Compliance

Clover does not operate its own cryptocurrency exchange or prediction market infrastructure. Instead, Clover serves as a mobile frontend interface to Polymarket, a third-party decentralized prediction market protocol.

All prediction market trades executed through the Clover app are routed directly to Polymarket's Central Limit Order Book (CLOB) and settled on the Polygon blockchain. Clover does not custody, hold, or process user funds at any point in the transaction lifecycle.

Polymarket API Documentation:

• docs.polymarket.com — Official API documentation
• github.com/Polymarket — Open-source smart contracts

Polymarket operates under its own regulatory framework. Clover participates in Polymarket's Builder / Referral Program, which is designed to encourage third-party frontend applications to route volume through Polymarket's infrastructure.

Clover utilizes Magic SDK (Magic.link) for user authentication and self-custodial wallet generation. Each user receives their own non-custodial wallet on the Polygon blockchain upon sign-up. Private keys are managed exclusively by the user via Magic's Delegated Key Management system — Clover Labs never has access to, holds, or controls user private keys or funds at any point.

This non-custodial model means Clover functions as a software wallet interface, similar to MetaMask or Coinbase Wallet, that allows users to sign their own transactions on the blockchain. Users interact directly with Polymarket's on-chain smart contracts through their own self-custodial wallets.

As a non-custodial wallet software, Clover does not function as a money transmitter, custodian, financial intermediary, or gaming operator, and does not require a gaming or gambling license. Clover does not operate, host, or control any prediction markets — all markets are operated by Polymarket.

Clover restricts access to prediction market trading features in jurisdictions where such activity is prohibited or where Polymarket's services are not legally available. Geographic restrictions are enforced strictly via backend IP-based geolocation checks. When a user's IP originates from a restricted region, all trading interfaces are completely disabled and the app transitions to a read-only portfolio tracker.

Clover has intentionally chosen IP-based enforcement over device GPS (CoreLocation) tracking to minimize invasive user location data collection, aligning with privacy-first principles. This approach provides robust compliance without unnecessarily tracking user movements.

The following countries are restricted from accessing trading features:

Additionally, the following specific regions within otherwise accessible countries are restricted:

Countries marked "Close-only" allow existing users to close positions and withdraw funds but cannot open new trades. This list is aligned with Polymarket's geographic restrictions and may be updated as regulatory landscapes evolve.

In addition to in-app geo-blocking, Clover has restricted its App Store availability to align with the same territory footprint as comparable Polymarket frontend apps that are approved and live on the App Store. This ensures consistent compliance at both the distribution and application level.

The following 26 territories are excluded from App Store availability (the app cannot be downloaded in these regions):

This list was determined by programmatically analysing the App Store territory availability of approved Polymarket frontend apps and mirroring their exclusion list exactly.

As a non-custodial frontend that routes trades to Polymarket, Clover inherits Polymarket's KYC and AML compliance framework. Polymarket implements its own identity verification and anti-money laundering procedures for users interacting with its protocol.

Clover additionally enforces geographic access controls, monitors for suspicious activity patterns, and cooperates with law enforcement requests in accordance with applicable law.

Clover Labs is aware of the FCA's requirements regarding crypto asset promotions under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (as amended). Clover does not directly promote or market specific financial products to UK consumers.

The app provides an interface to a third-party protocol and clearly discloses that prediction market participation involves risk, that users may lose their deposited funds, and that Clover Labs does not provide financial advice.

Clover charges zero trading fees. Users pay only the native Polymarket protocol fees (typically ~0.2% per trade) and standard Polygon network gas fees. Clover does not add any markup, commission, or hidden charges on top of protocol fees.

Clover Labs generates revenue through Polymarket's Builder Referral Program, which provides a revenue share of protocol fees for trades routed through third-party frontends. This model aligns Clover's incentives with user growth without imposing additional costs on users.