Privacy Policy
Last updated: [DATE]
This Privacy Policy describes how [Your App Name]
(“Company”, “we”, “us”, or “our”) collects, uses, shares, and protects your
personal information when you use our mobile application, website, and related
services (collectively, the “App” or the “Services”).
By installing or using the App, you agree to this Privacy Policy. If you do not
agree, please do not use the App.
1. Information We Collect
We only collect information that is necessary for the App to function, to reward
users, and to maintain security and compliance with platform policies (including
Google Play and Meta/Facebook).
1.1 Information You Provide Directly
We may collect the following information you provide:
- Email address or username
- Password or login credentials
- Country, language, and profile preferences
-
Account verification data (phone number or ID only if required for fraud
prevention and legal compliance)
- Support messages, feedback, and attachments you choose to send us
1.2 Information Collected Automatically
When you use the App, we automatically collect certain information for
functionality, analytics, fraud detection, and to comply with Google Play and
Facebook platform policies.
Device data may include:
- Device model and operating system version
- Device identifiers (such as Advertising ID/IDFA/GAID)
- Device language and time zone
- IP address and approximate location (city/country level)
App usage data may include:
- Screens viewed and buttons pressed in the App
- Offer and survey views, clicks, and completions
- Points or rewards earned and redemption activity
- Crash logs, performance diagnostics, and error reports
Tracking technologies we may use include:
- Cookies and local storage
- Software development kits (“SDKs”)
- Web beacons and similar technologies
These are used for analytics, attribution, fraud prevention, and to improve user
experience.
1.3 Information from Third-Party Partners
We may receive information from:
-
Survey and offerwall providers (for example:
TheoremReach, Pollfish, BitLabs, AdGate, AdGem, OfferToro, CPX Research and
similar partners), including:
- Offer or survey completion status and timestamp
- Reward or payout amount
- Anti-fraud and quality signals related to the completion
-
Gift card and reward fulfillment providers, including:
- Order status and delivery confirmation of your reward
-
Attribution and analytics providers (for example:
Google Analytics/Firebase, Facebook/Meta, Adjust, Appsflyer), including:
- Anonymous installation and campaign performance data
- Non-sensitive engagement events (such as app opens or registrations)
We do not receive your Facebook password, your private social media content, or
other sensitive account details from these partners.
2. How We Use Your Information
We use the information we collect to:
- Create, manage, and maintain your user account
- Deliver surveys, offers, tasks, and rewards
- Credit points and process redemptions and payouts
- Verify offerwall completions with partners
- Detect and prevent fraud, abuse, and duplicate accounts
- Improve and optimize the App’s functionality, UX, and performance
- Measure the effectiveness of advertising campaigns
- Provide customer support and respond to your requests
- Comply with legal obligations and platform policies
We do not use your data to infer sensitive characteristics such
as race, religion, political opinions, health, or sexual orientation.
We do not sell your personal data.
3. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), the United Kingdom, or a
similar jurisdiction, we process your personal data relying on one or more of
the following legal bases:
- Consent: For example, when you install the App, grant permissions, or opt in to tracking or marketing.
- Contractual necessity: To provide the Services you request, such as operating your account and delivering rewards.
- Legitimate interests: For fraud prevention, security, analytics, and service improvement.
- Legal obligations: To comply with applicable laws, regulations, and accounting requirements.
4. How We Share Your Information
We may share your information in the following situations:
4.1 Service Providers
We share data with trusted third-party service providers that help us deliver
the Services, including:
- Survey and offerwall networks
- Gift card and reward fulfillment vendors
- Cloud hosting and infrastructure providers
- Analytics and crash reporting services
- Fraud prevention and security tools
- Email and push notification providers
These providers only receive the minimum data necessary and are obligated to
protect your information.
4.2 Advertising & Attribution Partners
We may share limited, non-sensitive event data with advertising and attribution
partners such as Google and Meta/Facebook to:
- Measure app installations and campaign performance
- Understand which ads lead to downloads or registrations
- Optimize marketing spend
We do not share your personal messages, financial details, or
sensitive information with these partners.
4.3 Legal Requirements
We may disclose your information if required by law or if we believe in good
faith that such action is necessary to:
- Comply with a legal obligation or government request
- Protect our rights, property, or safety, or that of our users or the public
- Investigate and defend against legal claims
4.4 Business Transfers
If we are involved in a merger, acquisition, or asset sale, your information may
be transferred as part of that transaction, subject to this Privacy Policy.
5. Data Retention
We retain your information for as long as necessary to provide the Services,
comply with legal obligations, resolve disputes, and enforce our agreements.
When we no longer need your information, we will delete or anonymize it.
You may request deletion of your account and associated personal data, subject
to any legally required retention (for example, transaction and accounting
records).
6. Data Security
We use reasonable technical and organizational safeguards to protect your
information, including:
- Encryption in transit (HTTPS/SSL)
- Secure server configuration and access controls
- Monitoring and fraud detection measures
However, no method of transmission or storage is completely secure, and we
cannot guarantee absolute security.
7. Your Rights
Depending on your jurisdiction (for example, the EU, EEA, UK, Brazil, California),
you may have some or all of the following rights:
- The right to access the personal data we hold about you
- The right to request correction of inaccurate or incomplete data
- The right to request deletion of your personal data
- The right to restrict or object to certain processing
- The right to withdraw consent at any time (where processing is based on consent)
- The right to data portability
To exercise these rights, please contact us at:
[your-email]. We may need to verify your
identity before processing your request.
8. Children’s Privacy
The App is not intended for children under the age of 16. We do not knowingly
collect personal data from children under 16. If we become aware that a child
under 16 has provided us with personal data, we will take steps to delete such
data.
9. Permissions Used in the App (Google Play)
The App may request certain permissions on your device to function properly.
These permissions may include:
- Internet access: to connect to our servers, load offers, and deliver rewards.
- Push notifications (optional): to inform you about rewards, important updates, and new offers.
-
Device identifiers and advertising IDs: for fraud prevention,
security, analytics, and attribution of installs or in-app events.
-
Approximate location (country/city level): to show
region-specific offers and comply with partner targeting requirements.
We do not access your contacts, SMS, call logs, photos, precise GPS location,
microphone, or camera unless explicitly stated and consented to within the App.
10. Third-Party SDKs
Our App integrates third-party SDKs for surveys, offerwalls, analytics,
attribution, crash reporting, and fraud prevention. These SDKs may collect:
- Advertising ID (IDFA/GAID)
- IP address and basic device information
- App installation and engagement events
All SDKs are integrated and configured in line with Google Play’s Data Safety
requirements and the data usage policies of each provider.
11. Facebook / Meta Compliance
We comply with Meta/Facebook’s Advertising Policies, Platform Terms, and
applicable data restrictions. In particular:
- We do not upload personal contact lists or sensitive personal data to Facebook.
- We do not use Facebook data to build sensitive profiles or identify individuals outside of the App.
-
We may send anonymous or pseudonymous event data (such as app installs,
registrations, or purchases) to Meta for attribution and ad performance
measurement, in accordance with Meta’s policies.
12. Google Play Compliance
This Privacy Policy is designed to meet the requirements of the Google Play
Developer Program and Google Play Data Safety section. We clearly disclose:
- What types of data are collected and why
- How data is used and whether it is optional or required
- How data may be shared with third parties
- That certain data may be used for analytics, security, and fraud prevention
- That data is transmitted securely and handled responsibly
13. International Data Transfers
Your information may be processed and stored in countries other than your own,
where data protection laws may differ. We take steps to ensure that your data
receives an adequate level of protection, for example by using standard
contractual clauses and other safeguards where required.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes,
we will notify you by updating the “Last updated” date and, where appropriate,
by providing a more prominent notice within the App.
Your continued use of the App after any changes indicates your acceptance of the
updated Privacy Policy.
15. Contact Us
If you have any questions about this Privacy Policy, the App, or your data, you
can contact us at:
Email:
[your-email]
Company: [Your Company Name]
Address: [Your Company Address]