1. Introduction & Our Commitment to Privacy

Stack Gain (operated by Gates Digital, and accessible at www.stackgain.io) is a cashback rewards platform dedicated to helping users earn money back on their digital subscriptions, AI tools, and software purchases across Southeast Asia. We serve over 1,000 users and partner with more than 300 Digital Service Vendors, and we take the privacy of every individual we interact with seriously.

We are committed to safeguarding the personal data of our users, vendor partners, visitors, and anyone else with whom we engage throughout the provision of our services. While our core mission is to help you maximize savings on your digital spending, we recognize that protecting your personal information is equally important to us and to you.

This Privacy Policy explains how Stack Gain collects, uses, discloses, and protects your personal data when you use our platform, website, mobile applications, or any other Stack Gain services. We collect only the minimum information needed to operate our services effectively. Any data shared with our vendor partners is limited strictly to what is required to verify and track your cashback rewards.

If you have questions, concerns, or feedback regarding this policy, please reach out to us at:

Website : www.stackgain.io

Email : info@stackgain.io

Phone: +65 6369 8123

Address: Singapore

2. Scope of This Policy

This Privacy Policy governs the collection, use, and disclosure of personal data in connection with your use of:

• The Stack Gain website at www.stackgain.io
• Stack Gain mobile applications (where applicable)
• Stack Gain browser extensions and web tools
• Any other platforms, portals, or services operated by Stack Gain

By continuing to access or use any of the above services, you acknowledge that you have read and agree to the practices described in this Privacy Policy. Stack Gain reserves the right to update this policy at any time, and any changes will be published on our website. Continued use of our services after updates constitutes your acceptance of the revised policy.

3. Personal Data We Collect

Stack Gain collects personal data only to the extent necessary to provide you with our services, improve your cashback experience, and comply with our legal obligations. We may collect personal data in the following circumstances:

– When you register for a Stack Gain account or complete any onboarding forms

– When you sign up for our newsletter, alerts, or marketing communications

– When you contact our support team via email, phone, chat, or other means

– When you participate in promotions, referral programs, or platform surveys

– When you connect your Stack Gain account to a third-party platform (e.g., Google or social media sign-in)

– When you submit a job application or interact with us as a prospective employee or partner

– When you are referred to us by a business partner or Digital Service Vendor

3.1 Types of Personal Data Collected

The personal data we may collect includes, but is not limited to, the following categories:

Identity Information: Your full name, email address, date of birth, phone number, profile photographs, device ID, IP address, and payment-related details (such as bank account information or digital wallet credentials).

Interaction Records: Logs of your communications with Stack Gain, including support emails, call recordings, chat transcripts, and any other records of contact.

Account Information: Details associated with your Stack Gain account, including your login credentials and cashback balance history.

Platform Usage Data: Information about how you interact with our platform, such as the pages you visit, time spent on each page, items you click, search queries, redirect history, and other behavioural data collected through cookies and similar technologies.

Communication Preferences: Your preferences regarding how you wish to be contacted, including your preferred services, brands, and subscription categories.

Location Data: Where you grant us permission, we may collect location information to tailor our cashback offers and digital service recommendations to your geographic region.

Clipboard Data (App Only): With your explicit permission, our app may access content in your device clipboard for the sole purpose of tracking referral links or redirects to our vendor partners. We do not store clipboard content and do not access personal text, images, or sensitive data.

4. How We Use Your Personal Data

Stack Gain uses the personal data we collect for the following purposes:

• To create, manage, and maintain your Stack Gain account
• To process and credit cashback rewards to your account following qualifying purchases
• To verify and track your transactions with our Digital Service Vendor partners
• To provide personalized cashback recommendations and curated deals
• To send you transactional notifications, account updates, and cashback status alerts
• To send marketing communications (where you have consented), including newsletters, promotions, and platform updates
• To improve and optimize our platform’s performance, features, and user experience
• To detect, investigate, and prevent fraudulent activity or misuse of our services
• To comply with legal and regulatory obligations applicable in Singapore and across Southeast Asia
• To respond to your support inquiries and resolve any issues you experience
• To assess job applications submitted to Stack Gain

5. Disclosure of Personal Data to Third Parties

Stack Gain does not sell your personal data to third parties. However, we may share your data in limited circumstances as described below:

5.1 Digital Service Vendors

We share only the minimum necessary data with our partner vendors to verify and process your cashback. This typically includes transaction identifiers and referral tracking data — not your full personal profile.

5.2 Service Providers

We engage trusted third-party service providers (such as payment processors, cloud hosting providers, analytics platforms, and fraud detection services) to help us operate our platform. These providers are contractually bound to protect your data and may not use it for any purpose beyond what is required to perform services on our behalf.

5.3 Legal & Regulatory Compliance

We may disclose personal data if required to do so by law, court order, or government authority, or where disclosure is necessary to protect the rights, safety, or property of Stack Gain, our users, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the succeeding entity, provided they commit to upholding equivalent privacy protections.

5.5 Social Media & Third-Party Sign-In

If you choose to create or link your Stack Gain account via a third-party service such as Google or a social media platform, we will access and receive personal data (such as your name, email address, and profile details) shared by that platform, in accordance with their own terms and conditions.

6. Cookies and Tracking Technologies

Stack Gain uses cookies and similar tracking technologies to enhance your user experience, analyse platform usage, and support our cashback tracking functionality. Cookies are small data files stored on your browser or device.

The types of cookies we may use include:

• Essential Cookies: Required for the platform to function, including session management and security.
• Functional Cookies: Enable features such as saved preferences and account personalisation.
• Analytics Cookies: Help us understand how users navigate our platform so we can improve performance.
• Tracking Cookies: Used to track clicks and redirects to our vendor partners for cashback attribution purposes.

You may manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of Stack Gain’s cashback tracking features.

7. Data Security & Retention

Stack Gain implements industry-standard technical and organisational measures to protect your personal data from unauthorised access, loss, misuse, or alteration. These measures include encrypted data transmission, secure server infrastructure, and access controls limited to authorised personnel.

We retain your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. When your data is no longer needed, we will securely delete or anonymise it in accordance with our data retention procedures.

8. Your Rights & Choices

As a Stack Gain user, you have the following rights with respect to your personal data:

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may request that we update or correct inaccurate or incomplete information.
• Deletion: You may request that we delete your personal data, subject to our legal and contractual obligations.
• Withdrawal of Consent: Where our use of your data is based on your consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Opt-Out of Marketing: You may opt out of receiving marketing communications at any time by clicking ‘unsubscribe’ in any email or by contacting us directly.
• Data Portability: Where applicable, you may request that we transfer your data to another service provider in a structured, machine-readable format.

To exercise any of these rights, please contact our Data Protection Officer at: support@stackgain.io. We will respond to your request within a reasonable timeframe and in accordance with applicable data protection law.

9. Third-Party Links & External Platforms

Our platform may contain links to third-party websites, applications, or digital services operated by our vendor partners. Stack Gain is not responsible for the privacy practices or content of these external platforms. We encourage you to review the privacy policies of any third-party services you access through Stack Gain.

10. Children’s Privacy

Stack Gain’s services are intended for adults aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18. If we become aware that a minor has provided us with personal information, we will take steps to delete that data promptly. If you believe a minor has submitted data to us, please contact us immediately at info@stackgain.io.

11. Regional Availability & Governing Law

Stack Gain is available across Southeast Asia, including Singapore, Indonesia, Malaysia, Vietnam, and Thailand. Our primary operations are based in Singapore, and this Privacy Policy is governed by the laws of Singapore, including the Personal Data Protection Act 2012 (PDPA).

Where applicable, Stack Gain also endeavours to comply with the relevant data protection regulations of the other jurisdictions in which we operate across Southeast Asia.

12. Updates to This Privacy Policy

Stack Gain reserves the right to modify this Privacy Policy at any time to reflect changes in our services, business practices, or applicable law. When material changes are made, we will notify users via our platform or by email. The most current version of this policy will always be available at www.stackgain.io.

Your continued use of Stack Gain’s services following the publication of changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact Stack Gain at:

Stack Gain (Gates Digital)

Website: www.stackgain.io

Email: info@stackgain.io

Phone: +65 6369 8123

Availability: Available across Southeast Asia — Singapore, Indonesia, Malaysia, Vietnam, and Thailand

We take your privacy seriously and are committed to addressing any concerns you may have in a timely and transparent manner.