Privacy Policy

1. Who We Are

ClearEarn is operated by GIE Consultants Ltd, a company registered in England and Wales (company number 6480238). We can be contacted at:

• Email: service@clearearn.site
• Website: https://clearearn.site
• Registered address: Reading, UK

GIE Consultants Ltd is the Data Controller for personal data collected through the App for purposes of UK GDPR, EU GDPR, LGPD, PIPEDA and equivalent laws. In the United States, GIE Consultants Ltd is the Business handling your personal information under CCPA/CPRA and other state privacy laws.

2. Information We Collect

2.1 Information You Provide Directly

• Account information: Email address and password, collected only when you choose to register an account to claim your earnings. You can use the App anonymously until this point.
• Date of birth: Collected once at onboarding so we can verify you meet our minimum-age and payout-eligibility rules. See Section 10. Used only for age verification and stored as a date (not a full birth date plus location).
• Payout recipient email: The email address you want your rewarded payouts delivered to. This is collected separately from your account email so the two can differ (for example, if your payment provider account uses a different inbox). We verify ownership by sending a magic-link confirmation; the verification token is stored only as a one-way SHA-256 hash, expires within 24 hours, and is single-use. The verified address itself is retained as described in Section 8.
• Payout information: Any further recipient details required by your chosen payout method — collected only when you initiate a payout.
• Referral code (optional): If you enter a referral code during registration, we link your account to the referring user so they receive the referral bonus.
• Communications: Any messages or support requests you send us.

2.2 Information Collected Automatically

• Anonymous device ID: Generated locally on your device and used to associate your pre-registration wallet balance with your device (so you don't lose earnings before you register).
• Device information: Device type, operating system version, mobile network type, app version.
• Usage data: App activity, gameplay data, session duration, features used, in-app events.
• Advertising data: Ad impressions, ad requests, ad completions, placement IDs, completion states, ad-interaction events, reward-credit events, device identifiers, advertising identifiers where available, IP address, approximate location derived from IP address, and related technical signals used for ad delivery, measurement, frequency capping, fraud prevention, and personalised or contextual advertising where permitted.
• IP address: Used for fraud detection, rate-limiting, and approximate country-level analytics. Our ad partners may independently use IP address to determine ad rates paid per view.
• Device integrity data: Signals used to verify device authenticity and prevent fraudulent reward claims.

2.3 Information from Third Parties

• Offerwall and offer-completion data: When you open or complete offers through CPAlead or another offerwall partner, the partner may share offer IDs, click IDs, sub IDs, lead IDs, completion status, reward amount, country, timestamp, fraud or rejection status, reversal status, and related tracking or postback information with us so we can validate activity, credit or reverse Points, prevent fraud, and resolve support requests.
• Analytics data: Aggregated usage analytics from our service providers to help us understand and improve App performance.

3. How We Use Your Information

We use your information for the following purposes:

We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

4. Advertising

ClearEarn displays advertising served by third-party advertising partners, including Unity Ads. Advertising partners may collect or receive device identifiers, advertising identifiers where available, IP address, approximate location derived from IP address, app and device information, ad requests, ad impressions, ad completions, placement IDs, campaign events, and ad-interaction data. They use this information for ad delivery, measurement, reporting, fraud prevention, frequency capping, contextual advertising, and, where legally permitted and consented to where required, personalised advertising.

In the UK, EEA, Switzerland, and other regions where consent is required, we will request consent before enabling personalised advertising or non-essential ad tracking. You can withdraw consent or change your advertising preferences through the App where available, your device settings, and any privacy controls shown inside Unity Ads.

On Android, you can reset or delete your advertising ID and manage ad-personalisation settings in your device privacy settings. Where applicable, you may also opt out of “sale,” “sharing,” targeted advertising, or cross-context behavioural advertising by emailing service@clearearn.site with the subject line “Do Not Sell or Share My Personal Information.”

5. Offerwall

Our Earn tab includes an offerwall powered by CPAlead and may include other offerwall partners. When you open or complete offerwall content, CPAlead, the applicable advertiser, and any other offerwall partner may collect information directly from you and your device, including identifiers, IP address, device information, approximate location, click and offer IDs, completion status, and any information you choose to submit to the advertiser, such as survey responses, registration details, purchase details, subscription details, or app-install activity.

CPAlead and advertisers may process this information under their own terms and privacy policies. ClearEarn receives only the information we need to validate offers, credit or reverse Points, prevent fraud, keep wallet records, and respond to support requests. We do not control CPAlead’s or advertisers’ independent privacy practices. You should review the relevant offer terms and privacy notices before starting an offer.

Points for offers are credited only when CPAlead or the applicable offerwall partner confirms a valid completion through its tracking or postback systems. A credited offer may later be reversed if the partner or advertiser reports fraud, duplication, cancellation, refund, chargeback, advertiser rejection, tracking error, or breach of offer rules.

6. Payments, Payouts and Where the Service Operates

How we credit you in-app

Your in-app balance is denominated in Points. Unless the App states otherwise, 100 Points currently equals US $1.00 before local-currency conversion, provider fees, or currency charges shown at redemption. Points may be earned from the weekly community reward pool, validated partner offers, streak bonuses, referrals, or other eligible activities described in our Terms of Service and shown in the App.

Points are credited after the relevant qualifying activity is validated. For offerwall activity, this means confirmation from CPAlead or the applicable offerwall partner through tracking or postback systems. Watching ads inside games may provide in-game boosts and does not credit cash or Points.

How payouts are processed

Payouts are available in the redemption forms shown inside the App, currently including gift card redemptions and rewarded payouts where available. Gift cards are sent to the account email or redemption email shown in the App. Rewarded payouts require a verified payout email and are processed by third-party payout providers.

Rewarded payouts convert eligible Points to the applicable local currency at the time of withdrawal using the rate disclosed before you confirm. Provider fees, local-rail charges, or currency-conversion charges may apply where shown before confirmation.

Payout email verification

Before your first rewarded payout you must confirm the email address you want to receive money at. We send a one-time confirmation link to that address; clicking the link proves you control the inbox and unlocks redemption. Until you complete this step, the cash-payout option in the App is unavailable. You can change the verified address at any time by repeating the process.

We do this for two reasons: (1) to prevent a typo or compromise of your in-app account from sending money to the wrong inbox, and (2) because your payment provider's email is often different from the one you use to sign in to the App. The two are intentionally decoupled.

Technical detail: the confirmation link contains a 256-bit random token. We store only a one-way SHA-256 hash of that token in our database — never the token itself — and the token expires within 24 hours and can only be used once. A token leaked from our database cannot be replayed against the verification endpoint.

Sharing with payment providers and operations

When you request a payout, we share with the relevant provider the minimum information needed to deliver it (recipient email, amount, currency where applicable, and any other detail required by the chosen method). Your relationship with the payment provider is governed by its own terms and privacy policy.

For rewarded payouts that we currently process manually, our operations staff are notified when a request comes in. The notification email itself contains no personal information beyond "a new request exists" — full request detail is only visible to operations staff after they sign in to our internal admin interface.

If and when charitable-donation split payouts are enabled, those specific transactions may additionally be processed through a separate provider, identified at the moment of donation.

We do not store payment card numbers or full bank account numbers beyond what is required to submit the payout to the provider. Recipient details you provide at payout time are retained, in encrypted form, for reconciliation, fraud-prevention, and tax-reporting obligations.

Where the Service operates

The earning and rewards features of the App are currently available only to users physically located in the following countries: United States, United Kingdom, Ireland, Germany, France, Netherlands, Sweden, Norway, Denmark, Finland, Switzerland, Austria, Belgium, Australia, New Zealand, and Canada. We may expand or restrict supported countries over time and will update this policy and the App accordingly.

We do not discriminate based on your nationality, place of residence, or place of establishment. The country list above reflects the locations where we currently operate the service; our in-app gates check the device's detected physical location only, not your account residency or citizenship. This is consistent with the EU Geo-blocking Regulation (Regulation (EU) 2018/302) for users in the EU and EEA Member States we serve.

7. Data Storage and Security

Your data is stored with our cloud-infrastructure providers in the United States, European Union, or other regions where they operate.

For transfers of personal data from the UK or European Economic Area to countries without an adequacy decision, we rely on the UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO) and the European Commission respectively. For users in Brazil, Canada, Australia and other jurisdictions, equivalent contractual safeguards are in place with each processor.

We implement appropriate technical and organisational measures to protect your personal data, including encryption of data in transit and at rest, access controls, and validation of activity that affects your wallet.

8. Data Retention

Note on verified payout email addresses: we retain these for up to seven years even after account closure. We rely on the GDPR legitimate interest basis (Article 6(1)(f)) for this — specifically, the prevention of payout fraud across user accounts and the satisfaction of any anti-money-laundering / know-your-customer obligations imposed on our payment providers. The address is treated as an identifier only and is not used for marketing.

9. Your Rights

Regardless of where you live, you can contact us at service@clearearn.site to exercise any right below. We respond within 30 days (or sooner where the law requires).

Baseline rights for all users

• Access the personal data we hold about you
• Rectification of inaccurate data
• Deletion of your data (subject to our legal retention obligations described in the Data Retention section above)
• Data portability — receive your data in a structured, machine-readable format
• Withdraw consent at any time where processing is based on consent

Under UK GDPR / EU GDPR (UK, EEA, Switzerland)

In addition to the baseline rights, you have the right to:

• Restrict processing of your data
• Object to processing based on legitimate interests or direct marketing
• Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects
• Lodge a complaint with your local supervisory authority — in the UK, the Information Commissioner's Office (ICO) at ico.org.uk; elsewhere, see edpb.europa.eu

Under CCPA / CPRA (California) and other US state privacy laws

Residents of California, Colorado, Connecticut, Virginia, Utah, and other US states with privacy laws have the right to know, delete, correct, opt out of "sale" or "sharing" for cross-context behavioural advertising, limit use of "sensitive personal information," and not be discriminated against for exercising their rights.

ClearEarn does not sell your account or payout information in exchange for money. However, advertising and offerwall partners may receive identifiers, device data, ad-interaction data, offerwall activity, approximate location, and related technical information for advertising, attribution, measurement, fraud prevention, offer validation, and, where permitted, personalised advertising. Some US state privacy laws may treat this activity as “sale,” “sharing,” targeted advertising, or cross-context behavioural advertising.

You may opt out by using your device advertising settings, App privacy controls where available, Unity Ads privacy controls where shown, or by emailing service@clearearn.site with the subject line “Do Not Sell or Share My Personal Information.” If you interact directly with CPAlead or an advertiser, you may also need to exercise privacy rights directly with that third party under its own privacy policy.

Under LGPD (Brazil)

Brazilian residents have the rights to confirm processing, access, correct, anonymise, block or delete unnecessary data, port data to another service, obtain information about third parties with whom we share data, revoke consent, and review automated decisions. Complaints can be filed with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd

Under PIPEDA (Canada)

Canadian residents have the right to access and correct their personal information. You can also contact the Office of the Privacy Commissioner of Canada at priv.gc.ca

Under the Privacy Act 1988 (Australia)

Australian residents have rights of access and correction. Complaints can be made to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au

Other jurisdictions

If you live outside the regions listed above and your local law provides privacy rights, we will honour those rights in good faith. Contact us at service@clearearn.site to make a request.

10. Age policy and children's privacy

ClearEarn is an adults-only service:

• Minimum age to use the App: 18. All features — earning, redeeming gift cards, and requesting rewarded (cash) payouts — require users to be at least 18 years old. We collect a date of birth once at onboarding and reject any user who declares an age below 18.
• The 18+ requirement aligns with our payment providers' minimum age and with the app store rating assigned to ClearEarn for real-money-rewards content.

The minimum-age check is performed server-side at signup and again at every payout request, so a user who later changes their stored date of birth cannot retroactively bypass the policy.

ClearEarn is not directed to children. We do not knowingly collect data from anyone under 18. If we become aware that we have collected data from a person under 18, we will delete it immediately. If you believe we have inadvertently collected data from a minor, please contact us at service@clearearn.site.

This policy also satisfies our obligations under the Children's Online Privacy Protection Act (COPPA) in the United States, the UK Age-Appropriate Design Code, and equivalent children's privacy frameworks globally — all of which we exceed by setting the minimum age at 18 rather than 13.

11. Push Notifications

We may send push notifications for account activity, payout confirmations, and promotional messages. You can disable push notifications at any time through your device settings.

12. Categories of Third-Party Services

ClearEarn relies on the third-party providers and categories below. We may add, remove, or replace providers over time, but we will update this policy when a material provider change affects how your personal information is collected, used, disclosed, or protected.

Some third-party providers act as our processors or service providers, while others may act as independent controllers or businesses for their own purposes. In particular, Unity Ads, CPAlead, and advertisers may process certain information under their own privacy policies when they serve ads, operate offerwalls, validate offers, prevent fraud, or collect information directly from you. ClearEarn is responsible for the personal information it controls, but we do not control the independent privacy practices of CPAlead, Unity Ads, advertisers, payout providers, or app stores.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email, in-app notice, or website notice where appropriate. Material changes to advertising, offerwall, payout, or provider data-sharing practices will be reflected in this policy. The “Last updated” date at the top of this policy reflects the most recent revision. Continued use of the App after changes take effect constitutes acceptance of the updated policy where permitted by law; where consent is required, we will request consent separately.

14. Contact Us

For any privacy-related questions, requests, or complaints:

• Email: service@clearearn.site
• Address: Reading, UK

For UK GDPR matters, our Data Controller contact is: service@clearearn.site