Privacy Policy 

At Promogency, a leading digital platform dedicated to securing Gift Cards, Game Rewards, and Money Rewards, we deeply value the trust you place in us. Your privacy is not merely a legal requirement; it is a fundamental pillar of our operational philosophy. This comprehensive Privacy Policy outlines the conscientious practices governing the collection, utilization, and disclosure of your personal data as you interact with our website, https://promogency.com/, and our associated digital services.

We are committed to absolute transparency and compliance with global data protection frameworks, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). By engaging with the Promogency ecosystem to acquire your desired game rewards or monetary incentives, you acknowledge and consent to the data practices described herein.

Categories of Personal Information Collected (PII)

We only collect data that is strictly essential for delivering our premier Service, fulfilling contractual obligations, and providing superior user experience, consistent with the principle of data minimization. The categories of personal information we meticulously collect are categorized as follows:

1. Identifiers and Account Information

This information is mandatory for the registration and management of your Promogency Account and for the secure disbursement of your rewards.

  • Registration Data: Full name, email address (essential for reward notifications and account verification), unique password (hashed), and country of residence.

  • Contact Data: Postal address (required for physical gift card fulfillment or regulatory compliance), and telephone number.

  • Account Credentials: Internal user ID, and security question answers.

2. Commercial and Transactional Information

This data pertains directly to your pursuit and redemption of rewards, gift cards, and money prizes.

  • Activity Records: History of completed offers, surveys, and games; accrued rewards points balance; and redemption records for all digital gift cards and money rewards.

  • Payment Information (Non-Sensitive): Chosen payout method (e.g., PayPal email, bank account pseudonym, or cryptocurrency wallet address). Note: We do not directly store full credit card numbers; this process is managed by PCI-compliant third-party payment processors.

3. Internet Activity and Technical Data (Automatically Collected)

As you navigate our platform, certain non-personally identifiable information is logged to optimize Service performance and ensure platform integrity. This collection is crucial for our site optimization and fraud prevention mechanisms.

  • Online Identifiers: Internet Protocol (IP) address, operating system, browser type and version, device identifier, and unique mobile device ID.

  • Usage Data: Pages viewed, time spent on pages, clickstream data, referral source, and interaction with our advertisements and rewards offers.

  • Geolocation Data: General (non-precise) location derived from your IP address, used for geotargeting region-specific game rewards and offers.

 

The Purpose and Lawful Basis for Processing Your Data

We process your personal information under strict legal bases as defined by GDPR and other applicable data protection legislation. Our purpose for processing is unequivocally linked to the functionality of Promogency and the delivery of its core value proposition.

Purpose of ProcessingSemantic Keywords & IntentLawful Basis (GDPR)
Service Provision & Contract FulfillmentDelivering gift cards, processing money rewards, managing game rewards redemptions, and account servicing.Contractual Necessity
Security & Fraud PreventionData protection, preventing illegitimate access, maintaining platform security, and verifying user identity to protect your accrued rewards balance.Legitimate Interest & Legal Obligation
Personalization & User ExperienceCustomizing the display of relevant games and reward offers, enhancing site usability, and developing new features.Legitimate Interest & Consent (for non-essential cookies)
Marketing & CommunicationSending notifications about your rewards, promotional emails for new gift card offers, and platform updates (you can always opt-out).Consent (for marketing) or Legitimate Interest (for service-related messages)
Compliance & Legal ObligationResponding to legal requests, court orders, or complying with government regulations related to financial rewards and digital transactions.Legal Obligation

 

Data Sharing and Disclosure: Transparency in Partner Ecosystem

We respect the confidentiality of your data and do not engage in the indiscriminate selling of PII in the traditional sense. However, to operate the complex rewards ecosystem, we must share data with select, vetted third parties.

1. Service Providers and Vendors

We engage reputable third parties to perform essential functions on our behalf. These data processors are contractually bound to confidentiality and are forbidden from using your PII for any purpose other than providing services to Promogency.

  • Reward Fulfillment Partners: Sharing name and email to deliver your purchased Gift Cards (e.g., Amazon, Steam) or process money rewards via platforms like PayPal.

  • Analytics Providers: Using tools like Google Analytics to understand traffic flow, user behavior, and the performance of our game rewards pages.

  • Security & Anti-Fraud Agencies: Sharing IP and transaction history to screen for suspicious account activity and protect the integrity of the rewards system.

2. Advertising and Offer Partners

Our business model relies on presenting valuable offers and games from third-party advertisers. When you click an offer on our site, you are interacting directly with the partner, and your click is logged.

  • We may share non-personally identifiable information (e.g., a hashed user ID or device ID) to help our partners attribute your completion of an offer, which is necessary to credit your account with the appropriate rewards points.

  • This data exchange is solely for the purpose of validating the completion of the activity that earns you a reward.

3. Corporate Transactions and Legal Requirements

Your information may be disclosed in connection with a corporate merger, acquisition, or asset sale. Furthermore, we will disclose your PII when mandated by law, such as in response to a subpoena or similar legal process.

Your Data Subject Rights (GDPR and CCPA Compliance)

As a user of Promogency in Tier-1 countries, you are afforded powerful and indispensable rights over your personal data. We provide robust mechanisms for you to exercise these rights, empowering you with control and digital sovereignty.

1. The Right to Know and Access (CCPA)

You have the right to request disclosure of the specific pieces and categories of personal information we have collected about you, the sources of that information, and the business purposes for collecting or sharing it, over the preceding twelve (12) months.

2. The Right to Deletion/Erasure (GDPR)

You have the right to request the deletion of your personal information, subject to certain exceptions. We will comply unless we have a compelling legal or business reason to retain the data (e.g., to complete a pending rewards transaction or for legal defense).

3. The Right to Rectification/Correction

You have the right to request that any inaccurate or incomplete personal information about you be corrected or updated in a timely manner. Most of this data, such as your email and name, can be updated directly via your Account Dashboard.

4. The Right to Opt-Out of Sale or Sharing (CCPA)

Promogency respects your choice. If you are a California resident, you have the right to opt-out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising. We provide a clear and conspicuous “Do Not Sell or Share My Personal Information” link on our homepage and in the footer of this Policy.

5. The Right to Object and Restriction of Processing

Under GDPR, you have the right to object to the processing of your PII based on our Legitimate Interests. You can also request the restriction of processing while a dispute over data accuracy or legal basis is pending.

6. Exercising Your Rights

To exercise any of these fundamental rights, please submit a verifiable consumer request via:

  • Email: [Your Dedicated Privacy/Legal Email Address]

  • Postal Mail: [Your Company’s Registered Address]

  • Online Portal: [Link to your Data Subject Request/Contact Form]

 

Data Retention: Strategic Storage Limitation

We retain your personal information only for as long as is strictly necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. This adherence to storage limitation is crucial for compliance.

  • Account Data: Retained for the duration your Promogency account is active. Data is typically anonymized or deleted within a reasonable period (e.g., 90 to 180 days) after an account is deactivated or deleted, subject to legal hold requirements.

  • Transactional Data: Records of gift card redemptions and money rewards payouts are retained for a minimum of seven (7) years to comply with financial and tax regulations.

  • Marketing Consent: Retained until you withdraw your consent or opt-out of the subscription.

 

Cookies and Tracking Technologies

Like virtually all modern digital rewards platforms, Promogency utilizes cookies and similar tracking technologies to facilitate core functionality, administer the Service, analyze trends, and attribute the completion of games and offers to your account.

  • Essential Cookies: Required for the operation of the Service, such as keeping you logged into your account and securely tracking your accrued rewards points.

  • Analytics Cookies: Used to analyze how users interact with the platform, identify popular reward types, and measure the effectiveness of our interface.

  • Advertising & Affiliate Cookies: Crucial for our business model, these cookies track your journey from our site to an offer partner’s site, ensuring you receive the correct reward credit upon successful completion.

We utilize a robust Consent Management Platform (CMP) that prompts all users in regulated jurisdictions (e.g., EU, California) to provide granular consent for non-essential cookies, fulfilling the requirements for valid GDPR consent.

 

Data Security Measures: Protecting Your Rewards and PII

We implement sophisticated and state-of-the-art security protocols to protect your personal data from accidental loss, unauthorized access, misuse, or alteration. Our commitment to integrity and confidentiality is unwavering.

  • Encryption: All data transmitted between your browser and our servers is secured using Transport Layer Security (TLS/SSL) encryption. Sensitive PII is encrypted at rest.

  • Access Control: Access to your data is strictly limited to employees, agents, and third parties on a need-to-know basis, all of whom are subject to strict confidentiality obligations.

  • Regular Audits: We conduct routine penetration testing and security audits to proactively identify and mitigate vulnerabilities within our rewards infrastructure.

 

Children’s Privacy: A Policy of Prohibition

The Promogency Service is intended for individuals who are at least eighteen (18) years of age or the age of majority in their jurisdiction of residence. We do not knowingly collect or solicit personal information from children under the age of 16. If we become cognizant that we have inadvertently collected PII from a minor, we will take immediate and expedient steps to delete that information from our records in accordance with regulations like COPPA (Children’s Online Privacy Protection Act).

 

International Data Transfers and Jurisdictional Authority

Promogency operates globally, and the data we collect may be processed and stored in countries outside of your primary residence, including the United States, where our principal servers are located.

  • For users in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, we ensure all cross-border transfers of personal data are conducted lawfully using appropriate safeguards, such as the implementation of Standard Contractual Clauses (SCCs) or relying on other recognized derogations for data transfer.

  • By using our Service to claim your gift cards and game rewards, you understand and consent to your information being transferred to and processed in these other jurisdictions.

 

Amendments and Policy Revisions

We reserve the prerogative to update or modify this Privacy Policy periodically to reflect changes in our operating procedures, technological advancements, or prevailing legal and regulatory frameworks. We will notify you of any material changes by posting the new policy on this page, updating the “Last Updated” date, and, when appropriate, by notifying you directly via email or an in-service banner. Your continued use of the Promogency Service after the effective date of any revision constitutes your acceptance of the updated terms.

 


Disclaimer: This document is a template designed for compliance and SEO performance. Promogency and its owners are not a law firm. You must consult with a qualified legal counsel to adapt this policy to the specific legislative requirements governing your jurisdiction and business operations.