Last updated · 19 October 2026
Terms of use
What applies when you use this site, write to us or commission work from 21Core.
Identification
21Core AI is run by its founder, Afonso Martins, in Madeira, Portugal, while the company is being registered. Its registration details will appear here once registration completes. Contact: afonso@21coreai.com.
What this site is
21Core sells only to businesses. It serves four kinds of buyer: exchanges and brokers; funds, desks and trading apps; integrity, legal and policy teams; and data tools and media. We sell evidence, verification and data, all built from one record: Polymarket from late 2025 and Kalshi from January 2026, with every source graded. This site takes no payment or deposit, connects no venue account and places no trade.
Enquiries, the paid Diagnostic and engagement letters
Sending the form or booking a call creates no contract and no obligation to pay. Paid work starts with a Diagnostic: two weeks on your question and your markets. Its fee is credited in full against the engagement if you go ahead within 60 days. A trading strategy can start with the check instead, at the price shown on our validation page. The Diagnostic, the check and every engagement are agreed in writing before they start. The engagement letter sets the scope, price, delivery and our commitments. Before we agree any work, we may ask you to confirm your organisation, location and intended use.
Order of precedence
If a signed engagement letter or licence conflicts with these terms, the letter or licence prevails, but only to the extent of the conflict and only for that engagement or licence. These terms still govern your use of this site and anything the letter or licence does not cover. Nothing in either overrides mandatory law.
Evidence products
A Case File, Book Watch, an Exposure Report and a Pre-registered Study describe market activity. They make no finding of wrongdoing about any person, never name the person behind a wallet, and give no legal opinion. Whether a delivery is admissible as evidence, and the weight it carries, is for your counsel and the body that hears it. Book Watch adds to the surveillance you run and does not replace it. A Pre-registered Study’s method is published before the data is read. Either side of a question can commission one on the same terms, and the sponsor does not edit the result. Decisions stay with the body that commissioned the work.
Exchange products
A Contract Evidence Pack supports your counsel. It is not legal advice, and it does not decide whether a contract can be listed. A Market Quality Benchmark, sold to brokers as the Execution Quality Report, is private to the client who commissions it: we never publish it, and you decide who sees it. It measures the book and makes no finding about any trader.
Verification products
A Verified Record, a Capacity and Fill Audit and the Verified Leader Programme are independent technical review. They report what our tests did and did not establish, on the material supplied and the books we hold. They are not investment advice, an audit opinion in any regulated sense, a recommendation to follow anyone, or a forecast. A backtest is a simulation, not a promise of future results, and a record that passes can still lose money. The Clean Leader screen is for the client’s own review and makes no finding about any person. We remove a verification mark when a record stops passing. You remain responsible for your own capital decisions.
Data products
A Data and Clock licence is granted in writing, on its own terms. Polymarket and Kalshi data may both be licensed for resale inside your product under those terms. Vendor data goes to you only as each vendor’s licence allows. The clock and any similar series are estimates with intervals, measured on a stated population by a stated method, not exact constants. They change as markets change, so check that one fits your use. The Move Explainer is descriptive and after the fact: never a pick, a tip or a signal, and never a name behind a wallet. No licence gives a trading right or a relationship with any venue.
Wallet addresses in licensed data
Wallet addresses in data we license to you can be personal data. You receive them as an independent controller, responsible for your own compliance with data protection law, and you must:
- use them only for the purpose your licence states;
- not try to identify the person behind an address, or combine an address with off-chain identity data;
- protect them with appropriate security measures;
- delete them, and every copy, when the licence ends;
- pass them on only as the licence allows, and only to recipients bound by these same conditions;
- when we pass on an objection to an address, stop using it, and have anyone you passed it to do the same.
If you are outside the European Economic Area, you receive them under the European Commission’s standard contractual clauses, unless an adequacy decision covers the transfer.
Sources, grades and no warranty
The record combines our own capture, the public Polygon chain and licensed vendor history. Every delivery lists each input, where it came from and its grade: ground truth, verified or unverified. We confirm which sources cover your markets before work starts. Sources can be late, incomplete, corrected or wrong. We deliver data and findings as they stand, with their limits attached, and we do not remove a stated limit at a client’s request. We do not guarantee that any source, finding or service is complete, uninterrupted, without error or able to support a profitable decision.
Our founder’s trading and the wall
Our founder trades esports prediction markets on his own account. 21Core itself does not trade. We never write a Case File, an Incentive Audit or any other report on a market he traded, or on an incentive program that rewarded him, in the period it covers, and the body that commissions one can have his wallet addresses under NDA to check. Engagement letters for funds, desks and trading apps commit us to non-use of their material and commit our founder to not trading their strategy class in the named markets for an agreed period. Neither 21Core nor its founder is ever knowingly a client’s counterparty, and neither takes a share of a client’s gains or losses.
No client money and no advice
21Core holds no client money or assets, accepts no deposits, routes no orders for anyone and is not an investment adviser. We run no shared wallet, pooled vault or DAO treasury, and issue no token for pooled returns. We sell no tips, picks, signals or strategies. Nothing on this site or in a delivery is legal, tax, accounting or investment advice, a guarantee of any return, or an offer to open a trading, investment or betting account. How a contract is regulated depends on the contract, the client, its location and the service, and is for you and your advisers to judge.
Confidentiality
What you share is used only for the engagement it was shared for. We never disclose one client’s material to another, and we publish nothing about a client, its usage or its material without written permission. We delete it when the work ends, as the Privacy Policy describes. If you need a confidentiality agreement, we sign it before you share anything.
Intellectual property
You may use a delivery for the purpose its engagement letter or licence states, and show or pass it on only as that document allows. The 21Core name, record, methods, code and original content stay ours. Resale, systematic copying, or using a delivery to reverse engineer our methods or build a competing product, needs our written permission. Third-party content stays subject to its owner’s rights.
Business customers
21Core contracts only with businesses and institutions acting in the course of their trade, not with consumers. Where a mandatory consumer protection still applies to a particular person or transaction, nothing in these terms excludes it.
Third-party venues
Polymarket, Kalshi, the Polygon chain and our licensed vendors are run by third parties. Their rules, fees, data, eligibility and availability can change or end, and we control none of them. 21Core is independent and not affiliated with Polymarket, Kalshi, any league or any game publisher. Where we compare venues, contracts can differ in wording, settlement, clock, fees and who may trade them. A price we observed is not a quote anyone can still trade. Nothing we supply may be used to get round a venue’s eligibility checks, sanctions controls, geographic limits or local law.
Complaints and dispute resolution
You may raise a complaint at afonso@21coreai.com or through the Portuguese electronic complaints book. In a consumer dispute, you may refer the matter to the Centro de Arbitragem de Conflitos de Consumo da Região Autónoma da Madeira, without prejudice to any other legally available route.
Governing law
Portuguese law applies, without prejudice to mandatory consumer protection rules and to any governing-law clause agreed in a signed engagement letter or licence.
Questions about an engagement: afonso@21coreai.com.
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