction with us, whichever occurs first — consistent with the retention practices of Persona and our instructions to Persona — unless a longer retention period is required by applicable law. This schedule applies specifically to raw biometric scan data and is separate from, and shorter than, the retention period applicable to the resulting non-biometric KYC verification outcome, audit trail, and other required books and records, which are retained in accordance with CFTC Regulation 1.31 as described in Section 7 of the main Policy above.

6. Security

Biometric data is protected using the same or greater administrative, technical, and physical safeguards applied to our most sensitive (Restricted) data categories under our Data Classification and Systems Categorization Policy, including encryption and need-to-know access restrictions.

Notice for Illinois Residents: We use reasonable standards of care within our industry to store, transmit, and protect biometric data in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information. We will not sell, lease, or trade biometric data. Other than as set forth in Section 4 above, we will not disclose, redisclose, or otherwise disseminate biometric data unless: (a) doing so completes a transaction requested and authorized by you or your legally authorized representative; (b) it is required by state or federal law or municipal ordinance; (c) it is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction; or (d) you have expressly consented to the disclosure.