Privacy policy

Last updated

What Trovewall collects, why, and how little of it identifies anybody.

End users of our publishers

We do not know who your users are and we do not want to. When a user opens an offerwall we receive and store:

DataWhyKept
Your opaque user_idPer-user caps, duplicate detection, crediting the right person24 months
IP addressCountry targeting and fraud detection90 days, then truncated
User agent, device, OSDevice targeting and fraud detection24 months
Clicks and conversionsAttribution, billing, dispute resolution24 months

We never receive a name, an email address or a payment detail for an end user, and we do not set advertising cookies or build cross-publisher profiles. The user_id is meaningful only to the publisher who issued it.

Account holders

For publishers and advertisers we hold what is needed to run the account and pay it: name, email, company, country, VAT or tax identifier, bank details for payouts, and a log of sign-ins and administrative actions.

Legal basis

Contract performance for everything needed to run an account and settle money; legitimate interest for fraud prevention and security logging; legal obligation for financial records, which are kept as long as tax law requires regardless of the retention periods above.

Sharing

A click identifier and its country and device pass to the advertiser whose offer was clicked — that is how attribution works. A conversion's amount and your own user_id pass back to the publisher. Nothing else is shared, and we do not sell data.

We use a transactional email provider and standard hosting infrastructure. Both process data on our instructions only.

How long we keep it

These are the periods the platform actually enforces, not aspirations. Clicks that never convert are pruned by a scheduled job; they are not kept indefinitely because nobody wrote one.

WhatHow longWhy that long
Clicks that never converted Until the offer's conversion window closes, then pruned After the window a conversion cannot be accepted, so the record has no further purpose.
Clicks that converted, and the conversions themselves Kept as financial records They are the evidence for money that moved. A ledger with rows removed no longer reconciles.
Daily statistics Kept Aggregated counts by day, offer, country and device. No identifiers, so nothing in them is personal data.
Fraud flags and blocklist entries While the reason for them stands A blocklist that forgets is not a blocklist.
Account records and bank details While the account exists, then as long as tax and accounting law requires We cannot delete a payment record we are obliged to keep.
Service and audit logs Pruned on a rolling schedule Long enough to investigate an incident, not long enough to be an archive.

Your rights

Under the GDPR you may request access, correction, erasure, restriction or portability, and you may object to processing based on legitimate interest. Because we cannot identify an end user from a user_id alone, requests about an end user must come through the publisher who issued it.

For your own account, write to [email protected]. We answer within 30 days. There is no charge unless a request is repetitive or excessive, and we will say so before charging rather than after.

What we cannot delete. Records of money that moved. If you close your account we remove your profile and your bank details, but the ledger entries for deposits, conversions and payouts remain, because they are financial records of a real transaction and both tax law and our own ability to prove what we paid depend on them.

You also have the right to complain to a supervisory authority in your country. We would rather you came to us first, but that right does not depend on it.

Children

The platform is not for children. Accounts require you to be 18 or over, and publishers may not embed an offerwall in a product directed at children — that rule and its consequences are in the publisher advertising guidelines. If we learn that we hold data about a child, we delete it.

If you are a publisher or advertiser

Where you are the controller of your end users' data and we process it for you, the contractual terms are in the data processing addendum. It applies to every account automatically and lists our sub-processors, our security measures and our breach notification commitment. You do not have to request it.

Cookies

Covered separately, in the cookie policy. The short version is that we set two strictly necessary cookies on the dashboard, none at all on the offerwall, and no advertising or analytics cookies anywhere.

Changes

If what we collect or why changes, this page changes with it and the date at the top moves. Where the change is material to account holders, we will also say so by email.


Who you are dealing with

Trovewall is operated by Trovewall LLC., registered at Office 251 House of Francis, Ile du Port, Mahe, Seychelles.

Questions about this document [email protected]
Publisher accounts and traffic [email protected]
Advertiser accounts and campaigns [email protected]
Everything else [email protected]