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Privacy Policy

Draft — subject to legal review before public launch

This Privacy Policy explains how Earno ("Earno", "we", "us") collects, uses and shares personal data when you use our website, applications and services (the "Service"). By using the Service you acknowledge the practices described here.

Placeholder legal document. The data controller entity, registered address and Data Protection contact are marked [TBC] and will be completed, together with a counsel review, before Earno opens to the public. This draft does not constitute legal advice.

1. Who we are

The data controller is [TBC — Earno legal entity]. For any privacy request, contact [email protected].

2. Data we collect

  • Account data — email address, authentication identifiers (e.g. Google/Apple sign-in), country, and profile/preferences you provide.
  • Optional questionnaire — if shown, your answers about interests and goals.
  • Activity data — Offers viewed and completed, balances, transactions, referrals, and support messages.
  • Device & technical data — IP address, device and browser characteristics, a device fingerprint, and approximate location derived from IP, used for security and fraud prevention.
  • Verification (KYC) data — where required for withdrawals, identity information and documents, collected and processed via a third-party verification provider.
  • Cookies & similar — see our Cookie settings.

3. Why we use it and our legal bases

  • To provide the Service (create your account, track Offers, maintain balances, process withdrawals) — performance of a contract.
  • Fraud prevention and security (device checks, VPN/proxy detection, one-account enforcement) — legitimate interests and legal obligations.
  • Identity verification / anti-money-laundering — compliance with legal obligations.
  • Improvement and analytics — legitimate interests, and consent where required (e.g. analytics cookies).
  • Communications about your account and, with consent where required, product updates.

4. How we share data

We share personal data only as needed with:

  • Offer, survey and advertising Providers — to attribute completions (e.g. a click/transaction identifier), not to sell your identity.
  • Processors that operate on our behalf — hosting, KYC/identity verification, payout providers (crypto and gift-card issuers), fraud-scoring, email and analytics.
  • Authorities where required by law, or to protect our rights, users or the Service.

We do not sell your personal data.

5. International transfers

Your data may be processed in countries other than yours. Where it is, we rely on appropriate safeguards (such as Standard Contractual Clauses) as required by applicable law.

6. Retention

We keep personal data for as long as your account is active and as needed to provide the Service, then for the period required to meet legal, tax, accounting and fraud-prevention obligations, after which it is deleted or anonymized.

7. Your rights

Depending on your location, you may have the right to access, correct, delete, restrict or object to processing of your personal data, to data portability, and to withdraw consent. You may also lodge a complaint with your local data protection authority. To exercise a right, contact [email protected]. We may need to verify your identity, and some data must be retained where the law requires.

8. Children

The Service is for users 18 and older. We do not knowingly collect data from anyone under 18; if we learn we have, we will delete it.

9. Security

We use technical and organizational measures to protect personal data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Changes

We may update this Policy; the current version takes effect when posted, and the date above reflects the latest revision.

11. Contact

Privacy questions: [email protected].

We’re still in development

Earno isn’t open to the public just yet — we’re building it right now. Check back soon.

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