Privacy Policy


Last updated: 09/05/2019

This privacy policy ("Policy) describes how SurgePays Inc. ("Surge", "us", "our", and "we") collects, uses, and discloses personal information of users of the mobile application called "SurgeRewards" (the "App") and the services offered through the App (the "Services").

Information you submit through the App is collected by Surge as the application provider and then shared with 3rd Party advertising agencies.


We gather information about you in a range of ways.


To use the Services, we require you to create an account (an "Account") by registering with us and/or connecting to the Services via a social networking site ("SNS"). As part of creating an account, you may provide information such as your age, gender, telephone number, and email address.

If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may collect and use that information to provide geographically relevant ads and offers. If you would like to deactivate this feature, you can disable location services on your device, but please be aware that not all features of the App will work optimally without such location services.

We collect personal information that you provide when you correspond with us, participate in a contest, sweepstakes, or other promotion; or in the course of your use of the App and/or Services.


Generally. The App may collect certain information automatically, such as: the type of mobile device you use, mobile device identifiers, such as the resettable advertising identifier assigned to your device, the IP address of your mobile device, your mobile operating system, the Wi-Fi mac address in your area, the type of mobile Internet browsers you use, and information about the way you use the Application.. In addition, in the event our App crashes on your mobile device, we will receive information about your mobile device model software version, which allows us to identify and fix bugs and otherwise improve the performance of our App.

Log Files. We gather certain information automatically and store it in log files ("Log Files"), including IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to improve the content of the App and Services, for market research purposes, to communicate information to visitors and to better tailor the App and Services to our users' needs.

Cookies. We may log information using "Cookies." Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience through our App and Services. This type of information is collected to make the App and Services more useful to you and to tailor the experience with us to meet your special interests and needs.

Analytics. We may use third party analytics services to help analyze how users use the App and Services. Analytics services use Cookies to collect information such as how often users open the App and what features they use in the App. We use this information to improve our App and Services.

Collection of Information by Advertisers. We may work with analytics companies to help us understand how the Application is being used, such as the frequency and duration of usage. We also work with advertisers and third-party advertising companies that collect information about how you interact with advertising and content provided in the Application, which helps us keep the cost of the Application FREE. Advertisers and advertising companies use some of the information collected by the Application, including the advertising identifier assigned to your mobile device to serve advertisements that are targeted to your interests in the Application. These third parties may also obtain anonymous information about other applications you've downloaded to your mobile device, the mobile websites and applications you visit, and your location in order to help analyze user behavior and serve targeted advertising on the Application and on other applications and websites. This Policy does not apply to, and we are not responsible for, Cookies or pixel tags in third party ads. We encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies.


We use your personal information to:

  • Respond to comments, requests and questions and provide customer service;
  • Provide you with and communicate with you about the Services;
  • Help understand your needs and tailor the features and content of the Services to fit these needs;
  • Process and deliver the products and services you request;
  • Identify you as a user in our systems;
  • Facilitate the creation of and secure and administer your Account;
  • Resolve disputes and/or troubleshoot problems;
  • Develop and improve marketing and advertising for the App and Services; and
  • Market our products and services and those of third parties to you that we believe may be of interest to you.
  • We may also create anonymous and/or de-identified data records from your personal information by excluding information (such as your name) that makes the data personally identifiable to you.

    We use the anonymous data we collect to analyze trends, administer and improve the App and Services, track users' movements in the App, gather demographic information about our user base as a whole, better tailor our Services to our users' needs, and enhance the content of our Services and improve the App. For example, some of the Log Files may be collected so that when you use the App again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. However, we reserve the right to use and disclose anonymous data for any purpose.

    Feedback. If you provide feedback to us, we may use and disclose such feedback, provided we do not associate such feedback with your personal information. We may publish user feedback from time to time. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback. We will collect any information contained in such feedback and will treat the personal information in accordance with this Policy, provided that we may contact you regarding such feedback.


    We may disclose certain personal information:

    Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with the third parties that you authorize to receive such information.

    Third Party Service Providers. We may share your personal information with our third-party service providers that help us provide Services that we offer you.

    Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), if we have such Affiliates in the future, in which case we will require our Affiliates to honor this Policy.

    Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

    Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), we may disclose personal information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property or other users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Policy, or the Terms of Use you have with your phone manufacturer.


    Email Communications. We may periodically send you newsletters and other e-mails that directly promote the use of our App or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive. Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to this Policy or the Terms of Use, which you may not

    Cookies. If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser's technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.

    Changing or Deleting Your Personal Information. You may review, update, correct or delete the personal information by accessing your Account or by contacting Surge as described below. We will use commercially reasonable efforts to honor your request. If you completely delete all your personal information, then your Account may become deactivated, although your personal information associated therewith will remain on the Services unless you have deleted such personal information. We may also retain an archived copy of your records as required by law or for legitimate business purposes. Please remember, however, if we have already disclosed some of your personal information to third parties, we cannot access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Certain information is necessary in order for us to provide the Services; therefore, if you delete such necessary information you may not be able to use the Services.

    THIRD PARTY WEBSITES. Our App may contain links to third party websites. When you click on a link to any other website or location, you will leave our App and go to another site and another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

    INFORMATION DISCLOSED TO THIRD PARTIES. This Policy addresses only our use and disclosure of information we collect from and/or about you on the App and Services. If you disclose information to others; or authorize us to do the same under this Policy, the use and disclosure restrictions contained in this Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

    DATA RETENTION. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law. There may also be residual data that will remain within our databases and other records, which will not be removed.

    A NOTE ABOUT CHILDREN. This App and Services are not directed to children under the age of 18 and children under the age of 18 are not eligible to use our App or Services. We do not knowingly collect personal information from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected] We will delete such information from our files within a reasonable time.

    CONTACT INFORMATION. We welcome your comments or questions about this Policy. You may contact Surge at [email protected]

    CHANGES TO THIS POLICY. We may change this Policy from time to time for any reason. If we make any changes, we will change the last updated date above and post the new Policy here and notify you as required by law: You should consult this Policy regularly for any changes.