Privacy Policy

Last updated May 21, 2019


This privacy policy explains GCOW’s privacy practices in connection with information collected about you through your use of GCOW services, including our Gift Card Offerwall, our dashboard, and our website. (“GCOW” means GCOW  lnc. and its subsidiaries and affiliates, and may also refer to our advertiser and publisher services, including our dashboard, our Gift Card Offerwall, and our website.) 

What is GCOW?

GCOW lnc. operates a platform that enables mobile app publishers  to display Gift Card Offers thru our patent pending Gift Card Offerwall SDK.

Mobile app Publishers use GCOW by adding our SDK to their mobile apps; this allows us to display  Gift Card offers within the app (our advertising and monetization service).  (“SDK” is short for “software development kit”, meaning software that a publisher can include in its app to enable GCOW services in the app.)

Users use GCOW through engaging with Gift Card offers  we display through our Gift Card Offerwall in a participating publisher’s app. GCOW placements include a offerwall, which allows a user to choose from a page of various rewarded Gift Card Offers (“rewarded” meaning that the user receives a reward in the form of virtual currency for the app they’re using);. 

To further support our publishers, we also offer related optional services, such as analytics, which helps publishers understand how their users use their apps, and virtual currency management services, which helps publishers manage in-app virtual currency. 

We provide customer support for users who did not receive an expected in-app reward; this involves working with the advertiser, the user, and the publisher to identify and resolve the issue.  

What information does GCOW collect, and how is it used?

That depends on how you interact with GCOW. Read on to learn about the following categories: 

  • If you are an individual who uses a mobile app that uses GCOW , go to the section titled Information collected through our Gift Card Offerwall

  • If you are an individual who submitted a customer support ticket relating to a Gift Card Offer  go to Customer support information 

  • If you access GCOW’s corporate website (www.gcow.io), or if you use GCOW’s dashboard to manage your GCOW publisher services, go to the section titled Website and Dashboard User Information  

  • All users should also review the section titled General privacy practices

Information collected through our Gift Card Offerwall

If you are an individual who uses a mobile app, and the app’s publisher uses GCOW services, we receive and collect information about your device and the GCOW Gift Card Offers  that you view, and we use this information to reward you for offer engagement, to draw inferences about which offers may be more or less interesting to you, and to provide publishers with information about how their apps are used. This information is collected through our SDK, as integrated into the app you use to access GCOW Offers, and through your interactions with our Gift Card Offerwall. 

Here are the types of information that we collect:

  • Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as

    • Google Advertising ID (GAID), or Android ID in its absence (or MAC address, in the absence of both), for Android devices, and 

    • ID for Advertisers (IDFA), for iOS devices

    • The publisher’s user identifier 

  • Information about the device itself, including

    • Whether it is a smartphone or tablet

    • What operating system and version it uses (e.g., iOS, version 11.0)

    • Model and manufacturer (e.g., Apple iPhone X, Samsung Galaxy S8)

    • Screen size, screen density, and other information relevant to ad formatting and display

  • Information about the internet connection used to access our services, including

    • Mobile carrier

    • Network provider

    • Network type (e.g,. wifi)

    • IP address

    • Timestamp and duration (i.e., when the device connected to our services began and how long the connection lasted, for a given session)

  • Information about the app and our SDK, including  

    • Which version of our SDK is integrated in the app used to access our services

    • API key (identifier for application); Partner App version; list of installed apps (the applications and/or processes which are installed or run on your device while the Partner App is active or inactive).

  • Location-related information - We infer the perceived general location of the device based on:

    • The IP address used to access our services

    • Location-related device settings, such as the device’s country code, language setting, and time zone

How does GCOW use information collected through the Gift Card Offerwall? 

We use the information we collect through our Gift Card Offerwall -

  • To possibly show you customized Gift Card offers to what our system infers to be your interests, preferences, and locations, based on the information associated with your mobile device’s advertising identifier; this is referred to as behavioral or interest-based advertising

  • To track the Gift Card offers you complete so we can provide you with the reward you earned 

  • To respond to and resolve your customer support requests  

  • For analysis and research, both to improve our services and to report our services’ results to our advertisers and publishers

  • To prevent and detect fraud, and to maintain our services’ and systems security 

We keep this collected information as long as it remains necessary to provide the GCOW Services.

How does GCOW share information collected through the Gift Card Offerwall? 

  • Publishers using GCOW’s analytics service can access aggregated information about how their users interact with their apps. No information is provided on an individual basis. 

  • Advertisers using GCOW’s advertising service receive the device identifiers associated with those who view an ad offer via GCOW and go on to buy the advertiser’s advertised product or service from its website or app. 

  • Vendors and service providers working for GCOW, or for our advertisers or publishers, have access to information collected via our Gift Card Offerwall as necessary for them to perform their services we engaged them to do. Under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes.  

  • Our corporate family includes international subsidiaries; we provide each other with access to our shared resources as needed to fulfill our shared business responsibilities, including providing and supporting our Gift Card Offerwall.    

  • We may share your information, to the extent permissible by applicable laws, when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities, or to comply with legal process. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this privacy policy or our terms of service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of GCOW, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

  • Business Transaction. We may share your information with another company if they merge with us or purchase our assets, or as part of due diligence for such a transaction.

  • Consent. We may share your information in any circumstances where we have your consent.

  • Aggregated Data. We may aggregate, anonymize and/or de-identify information collected through our Gift Card Offerwall so that the information can no longer be associated with you or your device in specific; our use and disclosure of information that is not identifiable to a specific person or device is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.

How long does GCOW keep information collected through the Gift Card Offerwall? 

We keep information as long as necessary to provide our services, generally speaking. Information used for interest-based ad targeting is rotated out on a 90-day basis. Conversion data and non-production backups of production data are retained for longer due to financial records and disaster recovery requirements. 

Customer Support Information

To submit a request for GCOW customer support (for example, for help with a missing GCOW Gift Card offer reward), you must submit a working email address; this is required for us to be able to communicate with you about investigating and resolving your support issue. Emails and other information submitted for support purposes are used only for support purposes; depending on the circumstances, this may require us to share your information with the  publisher whose app are involved. Our SDK also offers in app chat support to end end users. 

Website and dashboard user information

GCOW dashboard

Our publishers have access to a GCOW dashboard, which allows them to manage their use of GCOW services and review their results. When you create a dashboard account, you provide information such as your name, the name of your company, your username and password, your email address, postal address, phone number, and payment information, as well as any required financial information (e.g., tax ID, VAT, or sales tax registration number). We use this information to provide you with GCOW services and support. If you invite other users to your GCOW dashboard account, we will collect the email address of the employee or other individual you wish to add and use it to send them a one-time email informing them they have been added. If they are not your employee, you must have their consent before providing us with their email address to invite them to join your dashboard account.

GCOW website and social media

Our corporate website, www.gcow.io provides general information about GCOW and our products and services; we also maintain a blog and various social media channels. If you post information through one of these channels, you understand that we cannot control what other users do with any content (including without limitation images, ratings, captions, and comments) you voluntarily post. You should not post any sensitive personal data, such as details of your ethnicity, health or political preferences or photos of yourself to any GCOW board, blog, social media channel, or forum, nor should you allow other users to have access to your content if you do not wish them to make your content publicly available to be collected and used by others, or to be redistributed through the Internet and other media channels.

Aggregated data

We may aggregate, anonymize and/or de-identify information collected through our website, dashboard, and social media channels so that the information no longer relates to you individually. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.

Cookies and Related Tracking Technologies.

When you use our website and dashboard, we may place and read cookies or access information on your device to obtain information about the performance of our site, enable you to move around the site, to record your preferences and to serve you with advertising that is relevant to your interests. This information may, where permitted by applicable law, then be combined with other information we hold about you. Information and technologies we may use include:

  • Device and usage information. When you interact with our website or dashboard, we may collect information such as (a) IP addresses, unique device identifiers, and other information about your device(s), browser types, browser language, operating system, the state or country from which you accessed the services; and (b) information related to the ways in which you interact with our website, such as: referring and exit pages and URLs, platform type, the number of clicks, internal GCOW subdomain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the services, error logs, and other similar information. As described in Online Analytics below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how the GCOW Web Services are used.

  • Location information. We may market to you based on your location, inferred from the IP address you use to reach our website or dashboard.  

  • Cookies and other technologies. When you use the GCOW website or dashboard, we use persistent and session cookies and other similar technologies to perform various tasks, such as: (a) storing your dashboard account username and password; (b) analyzing the usage of our website and dashboard; and (c) customizing our website and dashboard to your preferences. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies by visiting your browser’s help page. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some features of the GCOW Web Services. By using our website and dashboard with your browser set to accept cookies, you consent to our use of cookies in the manner described above. In addition to cookies, we may use a technology called clear gifs (a.k.a. web beacons) that help us better manage and analyze content. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages. Where permissible under applicable law, we may include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics purposes.

Online Analytics

To help understand your use of our website and dashboard, we use third-party web analytics providers, such as Google Analytics, which in turn use the technology described above at Cookies and related tracking technologies. Our service providers collect and use this information to evaluate how websites are used. To opt out of tracking via Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on.

How GCOW uses information collected through our website and dashboard

We use the information we collect through your use of our corporate website and our dashboard to provide our services, to manage your publisher or advertiser account, to do business with you as a publisher or advertiser (including taking orders, reporting results, and so on), to communicate with you (including responding to your inquiries, informing you about products and services based on your marketing preferences, and notifying you of new features), to analyze our user base and usage patterns, and to provide and improve our services. We also use this information to improve our corporate website content and to personalize the dashboard for you. We keep the information we collect for so long as we continue to provide our website, dashboard, and services.

How does GCOW share information collected through the website and dashboard? 

We don’t buy, sell, or trade in information collected through our website and dashboard. We share it only as described here:

  • Vendors and service providers working for GCOW, or for our advertisers or publishers, have access to information collected via our Gift Card Offerwall as necessary for them to perform their services we engaged them to do. Unless we tell you otherwise, under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes. These service providers include analytics providers, payment processors, product fulfillment providers, providers of technical infrastructure, technical support, email providers, and customer support vendors. 

  • Our corporate family includes international subsidiaries; we provide each other with access to our shared resources as needed to fulfill our shared business responsibilities, including providing and supporting our Gift Card Offerwall. 

  • We may share your information, to the extent permissible by applicable laws, when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities, or to comply with legal process. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this privacy policy or our terms of service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of GCOW, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

  • We may share your information in connection with any merger, reorganization, a sale of some or all GCOW assets, or a financing or acquisition of all or a portion of our business by another company (including in the course of due diligence for any such transaction).

  • We may share your information in any circumstances where we have your consent.

What choices do I have about use of information related to GCOW’s website or dashboard?

  • Commercial Marketing. We will comply with applicable marketing laws; for example, where applicable law requires prior consent, GCOW will only send you marketing email if you have opted in. To opt out of receiving marketing emails or other commercial communications from us, use the “unsubscribe” option in a commercial email from us or send us an email at [email protected] It may take several days for us to process your request, consistent with applicable law.

  • Publisher and Advertiser Accounts. If you have access to a dashboard publisher or advertiser account and do not want your email address used, contact us at [email protected]

  • Dashboard Account Deactivation. To request deactivation of your dashboard account, email us at [email protected] Some information may remain in our records after deactivation of your account based on business needs. After deactivation, we may continue to use aggregated data derived from or incorporating your personal information but not in a manner that would identify you personally.


General Privacy Practices


How does GCOW secure personal information?

We use physical, electronic, and managerial procedures designed to safeguard your information and data security, and to prevent unauthorized access to. These safeguards take into account the sensitivity of the information that we collect, process, and store and the current state of technology. Although we take such measures to safeguard against unauthorized disclosures of information, the Internet and the services are not 100% secure so we cannot assure you that all information we collect or store will be protected from all unauthorized access.

International Users

If you are located outside the United States and choose to use our services or provide information to us, your information is provided to GCOW in the United States, and may be and processed and stored in the United States and otherwise outside of your country of residence, by GCOW and by third parties with whom we share in accordance with this privacy policy. 

Child and youth users

If you are under the locally applicable minimum age of consent to data use, please do not register for or use any GCOW service or send us any information about yourself. (In the US, your minimum age is 13; in the EEA and Switzerland, it is age 16 unless your country has adopted a lower age.) Please inform us by emailing [email protected] if you learn that we have been provided with personal information from a child under the applicable minimum age without verified parental consent, so that we may take appropriate steps to delete that personal information. 

Changes to Our Privacy Policy

We reserve the right to update (amend) this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes and review them carefully, as our use of information at a given point is governed by the Privacy Policy that is then in effect. Your continued use of our services after a Privacy Policy update means that you consent to the updated policy.  

Third Party Sites and Services

Our services and communications may contain links to third-party websites, including social media services. Your use of these links, websites, or services may result in the collection, processing or sharing of information about you, depending on what you use. We are not responsible for the content or privacy practices of other websites or services that may be linked on our services. We do not endorse or make any representations about third-party websites or services. Any information you choose to provide to these services, or that they collect, is covered by their privacy policy rather than ours, so please make sure to read it.  We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy

Notice to California Users

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. As explained above, we do not sell or share your personal information (as that term is defined under California law) with third parties for use for their own marketing purposes.

The EU GDPR

The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires GCOW and the publishers and advertisers using our services to provide data subjects with information about the processing of personal data. (“Personal data”, as used in the GDPR, means information relating to an identified or identifiable natural person, including name, address, cookie identifiers, mobile device identifiers, and more; “data subject” here means the person involved; and “processing” of data includes collection, storage, and use.)  

This section provides representations and information in compliance with our GDPR obligations, for the benefit of our users located in the EEA countries and Switzerland only. 

Legal grounds for processing your personal data

The GDPR requires us to identify the legal ground we’re relying on to process personal data about you.  Our legal grounds for processing your personal data as described in this Privacy Policy will typically be because: 

  • You provided your consent. To store and access information on your device, we rely on your consent.  For this “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), to fulfill our obligations under the ePrivacy Directive, we rely on mobile app developers and oblige them contractually to pass on only legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to consent and its withdrawal.  

  • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing personal data to provide our and our commercial partners’ services. A legitimate interest we rely on, for instance, is the tailoring of offers and opportunities to obtain in-game rewards to users of mobile applications and services, which is beneficial to users and offers them a value exchange and goes beyond the original collection of mobile ad identifiers and also includes providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use personal data to maintain the security of our services, including fraud detection and identifying and fixing bugs. 

  • Contractual Relationships. Sometimes, we process personal data as necessary under a contractual relationship we have, such as our customer records and contact information).

  • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

Transfers of personal data

We operate globally from our headquarters based in the United States with offices around the world, and work with other global companies and technologies. As a result, we may need to transfer your personal data outside of its country of origin. For instance, we may transfer your personal data to commercial partners or service providers located in jurisdictions outside the EEA and Switzerland, which have data protection laws less strict than those in Europe.  

When we transfer personal data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect it; we use European standard contractual clauses and data processing agreements where required by European Data Protection Law, and are in the process of certifying to EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.  Contact us at [email protected].io for more information about the safeguards we use to protect your personal data and privacy rights.

Personal data retention 

As a general matter, we retain your personal data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally rotate through personal data used for ad personalization on a 90-day timetable, provided that we may retain data if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance, accounting or bug-fixes.     

If you are a GCOW publisher, we retain your information as long as your account is active and for as long as necessary for legal or operational purposes, such as auditing, corporate record-keeping, compliance, or accounting, after its closure.

Right to Access 

If you are a consumer and wish to exercise your right to access personal data we process as a data controller, you may do so by requesting access through the e-mail address [email protected] and following the instructions we provide you to authenticate your request and obtain access. We will assess requests to exercise data access rights on a case-by-case basis, factoring in the difficulty of verifying whether a mobile device identifier, and the data we have linked to it, truly and solely belongs to the person making the request, as well as the potential risk of harm through disclosure of personal data to the wrong individual. Because improper disclosure would likely harm the privacy rights and freedoms of the person involved, we may limit the personal data we make available. We only grant requests where we are the data controller, as explained further, below. Where we act as a processor for one of our advertisers or publishers, we will refer your request to that company; if your request involves an advertiser or publisher, please identify them (if possible) to simplify this process.

If you have a GCOW publisher or advertiser dashboard account, you may use your account settings to access and update or delete account information. You may also request access by emailing us at [email protected]

Right to Erasure

You also have the right to request erasure of personal data that we hold as a controller. The above opt-out process satisfies this right, because when a user opts-out (whether through device settings or by submitting a request to [email protected] and following our instructions), we stop using your personal data to provide our services to you; the data is permanently rendered disconnected to your device and will be automatically deleted from our production system. We may retain copies of some personal data for our own internal and necessary purposes, such as auditing, accounting and billing, legal, bug-detection, backups, and (if applicable) to ensure that you receive and that we are able to track the rewards you have received.   

GCOW: a data controller and a data processor

EU data protection law makes a distinction between organisations that process personal data for their own purposes (known as “data controllers”) and organisations that process personal data on behalf of other organisations (known as “data processors”).  If you have a question or complaint about how your personal data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers have primary responsibility for your personal data.

GCOW may act as either a data controller or a data processor in handling your personal data, depending on the precise circumstances. For instance, for personal data that we use internally to create our data-related services, such as interest-based ad targeting, and for personal data that we collect about our publisher and advertiser customers for use in marketing to them, we are a data controller. But when we handle personal data strictly on behalf of our customers to provide our services to them (for example, if they provide us with a list of device identifiers to use for targeting or suppression), we are a data processor. If you have questions about data that is used primarily on behalf of one of our publishers or advertisers, you should contact them. 

Contacting GCOW

If you have any questions or concerns regarding our privacy policies, please send us a message to [email protected]