Gain Privacy Policy

Last Updated: June 22, 2026

Big Propeller respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use Personal Data about you and how you can exercise your privacy rights.

This Privacy Policy applies to all users of Big Propeller, LLC. websites and services, including but not limited to bigpropeller.com, gainapp.com, gain.app, and gain.li.

If you have any questions or concerns about our use of your Personal Data, please contact us at privacy@gainapp.com.

What does Big Propeller / Gain do?

Big Propeller is a US-headquartered provider of software and maker of Gain. Gain is a collaboration and content management software platform for marketing teams. For more information about Gain see the main website at https://gainapp.com.

Our Role: Controller and Processor

When you create an account, contact us, or browse our websites, Big Propeller acts as a data controller of your Personal Data and this Privacy Policy governs how we handle it.

When our customers use Gain to manage and approve content on behalf of their own clients, that content and any Personal Data it contains is provided and controlled by our customer. In those cases, Big Propeller acts as a data processor and processes that data only on our customer’s instructions. Where required by applicable data protection law, we enter into a Data Processing Agreement (DPA) with our customers governing this processing, and a DPA is available to customers on request at privacy@gainapp.com. If you are an end client of one of our customers and have questions about how your data is used, please contact the customer (the agency or brand) that invited you to Gain.

Definition of Personal Data

“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Sensitive Personal Data” means any information consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Big Propeller will never knowingly collect or ask for Sensitive Personal Data from you.

When We Collect Personal Data

We collect information about you when:

You provide it directly to us
Third parties such as our service providers (e.g. companies with whom we integrate our Service), provide us with Personal Data about you
Personal Data about you is automatically collected in connection with your use of our Service

What Personal Data We Collect

We collect the following Personal Data from you in connection with the Service:

Contact and User Account Information: information we collect to contact you and identify you in the system, such as your first and last name, physical address, email address, telephone number, profile picture, password, and mobile device identification.
Company Information: information you provide about companies or organizations you work with/for, such as company or brand name, website, logo, and social media accounts.
Financial Account Information: information that you provide in connection with your purchase of the Service, including credit card number, credit card expiration date, credit card verification code, bank account number, bank account title, bank name, and routing number. Payment card details are processed by our payment provider and are not stored on our servers.
Transaction Information: information related to transactions you conduct on the Service, such as purchases, interactions with customer support, or when you register for a demo or webinar.
User Content: to the extent that you choose to input Personal Data as part of such content, images, comments, and other content that you post to or through the Service.
Data Collected Automatically: this may include information like your IP address, device or browser type, broad geographic location (e.g. country or city-level location), and information about how your device has interacted with our Service, including the pages/content accessed, mouse movements, and links clicked.
Social Network Platform Data: this is data we get about you from an integration with a social network API, which may include information like name, email, profile picture, and encrypted API access tokens.

Automated Processing and Artificial Intelligence

Some features of the Service use artificial intelligence to help you create, review, and improve content. When you use these features, the relevant content (such as captions, text, and images you choose to check or generate) is processed by third-party AI service providers acting on our behalf as sub-processors.

We use these providers solely to deliver the requested feature (for example, generating suggested copy or checking content against brand rules).
Our AI service providers process this content under their enterprise/API terms and do not use it to train their models.
These features do not make decisions that produce legal or similarly significant effects about you. AI suggestions are advisory only; a person remains in control of all content and approval decisions.

You can find the AI service providers we currently use in our sub-processor list (see below).

Sub-processors

We engage trusted third-party companies to help us provide and operate the Service, including hosting, payment processing, analytics, customer support, communications, and artificial intelligence features. These sub-processors process Personal Data only as needed to perform their functions on our behalf and are bound by contractual obligations to keep it secure and use it only for the purposes we specify.

A current list of our sub-processors is available on request at privacy@gainapp.com.

Cookies and Similar Tracking Technology

We use cookies and similar tracking technology (collectively, “Cookies”) to operate our websites, understand how they are used, and improve them.

What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website or use a platform. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
First and third-party cookies. Cookies set by the website owner (in this case, Big Propeller) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. interactive content and analytics).
Why do we use cookies? Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as “essential” or “strictly necessary” cookies. We also use cookies for analytics to understand how our Website is used.
How can you control cookies? You have the right to decide whether to accept or reject non-essential cookies. Where required by law, we will ask for your consent before placing non-essential cookies, and you can change your preferences at any time. You can also set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Website though access to some functionality may be restricted.

How We Use Personal Data

We use this Personal Data for the following purposes:

Operate and improve the Service
Provide customer support and assistance
Monitor use of the Service to ensure reliability, uptime, security, and fraud prevention
Learn more about our users and their behavior in the Service
Send you reminders, technical notices, administrative messages, announcements, newsletters, or marketing material through email or other means
Evaluate offers, products, or services that may be of interest to users or customers

To Whom We May Disclose Your Information

We may disclose your information, including Personal Data, to the following categories of recipients:

To our third party service providers and sub-processors who provide data processing services to us (for example, to facilitate or provide functionality of our Service)
To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or court order or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Policy
To any other person with your consent to the disclosure

We do not sell your Personal Data, and we do not share Personal Data with third parties for their own marketing purposes.

International Data Transfers

Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident, including the United States, where our servers are located. Our third party service providers also operate around the world.

Where we transfer Personal Data out of the European Economic Area, the United Kingdom, or Switzerland to a country that has not been deemed to provide an adequate level of data protection, we rely on appropriate safeguards to protect that data, including the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable). You may request a copy of the relevant safeguards by contacting us at privacy@gainapp.com.

How Long We Retain Personal Data

We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, in the limited circumstances where this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Your Data Protection Rights

We will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

The following rights, by law, must be extended to members of the European Union / European Economic Area, in accordance with the GDPR. However, Big Propeller, in its efforts to provide broad data protection to its customers, extends these rights to all users of their Service regardless of their country of residence.

You have the right to access, correct, or update your Personal Data at any time.
You have the right to withdraw consent to us processing your Personal Data at any time.
You have the right to request a full copy of all your Personal Data we have collected at any time.
You have the right to request us to delete all your Personal Data we have collected at any time.
You have the right to request that we port your personal data in a machine readable format to a new provider if you meet the qualifications set forth in Article 20, Recital 68 of the GDPR.
You have the right to object to the use of Personal Data for direct marketing purposes, use of Personal Data based on certain public interests or exercise of official authority, and use of Personal Data for research and statistical purposes.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or by turning off this option in the settings area of the Service.
You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
You have a right to be notified of any serious breaches to your Personal Data no later than 72 hours after Big Propeller becoming aware of such breach.

Your US State Privacy Rights

Depending on the US state in which you reside, comprehensive state privacy laws (including those in California, Colorado, Connecticut, Virginia, and a growing number of other states) may provide you with some or all of the following rights regarding your Personal Data:

Right to know and access the Personal Data we collect about you, the sources, the purposes for collecting it, and the categories of third parties with whom we share it, and to obtain a copy of it.
Right to correct inaccurate Personal Data.
Right to delete Personal Data we have collected from or about you, subject to certain exceptions.
Right to data portability, to obtain your Personal Data in a portable, machine-readable format.
Right to opt out of the sale of Personal Data, targeted advertising, and certain profiling. We do not sell your Personal Data, we do not share it for cross-context behavioral or targeted advertising, and we do not use it for profiling that produces legal or similarly significant effects about you.
Right to limit the use of Sensitive Personal Data. We do not knowingly collect Sensitive Personal Data.
Right to appeal a decision we make about a privacy request, where your state provides for an appeal.
Right to non-discrimination for exercising any of these rights.

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), provides the rights described above, including the right to know the categories of Personal Data collected and disclosed.

To exercise any of these rights, contact us at privacy@gainapp.com. We will not discriminate against you for exercising your privacy rights. You may use an authorized agent to submit a request on your behalf, subject to our verification of your identity and the agent’s authority.

How to Make a Privacy Request

You can submit a privacy request to us through either of the following methods:

By email: contact us at privacy@gainapp.com, specifying the scope of the data you want to access, correct, or remove.
By online request form: complete the privacy request form available at https://gainapp.com/privacy-request.

To initiate any of the above requests, please follow this procedure:

We will acknowledge your request and verify your identity before acting on it.
We will complete the request within the timeframe required by applicable law (generally within 30 days, with the possibility of a permitted extension where the request is complex).
We will contact you to inform you about completion of the request and, where applicable, provide you a copy of the relevant data, depending on the scope of your request.

Note that some of these requests may prohibit your continued use of the Service. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.

Minimum Age

We will never knowingly request personally identifiable information from anyone under the age of 16 without requiring parental consent. Any person who provides their Personal Data to us through our Service represents that they are 16 years of age or older.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

How to Contact Us

If you have any questions or concerns about our use of your Personal Data, or to exercise any of your rights, please contact our privacy team at privacy@gainapp.com.