Cookie Policy
Last updated: 7 October 2026
1. About this Cookie Policy
This Cookie Policy explains how Scrambly S.r.l., with its registered office at Via della Zecca 1, Bologna, 40121, Italy, (“Scrambly”, “we”, “us” or “our”), uses cookies, software development kits (“SDKs”), device identifiers, browser or session identifiers and similar technologies when you access or use the Scrambly.io website at https://scrambly.io, and the mobile applications and other consumer products operated by Scrambly that link to or otherwise make this Cookie Policy available, including, where applicable, Scrambly Play to Earn, Scrambly Walk to Earn, PenguPace and Spendback (the “Apps”), which may be renamed or updated from time to time (collectively, the “Service”).
This Cookie Policy should be read together with our Privacy Policy, which explains more generally how we collect, use, share and protect Personal Data when you use the Service.
If you have any questions about this Cookie Policy, you can contact us at [email protected].
2. What Are Cookies, SDKs and Similar Technologies
Cookies are small text files that may be stored on your browser or device when you use an online service. Our Website and/or the Apps may also use other technologies that perform similar or related functions, including SDKs, device identifiers, advertising identifiers - where available and permitted - and browser or session identifiers (hereinafter collectively referred to as “Cookies”).
Depending on the Cookies, it may allow information to be stored on or accessed from your device, or allow a particular browser, device, session or interaction with the Service to be recognised.
3. What Are Cookies Used For
Depending on the Service, product, device, platform and your privacy choices, we may use tracking technologies to:
- operate the Service and maintain sessions, authentication and account functionality;
- remember settings and preferences;
- protect the Service, detect fraud or abuse and maintain account and reward integrity;
- attribute qualifying activity, track offer or reward progress and validate rewards;
- understand how users interact with the Service, conduct A/B testing and other product experiments, measure performance and improve our products and features;
- measure offer, campaign and advertising performance; and
- support advertising and related measurement where available and permitted.
4. Which Categories Of Cookies Are Used On The Service
The Cookies used on the Service may be distinguished based on who provides them, how long they remain active, and the purpose for which they are used. The Cookies used may vary depending on the relevant Scrambly product, whether you use the Website or the Apps, your device or operating system, your location, the features available to you, and your privacy choices.
1) Based on who provides Cookies:
- First-party Cookies: these Cookies are set or operated directly by Scrambly through the Service, or used by service providers acting on Scrambly’s behalf. Scrambly processes the data collected from the first-party cookies for its own purposes, regardless of whether it programmed the Cookie itself or has implemented the Cookie of another legal entity;
- Third-party Cookies: these Cookies are installed by third parties whose services or technologies are integrated into the Service. Depending on the relevant processing activity, those third parties may process information on Scrambly’s behalf or for purposes they determine independently as set out in their respective privacy and cookie policies.
2) Based on how long the Cookies remain active:
- Session Cookies: these Cookies operate for the duration of a particular session and generally expire when the relevant session ends or the Website or App is closed;
- Persistent Cookies: these Cookies remain on your browser or device for a defined period or until they are deleted. They may, for example, allow preferences or previous actions to be remembered across different sessions. The specific duration or retention period applicable to the Cookies currently used through the Service is available under Section 7 of this Cookie Policy.
3) Based on their purposes:
- Strictly Necessary Cookies: these Cookies are necessary for the operation, security and core functionality of the Service or to provide a feature or service you requested. They may be used, for example, to authenticate users, maintain sessions, remember privacy choices, prevent fraud or abuse, or support functionality that is strictly necessary to complete or validate a requested payment or reward flow. If strictly necessary for the proper operation of the Service, these Cookies do not require your prior consent and cannot be switched off;
- Functional, Analytics and Product Improvement Cookies: these Cookies help us provide enhanced functionality and understand how the Service is used. They may be used to remember certain preferences, measure performance, identify technical or operational issues, conduct A/B testing and other product experiments, and develop or improve our products and features. Where applicable law requires consent before these Cookies may store or access information on your device or carry out the relevant analytics activity, they will not operate until the required consent has been provided. Thus, if you do not consent to these types of Cookies, Scrambly will not be able to improve the Service;
- Marketing, Advertising, Profiling and Targeting Cookies: these Cookies may be used to support advertising and marketing activities, including offer or campaign attribution, advertising measurement, campaign-performance measurement, remarketing and targeted advertising. They may also be used to create or use information about your interests, preferences or activity to determine which advertisements, offers or promotions are shown to you and how they are presented. Where applicable law requires prior or express consent, these Cookies will not operate until the required consent has been provided. Where applicable law permits another form of consent subject to appropriate information and choice, or instead provides a right to opt out, we apply the relevant consent or opt-out mechanism.
A single Cookie, SDK or provider may support more than one purpose. Where reasonably possible, we treat those purposes separately rather than applying the most permissive category to the technology as a whole.
5. How To Manage Cookies
You can review and change the choices available to you at any time through the made available through the Service.
Certain Strictly Necessary Cookies are required for the operation, security or core functionality of the Service and, where permitted by applicable law, may operate without prior consent. These Cookies may not be available to switch off through the Cookie Settings where they are necessary to provide the Service or a feature you have requested.
Where applicable law requires your prior consent before other Cookies may be used, those Cookies will not operate unless and until you have provided the required consent through a clear consent.
Where such prior consent is required, we use a cookie banner or other consent-management interface that allows you to accept Cookies, refuse optional Cookies or manage your preferences by category. Merely continuing to use the Service, scrolling or otherwise interacting with the Service without making the relevant choice will not, by itself, be treated as consent where applicable law requires a clear affirmative action.
You may refuse optional Cookies or withdraw or change your consent at any time through the . Withdrawing consent is as easy as providing it and applies to the relevant processing going forward. It does not affect processing that was lawful before your choice was changed.
Where applicable law permits another form of consent subject to appropriate information and choice, or provides a right to opt out of particular advertising, analytics, sharing or similar activities, you can exercise the applicable choice through the .
You may also be able to control or delete certain Cookies through your browser or device settings. These controls operate separately from Scrambly’s Cookie Settings. Blocking certain Cookies through your browser or device may affect the availability or operation of some features of the Service.
Please note that you can also exercise your rights regarding the personal data that are collected by way of Cookies, as described in our Privacy Policy or in Scrambly's partners' privacy notices.
6. How Cookie Choices Differ By Location
Privacy rules differ between jurisdictions, and the choices available to you may therefore depend on where you are located.
EU/EEA. Where applicable law requires prior consent before non-exempt Cookies may store or access information on your device or carry out the relevant tracking activity, those Cookies will not operate until the required consent has been provided.
United Kingdom. UK law provides certain exemptions for specific storage and access activities. Where a Cookie does not fall within an applicable exemption, we obtain consent where required by law.
Canada. Canadian privacy laws require appropriate knowledge and consent for the collection, use and disclosure of Personal Data. The appropriate form of consent depends on factors including the sensitivity of the information, the nature of the processing and reasonable user expectations. We provide privacy choices appropriate to the relevant technology and processing activity and obtain express consent where required by applicable law.
United States. Core operational Cookies and ordinary first-party or product analytics generally do not operate under an EU-style prior-consent model. However, applicable U.S. state privacy laws may provide rights to opt out of the sale or sharing of Personal Data, targeted advertising, or similar activities. Where applicable law requires a different consent, objection, or opt-out mechanism, we apply the relevant requirements.
7. Which Cookies Are Used On The Service
The specific Cookies and similar technologies used through the Service may differ depending on the Scrambly product you use, whether you access the Website or the Apps, your device and operating system, your location, the features available to you and your privacy choices.
The tables below provide information about the Cookies and similar technologies currently used through the Service, including the relevant provider, purpose and duration or persistence.
Where a technology uses more than one Cookie, identifier or form of device storage, the duration indicated below reflects the relevant standard or maximum persistence. More detailed information about individual storage technologies may also be available through our Cookie Settings.
Where a Cookie or similar technology is provided by a third party, we also provide, where applicable, further information about the relevant provider. A single provider, SDK or technology may support more than one purpose. Where reasonably possible, we classify and control those purposes separately in accordance with the categories described above.
1) Strictly Necessary Cookies
These Cookies are necessary for the operation, security or core functionality of the Service or to provide a feature or service requested by you.
| Cookie / Technology | Provider | First / Third- party | Purpose | Duration / Persistence | Further Information |
|---|---|---|---|---|---|
| Consent management/privacy preferences | Usercentrics | Third-party provider/ local storage | To display and operate our privacy choices interface and record and remember your Cookie and privacy preferences. | 1 year | https://usercentrics.com/privacy-policy/ |
| Authentication and sign-in technologies | Firebase Authentication (Google), including Google Sign-In, Sign in with Apple, and email magic-link authentication | Third-party provider | To authenticate registered users, maintain their signed-in state, and provide core account functionality. | Persistent until sign-out or browser storage is cleared. Email magic links are one-time use. | https://firebase.google.com/support/privacy https://www.apple.com/legal/privacy/en-ww/ |
| Fraud prevention and account-integrity technology | Verisoul | Third-party provider | To protect the Service against fraud and abuse, assess device, browser, network, and session risk signals, identify suspicious or duplicate activity, and protect account and reward integrity. | Session identifiers may persist for up to 24 hours; other storage depends on the technology used. | https://policies.verisoul.ai/privacy.html |
| Identity-verification technology | Veriff | Third-party provider | To verify your identity or account eligibility where verification is required, prevent fraud or abuse and, where applicable, enable the capture and upload of identity documents or other verification media. | Session to up to 2 years, depending on the technology used within the verification flow | https://www.veriff.com/privacy-notice https://www.veriff.com/cookie-notice |
2) Functional, Analytics and Product Improvement Cookies
These Cookies and technologies help us understand how the Service is used, measure performance, identify technical or operational issues, conduct experiments, provide support and improve our products and features.
| Cookie / Technology | Provider | First / Third Party | Purpose | Duration / Persistence | Further Information |
|---|---|---|---|---|---|
| Product analytics and event-routing technology | Segment (Twilio) | First-party storage/ Third-party provider | To collect information about interactions with the Service, measure product usage and performance, and route relevant events to analytics and other tools used by Scrambly. | 1 year for standard Cookies; local storage may persist until cleared or reset | https://security.segment.com/ |
| A/B testing and experimentation | GrowthBook | Third-party provider/ First-party storage where applicable | To conduct A/B testing and other product experiments, evaluate changes to the Service and support feature configuration. | Up to 4 hours for the standard feature cache | https://www.growthbook.io/legal/privacy-notice |
| Customer engagement and messaging technology | Customer.io | Third Party | To support in-app and other user communications and messaging based on user activity and interactions with the Service. | Data is retained until it is no longer needed for processing purposes. | http://customer.io/legal/privacy-policy |
| Website and product analytics technology | Google Analytics | Third Party | To understand how users interact with the Service, measure usage and performance, and improve our products and features. | Data is retained until it is no longer needed for processing purposes. | https://firebase.google.com/support/privacy |
| Error and performance monitoring SDK | Sentry | Third Party | To detect, diagnose, and resolve crashes, technical errors, and performance issues, and improve the stability and operation of the Apps. | Data is retained until it is no longer needed for processing purposes. | https://sentry.io/privacy/ |
| Customer support and messaging technology | Intercom | First-party storage/ Third-party | To provide customer support and messaging functionality, maintain support sessions, and enable users to access their conversations. | Up to 9 months; session Cookies generally 1 week; local storage may persist until cleared | https://www.intercom.com/legal/privacy |
| Customer support widget | Freshdesk - Freshworks | Third-party | To provide help, support content, and contact functionality through the Service. | Session and persistent, depending on the technology used | https://www.freshworks.com/privacy/ https://www.freshworks.com/list-of-cookies/ |
3) Marketing, Advertising, Profiling and Targeting Cookies
These Cookies and technologies may be used for advertising, offer or campaign attribution and measurement, advertising-related profiling, marketing or personalised or targeted advertising.
| Cookie / Technology | Provider | First / Third Party | Purpose | Duration / Persistence | Further Information |
|---|---|---|---|---|---|
| Google advertising and measurement technologies, including Google Analytics and Google Ads | First-party and Third-party technologies | To measure use of the Service and advertising and campaign performance, attribute visits or activity to marketing campaigns and, where applicable, support advertising and remarketing. | Session to up to 2 years, depending on the technology used | https://policies.google.com/privacy?hl=en-US | |
| Meta advertising technologies, including Facebook Pixel and related social/advertising technologies | Meta | First-party and Third-party technologies | To measure advertising and campaign performance, attribute conversions and, where applicable, support marketing and personalised or targeted advertising. | Up to 90 days | https://www.facebook.com/privacy/policy/ https://www.facebook.com/privacy/policies/cookies/ |
| Microsoft Advertising Remarketing | Microsoft | First-party and Third-party technologies | To measure advertising performance and conversions and support advertising and marketing. | Up to 13 months | https://www.microsoft.com/en-us/privacy/privacystatement https://help.ads.microsoft.com/apex/index/3/en/n5095 |
| Reddit Advertising | First-party and Third-party technologies | To measure campaign performance and conversions, attribute activity to Reddit advertising and, where applicable, support advertising optimisation and marketing. | Up to 90 days | https://www.reddit.com/policies/privacy-policy https://www.reddit.com/policies/cookies | |
| Pinterest Tag and advertising technologies | First-party and Third-party technologies | To measure advertising and campaign performance, attribute conversions and support advertising optimisation, remarketing and personalised advertising. | Up to 1 year | https://policy.pinterest.com/en/privacy-policy https://policy.pinterest.com/it/cookies | |
| TikTok Pixel and advertising technologies | TikTok | First-party and Third-party technologies | To measure advertising and campaign performance, attribute conversions and, where applicable, support advertising optimisation, marketing and personalised advertising. | Up to 13 months | https://www.tiktok.com/legal/page/us/privacy-policy/en https://www.tiktok.com/legal/page/global/tiktok-website-cookies-policy/en |
| Taboola advertising technologies | Taboola | First-party and Third-party technologies | To measure advertising performance and attribution and, where applicable, support personalised recommendations, advertising and marketing. | Session to up to 1 year, depending on the technology used | https://policies.taboola.com/privacy-policy/ https://policies.taboola.com/cookie-policy/ |
| Mobile measurement and attribution technology | Singular | Third-party | To attribute app installs and qualifying activity to relevant campaigns and measure campaign performance and support advertising attribution and analytics. | Data is retained until it is no longer needed for the relevant processing purposes. | https://www.singular.net/privacy-policy/ |
| Apple Ads attribution technology | Apple Search Ads | Third-party | To measure and attribute app downloads and other relevant activity to Apple advertising campaigns and measure campaign performance. | No fixed device-storage duration identified. Attribution window: up to 24 hours after an ad view, 30 days after an ad click, or up to 90 days for pre-orders. | https://www.apple.com/legal/privacy/en-ww/ |
8. Apps and Device Permissions
In the Apps, certain technologies may operate through SDKs, device identifiers or similar technologies rather than traditional browser cookies. Where applicable, the tables above identify the relevant SDK or technology instead of a conventional cookie name, together with its provider, purpose and applicable duration or retention information.
Your device or operating system may also provide separate permissions or privacy controls. For example, on iOS, Apple’s App Tracking Transparency (“ATT”) permission may be required for certain tracking activities.
ATT and other operating-system permissions are separate from the choices described in this Cookie Policy. An operating-system permission does not replace any consent or opt-out required under applicable privacy or electronic-communications law.
Similarly, marketing consent, push-notification permission, ATT permission and Cookie or SDK privacy choices relate to different activities and are not interchangeable.
9. Third-Party Cookies
Some Cookies used through the Service are provided by third-party service providers or business partners.
Depending on the relevant processing activity, those third parties may process information on Scrambly’s behalf or for purposes they determine independently. Where relevant, our Cookie Settings provide information about the applicable provider.
The Service may also contain links to third-party websites, apps, games or other services. Once you access or use a third-party service, that third party may use its own Cookies or similar technologies and process information in accordance with its own privacy notice and terms. Those independent activities are not controlled through Scrambly’s Cookie Settings.
10. International Data Transfer
Scrambly operates internationally, and information collected through the Cookies described in this Cookie Policy may be transferred to, accessed from, or otherwise processed in countries outside the country in which you are located and to third countries outside the European Economic Area which do not benefit from a decision of adequacy by the European Commission and do not offer the same level of data protection as in the European Union, including the United States of America as well as the non-EU countries where Scrambly operates or where the third parties managing the cookies are located.
Where responsible for an international transfer of Personal Data, Scrambly has implemented appropriate safeguards, including the stipulation of standard contractual clauses approved by the European Commission and/or additional contractual measures to ensure the protection of the personal data transferred.
For more information about international data transfers and the safeguards we use, please see our Privacy Policy or reach out to Scrambly at the contact details below.
Third-party providers may also process information in countries other than the country in which you are located. Where they process personal data for their own purposes, information about their international processing processes is available in their respective privacy notices. For more information about international data transfers for which Scrambly is responsible, please see our Privacy Policy.
11. Your Privacy Rights
Where information collected through Cookies constitutes Personal Data, you may have rights in relation to that Personal Data under applicable law. For information about your privacy rights and how to exercise them, please see our Privacy Policy or contact us at [email protected].
12. Changes To This Cookie Policy
We may update this Cookie Policy from time to time to reflect changes to the Service, the Cookies we use, or applicable law.
When we make changes, we will update the “Last updated” date at the beginning of this Cookie Policy. Where required by applicable law or appropriate because of the nature of a material change, we may provide additional notice through the Service or by another appropriate method.
13. How To Contact Us
If you have any questions about this Cookie Policy or our use of Cookies, please contact us at:
Email: [email protected]
Address: Scrambly S.r.l., Via della Zecca 1, Bologna, 40121, Italy
For more information about how Scrambly processes Personal Data, please see our Privacy Policy.