This Privacy Policy governs the manner in which Targo Lab LLC (referred to herein as "TarGo Lab," "We," "Us," or "Our"), a monetization technology provider operating in the offerwall, survey distribution, and fraud prevention sectors, collects, uses, maintains, and discloses information collected from users, publishers, and third-party partners.

---

1. Introduction and Scope

1.1. Who We Are

TarGo Lab LLC is a limited liability company duly organized and existing under the laws of the State of Wyoming, United States. We operate a technology platform that connects publishers (e.g., app developers, website owners) with advertisers and market research firms to facilitate user engagement, monetization, and data collection via services such as Offerwalls, Survey Distribution, and associated Monetization Technologies.

1.2. What This Policy Covers

This Policy describes Our practices in connection with the personal and non-personal information We collect through Our services, including:

• Use of Our Offerwall widget and/or Survey Distribution technology on third-party applications or websites ("Publisher Platforms").
• Fraud detection and prevention services.
• Data processing for market research, advertising, and user profiling.
• Server-to-server (S2S) communications and callback systems.

1.3. Where It Applies

This Policy applies to all individuals who interact with Our services, including:

• App Users/Website Users who view or interact with Our Offerwalls or Surveys on Publisher Platforms.
• Survey Respondents who participate in market research activities.
• Publishers (and their representatives) who integrate and utilize Our Monetization Technologies.
• Third-Party Partners (e.g., advertisers, survey routers, anti-fraud services) who interact with Our platform.

We are committed to processing all data in compliance with applicable international data protection frameworks, including, but not limited to, the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and the Lei Geral de Proteção de Dados (LGPD).

2. Information We Collect

TarGo Lab acts as a Data Controller in certain instances (e.g., managing direct relationships with Publishers and core platform operations) and as a Data Processor or Service Provider in others (e.g., processing survey responses on behalf of a market research partner). The information collected may include:

2.1. Log and Device Data (Collected Automatically)

• IP Address: Used for geotargeting, fraud prevention, and system diagnostics.
• Device Identifiers: Including Advertising Identifiers (e.g., IDFA, AAID), necessary for tracking offer completion and cross-app/site attribution.
• Technical Data: Browser type and settings, operating system, timestamp of interaction, request headers, referral URL, and interaction history with Our services.

2.2. Personal and Demographic Information

• Email Addresses and PII: Collected directly from Publishers for account management and contractual purposes.
• Demographic Data: Information such as age, gender, household income, education level, and employment status, which is collected during the survey process or received from third-party partners for user profiling and targeting. This data is typically processed in a pseudonymous or aggregated manner.

2.3. Location Data

• Coarse Location Data: Derived from the user's IP address (city/region level) for geotargeting surveys and offers.
• Precise Location Data: Only collected with the user's explicit consent via the Publisher Platform, for market research purposes requiring high-precision geo-fencing.

2.4. Cookies and Tracking Technologies

We deploy or permit third-party partners to deploy cookies, web beacons, pixels, and similar technologies on Publisher Platforms to: Tracking, Profiling, and Analytics.

2.5. Information Collected from Surveys and Offerwalls

• Survey Responses: Detailed answers, opinions, and qualitative/quantitative data provided by Survey Respondents.
• Offer/Task Completion Data: Records of user engagement and completion status for offers and tasks presented in the Offerwall.
• Reward Data: Information required for calculating, processing, and tracking the delivery of virtual or real rewards.

2.6. Data Provided by Publishers or Third-Party Partners

• Publisher Data: User IDs, in-app currency balances, and other contextual data necessary to integrate the Offerwall and process rewards.
• Partner Profiling Data: Pseudonymous user segments, audience attributes, and look-alike data received from survey routers or advertising partners for optimal matching.

3. How We Use Information

TarGo Lab processes the collected information for the following specific purposes:

• Core Service Delivery: Survey Matching, Offer Personalization, Reward Delivery and Tracking.
• Platform Integrity: Fraud Detection, Compliance and Security.
• Optimization: Publisher Analytics and Service Improvement.
• Communication and Legal Compliance.

4. Legal Bases for Processing (GDPR, LGPD)

For data subjects located in the European Economic Area (EEA), the UK, Brazil, and other jurisdictions with analogous data protection laws, Our legal bases for processing personal data are as follows:

Legal Basis	Applicable GDPR Article	Description
Consent	Article 6(1)(a)	Processing based on the data subject providing affirmative, explicit, and informed consent for one or more specific purposes.
Contractual Necessity	Article 6(1)(b)	Processing is necessary for the performance of a contract to which the data subject is party.
Legal Obligation	Article 6(1)(c)	Processing is necessary for compliance with a legal obligation to which TarGo Lab is subject.
Legitimate Interests	Article 6(1)(f)	Processing is necessary for the purposes of the legitimate interests pursued by TarGo Lab or a third party, except where overridden by the interests or fundamental rights.

Note on Survey Data: Data processed in connection with market research surveys is typically processed on the legal basis of Consent or Legitimate Interest as determined by the specific Market Research Client, for whom TarGo Lab often acts as a Processor.

5. How We Share Data

TarGo Lab processes the collected information for the following specific purposes:

• Survey Partners and Routers: To qualify users for surveys.
• Offer Providers and Advertisers: To attribute offer completions and facilitate S2S communications.
• Anti-Fraud and Security Tools: To prevent, detect, and investigate fraudulent activity.
• Publishers: To credit the user’s account with rewards.
• Payment Processors: For direct publisher payouts.
• Hosting and Infrastructure Providers: For secure data storage and processing.
• Legal Authorities: To comply with legal processes and governmental requests.

CCPA/CPRA Note: The sharing of certain identifiers (e.g., Advertising IDs, pseudonymous hashes) may constitute a "sale" or "sharing" under CCPA/CPRA. See our separate Do Not Sell My Personal Information notice for opt-out rights.

6. Data Retention and Security

6.1. Retention Period

We retain personal data for only as long as necessary to fulfill the purposes for which it was collected, including:

• Transaction/Reward Data: Retained for up to three (3) years.
• Publisher Account Data: Retained for the duration of the relationship and up to seven (7) years thereafter.

6.2. Security Measures

We employ robust technical and organizational measures, including Encryption (in transit and at rest) and Access Control, to protect personal data.

Limitation of Liability: While We implement strong security measures, We cannot guarantee the absolute security of information transmitted over the internet and accept no liability for unauthorized interception outside Our direct control.

7. International Data Transfers

7.1. Transfers Outside the EEA/UK

For data originating from the EEA and the UK, TarGo Lab relies on the following mechanisms:

• Standard Contractual Clauses (SCCs): Implementing the European Commission’s SCCs for data transfers to third countries.
• Legitimate Interests: Where SCCs are not applicable, data may be transferred based on performance of a contract or compelling legitimate interests.

8. Your Data Protection Rights

8.1. Rights for GDPR/LGPD Data Subjects

Includes the Right of Access, Right to Rectification, Right to Erasure ('Right to be Forgotten'), Right to Restriction of Processing, Right to Data Portability, Right to Object, and Right to Withdraw Consent.

8.2. Rights for CCPA/CPRA Data Subjects (California Residents)

• Right to Know: Request disclosure of collected data categories and specific pieces of information.
• Right to Delete: Request deletion of personal information, subject to exceptions.
• Right to Opt-Out of Sale or Sharing: Direct TarGo Lab not to "sell" or "share" your personal information (see separate notice).

9. Cookies Policy Summary

We use Essential, Analytics/Performance, Functionality, and Advertising/Profiling Cookies. Users can manage or disable cookies through browser settings or by utilizing the CCPA opt-out mechanism.

10. Children’s Privacy (COPPA)

Our services are not directed to individuals under the age of sixteen (16). We adhere strictly to the requirements of the Children's Online Privacy Protection Act (COPPA).

11. Business Transfers, Third-Party Links, and Policy Changes

User data may be transferred during Business Transfers (mergers, acquisitions). We assume no responsibility for the privacy practices of Links to Third Parties. We reserve the right to make Changes to This Privacy Policy and will communicate material changes via email or prominent website notice.

12. Contact Information

For any questions or requests regarding this Privacy Policy, please contact us by email:

• Official Privacy and DPO Email: [email protected]