This policy and our Terms of Use apply to your use of this app (App) and the services provided by us within the App (Services), once you have downloaded or activated a copy of the App onto your device (Device).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.


Plus44 Holdings Ltd (collectively referred to as “we”, “us” or “our” in this policy) is the controller of, and is responsible for, the personal data we collect and process through your use of the App.

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer at


We keep our privacy policy under regular review. This version was last updated on 30th September 2019. It may change and if it does these changes will be made available when the App is next updated.


The App may, from time to time, contain links to and from the websites and services of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.


We may collect, use, store and transfer different kinds of personal data about you as set out in this section. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Information you give us.

  • Identity Data: You may give us your name, date of birth, and gender when you fill in forms or correspond with us. This includes personal data you provide when you: subscribe to any of our Services; search for an App or Service; or enter a competition, promotion or complete survey. If you contact us, we will keep a record of that correspondence.
  • Profile Data: includes your interests, preferences, feedback and survey responses.

Information that is logged automatically when you use the App

We use technology, such as blocks of software code called SDKs, to collect certain information that is logged automatically when you use the App.

  • Device Data: This is technical information about your device, for example: the type of mobile device you use (brand and model), a unique device identifier (for example, your Device’s IMEI number, Device ID, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
  • Usage Data: This is data about how you use the App and Services, such as when and how often you use the App and Services, the events that occur within the App, your engagement with particular content, aggregated usage, performance data, and where the App was downloaded from.
  • Application Data: When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Information about your location

Location Data: If you have consented, we use Global Positioning System (GPS), WiFi and mobile cell data to determine the general location of your device (latitude and longtitude) with the accuracy approximately equivalent to a city block. You can withdraw your consent at any time by disabling location data in your settings.

Aggregated Data

We may use your data to create aggregated data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. This data is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine it with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  1. Where you have consented before the processing by signifying your agreement by a statement or clear opt-in. You can withdraw your consent at any time by contacting us at
  1. Where it is necessary for the performance of a contract we are about to enter or have entered with you.
  1. Where we need to comply with a legal or regulatory obligation that we are subject to.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at


Type of data

Lawful basis for processing

To manage our relationship with you including notifying you of changes to the operation of the App or any Services

Identity Data, Profile Data, Usage Data

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity Data, Device Data, Profile Data

Performance of a contract with you

To administer and protect our business and the App including troubleshooting, data analysis and system testing

Identity Data, Device Data, Usage Data

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content, advertisements, surveys, offers, promotions, or recommendations which are personal and relevant to you

Location Data, Identity Data, Device Data, Profile Data, Usage Data

Necessary for our legitimate interest to make our advertising and recommendations more relevant and more effective and to ensure that our content is personal and engaging

To measure and analyse the effectiveness of the advertising and content we serve you

Location Data, Identity Data, Device Data, Profile Data, Usage Data

Necessary for our legitimate interest to verify that the advertising which funds the App is effective

To monitor trends

Location Data, Identity Data, Device Data, Profile Data, Usage Data

Necessary for our legitimate interest to improve the App and our Services


We work with the following Technology Partners to provide the App. For more information on how they process data please read their privacy policies.


Privacy Policy






Google Ads




We may also share your data with:

  1. The MVNO (mobile virtual network operator) that is the provider of your Device and who we work with to provide the App, acting as a controller, based in the United States, for the purposes of user account management (including auditing, reconciliation, dispute resolution and customer care).
  2. Rewards providers. We may provide details of the rewards you have chosen and your email address to rewards providers so that they can provide your reward. If necessary we may provide them with further information to resolve any customer service issues.
  3. Service providers acting as processors based in the United States who provide hosting services.
  4. Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the United States or the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  5. Tax authorities, regulators and other authorities acting as controllers based who require reporting of processing activities in certain circumstances. As we are a UK company these authorities and regulators may either be in the United States or the United Kingdom.
  6. New owners. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.


As we are a company based in the United Kingdom, you benefit from some additional protections when we transfer data to another country which is not in the United Kingdom or the European Economic Area. We will use at least one of the following safeguards and you can contact us if you want to know more about the specific mechanism we’ve used:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  1. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  1. Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.


Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 6 months then we will treat the account as expired and your personal data may be deleted.


As we are a company based in the United Kingdom, you have more rights in relation to how we use your personal data. Under certain circumstances you have the right to:

  1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes. You can also ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You can exercise any of these rights at any time by contacting us at


Notwithstanding anything to the contrary in this privacy policy, the following provisions apply with respect to California residents from whom we collect personal information:

Do We Respond to Do Not Track Signals?

The App currently does not have the ability to respond to “Do Not Track” signals or other mechanisms that give you the ability to choose whether personally identifiable information about your online activity (on the App and other third party online services) is tracked over time.

Please see DISCLOSURES OF YOUR PERSONAL DATA for details of third parties that may track your online activity over time.

Rights under the California Consumer Privacy Act

With certain legal exceptions and limitations, you may exercise the following rights by contacting us at or by calling us toll-free on 1-844-871-6252.

Access. You have the right to request information about the categories and specific personal data we have collected about you, the sources of personal data, the purpose for collecting the personal data, the categories of third parties to whom we have sold your personal data or shared it for a business purpose and the types of personal data sold or shared. You may also request information about any third parties with whom we have shared your personal data for those third parties’ direct marketing purposes.

Deletion. You may request that we delete your personal data.

We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.