Welcome to FarmCash, a mobile application and service operated by Mega Unlimited LTD ("we," "us," or "our"). FarmCash allows you to earn rewards by completing offers, including installing applications, playing games, and participating in surveys.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our mobile application (the "App") and related services (collectively, the "Services"). By using FarmCash, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Who We Are

Data Controller: Mega Unlimited LTD is the data controller responsible for your personal data.

2. Information We Collect

We collect several types of information to provide and improve our Services:

2.1 Account Information

When you create an account, we collect:

• Email address
• Username (display name)
• Password (stored securely in hashed form)
• Date of birth (to verify you are 18 or older)
• Country of residence

2.2 Identity Verification Data (KYC)

Before you can withdraw funds, we are required to verify your identity. This process may involve:

• Government-Issued ID: Passport, driver's license, or national identity card
• Selfie or Live Photo: A photo of yourself, which may be compared against your ID document
• Proof of Address: In some cases, documents such as utility bills or bank statements
• Biometric Data: Facial recognition and liveness detection technologies may be used to verify your identity and prevent fraud
• Tax Information: For US users, we may collect your Social Security Number or Taxpayer Identification Number (TIN) for tax reporting purposes (IRS Form W-9 and 1099 requirements)

Identity verification is performed by third-party services (such as Onfido, Veriff, Jumio, or similar providers). These service providers process your verification data on our behalf according to their own privacy policies. We receive verification results, risk signals, and associated metadata, but typically do not store raw identity documents unless required for compliance or fraud prevention.

2.3 Payment and Withdrawal Information

To process withdrawals and rewards, we collect:

• PayPal email address or other payment account details
• Gift card redemption preferences
• Transaction history (dates, amounts, redemption status)

We do not store your full payment card details. Payment processing is handled by secure third-party payment processors.

2.4 Usage and Activity Data

We automatically collect information about how you interact with our Services, including:

• Offer completions and progress (e.g., games installed, levels achieved, offers completed)
• App interactions (screens viewed, buttons clicked, time spent in app)
• Virtual currency balances, earning history, and transactions
• Referral activity (if you participate in our referral program)
• Support requests and communications with customer service

2.5 Device and Technical Information

We collect information about the device and network you use to access FarmCash:

• Device type, model, manufacturer, and operating system version
• Unique device identifiers (e.g., Google Advertising ID, Apple IDFA, Android ID)
• IP address and approximate geolocation (country, state/region, city)
• Mobile network information (carrier)
• App version, crash logs, and diagnostic information

2.6 Survey Data

We offer two distinct types of surveys, and it is critical to understand the difference in how we handle data for each type:

First-Party Surveys (Conducted by FarmCash)

These are surveys that we create and conduct directly. When you participate in a first-party survey:

• We are the owner and custodian of the survey data you provide
• Your responses are collected, stored, and processed by us
• We use this data to improve our Services, personalize your experience, and conduct market research
• We will never share your first-party survey data with advertisers or third parties unless you provide explicit opt-in consent for such sharing

Third-Party Surveys (Conducted by Advertising Partners)

These are surveys provided by our advertising partners and network providers (such as Prodege, RevU, and other offer wall partners). When you participate in a third-party survey:

• We do NOT receive, record, store, or control the survey responses you provide
• Your responses go directly to the third-party advertiser or survey provider
• We only receive general completion statistics (e.g., whether you completed the survey, the timestamp, and the reward amount earned)
• The third-party provider is solely responsible for how your survey data is collected, used, stored, and shared
• We are not responsible for the data practices of third-party survey providers

For all third-party surveys, we strongly encourage you to review the privacy policy of the survey provider before participating. Third-party surveys will clearly identify the provider, and you have the choice whether or not to participate.

2.7 Cookies and Tracking Technologies

We use cookies, software development kits (SDKs), and similar technologies to collect information about your usage of our Services. See Section 13 for more details.

2.8 Information from Third Parties

We may receive information about you from our advertising partners and offer providers to verify offer completions, prevent fraud, and attribute rewards. This typically includes:

• Offer completion timestamps and verification status
• Device identifiers to match completions with your account
• Fraud prevention signals and risk scores

We may also obtain information from public databases, identity verification services, fraud prevention services, and data aggregators to verify your identity and prevent fraudulent activity.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Improving Our Services

• Creating and managing your account
• Processing offer completions and awarding virtual currency
• Processing withdrawal requests and issuing payments
• Providing customer support and responding to inquiries
• Improving app functionality and user experience
• Developing new features and services
• Analyzing usage patterns and trends

3.2 Identity Verification and Compliance

• Verifying your age (18+) and identity before allowing withdrawals
• Complying with anti-money laundering (AML) and Know Your Customer (KYC) regulations
• Meeting tax reporting obligations (e.g., IRS Form 1099 for US users)
• Responding to legal requests and enforcing our Terms of Service

3.3 Fraud Prevention and Security

• Detecting and preventing fraudulent activity, including fake accounts, offer manipulation, and unauthorized access
• Identifying multiple accounts linked to the same individual
• Monitoring unusual activity patterns and investigating suspected violations
• Protecting the integrity of our rewards system

3.4 Communications

• Sending you service-related notifications (e.g., account updates, offer completions, withdrawal confirmations)
• Sending promotional communications about new offers, features, and rewards (you may opt out at any time)
• Responding to your questions, feedback, and support requests

3.5 Marketing and Personalization

• Personalizing the offers and content shown to you based on your interests and activity
• Measuring the effectiveness of our marketing campaigns
• Understanding user preferences and behavior
• Using first-party survey data to improve our product, tailor marketing messages, and better understand user needs (we will never share this data with advertisers or third parties without your explicit consent)

3.6 Legal Bases for Processing (GDPR/UK GDPR)

For users in the EEA, UK, or Switzerland, we process your personal data based on the following legal grounds:

• Performance of a Contract: To provide the Services you have requested (account creation, offer tracking, withdrawals)
• Legal Obligation: To comply with legal requirements such as KYC/AML laws, tax reporting, and law enforcement requests
• Legitimate Interests: To prevent fraud, improve our Services, and conduct analytics (balanced against your rights and interests)
• Consent: For marketing communications and certain optional data collection (you may withdraw consent at any time)

4. How We Share Your Information

We do not sell your personal information. However, we may share your information with the following parties under specific circumstances:

4.1 Advertising Partners and Offer Providers

To facilitate offer completions and reward attribution, we share limited information with our advertising partners (including Prodege, RevU, AyeT-Studios, and other offer wall providers). This typically includes:

• Device identifiers (e.g., Google Advertising ID, Apple IDFA)
• IP address and approximate location (country/region)
• Offer engagement data (clicks, installs, completions)

Important: When you participate in third-party surveys provided by our advertising partners, your survey responses go directly to the third-party provider. We do not receive, store, or have access to the substantive content of your third-party survey responses. We only receive confirmation that you completed the survey and the associated reward amount.

For first-party surveys (surveys we conduct ourselves), we retain full control over the data and will never share your responses with advertisers or third parties unless you explicitly opt in to such sharing.

4.2 Service Providers

We work with third-party service providers who perform services on our behalf, including:

• Identity Verification: Onfido, Veriff, Jumio, or similar KYC providers to verify your identity and age
• Payment Processors: PayPal, gift card fulfillment services, and payment gateways to process withdrawals
• Cloud Hosting: Amazon Web Services (AWS), Google Cloud Platform, or similar providers to host our infrastructure
• Analytics: Google Analytics, Firebase, Mixpanel, or similar tools to analyze app usage
• Customer Support: Zendesk, Intercom, or similar platforms to manage support tickets
• Email Services: SendGrid, Mailgun, or similar providers to send transactional and promotional emails
• Fraud Prevention: SEON, SHIELD, or similar fraud detection services to identify and prevent fraudulent activity

These service providers are contractually obligated to use your information only for the purposes we specify and to maintain appropriate security measures.

4.3 Business Transfers

If we are involved in a merger, acquisition, asset sale, bankruptcy, or similar corporate transaction, your personal information may be transferred to the acquiring entity. We will notify you via email or prominent notice in the App before your information is transferred and becomes subject to a different privacy policy.

4.4 Legal Requirements and Safety

We may disclose your information if required to do so by law or in response to:

• Legal process (court orders, subpoenas, search warrants)
• Law enforcement or government requests
• Investigations of potential violations of our Terms of Service
• Protecting the rights, property, or safety of Mega Unlimited LTD, our users, or others

4.5 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized data that does not identify you personally with third parties for research, analytics, marketing, or other purposes. For example, we might share statistics about app usage trends or offer completion rates.

5. International Data Transfers

Mega Unlimited LTD is based in the United Kingdom. If you are accessing our Services from outside the UK, your personal data may be transferred to, stored, and processed in the UK, the European Economic Area (EEA), the United States, or other countries where we or our service providers operate.

These countries may have data protection laws that differ from those in your country. Where we transfer personal data from the EEA or UK to countries that do not provide an adequate level of protection (as determined by the European Commission or UK authorities), we implement appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission or UK authorities
• Data Processing Agreements with our service providers
• Other mechanisms recognized under applicable data protection laws

By using our Services, you consent to the transfer of your information to countries outside your country of residence, including countries that may not provide the same level of data protection as your home country.

6. Advertising and Analytics

6.1 Advertising Partners

Our Services integrate with third-party advertising networks and offer providers to present you with earning opportunities. These partners may collect information through their own SDKs embedded in our App, including:

• Device identifiers (Advertising ID, IDFA)
• IP address and location data
• App usage and engagement data
• Information about ads viewed and offers completed

These advertising partners use this data to:

• Deliver and measure the effectiveness of advertising campaigns
• Attribute offer completions and prevent fraud
• Personalize the offers shown to you across multiple apps and services

Our primary advertising partners include Prodege, RevU, and AyeT-Studios. Each partner operates under its own privacy policy. You can learn more about their data practices and your choices by visiting their websites.

6.2 Analytics Services

We use third-party analytics services such as Google Analytics, Firebase, and Mixpanel to understand how users interact with our App and Services. These services collect information such as:

• How often you use the App
• Which features you use
• How long you spend in the App
• Performance data (crashes, errors, load times)

This helps us improve the user experience, fix bugs, and develop new features.

6.3 Your Choices

You can limit tracking and personalized advertising by:

• iOS Users: Enabling "Limit Ad Tracking" or denying app tracking permission in Settings > Privacy > Tracking
• Android Users: Opting out of personalized ads in Settings > Google > Ads > Opt out of Ads Personalization, or resetting your Advertising ID

Please note: Opting out of personalized advertising or limiting tracking may affect your ability to complete certain offers or earn rewards, as we may not be able to accurately attribute offer completions to your account.

7. Data Protection for Biometric Information

As part of our identity verification process (KYC), we may collect biometric data, such as facial recognition data derived from selfies or live photos. This data is considered highly sensitive, and we take additional precautions to protect it.

7.1 Purpose of Biometric Data Collection

We collect biometric data solely for the following purposes:

• Verifying your identity before allowing withdrawals
• Preventing fraud and ensuring that each user operates only one account
• Complying with anti-money laundering (AML) and Know Your Customer (KYC) legal requirements

7.2 How Biometric Data is Processed

• Biometric verification is performed by trusted third-party providers (such as Onfido, Veriff, Jumio, or similar services) who specialize in secure identity verification
• These providers extract biometric identifiers (e.g., facial geometry) from the selfie you provide and compare them to your government-issued ID
• We receive only the verification result (pass/fail), a confidence score, and associated metadata (e.g., timestamp, risk signals). We do not receive or store the raw biometric template itself unless required by law
• Raw images (selfies and ID scans) are typically retained by the verification provider only as long as necessary for verification, compliance audits, and dispute resolution, then securely deleted in accordance with their retention policies

7.3 Retention of Biometric Data

Biometric data and related verification records are retained only as long as necessary to fulfill the purposes for which they were collected:

• Verification results and risk signals: Retained as long as your account is active and for up to 3 years following account closure for fraud prevention and compliance purposes
• Raw images and biometric templates: Typically retained by our verification partners for a limited period (often 30-90 days) unless legal obligations require longer retention

You may request deletion of your biometric data by contacting us at [email protected]. However, please note that deletion may prevent us from processing future withdrawal requests or complying with legal obligations.

7.4 Additional Protections for Illinois Residents

If you are a resident of Illinois, the Illinois Biometric Information Privacy Act (BIPA) provides you with additional rights. Under BIPA:

• We will not collect, capture, or otherwise obtain your biometric data without first providing you with notice and obtaining your written consent
• Biometric data will be stored, transmitted, and protected using a reasonable standard of care, at least as protective as the manner in which we store, transmit, and protect other confidential and sensitive information
• We will not sell, lease, trade, or otherwise profit from your biometric data
• We will permanently destroy biometric data when the initial purpose for collection has been satisfied or within 3 years of your last interaction with us, whichever occurs first, unless a valid legal obligation requires retention

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Our standard retention periods are as follows:

• Account Data: Retained for as long as your account remains active, plus an additional period following account closure for legal and fraud prevention purposes.
• Identity Verification Data: We retain verification results, timestamps, and risk signals as long as needed to provide services and for fraud prevention (typically 3 years). Raw images (documents/selfies) are generally retained by our verification partners only as long as strictly necessary for verification, audit, and compliance purposes.
• Transaction Data: Retained for at least 7 years to comply with tax and accounting requirements.
• Usage Data: Generally retained for up to 3 years for analytics purposes, unless anonymized earlier.
• Fraud Prevention Data: May be retained indefinitely for platform security and to prevent repeat offenders from creating new accounts.
• First-Party Survey Data: Retained for as long as necessary to fulfill the purposes for which it was collected (product improvement, marketing insights), typically up to 3 years unless you request deletion.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls limiting data access to authorized personnel
• Regular security assessments and monitoring
• Secure password storage using industry-standard hashing
• Contractual obligations on service providers to maintain appropriate security

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you use our Services at your own risk.

10. Your Rights

Depending on your location, you may have certain rights regarding your personal data:

10.1 Rights for All Users

• Access: Request information about the personal data we hold about you
• Correction: Request correction of inaccurate personal data
• Account Deletion: Request deletion of your account
• Marketing Opt-Out: Opt out of promotional communications at any time
• Withdraw Consent: Where processing is based on consent, withdraw that consent

10.2 Additional Rights for EEA/UK Users

If you are located in the EEA, UK, or Switzerland, you also have the right to:

• Erasure: Request deletion of your personal data in certain circumstances
• Restriction: Request restriction of processing in certain circumstances
• Portability: Receive your personal data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests
• Automated Decision-Making: Not be subject to decisions based solely on automated processing that produce legal effects

10.3 Additional Rights for US Users

Depending on your state of residence (including California, Virginia, Colorado, Connecticut, and other states with privacy laws), you may have additional rights including:

• Right to Know: Request disclosure of categories and specific pieces of personal information collected
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of "sales" or "sharing" of personal information for targeted advertising
• Non-Discrimination: Not be discriminated against for exercising your privacy rights

10.4 Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before processing your request. We will respond to valid requests within the timeframes required by applicable law (typically 30 days for GDPR, 45 days for US state laws).

Please note that certain data may be exempt from such requests, including data needed to complete a transaction, comply with legal obligations, or for fraud prevention purposes.

10.5 Complaints

If you are in the EEA or UK, you have the right to lodge a complaint with your local data protection authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

11. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18 years of age.

If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information as quickly as possible. If you believe we may have collected data from a child under 18, please contact us immediately at [email protected].

12. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, and services, including offers from our advertising partners. These third parties have their own privacy policies, and we are not responsible for their privacy practices.

When you engage with an offer and install a third-party application or participate in a third-party survey, that application or survey provider's own privacy policy and terms will govern your use of that service and the data you provide. We encourage you to review the privacy policies of any third-party services before using them.

13. Cookies and Tracking Technologies

Our App and any associated websites may use cookies, SDKs (software development kits), and similar tracking technologies to collect and store information. These technologies are used to:

• Maintain your session and account preferences
• Track offer completion and attribution
• Analyze usage patterns and improve our Services
• Prevent fraud and ensure platform security
• Measure the effectiveness of marketing campaigns

You may be able to limit certain tracking through your device settings, including resetting your advertising identifier or limiting ad tracking. However, disabling tracking may affect your ability to earn rewards, as we may be unable to verify offer completions.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational, legal, or regulatory reasons.

When we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and, where appropriate, provide additional notice through the App or via email.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For data protection inquiries or to exercise your privacy rights, please email [email protected] with the subject line "Privacy Request".

We aim to respond to all legitimate inquiries within 30 days. If your request is particularly complex, we may require additional time, in which case we will notify you accordingly.