Privacy Policy

Freeward Int Group Ltd

Effective Date: 27 May 2025  |  Last Updated: 27 May 2025

1. Who We Are

Freeward Int Group Ltd ("Freeward", "we", "us", or "our") is a company registered in England and Wales. We operate the Freeward platform, a get-paid-to rewards service where users earn coins redeemable for PayPal cash, cryptocurrency, and gift cards.

We are committed to protecting your personal data and complying with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR) where applicable, and the Data Protection Act 2018.

For all data protection enquiries, please contact us at: [email protected]

 

2. Personal Data We Collect

We collect the following categories of personal data:

 

Data category	Purpose	Legal basis (Art. 6 UK/EU GDPR)
Email address	Account registration, reward delivery, newsletters	Contract performance Legitimate interests
IP address	Fraud prevention, country localisation, analytics	Legitimate interests Legal obligation
Device identifiers User-Agent, GAID	Offer attribution, fraud prevention	Legitimate interests
Profile info Name, age, gender, education, job — optional	Personalisation of surveys and offers	Consent
Survey responses	Survey matching and partner reporting	Consent

 

3. Legal Bases for Processing

We rely on the following legal bases under Article 6 of the UK/EU GDPR:

• Contract performance (Art. 6(1)(b)): Processing necessary to provide the Freeward service to you, including delivering rewards and managing your account.
• Legitimate interests (Art. 6(1)(f)): Fraud prevention, security, service improvement, and analytics — where these do not override your rights and freedoms.
• Consent (Art. 6(1)(a)): Where you have freely given, specific, and informed consent — for example, sharing your email with survey partners or providing optional profile information. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legal obligation (Art. 6(1)(c)): Where we are required to process data to comply with applicable law.

 

4. How We Use Your Data

We use your personal data to:

• Operate and maintain the Freeward platform and deliver your rewards.
• Prevent fraud, abuse, and policy violations.
• Send transactional emails (reward confirmations, account notifications).
• Send newsletters and promotional communications — you can unsubscribe at any time.
• Provide analytics and service performance monitoring.
• Comply with legal and regulatory obligations.

 

5. Data Sharing and Third Parties

We share your data only as necessary to operate the Service. Below is a full list of our data partners and what is shared with each:

 

Offer and Video Providers

OfferToro, Adgem, CPA Lead, Wannads, Kiwi Wall, Tapjoy, Persona.ly, MediumPath, Adcolony, Hangmyads, Adworkmedia, Offerdaddy, Ayetstudios

Shared data: IP address, device advertising identifier. Purpose: offer attribution and fraud prevention.

 

Survey Providers

Yuno Surveys, Tapresearch, Theoremreach

Shared data: IP address, survey responses. Purpose: survey matching and delivery.

 

Analytics

Google LLC (Firebase / Google Analytics)

Shared data: IP address, email address. Purpose: error monitoring and service analytics.

 

Email Service

Sender Inc.

Shared data: Email address. Purpose: transactional and newsletter emails.

 

We do not sell your personal data to third parties.

 

6. International Data Transfers

Some of our third-party partners are located outside the UK and European Economic Area (EEA). Where we transfer your data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK ICO or the European Commission.
• Transfers to countries with an adequacy decision by the UK or EU authorities.

You may request further information about our transfer mechanisms by contacting [email protected].

 

7. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy, or as required by law. Our standard retention periods are:

• Account data (email, IP logs): Retained for the duration of your account and up to 2 years after closure, for fraud prevention and legal compliance purposes.
• Survey data: Retained for up to 1 year after collection, or as required by our survey partners' agreements.
• Transaction and reward records: Retained for up to 6 years in accordance with UK financial record-keeping obligations.
• Newsletter subscription data: Retained until you unsubscribe.

When data is no longer required, it is securely deleted or anonymised.

 

8. Your Rights

Under the UK GDPR and EU GDPR, you have the following rights in relation to your personal data:

• Right of access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can ask us to correct inaccurate or incomplete data.
• Right to erasure: You can request deletion of your personal data in certain circumstances.
• Right to restrict processing: You can ask us to limit how we use your data.
• Right to data portability: You can request your data in a structured, machine-readable format.
• Right to object: You can object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to lodge a complaint: You have the right to complain to a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk. In the EU, you may contact your local data protection authority.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.

 

9. Data Export and Deletion Requests

To export a copy of your data, email [email protected].

To delete your account and associated data, email [email protected]. We will process deletion requests within 30 days and will request our partners to delete your data where applicable. Please note that some data may be retained where we have a legal obligation to do so (e.g. financial records).

 

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include access controls, encrypted data transmission, and regular security reviews.

While we take reasonable steps to protect your data, no system is completely secure. We cannot guarantee absolute security but commit to notifying affected users and relevant authorities in the event of a data breach, in accordance with our legal obligations.

 

11. Cookies and Tracking

Freeward uses cookies and similar tracking technologies for session management, fraud prevention, and analytics. For full details of the cookies we use and your options for managing them, please refer to our Cookie Policy at freeward.net/cookies.

 

12. Children's Privacy

The Service is not directed at children under 13 (or 16 in the EU; 18 in India). We do not knowingly collect personal data from children below the applicable age threshold. If you believe we have inadvertently collected a child's data, please contact us at [email protected] and we will delete it promptly.

 

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or by posting a prominent notice in the Service at least 14 days before the changes take effect. The current version is always available at freeward.net/privacy.

 

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

Email: [email protected]

Freeward Int Group Ltd — Registered in England and Wales