Privacy Policy

Scope: This Privacy Policy applies to the processing of personal data by FlipCoins as the Data Controller.

Contact Details of the Data Controller: Mobavenue Global Holdings Limited, 803 Wimhurst Court, 168 Upper North Street, London, United Kingdom E14 6TX, support@flipcoins.app.

Source of the processed data: Data provided automatically or actively by you, and, where applicable, data provided by third parties (e.g., identity verification and analytics providers).

Purposes of processing: Access to and provision of the App, account registration and authentication, age and identity verification, security and fraud prevention, crediting and redemption of Rewards, service improvement, product development, legal compliance, communication, and marketing, and, where you have consented, matching and enabling optional surveys and other partner activities.

Recipients: Service providers (including hosting, analytics, attribution, payment, and identity-verification providers), government agencies where legally required, and, where you participate in a survey, offer, or game from one of our business partners, that business partner.

Retention period: Data is stored for as long as necessary for the purposes listed above, or longer where required by law or otherwise permissible.

Your control: You may withdraw consent, object to certain processing, and exercise the rights described in Section 10 below at any time by contacting us at the details above.

1. Contact Information for the Data Controller

You can reach us at:

Mobavenue Global Holdings Limited 803 Wimhurst Court, 168 Upper North Street London, United Kingdom, E14 6TX

If you have questions regarding the protection of your personal data, you can also contact us at support@flipcoins.app.

2. Sources of Personal Data

We process personal data from the following sources:

Automatically Collected Data: Technical and usage information collected automatically when you interact with or use the App, including your IP address, advertising ID (GAID), device and app identifiers, information about installed applications, device information (such as device model, operating system, OS version, language, timezone, network and connectivity information), browser type and user agent, app interactions and session information, app usage data described in Section 3, and attribution information such as campaign, source, and referral details. Information about installed applications may be used to determine whether an offer app is already installed on your device, validate eligible offers, and help prevent duplicate or ineligible Rewards. We may also collect technical and usage information for security, fraud prevention, analytics, offer validation, and attribution purposes.

Data actively provided by you: Profile data (e.g., name, email address, date of birth, gender, country, phone number, personal preferences), payment/payout details, identity verification documents, and communications with our support team.

Third-party services: Data from identity-verification, analytics, and attribution service providers, and, where applicable, our business partners (which may include survey, offer, and game providers).

3. Purposes and Legal Basis for Processing

We process personal data for limited purposes and only where we are contractually or legally authorised or obligated to do so, or where you have consented.

3.1 Security and Operation

We process your personal data to technically provide the App and to ensure the security of the services offered to you. Each time you use the App, your device sends technical information to us, which is stored in server logs. This includes connection and access data such as the date and time of use, IP address, device type, operating system, app version, and logins and tasks performed within the App.

We use this data to enable and secure the App, to prevent abuse, and to detect, prevent, and correct errors, including determining whether activity originates from you or from a bot or other automated process.

The legal basis for this processing is our legitimate interest in the protection and functionality of the App.

3.2 Provision of the App and Rewards Program

This includes registration data, contact information, and login credentials so you can create and access your account, and communications to inform you of updates to these Terms or this Policy.

To enable redemption of Rewards, we ask for payment or payout information, which may include your PayPal account information, bank details, or digital wallet identifiers.

We may process identity and age verification data where necessary, including government-issued identification documents, selfies or liveness checks, and related verification data (such as verification status and risk indicators). This data is used to verify your identity and age, enable secure redemptions, prevent fraud, and comply with legal or partner requirements.

We process transaction and Rewards-related data in connection with your participation in Activities on the App, including information about completed Activities, earned Rewards, and related redemption activity.

To prevent fraud and misuse of the App, we may use external service providers acting on our behalf for identity verification and fraud prevention. See Section 7 (Recipients) for more detail.

We process this data where necessary for the performance of our contract with you (these Terms), or to take steps at your request prior to entering into that contract, and based on our legitimate interest in the secure provision of the App.

3.3 Biometric Information

As part of the identity verification process described in Section 3.2, we and our service providers may collect and process biometric identifiers and biometric information, including a selfie photograph or short video, information extracted from a government-issued identification document, and facial geometry or a face template derived from that photograph, for the purpose of confirming that you are the person named in your Account and preventing fraud.

Where required by applicable state law (including the biometric privacy laws of Illinois, Texas, and Washington), we will provide any additional notice and, where required, obtain any written release or consent necessary before collecting this information, and we will not sell, lease, trade, or otherwise profit from your biometric information.

We (or our identity-verification service providers acting on our behalf) retain biometric information only for as long as necessary to complete verification, prevent fraud, and comply with our legal obligations, after which it is permanently deleted or destroyed in accordance with applicable law and our data retention practices.

3.4 Location Data

With your permission, the App may collect approximate or precise location information from your device (for example, to confirm your eligibility to participate in an Activity that is limited to certain states or regions, to prevent fraud, or to improve the relevance of Activities shown to you).

You can enable or disable location access at any time in your device settings. Declining location access does not prevent you from creating or using your Account, though it may limit your ability to participate in Activities that depend on location.

We process this data on the basis of your consent to enable the relevant device permission, and based on our legitimate interest in preventing fraud and ensuring Activities are offered only where permitted.

3.5 Camera Access

With your permission, the App may request access to your device’s camera to allow you to capture a photograph — for example, as part of the identity verification process described in Section 3.3, or to complete certain camera-enabled Activities within the App.

We only access the camera when you actively choose to use a feature that requires it, and any photograph you capture is used solely for the purpose for which it was requested. You can withdraw camera access at any time in your device settings; declining does not prevent you from using your Account generally, though it may prevent you from using features that require the camera.

3.6 Device-Data Features (Installed Apps and App Usage)

The App uses two device-data features related to the apps installed on your device and your usage of them.

We collect information about the apps installed on your device as a standard part of using the App; this does not require a separate device permission. We use this information to filter and exclude offers for apps you already have installed, and to help validate eligible offers and prevent duplicate or ineligible Rewards. Separately, to participate in Android app and game offers, you must grant the relevant usage-access permission, which allows us to measure your use of the apps and games that are part of FlipCoins Activities in order to verify your participation and credit your Rewards. We do not collect usage data for apps that are not part of a FlipCoins Activity, and we do not sell this data or share it with third parties for their own independent purposes.

The installed-apps information described above is collected as part of the App’s core functionality and is not optional. The usage-access permission is required in order to participate in Android app and game offers that depend on usage measurement; you can decline or withdraw this permission at any time in your device settings, but doing so will prevent you from participating in those specific Activities, though it does not otherwise prevent you from creating or using your Account.

We process installed-apps information based on our legitimate interest in operating the Rewards Program and preventing fraud, and as necessary to perform our contract with you where used to validate offers. We process app-usage data based on your grant of the usage-access permission, to perform our contract with you where the data is used to verify participation and credit Rewards, and based on our legitimate interest in preventing fraud and abuse.

3.7 Partner Activities, Surveys, and Special Category Data

In addition to games offered directly within the App, you may earn Rewards by completing activities in partner apps, playing partner games, or, on a more limited basis, completing optional surveys made available by our business partners. This Section explains how we handle the additional profile information associated with these partner activities, and the special category data that may arise specifically from surveys. Surveys are available only to users who are 18 years of age or older (consistent with Section 4 above), and your consent to participate is given when you choose to take a specific survey.

To match you to surveys for which you may be eligible, we may ask you to answer a short set of profile questions (the profiler), such as your gender, date of birth, and postal code.

Some survey providers may ask additional qualification questions before a survey begins. These questions, and the answers you provide, may relate to categories of personal data considered sensitive under applicable law, for example your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, or data concerning your sex life or sexual orientation. Where such questions are answered within the App, your answers are relayed to the relevant survey provider so it can determine whether you qualify; we do not store or log these answers ourselves.

We process the profile information and any sensitive personal data described above only on the basis of your explicit consent. Before surveys are enabled, we ask you to confirm that you are 18 or older. If the information you provide indicates that you are under 18, we do not enable surveys for you.

We use this information solely to identify, match, and enable surveys for you, and not for any other purpose (including other Activities, advertising, analytics, or model training). Your profile answers are stored in encrypted form, with access restricted to a limited group of authorised personnel.

Where a survey is conducted on the survey provider’s own platform (e.g., following a redirect or within an embedded frame), the survey provider processes your responses as an independent controller under its own privacy policy.

Participation in surveys is optional and consent is given on a survey-by-survey basis when you choose to take a specific survey. You may withdraw from a survey at any time before completing it by exiting the survey, and you may decline to participate in any future survey. Withdrawal does not affect the lawfulness of processing carried out before withdrawal; if you have a broader question about survey-related processing, you may contact us using the details in Section 1.

3.8 Improving the App

We continuously work to improve the App, including through data analysis. Where you have consented to the analysis of your personal data for this purpose, we rely on that consent; otherwise, we rely on our legitimate interest in continuously improving the App. We do not use the profile information or survey answers described in Section 3.7 for the analysis and improvement purposes described in this Section.

3.9 Direct Marketing

We may contact you by email or push notification for commercial purposes, such as to inform you about new features, promotions, or special offers. If you are not an existing user, we will only use your contact information for direct marketing if you have given explicit consent. As an existing user, we may process your relevant contact information based on our legitimate interest in providing commercial information related to the App, unless you have objected.

You may opt out of marketing communications at any time, at no cost and without providing a reason, e.g., by using the unsubscribe link or adjusting your notification settings.

3.10 Communication and Support

When you contact us requesting technical or other support, we process the data necessary to respond to your request and provide assistance. We process this data based on the performance of our contract with you and our legitimate interest in providing support.

We may use artificial intelligence or machine-learning-assisted tools to help provide customer support and respond to your inquiries. These tools process the information you provide us in order to generate a response, and outputs may occasionally be inaccurate; we review and may correct such outputs. We process this data on the same legal bases described in this Section.

3.11 Compliance with Legal Obligations

We process personal data where legally obligated to do so, for tax purposes, or based on our legitimate interest in asserting or defending legal claims.

3.12 Audits and M&A Transactions

During the review or negotiation of mergers, financings, acquisitions, or similar transactions, we may analyse personal data and, after balancing the interests of affected parties, disclose it to external auditors, consultants, or attorneys, and other third parties, in connection with such a transaction. The legal basis for this processing is our legitimate interest in demonstrating compliance and ensuring necessary business functionality.

4. Age Requirement

The App is intended solely for use by individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18; confirming that you meet this age requirement is part of the consent screen presented when you use the App.

If we learn that we have collected personal data from someone under 18, we will take steps to delete that data and close the associated Account. If you are a parent or guardian and believe your child has provided us with personal data, please contact us using the details in Section 1.

5. Recipients

We do not sell personal data to third parties for monetary consideration. We may disclose personal data to others where you have given consent, where necessary for the performance of our contract with you, or where required by law. Recipients include, in particular:

Hosting and infrastructure providers: to host and operate the App and its data (the App is hosted on cloud infrastructure located in the United States).

Analytics and attribution providers: to measure app performance, usage, and marketing attribution.

Payment and payout providers: to process redemptions, including gift card and cash payouts.

Identity verification and fraud-prevention providers: to verify your identity and age and to detect and prevent fraud, as described in Sections 3.2 and 3.3.

Business Partners: where you participate in a survey, offer, or game made available by one of our business partners, we share the profile and activity information necessary to determine your eligibility for, and to deliver, that activity, and we relay any qualification answers you provide, on the basis of your consent or as necessary to provide the Rewards Program. We do not permit our business partners to use this information for their own independent marketing purposes.

Government authorities: where required by law or legal process.

Professional advisors: legal, financial, and other advisors, auditors, and other third parties who are subject to confidentiality obligations, including in connection with the audits and transactions described in Section 3.9.

Current Vendor / Sub-Processor List (to be completed and kept current by the technical team — add a row per vendor actually integrated)

All service providers are contractually bound to appropriate confidentiality and data-protection obligations. Upon request, we can provide additional information regarding the categories of recipients of your personal data.

6. Cross-Border Data Transfers

We are part of a corporate group with operations in the United Kingdom, the United States, and India. Your personal data may accordingly be transferred to, and processed in, countries other than the one in which you reside, including the following:

United States: The App’s production data is hosted on cloud infrastructure located in the United States, and certain service providers described in Section 5 are located there.

India: Members of our affiliated engineering and support teams, located in India, may access production data hosted in the United States for development, maintenance, and customer-support purposes.

United Kingdom: We, as the data controller, are established in the United Kingdom.

Where we or our affiliates transfer personal data out of the United Kingdom or the European Economic Area to a country that has not been recognised as providing an adequate level of data protection, we rely on appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (together with any additional measures necessary in the circumstances), or another applicable exception. This includes the transfer of data access described above between our United Kingdom, United States, and India operations.

We maintain internal access controls limiting which personnel, including our India-based engineering and support teams, may access production data, and access is limited to what is necessary for their role.

Upon request, we can provide additional information regarding the safeguards applicable to a specific transfer.

7. Retention and Deletion

We generally process personal data only until the purposes described in this Policy have been fulfilled. Afterward, we delete or anonymise personal data, unless we are legally required to retain it for a longer period (e.g., for tax or accounting purposes), you have consented to further storage, or we have a legitimate interest in further processing that outweighs your interest in deletion, such as where processing is necessary to assert or defend legal claims.

We store the personal data processed during registration and login for the duration of your account with us and, where necessary, beyond that period to demonstrate compliance with contractual or legal obligations or to assert or defend legal claims.

Where your Account has not been used for six (6) months or more, it may be considered inactive; see Section 11 of our Terms of Service for how we handle inactive and closed Accounts. Even after your Account is closed or a data deletion request has been completed, we may retain certain device-specific information (such as a device identifier) for a further period, solely for fraud-prevention purposes.

Where you have enabled surveys, we retain your encrypted profile answers for as long as your consent remains active and the data is needed to match and enable surveys for you. If you withdraw consent or delete your Account, we delete or anonymise this data. Qualification-question answers relayed to survey providers are not stored by us.

Identity verification data, including any biometric information described in Section 3.3, is retained for as long as necessary to comply with our fraud-prevention and legal obligations, after which it is deleted or anonymised in accordance with applicable law.

8. Your Privacy Rights

Depending on your state of residence, you may have rights under applicable US state privacy laws (which may include, among others, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and other state comprehensive privacy laws in effect from time to time). Subject to applicable law and any exemptions, these rights may include the right to:

Know/access the categories and specific pieces of personal data we have collected about you, and the categories of sources, purposes, and third parties involved.

Delete personal data we have collected from you, subject to certain exceptions (e.g., to complete a transaction, detect security incidents, or comply with a legal obligation).

Correct inaccurate personal data we maintain about you.

Opt out of the sale or sharing of your personal data, where applicable. We do not sell personal data for monetary consideration; some data-sharing arrangements with analytics or attribution providers described in Section 5 may nonetheless be considered a sale or share under certain state laws’ broad definitions.

Limit the use and disclosure of sensitive personal information, where applicable (e.g., certain data described in Section 3.7).

Non-discrimination for exercising any of these rights.

Appeal a decision we make regarding your request, where applicable under your state’s law.

To exercise these rights, you or your authorised agent may contact us using the details in Section 1. We may need to verify your identity before completing your request. If we deny your request, you may have the right to appeal that decision using the process we provide in our response.

We do not respond to browser “Do Not Track” signals. Where the personal data we share with the service providers described in Section 5 is used solely to track your completion of Activities and credit your Rewards, that sharing is necessary to provide the Rewards Program you requested and does not constitute a “sale” or “share” of personal data, or processing for targeted advertising, under applicable state law; accordingly, opt-out preference signals (such as the Global Privacy Control) do not affect this specific data flow, though we otherwise honor such signals where they indicate an opt-out of a sale or share as described above.

If you are a California resident, you may request, once per year and free of charge, information about personal data we disclosed to third parties for their direct marketing purposes in the preceding calendar year, under California Civil Code Section 1798.83 (“Shine the Light”). If you are a Nevada resident, you have the right to direct us not to sell certain covered information about you to third parties for monetary consideration; we do not engage in such sales, but you may still submit a request using the contact details in Section 1.

As the data controller, we are established in the United Kingdom and are separately subject to UK data protection law with respect to our own compliance obligations as a controller; this does not itself confer rights under the UK GDPR or EU GDPR on users located in the United States, whose rights are governed by the applicable US state law described above.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Changes are effective immediately when posted within the App or at the linked web page. Your continued use of the App following the posting of a revised Policy means you accept the changes. We encourage you to review this Policy periodically.

10. Contact Us

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us at:

Mobavenue Global Holdings Limited 803 Wimhurst Court, 168 Upper North Street London, United Kingdom, E14 6TX, support@flipcoins.app.