Our website uses cookies
By continuing, we assume your permission to deploy cookies as detailed in our Privacy Policy.
Accept
Notice of Collection of Information
(For California Residents Only)
Effective Date: June 15, 2026
If you are a California resident, you have the right to notice of our collection of Personal Information under the California Consumer Privacy Act of 2020, as amended by the California Privacy Rights Act (collectively, “CCPA/CPRA”), Civil Code §1798.100 et seq. This Notice is provided by Mode Mobile, LLC (“Mode Mobile,” “we,” “us,” or “our”). All capitalized terms used but not defined in this Notice have the meanings given to them in the CCPA/CPRA or applicable regulations thereunder.
Under the CCPA/CPRA, “Personal Information” means any information that directly or indirectly identifies, describes, relates to, is capable of being associated with, or can reasonably be linked to a particular consumer or household, subject to certain exceptions.
The table below sets forth the categories of Personal Information we collect through our Services, examples of the specific types of information within each category, whether we collect that category, and the business or commercial purposes for which we collect and use it.
CCPA/CPRA Category
E. Biometric Information
Examples of Personal Information Collected
A. Identifiers
Real name, username, mobile phone number, mobile device ID, IP address, email address, hashed email identifier, Google Advertising ID, unique account identifier
Name, telephone number, date of birth, gender
Age, date of birth, gender (provided voluntarily for survey qualification and offer matching)
Yes (voluntary)
Information provided in job applications (for applicants only)
Audio data (where you use voice-related features, if applicable)
App interactions and events, activities completed, surveys and offers engaged with, advertising viewed or clicked, attribution data, app install and usage data, length of time using features, gyroscopic position, service strength, data provider information
Approximate location derived from IP address, device settings, and country code. No precise GPS location collected.
Facial scan / face map (mathematical representation of facial geometry) generated from a video selfie for identity verification at redemption
Survey eligibility screening; offer matching; analytics
Earn Points earned and redeemed, rewards redemption history, activity completion records, payout records
B. Personal Information — Cal. Civ. Code §1798.80(e)
C. Protected Classification Characteristics
D. Commercial Information
F. Internet or Other Electronic Network Activity
G. Geolocation Data
H. Sensory data.
I. Professional or employment-related information.
None.
Profiles reflecting a person’s preferences, characteristics resulting from or relating to Earn Points acquired and rewards redeemed, behavioral and engagement patterns
K. Inferences
J. Education Information (FERPA)
Collected?
Busines / Commercial Purpose
Yes
Account creation and management; fraud prevention; advertising measurement; audience matching and suppression; identity resolution
Yes
Account management; survey targeting; demographic segmentation; offer personalization
Yes
Reward calculation; payout processing; fraud prevention; analytics; advertising measurement
Yes (with express opt-in consent only)
Identity verification; detection and prevention of account duplication and fraudulent redemptions. Not sold or shared.
Yes
Service operation; Earn Points calculation; fraud prevention; advertising delivery and measurement; analytics; personalization
Yes (approximate only)
Yes
Offer and survey personalization; advertising targeting and measurement; analytics; fraud scoring
Territory eligibility verification; fraud and VPN detection; compliance with geographic restrictions; offer and survey targeting
Limited / feature-dependent
Feature functionality
Yes (applicants only)
No
N/A
Busines / Commercial Purpose
L. Sensitive Personal Information (CPRA)
Biometric data (facial scan / face map) — see Category E above
Yes (with express opt-in consent only)
Identity verification and fraud prevention only. Use is limited to purposes permitted under CCPA/CPRA §1798.121.
How We Use the Personal Information We Collect
Service Operation. To establish and maintain your Earn App account, calculate and credit Earn Points, process redemptions and payouts, provide customer support, and operate the Mode Mobile Services.
Identity Verification and Fraud Prevention. To verify your identity at redemption (including through biometric verification with your consent), detect and prevent fraudulent activity, account duplication, and policy violations, and enforce our one-account-per-person controls.
Advertising and Analytics. To deliver, measure, and improve advertising displayed within the Services; to operate and measure advertising campaigns; to provide advertising partners and analytics providers with data for measurement, audience matching, and attribution; and to analyze usage trends and improve the Services.
Survey and Offer Personalization. To match you with surveys, offers, and games for which you are eligible and that may be of interest to you, based on your profile and activity data.
Communications and Referrals. To send you service notifications and updates; and, where you have opted in, to facilitate friend referrals through your device contacts.
Legal and Compliance. To enforce our Terms of Service, comply with legal obligations, respond to law enforcement requests, defend legal claims, and otherwise protect our rights and those of our users.
In addition to the above, we disclose Personal Information to service providers and third parties as described in our Privacy Policy, which may include advertising networks, analytics providers, identity-resolution platforms, survey and offer partners, game publishers, payout processors, and others.
Categories of Third Parties With Whom We Share Personal Information
Service Providers: Cloud hosting providers, identity verification providers (Facetec), survey and offer partners, game publishers, advertising and analytics providers (including mobile advertising networks and analytics platforms), attribution partners, customer support providers, notification providers, and payout processors.
Advertising and Identity-Resolution Partners: Third parties that receive identifiers (including hashed email identifiers, device identifiers, and IP addresses), commercial information, internet or network activity, geolocation data, and inferences for purposes of advertising, audience matching, measurement, and suppression. These disclosures may constitute a “sale” or “sharing” of Personal Information under the CCPA/CPRA. California residents may opt out of these disclosures as described in our Notice of Right to Opt Out of Sale or Sharing of Personal Information.
Affiliates and Subsidiaries: Other Mode Mobile entities that share reward, fraud, and payout infrastructure.
Business Transfer Recipients: Potential or actual acquirers, successors, or assignees in connection with a merger, acquisition, or sale of assets.
Legal and Governmental Authorities: Courts, regulators, law enforcement agencies, and other governmental authorities, where required by law or necessary to protect our rights or the rights of others.
Special Notice Regarding Biometric Information
Mode Mobile collects biometric information (facial scan data) only from users who provide express opt-in consent before any biometric capture. Biometric data is collected solely for identity verification and fraud prevention in connection with Earn Points redemptions, is stored encrypted on company-owned or vendor-controlled servers, and is not sold, leased, traded, or otherwise disclosed except to our verification provider acting on our behalf. We retain biometric data only until the earlier of: (1) thirty (30) days after we receive notice of an account deletion request; or (2) one (1) year after the purpose for collection has been fulfilled. For more information, see Section 2 of our Privacy Policy.
Annual Statistical Data (California Residents)
Commencing with our first full calendar year of operation and updated annually thereafter as required by the CCPA/CPRA, we will publish a summary of statistical data pertaining to the following categories of California-resident consumer privacy requests received during the preceding calendar year:
(1) Requests to Know; (2) Requests to Delete; (3) Requests to Correct; (4) Requests to Opt Out of Sale or Sharing; and (5) Requests to Limit Use of Sensitive Personal Information.
The statistical data will include: (A) the number of requests received in each category; (B) the number of requests complied with in whole or in part; (C) the number of requests denied; and (D) the median number of days within which requests were responded to.
Contact Us
For more information about our data practices and your rights, please see our Privacy Policy at https://www.modemobile.com/privacy. If you have questions about this Notice, contact us at:
Mode Mobile, LLC
One East Erie, Suite 525
Chicago, IL 60611
Email: privacy@modemobile.com
Subject line: “California Privacy Rights”
The Mode Earn Phone is not rent-to-own. As long as you maintain your subscription you can keep earning up to $900 or more every year with your Mode Earn Phone. Receive a new device after 12 months.
