1. Data Controller & Contact Information
FreeGiftZone.net (“FreeGiftZone”, “we”, “us”, or “our”) serves as the data controller for personal data processed through our platform. We are committed to safeguarding user privacy and operating with transparent data practices.
2. Information We Collect & Collection Methods
We collect information to operate our rewards tracking directory, calculate milestone achievements, and fulfill digital gift card redemptions. We collect only what is necessary:
Directly Provided Information
- Account email address and username for login and communication.
- Inquiry details, screenshots, and ticket messages submitted via Support.
- Evidence submitted during offerwall milestone dispute resolution.
Automatically Collected Identifiers
- Truncated, pseudonymized IP address for fraud detection and country matching.
- Device user-agent, operating system, and browser version.
- Session tokens (
click_idandsubid) to correlate offer postbacks.
Mobile Advertising Identifiers
Apple iOS App Tracking Transparency (ATT): On iOS 14.5 and newer, our platform and third-party partner offerwalls only access the Identifier for Advertisers (IDFA) if you explicitly grant permission by tapping “Allow” on the native iOS prompt. If you decline, the IDFA is zeroed out by iOS, and milestone tracking must rely on non-tracking contextual session keys.
Google Android Advertising ID (GAID): On Android devices, sponsored games utilize the Google Advertising ID to verify milestone progression. You may reset or opt out of personalized advertising at any time in Android system settings.
3. Legal Bases for Processing under GDPR (EU & UK)
If you reside in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following legal bases pursuant to Article 6 of the General Data Protection Regulation (GDPR):
- Article 6(1)(b) — Performance of a Contract: Necessary to register your account, record completed game milestones and surveys, calculate points progress, and fulfill digital gift card vouchers.
- Article 6(1)(f) — Legitimate Interests: Necessary for network security, preventing emulator abuse, mitigating multiple accounts, enforcing anti-fraud policies, and resolving partner disputes.
- Article 6(1)(a) — Consent: Applicable where you voluntarily consent to mobile advertising attribution (ATT) or opt into optional service notifications.
- Article 6(1)(c) — Legal Obligation: Necessary to maintain transaction records for statutory accounting, tax, and anti-fraud auditing compliance.
4. California Consumer Privacy Act (CCPA / CPRA) Disclosures
FreeGiftZone has never sold, rented, released, disclosed, disseminated, transferred, or otherwise communicated consumer personal information to third parties for monetary or other valuable consideration. Furthermore, we do not share personal information for cross-context behavioral advertising.
California residents possess specific statutory rights under the CCPA/CPRA:
- Right to Know / Access: You may request disclosure of the specific pieces and categories of personal information collected.
- Right to Delete: You may request erasure of your personal data, subject to anti-fraud registry retention requirements.
- Right to Correct: You may request correction of inaccurate personal records.
- Right to Non-Discrimination: Exercising your privacy rights will never result in altered coin collection rates, delayed redemption fulfillments, or denial of platform access.
- Global Privacy Control (GPC): Our web servers recognize and honor browser-level Global Privacy Control signals.
5. Third-Party Offerwalls & Independent Controllers
When participating in coin-collection activities, you may interact with independent third-party offerwalls (such as Torox, AdGate Media, RevU, BitLabs, and CPX Research) and digital storefronts (Google Play, Apple App Store).
These partner networks act as independent data controllers. FreeGiftZone transmits only non-personally-identifiable click tokens (click_id) to associate completions. When you visit partner platforms, their respective privacy policies govern data collection.
6. Data Retention Schedules
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with statutory retention requirements:
| Data Category | Retention Period | Action at End of Cycle |
|---|---|---|
| Active User Account Data | Duration of active account + 24 months inactivity | Automated deletion; points balance archived |
| Reward Redemption Records | 7 Years from date of redemption | Cold storage for statutory accounting compliance |
| Server Access & Error Logs | 90 Days rolling window | Automated rolling purge |
| Anti-Fraud Ban Registry | Indefinite (Hashed device/IP tokens) | One-way cryptographic hash (SHA-256) to prevent ban evasion |
| Support Tickets & Appeals | 3 Years from ticket resolution | Purged from support database |
7. User Rights & Privacy Escalation Process
To exercise your GDPR, CCPA, or regional data protection rights, please contact our Data Protection Officer at privacy@freegiftzone.net or submit an intake ticket through our Support Help Desk.
We verify all requests against the registered account email before releasing or deleting records. In accordance with statutory guidelines, we respond within 30 days (GDPR) or 45 days (CCPA).
8. Children's Privacy (COPPA & GDPR-K)
FreeGiftZone is not intended for or directed toward children under 13 years of age (or under 16 where required by EEA member state law). We do not knowingly collect personal information from individuals under 13. If you become aware that a child has created an unauthorized account, please notify privacy@freegiftzone.net for immediate account deactivation and data purging.
9. Data Security & International Transfers
We implement industry-standard technical and organizational security controls to prevent unauthorized access, alteration, disclosure, or destruction of personal data:
- End-to-end TLS 1.3 encryption across all web traffic.
- AES-256 encryption at rest for databases and persistent storage.
- Cryptographic HMAC-SHA256 signature verification for partner webhook callbacks.
- Standard Contractual Clauses (SCCs) governing international data transfers between EEA, US, and APAC jurisdictions.
