Draft document
This is an initial draft that must be reviewed by a qualified lawyer before ViewEarn launches. It does not claim compliance with any specific law. Items in [square brackets] are placeholders to be completed by the operator.
1. Controller
[OPERATOR LEGAL NAME], [REGISTERED ADDRESS], is the controller of your personal data. Data protection contact: [DPO / PRIVACY CONTACT EMAIL].
2. Data we collect
Account data: username, email address, hashed password, country, date of birth (to confirm you are an adult), language and preferences.
Activity data: offer completions and reversals reported by offer networks, wallet transactions, redemption requests, referrals, support tickets and achievements.
Technical and security data: IP address, browser user agent, session records, login attempts and a device identifier used for fraud prevention.
Reward fulfilment data: the delivery email you provide and the reward details we issue to you.
3. Why we use your data
To provide the service under our contract with you (accounts, crediting points, redemptions, support).
For our legitimate interests in preventing fraud, securing accounts and improving the service.
To comply with legal obligations such as accounting and tax record keeping.
With your consent, for optional marketing emails, which you can switch off at any time.
[LEGAL BASES TO BE CONFIRMED BY COUNSEL FOR EACH JURISDICTION.]
4. Sharing
Offer networks (such as Offerwall.GG) receive a pseudonymous user identifier so that completions can be attributed to your account. When you interact with an offer, the network and advertiser process data under their own privacy policies.
We use service providers for hosting, email delivery and security, bound by data-processing agreements. We do not sell your personal data.
5. International transfers
[TO BE COMPLETED BY COUNSEL: transfer mechanisms such as Standard Contractual Clauses where data leaves the EEA / your country.]
6. Retention
We keep account data while your account is open. Financial ledger records and fraud-prevention records are retained for the period required by law and for our legitimate interests [RETENTION PERIODS TO BE CONFIRMED].
7. Your rights
Depending on your location you may have the right to access, correct, delete, restrict or port your data, and to object to certain processing. You can exercise these rights by contacting us. You may also complain to your data protection authority.
8. Public information
Your username, country and achievement data may appear on leaderboards or your public profile. You can make your profile private and opt out of leaderboards in settings. Your email and personal details are never shown publicly.
Version: draft, not yet in force.