EarnWise— Privacy Policy

Last Updated: June 22, 2026

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Contents

1. Information We Collect

2. Personal Information YouProvide Us

3. Personal InformationObtained From Third Parties

4. Personal Information WeCollect Automatically From Your Use of the Services

5. How We Use Your PersonalInformation

6. How We Share YourPersonal Information

7. Third Party Services andLinks

8. Security

9. Data Retention

10. Your Rights and Choices

11. Use of Services ByChildren

12. InternationalCross-Border Data Transfer

13. Your California PrivacyRights (California Residents Only)

14. Residents of Other U.S.States

15. Updates To This PrivacyPolicy

16. Contact Us

At Mode Mobile, your privacy isimportant to us. This Privacy Policy explains how we collect, use, process,share, and safeguard Personal Information about you gathered through theEarnWise mobile application and related online services (collectively, the“Services”). It also describes your rights and choices and how to contact us.The terms “EarnWise,” “Mode Mobile,” “we,” and “us” include Mode Mobile, LLCand its affiliates and subsidiaries. By using the Services, you agree to theprocessing of your Personal Information as described in this Privacy Policy.Your use of the Services is also subject to our Terms of Service.

EarnWise is currently offered onAndroid only and is intended for users located in the United States who are atleast 18 years old.

1. Information We Collect

For the purpose of this PrivacyPolicy, “Personal Information” means any information relating to an identifiedor identifiable individual. We obtain Personal Information about you from thesources described below. Where applicable, we indicate whether you must providePersonal Information and the consequences of not doing so. If you do notprovide Personal Information when requested, you may not be able to use theServices or particular features if that information is necessary to providethem or if we are legally required to collect it.

2. Personal Information You ProvideUs

Registration.

To use EarnWise, you sign inwith Google. Through Google Sign-In, we receive your name and email address,and a unique account identifier is created on a one-to-one basis with youremail. You may also set a display name within the app.

Profile Information.

You may provide additionalprofile information, such as your date of birth, gender, postal code, and age.Some of this information is optional, and you may be rewarded with EarnWiseCredits for providing it.

Survey Responses.

When you complete surveysoffered through the Services, we and our survey partners collect the responsesyou provide, which may include demographic and lifestyle information.

Identity Verification and Biometric Data.

To cash out EarnWise Credits, werequire identity verification using our third-party provider, Verisoul. Withyour express opt-in consent, provided via a separate in-app consent screenpresented before any biometric capture, this may include:

●     Facial scan. You provide a “video selfie” using your device camera. Fromthis, a face map (a mathematical representation of your face) is generated toverify your identity, confirm that redemptions are genuine, and detect accountduplication and fraud. Under applicable laws, the facial scan may be considered“biometric data.”

●     Government identificationdocument. Where facial verification isunavailable or unsuccessful, you may be asked to submit an image of agovernment-issued identification document, from which we and Verisoul mayextract identifying information to verify your identity.

As used in this Privacy Policy, biometricdata means any biological characteristic of a person, or information basedon such a characteristic, including characteristics defined as “biometricidentifiers” and “biometric information” under the Illinois BiometricInformation Privacy Act, 740 ILCS 14/1, et seq. A “biometric identifier”includes a scan of face geometry; “biometric information” means any informationbased on a biometric identifier used to identify an individual.

We retain and use biometric dataas follows:

●     Purpose of Collection. We use biometric data solely to detect and protect againstdeceptive, fraudulent, or illegal activity, specifically to verify youridentity, expedite legitimate redemptions, and assess possible accountduplication.

●     Express Consent. We collect biometric data only from users who first consentand opt in via a separate written consent screen presented in the app beforeany biometric capture. Without express consent, no biometric data is collected.

●     Storage and Third-PartyDisclosure. Biometric data is storedencrypted on Verisoul’s servers. Mode Mobile does not store raw biometric dataon its own servers. We share biometric data only with Verisoul, acting on ourbehalf solely to perform identity verification. We do not sell, lease, trade,or otherwise profit from biometric data.

●     Disclosure for LegalPurposes. We will not otherwise disclosebiometric data except as required by law.

●     Retention. We retain biometric data only until, and permanentlydestroy it upon, the earlier of: (1) within thirty (30) days of receivingnotice of an account deletion request; or (2) within one (1) year of when theinitial purpose for collection or retention has been satisfied.

Communications.

If you contact us (for example,through the in-app “Message us” support form, by submitting a review, or byemail), we may receive your name, email address, the contents, date, and timeof your message, and other information you choose to provide.

3. Personal Information Obtained FromThird Parties

Google Sign-In.

When you sign in with yourGoogle credentials, we collect the information you have authorized Google toshare with us, such as your name and email address. Please refer to Google’sprivacy policy for information about what Google shares.

Survey, Offer, and Game Partners.

When you engage with surveys,offers, or games offered through the Services, our partners (for example,survey providers and game publishers) may share with us information about youractivity, such as completion status, completion postbacks, reward eligibility,and identifiers used to attribute your activity.

Attribution and Advertising Partners.

We work with attribution andadvertising partners that may provide us with information about how you came toinstall or use the Services and about advertising you have been served.

4. Personal Information We CollectAutomatically From Your Use of the Services

When you use the Services, weand our third-party service providers may collect information through automatedmeans, such as SDKs, mobile identifiers, and server logs. The informationcollected in this manner includes: IP address, device IDs and characteristics(including advertising identifiers such as the Google Advertising ID),operating system and version, language preferences, country code andapproximate location, network information, app interactions and events, theactivities you complete, the surveys, offers, and games you engage with, andyour reward and redemption history. We may use this information to operate andsecure the Services, calculate EarnWise Credits, confirm legitimate taskcompletion, detect and prevent fraud, personalize content and offers, andanalyze usage.

Location.

We collect approximate locationand related signals (for example, from IP address and device settings) toconfirm that you are eligible to use the Services in your territory and todetect and prevent fraud, including the use of VPNs or location-spoofing. We donot collect precise GPS location at launch.

Analytics.

We work with analyticsproviders, including Mixpanel, that use SDKs and similar technologies tocollect and analyze information about use of the Services and report onactivity and trends.

Advertising.

Third parties that advertisegoods or services through the Services, and our advertising partners (includingmobile advertising networks such as AppLovin/MAX), may use identifiers andsimilar technologies to measure and deliver advertising, including interest-basedadvertising, and to provide us with measurement and analytics. Your devicesettings let you manage advertising identifiers and interest-based advertising.On Android, you can reset or delete your Advertising ID and opt out ofpersonalization in your device’s settings. You may also learn about yourchoices through the Digital Advertising Alliance’s AppChoices tool.

Hashed Email Identifiers.

We may convert your emailaddress into a hashed identifier (a fixed-length alphanumeric string generatedby applying a cryptographic algorithm to your email address) for use in fraudprevention, audience matching, advertising measurement, and other purposesdescribed in this Privacy Policy. We treat hashed email identifiers as PersonalInformation, because a hashed email may be matched to your identity throughidentity-resolution tools or third-party datasets. Hashed email identifiers maybe shared with advertising and identity-resolution partners for audiencematching, measurement, and suppression, and to prevent previously banned orfraudulent users from re-registering. We retain hashed email identifiers for nolonger than 24 months from collection or last interaction, unless a longerperiod is required by law or necessary to defend against legal claims. You mayexercise your rights with respect to hashed email identifiers by contacting usat privacy@modemobile.com.

5. How We Use Your PersonalInformation

Internal and Service-Related Usage.

We use Personal Information tooperate, provide, and maintain the Services, including to calculate EarnWiseCredits, process redemptions, and reuse our shared reward, fraud, and payoutinfrastructure.

Identity Verification and Fraud Prevention.

We use Personal Information,including verification and biometric data (with consent) and behavioral anddevice signals, to verify your identity, confirm legitimate redemptions, detectand prevent fraud, deception, and policy violations, and enforce one-account-per-personand account-clustering controls.

Analytics and Improving the Services.

We and our service providers usePersonal Information, such as your location and activities, to monitor andanalyze usage and to improve the Services.

Communications.

We may contact you forcustomer-service or technical-support purposes and to send you information,updates, and push notifications about the Services and features.

Advertising and Tailored Content.

We and our partners may usePersonal Information, including your location and activities, to deliver andmeasure advertising and to provide you with personalized content, surveys,offers, and recommendations.

Aggregate Data.

We may de-identify and aggregateinformation for statistical analysis and other lawful purposes.

Legal.

We may use Personal Informationto enforce our Terms of Service, defend our legal rights, and comply with ourlegal obligations and internal policies.

Automated Decision-Making.

We use automated processing inconnection with the Services, including: (a) Credit calculation based onpredefined rules and your activity; (b) redemption and identity verification,including facial recognition where you have consented, to assess whether aredemption is legitimate and whether account duplication has occurred; (c) fraudand abuse detection based on behavioral and account-activity signals, whichmay result in temporary or permanent account restrictions and Creditforfeiture; and (d) personalization of content, offers, andrecommendations based on your usage and preferences. Where any such automatedprocess produces a decision with a legal or similarly significant effect on you(such as account suspension, redemption denial, or earning disqualification),you may contact us at privacy@modemobile.com to request human review, expressyour point of view, and contest the decision.

6. How We Share Your PersonalInformation

We disclose Personal Informationto third parties in the following circumstances:

●     Affiliates andsubsidiaries. We may share PersonalInformation with our affiliates and subsidiaries, including for shared reward,fraud, and payout infrastructure across our applications.

●     Service providers. We share Personal Information with third-party serviceproviders that perform services on our behalf under our instructions andappropriate safeguards, such as cloud hosting, identity verification, paymentand payout processing, survey and offer provision, analytics, customer support,fraud prevention, and advertising measurement. Our current providers include,among others: Google (authentication), Verisoul (identity and biometricverification and fraud signals), our survey partners (including TapResearch andPrime Insights), our game and offer partners, AppLovin/MAX (advertising), ourattribution partner(s), Mixpanel (analytics), our notifications provider,PayPal (payouts), and our prepaid card issuer (payouts).

●     Payout providers. When you redeem Credits, we share the information necessaryto process your payout (such as your linked PayPal email or card details) withthe applicable payout provider.

●     Sale or sharing foradvertising. We may sell or share certainPersonal Information with advertising partners, analytics providers, andidentity-resolution platforms for commercial purposes. As used here, “sell”means disclosing Personal Information to a third party for monetary or othervaluable consideration, and “share” means disclosing it for cross-contextbehavioral advertising, as those terms are defined under the CaliforniaConsumer Privacy Act as amended (“CCPA/CPRA”). Categories we may sell or shareinclude identifiers (such as email, hashed email identifiers, IP address, anddevice identifiers), commercial information (such as reward and redemptionhistory), internet or network activity, geolocation data, and inferences. Ifyou are a California resident, you have the right to opt out of the sale orsharing of your Personal Information at any time; see Section 13 or contact usat privacy@modemobile.com.

●     Business transfers. We may share Personal Information with a potential oractual acquirer, successor, or assignee as part of any merger, sale, financing,reorganization, or similar transaction. We will use reasonable efforts todirect the recipient to process your information consistently with this PrivacyPolicy.

●     Legal and protection. We may disclose Personal Information if required by law orin the good-faith belief that disclosure is appropriate to comply with legalprocess, respond to governmental requests, enforce our Terms, protect ouroperations or those of our affiliates, or protect our or others’ rights,privacy, safety, or property.

●     Aggregate or de-identifiedinformation. We may use and discloseaggregate or de-identified information that does not identify an individual forany purpose.

Third parties that receive yourPersonal Information from us are required by contract to use it only for thepurposes for which it was disclosed and in compliance with applicable law.

7. Third Party Services and Links

This Privacy Policy applies onlyto the processing of your Personal Information by Mode Mobile. It does notaddress, and we are not responsible for, the privacy or other practices ofthird parties, including any third-party survey provider, game publisher,advertiser, payment provider, or site or service to which the Services link.The inclusion of a link or integration does not imply endorsement. Pleasereview the privacy policies of those third parties.

8. Security

We maintain administrative,technical, and physical safeguards intended to protect Personal Informationagainst accidental or unlawful destruction, loss, alteration, unauthorizeddisclosure or access, misuse, and any other unlawful form of processing. Nomethod of transmission or storage is completely secure, and we cannot guaranteeabsolute security.

9. Data Retention

We take measures to delete yourPersonal Information, or keep it in a form that does not identify you, when itis no longer necessary for the purposes for which we process it, unless we arerequired by law to keep it longer. The following retention periods apply to theprincipal categories of Personal Information we collect:

●     Account and profile data: retained for the duration of your account and deletedwithin 30 days of a confirmed account deletion request, provided that if youraccount is banned for violating our Terms of Service and you subsequentlyrequest deletion, we may retain limited Personal Information for up to three(3) years to prevent you from creating a new account.

●     Behavioral and engagementdata: retained for the duration of youraccount and deleted or anonymized within 30 days of a deletion request;aggregate anonymized analytics may be retained indefinitely.

●     Authentication andsecurity logs: retained for up to 12months from collection for fraud prevention and security.

●     Support and communicationsrecords: retained for up to 3 years fromlast interaction to respond to complaints and defend legal claims.

●     Biometric data: retained only until the earlier of 30 days after an accountdeletion notice or 1 year after the purpose for collection is fulfilled, asdescribed in Section 2.

●     Hashed email identifiers: retained for up to 24 months from collection or lastinteraction, as described in Section 4.

Where a specific legalobligation requires a longer retention period, we will retain the relevant datafor the legally required duration.

10. Your Rights and Choices

Marketing and Notifications.

You can manage pushnotifications in your device settings. If you no longer wish to receivemarketing emails, follow the unsubscribe instructions in any such email oremail us at privacy@modemobile.com.You may continue to receive administrative messages about the Services.

Account Deletion.

You can request deletion of youraccount in the app (Settings) or by emailing cs@modemobile.com. Deletion is subject to theretention exceptions in Section 9 (including limited retention to preventre-registration by banned or fraudulent users).

Access, Correction, and Other Rights.

Depending on your state ofresidence, you may have rights to access, correct, or delete your PersonalInformation, and to opt out of certain processing, as described in Sections 13and 14. To exercise these rights, contact us at privacy@modemobile.com.

11. Use of Services By Children

The Services are intended forusers who are at least 16 years old and are not directed to children. We do notknowingly collect, maintain, or use Personal Information from children underthe age of thirteen (13) (as defined under the Children’s Online PrivacyProtection Act). If a parent or guardian becomes aware that a child hasprovided us with Personal Information, please contact us at privacy@modemobile.com,and we will take steps to delete it.

12. International Cross-Border DataTransfer

Mode Mobile is based in theUnited States, and the Services are currently offered only to users in theUnited States. Your Personal Information is processed in the United States. Ifyou access the Services from outside the United States, you do so on your owninitiative and are responsible for compliance with local laws.

13. Your California Privacy Rights(California Residents Only)

If you are a Californiaresident, you have the following rights under the CCPA/CPRA, subject to certainexceptions and limitations:

●     Right to Know about the Personal Information we collect, use, disclose,sell, and share.

●     Right to Delete Personal Information we collect or maintain.

●     Right to Correct inaccurate Personal Information.

●     Right to Opt Out of Saleor Sharing of Personal Information. Toexercise this right, use the “Do Not Sell or Share My Personal Information”control in the app settings or contact us at privacy@modemobile.com.

●     Right to Limit Use ofSensitive Personal Information. SensitivePersonal Information includes biometric data used to identify you. To exercisethis right, contact us at privacy@modemobile.comor use the in-app controls.

●     Authorized Agent. You may use an authorized agent to submit requests, subjectto verification, including (for mailed requests) a power of attorney ornotarized statement.

●     Right toNon-Discrimination for exercising yourprivacy rights.

How to Submit a Request.

You may submit requests (i)using the “Do Not Sell or Share My Personal Information” control in the appsettings; (ii) by emailing privacy@modemobile.com  (Attn: California Privacy Requests); or (iii)by mail to Mode Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611 (Attn:California Privacy Requests). We will respond in accordance with the CCPA/CPRAand may ask you to verify your identity.

California “Shine the Light.”

California residents mayrequest, once per year and free of charge, a notice describing categories ofPersonal Information shared with third parties for their direct marketingpurposes. Email privacy@modemobile.com with the subject “California ShineThe Light Request.”

14. Residents of Other U.S. States

If you are a resident of anotherU.S. state with a comprehensive privacy law, you may have one or more of thefollowing rights: to access, correct, or delete your Personal Information; toobtain a portable copy; and to opt out of targeted advertising, the sale ofyour Personal Information, and certain profiling. We will not discriminateagainst you for exercising these rights. To submit a request, contact us atprivacy@modemobile.com. You may have the right to appeal a denial by contactingus at legal@modemobile.com.

15. Updates To This Privacy Policy

We may make changes to thisPrivacy Policy. The “Last updated” date at the top indicates when it was lastrevised. If we make material changes, we may notify you through the Services orby other communication. Your continued use of the Services following changesmeans you accept the revised Privacy Policy.

16. Contact Us

Mode Mobile, LLC is responsiblefor the processing of your Personal Information. If you have questions aboutthis Privacy Policy or wish to exercise your rights, contact us at privacy@modemobile.comor write to:

Privacy Team (Attn: Justin M.Hines) Mode Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611USA

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