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.
• Payout information: The PayPal email address you wish to receive funds at, collected only when you initiate a cash withdrawal.
• 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, placement IDs, completion states, and reward credits.
• 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: Device attestation tokens via Google Play Integrity API (Android) and Apple App Attest (iOS) to prevent fraudulent reward claims.

2.3 Information from Third Parties

• Offer completion data: When you complete offers through our offerwall partner (CPAlead), they share confirmation of offer completion and reward amounts with us.
• Analytics data: Aggregated usage analytics from Unity Ads and Supabase to 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 Unity Ads (Unity Technologies). Unity Ads may collect device identifiers (GAID on Android, IDFA on iOS), IP address, and ad interaction data. Unity Ads' privacy policy is available at: unity.com/legal/privacy-policy

You can opt out of personalised advertising on Android by enabling "Opt out of Ads Personalisation" in your device settings, or on iOS by selecting "Limit Ad Tracking."

5. Offerwall

Our Earn tab includes an offerwall operated by CPAlead. When you engage with offerwall content, CPAlead collects data necessary to verify offer completions and shares offer completion confirmation with us to credit your wallet. CPAlead's privacy policy is available at: cpalead.com/privacy.php

6. Payments and Payouts

Cash payouts are processed through the PayPal Payouts API (PayPal Holdings, Inc.). When you request a cash withdrawal, we share your PayPal email and the payout amount with PayPal solely to deliver the funds. Your relationship with PayPal is governed by PayPal's own Privacy Statement: paypal.com/uk/legalhub/privacy-full

If and when charitable-donation split payouts are enabled, those specific transactions may additionally be processed through Tremendous, Inc. (tremendous.com/privacy).

We do not store payment card numbers or bank account details. Only the PayPal email you provide at payout time is retained, in encrypted form, for reconciliation and tax-reporting obligations.

7. Data Storage and Security

Your data is stored on servers operated by Supabase (Supabase Inc.), which provides encrypted database and authentication services. Data may be stored in the United States, European Union, or other regions where Supabase operates infrastructure.

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:

• Encrypted data transmission (TLS 1.2+)
• Database-level row-security policies
• Device integrity verification before processing rewards
• Server-side validation of all financial transactions

8. Data Retention

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 — see §8)
• 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.

We do not sell your personal information in exchange for money. Advertising identifiers shared with Unity Ads for ad delivery may, under some US state laws, be considered "sharing" for cross-context behavioural advertising. You may opt out by adjusting your device's advertising settings (see §4) or by emailing us at service@clearearn.site with the subject line "Do Not Sell or Share My Personal Information."

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. Children's Privacy

ClearEarn is intended for users aged 18 and over worldwide. We do not knowingly collect personal information from anyone under 18, which is also the minimum age required by PayPal to receive payouts in most jurisdictions. We comply with the Children's Online Privacy Protection Act (COPPA) in the United States (applicable to users under 13), the UK Age-Appropriate Design Code, and equivalent children's privacy frameworks globally. 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.

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. Third-Party Services

ClearEarn integrates the following third-party services, each with their own privacy policies:

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or via an in-app notification. The "Last updated" date at the top of this policy reflects the most recent revision. Continued use of the App after changes constitutes acceptance of the updated policy.

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