Privacy Policy
  • 31 Jan 2023
  • 22 Minutes to read
  • Dark

Privacy Policy

  • Dark

Article summary

At Earnly, your privacy is important to us. This Privacy Policy is designed to explain how we collect, use, process, share, and safeguard Personal Information about you gathered through our websites, including (the “Sites”), and the Earnly mobile applications, including Android-based "Earnly - Earn Free Bitcoin" (collectively, the “Services”). It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. The terms “Earnly,” “we,” and “us” include Earnly ("3D Asset Holdings LLC"), our affiliates and subsidiaries. By using the Services, you agree to the processing of your Personal Information as described in this Privacy Policy. Beyond the Privacy Policy, your use of the Service is also subject to our Terms of Service.

  1.  Personal Information We Collect

    1a) What Type of Data Do We Collect

  2.  Personal Information You Provide Us

  3.  Personal Information Obtained From Third Parties

  4.  Personal Information We Collect Automatically From Your Use of the Services

  5.  How We Use Your Personal Information

  6.  Who are the Third Parties We Share Personal Information With

  7.  How Can I Stop Sharing of My Data

  8.  Third Party Services And Links

  9.  Security

  10.  Data Retention & Deletion

  11.  Your Rights And Choices

  12.  Use of Services by Children

  13.  International Cross-Border Data Transfer

  14.  California Privacy Rights

  15.  CAN-SPAM Act (Email Communication)

  16.  Poll Fish Plugin

  17.  Updates To This Privacy Policy

  18.  Contact Information

1. Personal Information We Collect

For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with them or if we are legally required to collect it.

1a. What type of data do we collect?

  • Identifiers; user ID, username, and hashed email. Shared to help identify you and track your progress on a provider's task.
  • Basic data; birthdate, gender, and postal code. Shared to help providers find more tasks based on age, gender and location.
  • Device data; browser and IP address, geo location, messaging ID and other device related information. Shared to help providers find more tasks based on geo location and device information.
  • Profiling data; education, ethnicity/race, income, etc. Shared to help providers find more tasks based on any profiling data from our survey area.
  • App Usage & Installation data; Information on which apps you have installed on your device and how much time you spend in each app. This data is used to provide real time reward calculations.

2. Personal Information You Provide Us

Registration: If you wish to have access to certain features on Earnly, including earning points (“Coins”), you may be required to become a registered user, and to submit the following types of Personal Information to Earnly:

  • Name
  • Email address
  • Phone number

Other Optional Information: We may ask you for additional information about yourself, such as age, country or city, tastes and preferences, and other survey questions. This information is optional to provide, and you may be rewarded for providing it with Earnly Coins.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we may receive your name, email address, phone number, the contents, date and time of a message or attachments that you may send to us, and other information you choose to provide.

Business Partners. If you work for one of our business partners or vendors ("Third-Parties"), we will collect your contact details to manage the business relationship.

3. Personal Information Obtained From Third Parties

Social Networks and Media Streaming.

We collect information from social media services when you use your credentials for these services to log into the Service, or when you connect your social media accounts to the Service. For example, when you log in with your Facebook or Google+ credentials, we collect the information you have authorized the platform to share with us, such as your name, email address, gender, date of birth, friend list, profile picture and playlists, along with other elements of your social network profile that you have made available may be shared with other Earnly users. We may also obtain other non-public information, such as pages you follow or create, and content you’ve liked. Please refer to the privacy policy of your social network or music streaming account for information about what information is shared with us.  

Friend Referrals.

We may provide you with an opportunity to invite your friends, family and acquaintances (“Friends”) to use the Apps. If you elect to use our referral service for informing a Friend about Earnly , you will be asked to allow Earnly to access your contacts; you will be prompted to select contacts to whom you wish Earnly to contact with information about the Apps; and then you will be prompted to consent to Earnly contacting your Friends. Using our referral service permits us to automatically send the Friend one or more emails or other communications, on your behalf, inviting them to visit or register for Earnly (which invite may include additional subsequent reminders and communications). You warrant and represent that you have your Friend’s consent to provide us with his or her information for this purpose, and that you will not give us referral information for any person not permitted to use Earnly , including, without limitation a child under the age of , a person whose account has previously been suspended or deactivated, or a person residing or located in a territory where use of Earnly is not authorized.

4. Personal Information We Collect Automatically From Your Use of the Services

When you use our Services, we and our third party service providers may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Services, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, gyroscopic position, service strength, data provider, device IDs and characteristics, country code or approximate location, operating system version, language preferences, referring URLs, and information about the usage of our Services, such as length of time (in seconds) a user plays music, metadata (genre, artist, album, title, description, tags) and type of media.  We may use this information, for example, to ensure that the Services function properly, to create an account on your behalf when you have not formally registered for an account, to analyze your listening behavior and preferences in order to provide you with tailored content, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We work with analytics’ providers such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at

Third parties that advertise goods or services on the Service (collectively, “Advertisers”) may also use cookies or other technologies to track your use of the Service. Advertisers also may use cookies to track your online activities across websites over time to provide interest-based advertising. Those third parties may also provide us with data collection, reporting, ad-response measurement, analytical information, and assist with delivery of relevant marketing messages and advertisements. Some of our Advertisers are members of the Network Advertising Initiative or the Digital Advertising Alliance, or for users in the EU, the European Interactive Digital Advertising Alliance’s Consumer Choice Page ( Please visit these organizations' opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. Please visit your device’s settings or install the AppChoices app to learn more about how you may opt out of receiving personalized ads in mobile apps. 

Further, if you are a resident of the EU, advertisements shown to you may be supplied via the
Ogury Choice Management Platform (“Ogury CMP”), which is compatible with version 2.0 of
the IAB Europe Transparency and Consent Framework (“TCFV2”). Accordingly, your prior
consent will be collected via Ogury CMP, which supports TCFV2.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your device of a particular cookie (or cookies) from a particular site. You may also wish to refer to Your mobile operating system should also give you the option to manage your cookies and advertising preferences (this may be found in the "settings" function on your device).

If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.

5. How We Use Your Personal Information

Calculating & Distributing Rewards (Coins) We use personal information, such as app installation and usasge data, to calculate real-time reward payouts for rewarded actions within the "Earnly" application and website. 

Internal and Service-Related Usage. We use Personal Information for internal and Service-related purposes, including to operate, provide and maintain the Services. For example, we use information we obtain from third parties and collect automatically to do the Earnly Coins reward calculation.  

Analytics and Improving the Service. We and our service providers use Personal Information that we collect on the Services, such as your location and your activities on the Services, to monitor and analyze usage of the Services and to improve and enhance the Services.

Communications. We may contact you (i) for customer-service or technical-support purposes, or (ii) to send you (a) information about topics or content that we think may interest you, or (b) updates about the latest developments or features on the Services. We also may send push notifications to your device and periodic communications to the email address you provide to us in the event that you subscribe to receive such notifications and communications.

Advertising. We and our advertising partners may use your Personal Information, including your location and your activities on the Service to facilitate the delivery of advertisements.

Tailored Content. We may use your Personal Information to provide you with personalized services, content, offers and recommendations. For example, we may analyze your listening history to recommend similar content that we think would be of particular interest to you, send you tailored recommendations based on your location or send you personalized marketing communications based on Personal Information we have collected about you.

Aggregate Data. We may de-identify and aggregate information collected through the Services for statistical analysis and other lawful purposes.

Anti-Fraud We may use your Personal Information to protect our platform and services from fraud and suspicious activity. 

Business Partners. We may use your personal information to manage our business relationships, including:

  • with whom we jointly offer products and services;
  • with whom we have entered into an agreement that provides for the disclosure, sale, lease, or license of your Information; or
  • to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the Business Partner.

Legal. We may use your Personal Information to enforce our Terms of Service, to defend our legal rights, to comply with our legal obligations and internal policies.

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when: 

  • You have consented to the use of your Personal Information, for example to receive electronic marketing communications;
  • We need your Personal Information to provide you with the Services, including for account registration, to respond to your inquiries, or for customer support;
  • We have a legal obligation to use your Personal Information; or 
  • We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to personalize our services and provide you with tailored content, conduct business analytics, and otherwise improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

6. Who are the Third Parties We Share Personal Information With

ProviderOther namesData sharedPrivacy URL
AdGate Media LLC

AdGate Rewards

Identifiers and basic data
AdGem LLC Identifiers
Adscend Media LLC

AdWall and

Identifiers and basic data
adjoe GmbH


Identifiers, app usage & app installation data
ayeT-Studios GmbH Identifiers
inBrain Identifiers, profiling data, device data
Lucid Holdings, LLC

Identifiers and profiling data
Market Cube LLC

Sample Cube

Identifiers, basic data, and profiling data
O.P. Vision LTD

Identifiers and basic data
OfferToro Identifiers
PointClick, LLC

Wall Ads

Pollfish Inc. Identifiers
Precision Sample, LLC


Identifiers, basic data, and profiling data
Research For Good Inc.

SaySo Rewards

Identifiers, basic data, and profiling data
Research Now Group, Inc

Peanut Labs

Identifiers and basic data
Revenue Universe LLC Identifiers
TheoremReach, LLC Identifiers
Wannads Identifiers and basic data

Your Surveys

Identifiers, basic data, and device data
Yuno Surveys

Dalia Research GmBH

Identifiers, basic data and device data

7. How Can I Stop Sharing of My Data?

If you wish to stop sharing all data immediately then please contact us to turn off your Consent to share

By turning off your consent to share data your access to Earnly features and opprtunities will be limited. 

This Privacy Policy applies only to the processing of your Personal Information by Earnly. It does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link, such as social networks or music streaming sites. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

9. Security

We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. 

10. Data Retention & Deletion

We take measures to delete your Personal Information or keep it in a form that does not allow you to be identified when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, your ability to claim Coins you have earned via our services, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

11. Your Rights and Choices

Marketing Communications

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at Please be aware that, even after you opt out from receiving commercial messages from us, you may continue to receive administrative messages from us regarding the Services.

European Privacy Rights

Depending on your country and, in particular, if you are located in the European Economic Area or Switzerland, you may have the following additional rights: 

  • Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place. 
  • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

12. Use of Services By Children

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide personal information through the Services. We do not knowingly collect, maintain or use Personal Information (as that term is used herein and as defined in the Federal Trade Commission’s Children’s Online Privacy Protection Act Rule) from children under the age of thirteen (13).  If you are located in the European Economic Area or Switzerland, we do not knowingly collect, maintain or use Personal Information from children under the mandated minimum age set by each country within the European Economic Area. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at, and we will take steps to immediately delete that information.

We do not specifically market to children under the age of 13 years old.

13. International Cross-Border Data Transfer

Earnly is based in the United States. If you are visiting the Service from Europe or other regions with laws governing data collection and use, then please note that your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. By providing your Personal Information to the Services, you consent to any transfer of your Personal Information to the United States and other countries in accordance with this Privacy Policy. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Policy.

14. California Privacy Rights

If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. You may request such notice once a year and free of charge. To request a notice, please contact Earnly as provided in the “Contact Us” section of this Policy and indicate in the email subject line “California Shine The Light Request” so that we can process your request. Please include your mailing address, state of residence and email address with your request.

In addition, if you are a California resident under the age of 18 and are a registered user of the Service, you may request that we remove content or information about you that you posted on the Service by (i) submitting a request in writing to and (ii) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. Please note, we are not required to, and may not be able to, erase or otherwise eliminate content or information if (a) other state or federal laws require us or a third party to maintain the content or information; (b) the content or information was posted, stored, or republished by another user; (c) the content or information is anonymized so that you cannot be individually identified; (d) you do not follow the instructions posted in this Privacy Policy on how to request removal of your content or information; or (e) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.

Those rights may be limited in some circumstances by local law requirements.  You may exercise these rights by contacting us as specified below.  

As of January 1, 2020, California residents also have the following rights provided to them under the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA): (1) Right to Know About Personal Information Collected. California residents have the right to request that a business disclose to them the Personal Information it collects, uses, discloses, and sells, subject to certain exceptions and limitations. (2) Right to Request Deletion of Personal Information. California residents also have the right to request the deletion of their Personal Information collected or maintained by Earnly , subject to certain exceptions and limitations.  (3) Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information. Under the CCPA, the “sale” of Personal Information broadly includes any communication of Personal Information to any business that is deemed to be a “third party” (as defined in the CCPA) for monetary or other valuable consideration, subject to certain exceptions and limitations. (4) Authorized Agent. California residents may use an authorized agent to exercise certain privacy-related requests and rights on their behalf. The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose. If your authorized agent submits the exercise or request online via the link below, a copy of the power of attorney or the original notarized statement shall be mailed to the following address: 3D Asset Holdings LLC 16192 Coastal Highway, Lewes, DE 19958; Attention: Privacy Team, within five (5) days after submitting such online request, or we may in our discretion otherwise verify the agent’s authority to our reasonable satisfaction. (5) Notice of Financial Incentive. California residents have the right to receive notice of financial incentives provided to them by a business. (6) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. California residents have a right not to receive discriminatory treatment by a business in the event that the California resident exercises one or more of their privacy rights conferred by the CCPA. (7) How to Submit Your Request. Earnly offers California consumers (or their authorized agent) two (2) ways to submit requests concerning their California privacy rights under the CCPA: (i) by emailing us at (Attn: California Privacy Requests); or (b) by mailing your request to the following address: Earnly Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611 (Attn: California Privacy Requests). Earnlywill review all properly-submitted requests and respond in a timely manner in accordance with the CCPA and applicable regulations thereunder. As part of this process, and to prevent unauthorized use of your Personal Information, you may be asked to verify your identity so that we can match you to a person in our systems. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question, Service activity and other information; such verification may be conducted by a third-party on our behalf. (8) Publication of CCPA Statistical Data. Starting January 1, 2021, and updated each year thereafter (if and as required by the CCPA), Earnly will publish a summary of statistical data pertaining to the following categories of California-resident consumer privacy requests: (1) “Requests to Know”, (2) “Requests to Delete”, and (3) “Requests to Opt-Out of Sale.” The statistical data Earnlywill publish will include: (A) the number of requests Earnly received in each category of California-resident consumer privacy request, (B) the number of such requests that earn.lyplied with in (in whole or in part), (C) the number of such requests which Earnly denied, and (D) the median number of days within which such requests were responded to.

15. CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

      Send information, respond to inquiries, and/or other requests or questions

      Process orders and to send information and updates pertaining to orders.

      Send you additional information related to your product and/or service

      Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

      Not use false or misleading subjects or email addresses.

      Identify the message as an advertisement in some reasonable way.

      Include the physical address of our business or site headquarters.

      Monitor third-party email marketing services for compliance, if one is used.

      Honor opt-out/unsubscribe requests quickly.

      Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

  • Follow the instructions at the bottom of each email. 
  • Use the unsubscribe link at the bottom of each email.
  • Contact us directly at

16. Poll Fish Plugin

This website uses Pollfish web plugin. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones and website owners in order to have access to users of such applications/websites and address survey questionnaires to them. This website uses and enables Pollfish cookies. When a user connects to this website, Pollfish detects whether the user is eligible for a survey.

Data collected by Pollfish will be associated with your answers to the questionnaires whenever Pollfish sents such questionnaires to eligible users. For a full list of data received by Pollfish through this website, please read carefully Pollfish respondent terms located at By using this website you accept this privacy policy document and you hereby give your explicit consent for the placement of a Pollfish cookie in your system and the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website or by disabling “third party cookies” from your browser’s settings. We once more invite you to check the Pollfish respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works works.


17. Updates To This Privacy Policy

We may make changes to this Privacy Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes, we may notify you through the Services or by sending you an email or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. Your continued use of the Services following these changes means that you accept the revised Privacy Policy.

18. Contact Information

Please use the methods below to contact our data protection officer if you need further help understanding this policy or concerns regarding your personal data.

Was this article helpful?