Effective Date: January 1, 2026

1. Introduction

Splash Market, LLC(“Splash Market,” “we,” “our,” or “us”) is a registered Introducing Broker with the Commodity Futures Trading Commission (CFTC) and a Member of the NationalFutures Association (NFA). Splash Market introduces customers to QCX Limited Liability Company (d/b/a Polymarket US) (“Polymarket US”), a Designated Contract Market (DCM), for the purpose of trading event contracts listed and executed on Polymarket US platform. All clearing and settlement of trades introduced by Splash Market are performed exclusively by QC Clearing Limited Liability Company (d/b/a Polymarket Clearing), a Derivatives Clearing Organization (DCO) registered with the CFTC.

By accessing or using the Splash Market website, mobile application, or any services offered by Splash Market (collectively, the “Services”), you agree to be bound by these Terms of Use (the “Terms”). If you do not agree, do not use our Services.

2. Regulatory Status

Splash Market is registered as an Introducing Broker (IB) with the CFTC and is an NFA Member. Splash Market does not hold or control customer funds. All customer funds are deposited, held, and maintained in accounts controlled by Splash Player Reserve, LLC, a special purpose entity, and Polymarket Clearing pursuant to CFTC Regulations and Polymarket US membership and clearing agreements.

3. Eligibility and Trading Prohibitions

To access or use the Services, you must:

  • Be at least 18 years of age (or the age of majority in your jurisdiction);
  • Be a U.S.person residing in a jurisdiction where Polymarket US event contracts are lawfully offered;
  • Complete account onboarding with Polymarket US;
  • Agree to all applicable Polymarket US customer agreements, disclosures, and risk acknowledgments; and

Trading in specific sports event contracts will be prohibited if you are a:

  • current or former player, coach or staff of the league, association or organization(s)governing the event. For college leagues/associations specifically, or where otherwise appropriate (as identified by Polymarket US), this applies to current and former players/coaches/staff of the specific teams in the sports event rather than the league/association as a whole (e.g., if the Division I Gonzaga Men’sBasketball Team is playing in a basketball game, this prohibition will restrict trades by current/former players of that team, rather than all current/former players/coaches/staff in any NCAA sport);
  • paid employee of the league and league participants;
  • owner of a team (or teams) or the league; or
  • household member or immediate family of all above.

4. Nature of Services

Splash Market provides educational content and introductions to Polymarket US, and customer support for user accounts trading on Polymarket US. Splash Market does not execute orders, handle customer funds, or provide investment advice.

5. No Guarantee or Advice;

Trading event contracts involves risk of loss and may not be suitable for all customers. Past performance is not necessarily indicative of future results. Splash Market does not provide individualized investment advice.

6. Required Risk Disclosures

Hypothetical or simulated performance results have inherent limitations. Testimonials may not be representative of other customers’ experiences and are not a guarantee of future performance.

Sports event contract trading is a derivatives product offered by Polymarket US. Trading sports events contracts involves risk and may not be appropriate for all. By trading you risk losing your cost to enter any transaction, including fees. You should carefully consider whether trading on Splash Market is appropriate for you in light of your investment experience and financial resources. Any trading decisions you make are solely your responsibility and at your own risk.

Polymarket US event contracts available on the Platform have not been endorsed by any individual or entity. The use of the name of any individual or entity does not indicate any endorsement of this tradeable financial instrument.

To the extent that you consent to opening an account with Polymarket US for prediction market trading by acknowledging the Polymarket US Terms of Use, the Polymarket US Privacy Policy, the Risk Disclosure Statement, the Membership Agreement, and the Polymarket US Rulebook, you acknowledge and agree that Splash Market (or any of its affiliates) is authorized to act on your instruction received through the use of your username and password to withdraw from your Splash Sports Account, and take deposits to your Splash SportsAccount, upon your instructions and independent relationship with Polymarket US. Splash Market does not hold funds for prediction market trading.

Additional risk disclosures specific to Splash Market may be found here.

7. Customer Accounts Fund Protections and Account Structure Disclosure

All customer accounts introduced by Splash Market are opened, maintained, and cleared by Polymarket US and Polymarket Clearing. All funds are processed and held in accounts maintained by Splash Player Reserve, LLC and Polymarket Clearing. Splash Market does not accept or transmit funds.

Splash Market, LLC acts solely as an Introducing Broker and does not operate as, or maintain any relationship equivalent to, a Futures Commission Merchant (FCM). Customer accounts introduced by Splash Market are not carried by an FCM, and no intermediary FCM stands between the customer and the exchange.

All customer event contract transactions are executed directly on Polymarket US, a Designated Contract Market (DCM) registered with the CFTC, and all clearing and settlement of such transactions are performed by Polymarket Clearing, a Derivatives Clearing Organization (DCO). Splash Market does not carry positions, margin, or balances on behalf of any customer.

Funds that may be deposited by customers into accounts identified as Splash Player Reserve, LLC (or any similar account associated with Splash Market) are not subject to the segregation, protection, or insolvency safeguards afforded to customer funds under Section 4d of the Commodity Exchange Act (CEA) or CFTC Regulations 1.20 et seq.

Such funds are not treated as “customer segregated funds” for futures or cleared derivatives purposes and are not guaranteed or protected in the event of the bankruptcy, insolvency, or default of any party, including Splash Market, LLC, Splash Player Reserve, LLC, Polymarket US, or Polymarket Clearing.

By opening an account through Splash Market, customers acknowledge that:

  • All trading activity occurs directly with Polymarket US, and not through an FCM.
  • All funds supporting event contract positions are held by or on behalf of Polymarket Clearing, the registered DCO responsible for clearing and settlement.
  • Splash Market and Splash Player Reserve, LLC do not carry or segregate customer property under CEA § 4d.

By using Splash Market’s Services, you expressly acknowledge and agree that:

  • Your funds are not protected by CEA § 4d segregation requirements;
  • You will have a direct customer relationship with Polymarket US for trading and with Polymarket Clearing for clearing and settlement; and
  • SplashMarket, LLC and Splash Player Reserve, LLC are not responsible for the safekeeping, loss, or recovery of such funds beyond the scope of their introducing broker obligations.

7.1 Other Protections

Notwithstanding the provisions of Section 7, funds that may be deposited by customers into accounts identified as Splash Player Reserve, LLC may be subject to other protections as required by state fantasy sports laws and/or regulations.

8. Intellectual Property

All content displayed on the Splash Market website or app is owned by or licensed to Splash Market and protected by applicable law.

9. Privacy

Splash Market respects your privacy and handles personal information in accordance with its Privacy Policy. Information shared with Polymarket US or Polymarket Clearing is subject to their respective privacy policies.

10. Limitation of Liability

To the fullest extent permitted by law, Splash Market shall not be liable for any damages arising out of or relating to your use of the Services or trading on Polymarket US. Services are provided “as is,” without warranties of any kind.

11. Indemnification

You agree to indemnify and hold harmless Splash Market, its officers, directors, employees, and affiliates from any claim or expense arising from your use of the Services, violation of these Terms or Privacy Policy, or trading activities on Polymarket US.

12. Mandatory Arbitration

All disputes arising out of or relating to these Terms shall be resolved by binding arbitration administered by the National Futures Association (NFA) pursuant to its Code of Arbitration (NFA Compliance Rules, Part 10). Arbitration shall take place in New York, New York, unless otherwise agreed. The arbitrators’ decision shall be final and may be entered in any court of competent jurisdiction.

13. Customer Arbitration Waiver Disclosure

By signing or electronically accepting these Terms, the customer acknowledges that any disputes between the customer and Splash Market, LLC may be subject to arbitration before the National Futures Association (NFA) or another recognized arbitration forum. Customer further acknowledges that:

  • Arbitration is final and binding on all parties;
  • The parties are waiving their right to seek remedies in court, including the right to a jury trial;
  • Pre-arbitration discovery is generally more limited than in court proceedings;
  • The arbitrators’ award is not required to include factual findings or legal reasoning; and
  • The right to appeal or seek modification of an award is strictly limited.

14. Governing Law

These Terms are governed by and construed under the laws of the State of New York without regard to conflicts of laws principles and applicable U.S. federal law.

15. Amendments

Splash Market may amend these Terms at any time by posting an updated version on its website. Continued use of the Services constitutes acceptance.

16. Contact Information

Splash Market, LLC
Registered Introducing Broker (CFTC & NFA Member)
Address: 44 Cook St #100, Denver, CO 80206
Email: info@splash-market.com
Phone: 844-999-1699
NFA ID# 572313