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Privacy Policy

Effective 22 September 2026Version 2026-09-22

This Policy explains how SGain processes personal data when an application is submitted and reviewed, when the referral program is used, and during subsequent operational follow-up. It applies to the public SGain website, application form, and related internal processes.

1. Who is responsible for processing

SGain is operated and personal data is controlled by Sole Proprietor Oksana Farenik, Ukraine.

For privacy, data-access, or other rights requests, contact info@basehands.com.

2. Information we process

We process information you provide in the form, application-attribution data, and limited operational records needed to review applications, communicate, maintain security, and operate the service.

  • first and last name, country, city, and selected language;
  • email, phone, Telegram, WhatsApp, and Viber — only the contact methods you choose to provide;
  • selected social platforms;
  • application identifier, submission date and time, participant status, and internal operational notes;
  • the time legal documents were accepted, age confirmation, and the versions of the consent, Privacy Policy, and Terms of Use;
  • personal referral code, submitted referral code, the referral relationship, and information needed to verify referral attribution;
  • acquisition source and UTM source, medium, campaign, content, and term when provided with the visit;
  • Pipedrive synchronization identifiers, statuses, errors, and timestamps;
  • privacy-preserving hashes derived from contact, network, or other application information for rate limiting, duplicate detection, and abuse prevention;
  • application data may be processed by authorized administrators through search, filtering, status updates, internal notes, and creation of CSV exports for operational work.

3. Information you should not provide

The initial application does not collect passwords, login codes, recovery keys, social-platform credentials, identity documents, or payment details. Do not enter or send this information through the form or contact fields.

4. Why we use the information

Submitting an application does not guarantee acceptance, cooperation, use or rental of an account, availability of an opportunity, payment, income, or any specific referral reward.

  • to receive, check, and process an application for potential cooperation;
  • to contact you about possible cooperation and explain its separate terms;
  • to maintain internal records of applications, statuses, notes, and communications;
  • to transfer the minimum information needed to the CRM for operational follow-up;
  • to create a personal referral code or link, record valid attribution, and administer potential referral rewards;
  • to understand how applications reach SGain and assess acquisition channels;
  • to document acceptance of the Terms and consent to data processing;
  • to protect the form and systems from spam, repeated automated applications, fraud, and technical errors;
  • to meet applicable legal obligations, resolve disputes, and protect legitimate rights.

5. Consent and other processing grounds

When you submit an application, we request your explicit consent to process personal data for the purposes described in this Policy and record the corresponding time and document versions. You may withdraw consent by emailing info@basehands.com. Withdrawal does not affect the lawfulness of processing carried out before it.

Some limited information may continue to be processed where reasonably necessary to comply with applicable law, maintain security, prevent fraud, resolve disputes, or establish prior consent or interactions. If actual cooperation begins, its separate terms may involve additional purposes and processing grounds that will be communicated separately.

6. Referral program

After a successful application, SGain generates a unique personal referral code and link for the participant. When a new participant applies through a valid referral relationship, we record that attribution. The public referral feature does not disclose the referred participant’s personal information to the referrer.

Recorded attribution does not by itself create a right to payment. The availability, amount, trigger, timing, and method of a potential reward may depend on the platform, opportunity, campaign, demand, and actual cooperation. Relevant terms are communicated before they begin to apply.

7. Service providers and international processing

SGain uses external providers: Supabase for database, authentication, and backend infrastructure; Pipedrive for CRM and operational follow-up; and Render for application hosting and infrastructure. Data may also be accessed only by authorized SGain administrators within their work responsibilities.

Providers may process data in different jurisdictions. Depending on the provider, configuration, and applicable law, provider and contractual safeguards may apply.

An authorized administrator may export results to CSV for permitted operational work. Those files are manual copies and must be kept only while needed for the purpose for which they were exported.

8. Retention and deletion

Following a justified deletion request, we delete or anonymize information that no longer needs to be retained. Where secure backups exist, deletion may take additional time to propagate through them.

  • data for active or potential participants is kept while reasonably required for current or potential cooperation;
  • inactive or rejected applications may be kept for up to 24 months after the last meaningful interaction;
  • anti-abuse and security hashes may be kept for up to 12 months;
  • referral attribution is kept while the participant relationship remains relevant or while reasonably required to administer or verify referral rewards;
  • consent and legally relevant interaction evidence may be kept longer where reasonably necessary to comply with law, resolve disputes, protect rights, or establish prior consent or transactions;
  • CSV exports and other manual operational copies must be deleted by authorized users when no longer needed for the purpose for which they were created.

9. Security and its limitations

We use technical and organizational measures designed to restrict access, verify administrator permissions, minimize logs, protect secrets, and prevent abuse. However, no method of transmission, processing, or storage can guarantee absolute security.

10. Browser storage, cookies, and similar technologies

The public application may temporarily use browser storage to preserve an unfinished draft on the current device and avoid losing entered information during navigation or a language change. After a successful submission, personal draft data is cleared; without retaining the full draft, only the minimum success and referral information needed to continue the confirmation experience may be kept temporarily.

SGain does not currently intentionally use advertising pixels or non-essential marketing cookies in the public application. The private Admin Panel may use Supabase Authentication cookies or browser storage to maintain a secure administrator session.

11. Your rights

You may email info@basehands.com to request access to your personal data, correction, deletion, withdrawal of consent, or another privacy right applicable in your jurisdiction. To protect the data, we may ask for enough information to verify the requester and locate the relevant record.

Some limited information may need to be retained where reasonably required by law, security, fraud prevention, dispute resolution, or evidence of prior consent or transactions. The availability of other rights, including restriction, objection, portability, or complaint, depends on applicable law.

12. Age and geography

An SGain application may be submitted from age 16. SGain accepts applications worldwide, but opportunity availability depends on country, applicable law, individual platform requirements, and the terms of a particular cooperation. Submitting an application does not guarantee that an opportunity will be available in your country.

13. Policy updates and contact

We may update this Policy when processes, technology, or legal requirements change. The current version and effective date are shown on this page. If a change materially affects consent already provided, we will request a new confirmation where required.

Privacy contact: info@basehands.com.

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