Privacy Policy
This Privacy Policy describes how EarnPass ("EarnPass", "we", "us", or "our"), operated by G2 Flow Ltd, a company registered in England & Wales, collects, uses, discloses, and protects personal data when you use the EarnPass website, mobile applications, and related services (collectively, the "Service").
EarnPass is committed to compliance with the EU General Data Protection Regulation 2016/679 ("GDPR"), the UK GDPR and the Data Protection Act 2018, and applicable U.S. state privacy laws including the CCPA/CPRA where they apply.
1. Information we collect
1.1 Account information
- Email address and account credentials
- Profile preferences and language / region
- Payout details (e.g., PayPal email, gift card preference, crypto wallet address)
1.2 Device and technical data
- Device model, operating system, IP address, and approximate location (country / region)
- Browser type, language settings, and time zone
- Device identifiers (e.g., advertising ID, device fingerprint) for fraud prevention and offer attribution
1.3 Offer completion data
- Offers viewed, started, and completed
- Reward eligibility events and timestamps
- Server-to-server postback data received from advertising and offerwall partners
1.4 Communications
- Messages you send to support, partnerships, or via our contact forms
2. How we use information
- Provide the Service — operate your account, track offer completions, and process reward payouts.
- Fraud prevention — detect and prevent abuse, multi-accounting, and fraudulent reward claims.
- Partner attribution — share required attribution events with advertising and offerwall partners so they can credit your activity.
- Communications — respond to support requests, send transactional emails (e.g., payout confirmations), and notify you about important changes.
- Analytics — measure feature usage and improve the Service.
- Legal compliance — comply with applicable laws and respond to lawful requests.
3. Lawful bases for processing (GDPR)
Where the GDPR or UK GDPR applies, we rely on the following lawful bases:
- Contract — to deliver the Service you've signed up for.
- Legitimate interests — to operate, secure, and improve the Service, including fraud prevention.
- Consent — for non-essential cookies and certain marketing communications. You can withdraw consent at any time.
- Legal obligation — where we must process data to comply with the law.
4. Third-party partners
EarnPass shares limited data with carefully selected third parties strictly to operate the Service:
- Advertising and offerwall networks (offer attribution and reward eligibility data)
- Payment processors (PayPal, gift card vendors, cryptocurrency payout providers)
- Cloud infrastructure and analytics providers (hosting, error monitoring, product analytics)
- Fraud-prevention vendors (device fingerprinting, IP reputation, behavioral analytics)
These partners act either as our processors or as independent controllers. We do not sell personal data.
5. International transfers
Personal data may be transferred to and processed in countries outside the UK and EEA. Where this happens, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement, or rely on adequacy decisions where available.
6. Data retention
We retain personal data for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and prevent fraud. Specific retention periods vary by data category. Aggregated and anonymized data may be retained indefinitely.
7. Your rights
Subject to applicable law, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion ("right to be forgotten") where applicable
- Object to or restrict certain processing
- Receive a portable copy of your data
- Withdraw consent at any time, where consent is the lawful basis
- Lodge a complaint with your local supervisory authority — in the UK, the Information Commissioner's Office (ICO)
To exercise any of these rights, email privacy@earnpass.app. We respond within one month, as required by GDPR.
8. Cookies
See our Cookie Policy for details on the cookies we use and how to manage them.
9. Children's privacy
EarnPass is intended for users aged 18 and over. We do not knowingly collect data from children under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
10. Security
We use industry-standard administrative, technical, and physical safeguards to protect personal data, including encryption in transit, restricted access, and ongoing security review. No system is perfectly secure, and we encourage you to use a strong unique password and enable any multi-factor protections we offer.
11. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be highlighted on this page and, where appropriate, notified via the Service.
12. Contact
Privacy enquiries: privacy@earnpass.app
Data Controller: G2 Flow Ltd, registered in England & Wales.