Privacy Policy

Pursuant to Regulation (EU) 2016/679 (GDPR) · Last updated: 12 September 2026

1. Controller

itereon GmbH, Arsenalstraße 11, 1030 Vienna, Austria · office@itereon.eu · Commercial register FN 681324y, Handelsgericht Wien. See the imprint.

2. The short version

The polydesk clicktrader desktop application is designed to process as little of your data as possible. It runs locally and connects directly from your machine to the Polymarket API. Your wallet and signer key never touch our infrastructure. Processing on our side relates to (a) this website (server logs), (b) the purchase of a Plus license, (c) technical error and crash diagnostic data for troubleshooting, and (d) support channels you choose to use. We process no trading or usage data: no orders, positions, market data or wallet information.

3. Data processed by the desktop application

  • Market data and orders: requested and sent directly between your machine and the Polymarket API. We are not a party to this traffic and do not receive it.
  • Signer key and wallet data: generated and stored exclusively on your device. Never transmitted to us.
  • License key (Plus): the license key is entered and stored locally on your device. The app does not transmit it to itereon and performs no online validation.
  • Error and crash diagnostics: technical error and crash diagnostic data (app version, operating system, stack trace) is processed for troubleshooting via our processor Sentry (Functional Software, Inc.), see sub-processors (Art 6(1)(f) GDPR, legitimate interest in a functioning product). No trading or usage data is included. Reports are stored in Sentry's EU data region and deleted after 90 days at the latest. You may object to this processing at any time (Art 21 GDPR, see section 9).
  • Feedback (optional): if you use the feedback function in the app, we receive your rating (1 to 10), the text you write, the app version and your platform, transmitted anonymously via Sentry (Art 6(1)(a) GDPR; you consent by sending). No contact details, no wallet, trading or usage data. Nothing is sent unless you press Send. Feedback is stored in Sentry's EU data region and subject to the same 90-day retention as diagnostic data; should your text itself contain personal data, it is treated the same way.
  • Builder attribution: orders you send through the Software carry itereon's public builder identifier under Polymarket's Builder Program, at a 0% fee rate in the Free tier, during the open beta and under a Plus license. Polymarket can therefore attribute orders placed through the Software to itereon and provides us with aggregate statistics for our builder profile (Art 6(1)(f) GDPR, legitimate interest in operating and maintaining the Software). We receive no personal data from this: no wallet addresses, positions or individual orders.

4. Data processed by this website

  • Server logs: IP address, timestamp, requested resource, user agent, processed by our hosting provider to deliver the site and defend against attacks (Art 6(1)(f) GDPR, legitimate interest). We do not store these logs ourselves; retention follows the hosting provider's data retention policy for Azure Static Web Apps.
  • Local storage, cookies and analytics: this website uses only technically necessary storage, which requires no consent (§ 165 Abs 3 TKG 2021). We currently use no analytics or tracking tools. Should we introduce analytics, it will run only after your opt-in (Art 6(1)(a) GDPR) and this policy and the cookie preferences page will be updated beforehand.
  • Downloads and release notes: application builds are distributed via GitHub, and the release list on our changelog page is read from GitHub by us when the website is built, not by your browser. GitHub, Inc. (USA) receives your data only when you follow a link to GitHub, for example to download a build; GitHub's own privacy terms then apply.

5. Purchase of a Plus license

When you purchase a Plus license we process the data required for contract execution, invoicing and issuing the license: name, e-mail, billing address, VAT ID where applicable, payment confirmation and the wallet address the license is bound to (Art 6(1)(b) and (c) GDPR). A wallet address is personal data; we use it only to issue and, on renewal, re-issue your license key, and we keep it in our license records for the term of your license and thereafter for the statutory limitation period of three years. Payment data is processed by our payment provider, which will be named in the list of sub-processors before Plus sales open; we do not receive full card or account details. Providing this data is necessary to conclude and perform the contract; without it we cannot issue a license. Invoicing data is retained for 7 years (§ 132 BAO).

6. Support channels and Pro setup

If you contact us by e-mail, via X or, once our community server opens, on Discord, we process the data you provide to handle your request (Art 6(1)(b) or (f) GDPR). Support correspondence is kept until your request is resolved and thereafter for the statutory limitation period of three years. Discord and X are independent controllers of their platforms; their own privacy policies apply.

A Pro setup, and any later support access to your own system, takes place only on your instruction, for a limited time and under a data processing agreement (Art 28 GDPR) that forms part of the Pro agreement. itereon holds no standing access to your system.

7. Recipients

We use a small number of processors under Art 28 GDPR contracts, and a few platforms that act as independent controllers; see the current list of sub-processors and other recipients. No data is sold, and no data is shared with advertisers.

8. Third-country transfers

This website is hosted on Microsoft Azure Static Web Apps under a contract with Microsoft Ireland Operations Ltd. (EU). Static content is delivered from Microsoft's globally distributed edge network, so a request may be processed at an edge location outside the EU, including in the USA; the Microsoft Products and Services Data Protection Addendum with EU standard contractual clauses applies. Sentry stores diagnostic data and feedback in its EU region. Where a recipient is established in the USA, transfers rely on the EU-US Data Privacy Framework where the recipient is certified (Microsoft Corporation; GitHub, Inc.; Functional Software, Inc. d/b/a Sentry) and otherwise on EU standard contractual clauses (Art 44 ff GDPR), in particular for Discord Inc. and X Corp. You may request a copy of the applicable safeguards at office@itereon.eu.

9. Your rights

You have the right to access, rectification, erasure, restriction and data portability (Art 15 to 20 GDPR), and to withdraw consent at any time with future effect. Contact: office@itereon.eu.

Right to object (Art 21 GDPR). Where we process your data on the basis of legitimate interests (server logs, error and crash diagnostics, builder attribution, support requests), you may object at any time on grounds relating to your particular situation. We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms.

You may lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde, Barichgasse 40 to 42, 1030 Vienna, dsb.gv.at) or your local supervisory authority.

10. No automated decision-making

We do not use automated decision-making or profiling within the meaning of Art 22 GDPR.

11. Changes

We will update this policy when the product or legal requirements change. The current version is always published on this page.