Privacy Policy

Last updated: 7 October 2026

1. Who we are

The Scrambly.io website, available at https://scrambly.io (hereinafter, the "Website"), the mobile applications and other consumer products operated by Scrambly that link to or otherwise make this Privacy Policy available, including, where applicable, Scrambly Play to Earn, Scrambly Walk to Earn, PenguPace and Spendback, which may be renamed or updated from time to time (hereinafter, the “Apps” and, collectively with the Website, the “Service”), are operated by Scrambly S.r.l. (“Scrambly”, “we”, “us” or “our”) with registered office at Via della Zecca 1, Bologna, 40121, Italy.

Scrambly acts as Data Controller in respect of the processing of Personal Data as outlined in this privacy policy (hereinafter, the “Privacy Policy”).

Certain Scrambly products use a shared Scrambly account, backend and reward infrastructure. This means that account, profile, reward and other information may be used across those products where necessary to provide the Service, although certain features and processing activities are specific to a particular product, device or platform.

2. How to Contact Us

If you have any questions about this Privacy Policy or about how Scrambly processes your Personal Data, or if you wish to exercise your privacy rights, you can contact us at:

Email: [email protected]

Address: Scrambly S.r.l., Via della Zecca 1, Bologna, 40121, Italy

3. How We Use Your Personal Data

This Privacy Policy describes how Scrambly collects and processes your Personal Data when you register for, access, or use the Service. We process your Personal Data in compliance with the applicable data protection and privacy laws, including the EU General Data Protection Regulation 2016/679 (hereinafter, the “GDPR”), the Italian Legislative Decree 196/2003, as lastly amended and integrated (hereinafter, the “Privacy Code”), the UK General Data Protection Regulation (hereinafter, the “UK GDPR”) and the UK Data Protection Act 2018, and, where applicable, other privacy and data protection laws in the jurisdictions in which we offer the Service. Additional information for users in certain jurisdictions is provided below.

We process your Personal Data when you register for, access, or use the Service, including providing and maintaining our services and managing your account and rewards, attributing qualifying activity, preventing fraud, personalising your experience, communicating with you, and complying with our legal obligations.

The specific purposes for which we use Personal Data and the legal bases we rely on are explained below.

4. What Personal Data We Collect and Where It Comes From

Scrambly may process the following categories of Personal Data, depending on which features of the Service you use. We collect some information directly from you, some automatically when you use the Service or enable particular features, and some from third parties involved in providing, measuring, securing and rewarding the Service (hereinafter, collectively referred to as “Personal Data”):

Information you provide to us

Account and authentication data, such as your email address, display name, date of birth and other information required to create or manage your account. If you choose to sign in using a third-party authentication provider, such as Google or Apple, we may also receive information associated with that sign-in. Where applicable, this may include your first and last name.;
Profile and survey information, such as your gender, interests, preferred offer, game or categories, information about your in-app purchase behaviour or approximate spending ranges, how you heard about Scrambly and other preferences or information you choose to provide.
Reward and transaction information, including information relating to your reward balance, earnings, bonuses, reward claims, withdrawals, referrals and, where applicable, Premium or subscription functionality.
Spendback expense information, where you use Spendback’s expense-tracking functionality, such as the amount, category and date of an expense and other information you choose to enter to use the expense-tracking functionality.
Referral information, where you participate in Scrambly’s referral programme, such as your referral code or link and information required to attribute the referral and determine whether the applicable reward conditions have been met.
Customer support and communications information, including communications with Scrambly, attachments and other information you choose to provide when contacting .

Information we collect when you use the Service

Device and technical information, such as your IP address, browser and operating-system information, device type, device identifiers, language, country or time zone, network information, session information, referral source and diagnostic information.
Usage and activity information, including information about how you access and use the Service, such as login activity, sessions and interactions with features and content.
Offer, attribution and conversion information, including the offer or campaign you interact with, a Click ID or similar attribution identifier, campaign information, device or advertising identifiers where available and permitted, and information about qualifying events reported in connection with an offer. Depending on the relevant offer or campaign, this may include information about an app installation, game or offer milestone, subscription, in-app purchase, ad views or other in-app advertising activity (including where relevant to IAA-based offers), or other qualifying activity, together with information such as the relevant event, purchase value and currency, country or IP information and limited device, network or carrier information.
Reward and offer activity, including offers started or completed, reward eligibility and claims, offer progress, earning history and information required to administer and validate Scrambly’s reward system.
Advertising and measurement information, where advertising or rewarded advertising is available through the Service, such as advertising identifiers where available and permitted, ad impressions, interactions and related measurement and fraud-prevention information.
Fraud, security and account-integrity information, such as device, IP, session and network signals, duplicate-account or device indicators, geographic inconsistencies, fraud or risk scores and flags, behavioural information relating to offers or rewards, and other information used to protect Scrambly, its users and business partners.
Walking and activity data, where you use a Walk-to-Earn feature. Depending on the relevant App and device, the App may access your step count through Google Health Connect on Android or Apple HealthKit on iOS. Scrambly receives and stores your step count for the current day where necessary to provide the walking-reward functionality, determine eligible rewards, and prevent fraud or abuse. Health and activity data accessed through Health Connect or HealthKit is not used for advertising or marketing purposes, sold, or shared with advertising partners.
Daily Rewarded Playtime information, where you enable the Daily Rewarded Playtime feature on a supported Android device. The app may access information about apps used on your device and the time spent using them in order to determine eligible playtime rewards. Scrambly receives information associated with eligible playtime reward claims, such as the relevant app or package identifier, usage duration or related time information, and limited information necessary to validate the claim and prevent fraud.
Payout and reward-fulfilment information, such as your Scrambly user identifier, email address, display name, selected reward or withdrawal amount, and other information necessary to fulfil or support a payout or reward. Scrambly does not ordinarily receive or store your payment-card or bank-account credentials in connection with ordinary reward payouts; the relevant payout or redemption provider may collect additional information directly from you where required.

Information we receive from third parties

Identity-verification information, where identity verification is required, our identity-verification provider may collect your identity document, selfie, and other verification information and may process biometric information for facial matching where permitted by applicable law. Scrambly does not currently store copies of your identity document or selfie on its own systems, although authorised Scrambly personnel may access and review the verification information and documents through our identity-verification provider where necessary. Scrambly receives and uses the outcome of the verification and selected information, including verification status, verified date of birth, document-issuing country, and related session or decision information.
Authentication providers, such as Apple or Google, if you choose to sign up or register using their services;
Advertisers, app developers, advertising networks and mobile measurement or attribution providers, including through the Scrambly SDK or similar integrations incorporated into participating apps or games, which may provide information such as user or device identifiers, installs, gameplay activity, qualifying events, game or offer milestones, purchases, subscriptions and other information required to attribute activity, track progress, administer and validate rewards, measure campaign performance and prevent fraud.
App stores and platform providers, where relevant to purchases, subscriptions or functionality available through the Service.

5. Why We Use Your Personal Data

We use Personal Data for the purposes described below, including the legal basis on which we rely.

1) Providing the Service

We process your Personal Data where necessary for the provision and maintenance of the Service, and to perform our contract with you, including:

To provide and maintain the Service, including creating, authenticating and managing your account;
To enable the same Scrambly account to be used across applicable Scrambly products;
To personalise and determine the selection of offers, games and other opportunities made available or displayed to you from the broader catalogue available through the Service, including by using relevant account information, profile information, preferences expressed during onboarding and applicable offer eligibility criteria;
To provide the products and features you choose to use, including Walk-to-Earn, Daily Rewarded Playtime and Spendback functionality where applicable;
To provide and manage rewards, earnings, balances, offer progress, withdrawals and other transactions available through the Service;
To record the relevant offer and reward configuration and attribute qualifying activity to your account;
To determine whether the applicable conditions for a reward have been satisfied and credit eligible rewards;
To manage our referral program, including tracking invitations and providing any applicable rewards;
To operate our leaderboards and community features, including displaying your name and rewards;
To provide Premium or subscription functionality where applicable;
To process and facilitate payments and other transactions, including through our payment and service providers; and
To provide customer support and operational communications related to the Service, including security updates and other information necessary for its operation.

(hereinafter “Contractual Purposes”)

The processing of Personal Data for the Contractual Purposes is necessary for the provision of the Service requested by you and the performance of the contract with you. If you do not want your Personal Data to be processed for such purposes, it will not be possible for Scrambly to provide you with the requested Service.

2) Verifying your identity and account eligibility

We may verify your identity or other account information where this is required to enable particular functionality, support withdrawals, verify eligibility, protect the Service or investigate suspected fraud or abuse.

This may include using selected information and verification results received from our identity-verification provider and comparing them with information associated with your Scrambly account.

Depending on the circumstances, Contractual Purposes, Legal Obligations and/or our Legitimate Interests in verifying users, protecting the Service and preventing fraud is the legal basis we act on, according to Article 6(1)(b), 6(1)(c) and/or 6(1)(f), depending on the circumstances.

Where biometric information is processed for identity verification, and applicable law requires explicit consent or another specific condition for that processing, the relevant condition will apply.

3) Preventing fraud and protecting the Service

We process your Personal Data to prevent, detect and investigate fraud, duplicate accounts, manipulation of offers or rewards, unauthorised activity and other misuse of the Service.

This may include assessing device, IP, session, identity, geographic and behavioural signals and verifying whether accounts, reward claims, conversions or withdrawals are genuine and eligible.

Our Legitimate Interests in protecting Scrambly, our users and business partners, preventing fraud and ensuring that rewards are paid only for eligible activity is the legal basis we act on.

4) Personalisation & Profiling

We use certain information about you to personalise the Service and determine which offers, games and other earning opportunities are made available or displayed to you and how they are presented.

As part of providing the Service, we therefore personalise the catalogue to determine an appropriate subset of opportunities for you.

This personalisation is primarily rule-based or configured through Scrambly’s internal systems. For the core personalisation of your offer catalogue, we may use information such as your age or date of birth, gender, interests and preferences expressed during onboarding, location and applicable offer eligibility criteria. These criteria may be used to include or exclude particular offers or to determine how offers are ranked or presented to you. As a result, the offers and earning opportunities displayed to you may differ from those displayed to other users.

This processing may involve profiling, meaning the automated use of Personal Data to evaluate or apply certain characteristics or preferences relating to you for the purpose of determining the selection of opportunities presented through the Service.

We rely on the performance of our contract with you under Article 6(1)(b) GDPR for this core Offer personalisation because it is an integral part of the Scrambly Service and is necessary to provide you with a personalised selection from the broader catalogue of available opportunities.

Scrambly does not currently use walking or health-activity information to personalise offers.

Separately, where we use Personal Data to personalise promotional or marketing communications, including to determine which promotional communications may be relevant to you, that processing is subject to the legal bases and choices described under “Marketing Communications” below. Where a particular form of personalisation relies on cookies, SDKs or similar technologies for which applicable law requires consent, we rely on consent for that technology or processing as applicable.

5) Analytics and improving the Service

We process information about how users interact with Scrambly to understand how the Service is used, identify technical or operational issues, evaluate product and campaign performance, conduct A/B testing and other product experiments and develop or improve Scrambly’s products and features.

This may include analysing activity relating to anonymous or registered users and, where appropriate, linking activity that takes place before registration with a subsequently created Scrambly account.

Legitimate Interests in operating, understanding and improving the Service is our legal basis. Where analytics depends on cookies, SDKs or similar technologies for which applicable law requires consent, we rely on consent for that processing.

6) Comply with Legal Obligations

Scrambly processes your Personal Data to ensure compliance with legal, tax, and accounting obligations, and in particular for the following legal purposes:

To comply with the requirements of the laws, regulations, and protocols provided for in national and EU legislation;
To implement any decisions issued by EU and national public Authorities.

(hereinafter “Law Purposes”)

The processing of Personal Data for Law Purposes is necessary as it is required by applicable laws. If you do not want your Personal Data to be processed for such purposes, you should not use the Service.

7) Marketing Communications

Scrambly may process, where permitted by applicable law and, where required, with your prior consent, your Personal Data for the following Marketing Purposes:

To send commercial and promotional communications and periodic updates (e.g., via email, push notifications, social networks and newsletters) relating to Scrambly’s Service, offers, promotions, initiatives and events;
To conduct surveys and market research relating to Scrambly’s Service; and
To carry out statistical analyses of the user audience and to optimize the delivery of marketing communication.

(hereinafter “Marketing Purposes”)

Where applicable law requires prior consent for a particular type of marketing communication, we will rely on your consent according to Article 6(1)(a) of the GDPR.

Where applicable law permits marketing without prior consent subject to specific conditions, we may rely on that basis where those conditions are satisfied.

You may freely decide not to provide your Personal Data for Marketing Purposes and may withdraw your consent at any time by opting out of marketing emails at any time using the unsubscribe mechanism included in the relevant email or by contacting us. Where additional marketing preference controls are available through the Service, you can also use those controls.

Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, Scrambly will stop sending you marketing communications.

8) Protecting our legal rights and managing our business

Scrambly may also process your Personal Data for additional legitimate interest purposes, and in particular:

To exercise or defend legal claims in court proceedings or in administrative or out-of-court procedures relating to the rights of Scrambly and/or its representatives, shareholders, officers and directors;
To enable the technical management of the Service and its operational functions, including solving technical problems and performing tests, updates and upgrades that cannot be performed through non-personal data;
To enhance your experience with Scrambly and your use of the Service;
To conduct audits and due diligence, complete a potential merger, sale of assets, transfer of all or a material part of Scrambly’s business, or financing transaction by disclosing and transferring Personal Data to the third party or parties involved in the transaction as part of the transaction.

(hereinafter “Legitimate Interests”)

The processing of your Personal Data for Legitimate Interest Purposes is carried out pursuant to Article 6(1)(f) of the GDPR for the pursuit of Scrambly’s legitimate interests, which are adequately balanced with your interests because the processing is performed within the limits strictly necessary to perform such activities. Such processing is not mandatory, and you can object to it at any time through the modalities set out in this Privacy Policy. In such case, Scrambly will cease processing your Personal Data for those Legitimate Interest Purposes, except where Scrambly demonstrates compelling legitimate grounds or a right to continue processing pursuant to Article 21 of the GDPR.

6. Cookies, SDKs And Similar Technologies

Scrambly uses cookies, software development kits (“SDKs”), device identifiers, browser or session identifiers and similar technologies for purposes such as operating and securing the Service, maintaining sessions and preferences, analytics, offer attribution and reward validation, measuring campaign performance and, where available, advertising.

On the Website, we may use first-party identifiers to recognise an anonymous browser or session and preserve information relating to activity before registration. If you subsequently create or identify your Scrambly account, relevant information associated with that identifier may be linked to your account as described above.

Where applicable law requires consent before information is stored on or accessed from your device, or before a particular analytics, advertising or tracking activity takes place, we will request the relevant consent.

Where applicable law instead provides a right to opt out of certain advertising or tracking activities, we will provide the applicable choice.

On iOS, Apple’s App Tracking Transparency (“ATT”) permission may also be required for certain tracking activities. ATT is an operating-system permission and is separate from any consent or other legal requirement that applies under privacy or electronic-communications laws.

Marketing consent, push-notification permission, ATT permission and cookie or SDK privacy choices relate to different activities and are not interchangeable.

For more information about the technologies we use and the choices available to you, please see our Cookie Policy and the .

7. How We Process And Protect Your Personal Data

The processing of your Personal Data is primarily carried out by electronic means and within the limits necessary to pursue the purposes described in this Privacy Policy.

Scrambly uses technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and other unlawful processing.

Access to Personal Data is limited according to role, operational need and applicable access permissions, and authorised personnel and service providers are expected to process Personal Data only for the purposes relevant to their role or services.

For the purposes indicated above, and depending on the relevant processing activity, Scrambly may communicate your Personal Data to the following third parties:

cloud, infrastructure, software, analytics and technical service providers that support the operation, security and analysis of the Service;
CRM, customer-support and communications providers;
advertisers, app developers, advertising networks and attribution or mobile measurement providers, where necessary to provide offers, attribute qualifying activity, validate rewards, measure campaign performance or prevent fraud;
advertising and mediation providers where advertising is available through the Service;
identity-verification, fraud-prevention, security and device-risk providers;
payout and reward providers;
app stores, payment platforms and subscription providers where applicable;
professional advisers, including legal, accounting, tax, audit and insurance advisers;
courts, regulators, law-enforcement bodies and other authorities where disclosure is required or permitted by applicable law; and
potential investors, purchasers and other parties involved in an actual or proposed financing, investment, merger, acquisition, restructuring or sale of all or part of Scrambly’s business.

The abovementioned recipients will process your Personal Data as independent data controllers, data processors or persons in charge of processing, depending on the circumstances.

Scrambly does not generally make your Personal Data publicly available. However, where you participate in a leaderboard, community or similar feature, limited information such as your display name, ranking, reward or achievement information may be visible to other users.

A complete list of data processors is available, upon request to Scrambly, through the modalities set out in this Privacy Policy.

9. International Data Transfers

Scrambly operates internationally. Your Personal Data may be transferred to, accessed from, or otherwise processed in countries outside the European Economic Area (“EEA”), including by Scrambly personnel and contractors and by the recipients and service providers described above. This may include processing in the United States and other countries where our personnel, contractors or service providers are located.

For transfers from the EU to countries not considered adequate by the European Commission, Scrambly has put in place appropriate and suitable safeguards to protect the Personal Data. Accordingly, Personal Data are transferred in compliance with the requirements and obligations provided by applicable data protection laws, including Articles 44 et seq. of the GDPR.

For further information about the appropriate or suitable safeguards and the means by which to obtain a copy of them, you can contact Scrambly through the modalities set out in this Privacy Policy.

10. How Long We Keep Your Personal Data

Scrambly retains Personal Data only for as long as is necessary to achieve the purposes for which Personal Data were collected and further processed, including any retention period required under applicable legislation.

Scrambly generally retains Personal Data processed for Contractual and Legitimate Interest Purposes for as long as necessary to provide the Service, manage your account, fulfill the relevant purpose, resolve disputes and enforce our agreements and, in any case, for no more than 10 years from the termination of the agreement or the provision of the Service.

Personal Data processed for Law Purposes will be stored for the period strictly necessary to comply with applicable laws.

Personal Data used for offer personalisation and profiling that is necessary to provide the Service will be retained for as long as necessary to provide the relevant Service and manage your account, subject to the retention principles described above. Personal Data used for Marketing Purposes or for other processing based on consent or Legitimate Interests will be retained for as long as necessary for the relevant purpose, subject to your right to withdraw consent or object to the processing where applicable.

Closing or deleting your Scrambly account does not necessarily mean that every record associated with your account is immediately erased. Certain information may continue to be retained where Scrambly has a lawful reason to do so, including for fraud prevention, transaction and financial records, disputes or legal obligations. Where Personal Data is no longer required, we will delete, anonymise or otherwise handle it in accordance with applicable law and Scrambly’s applicable retention and deletion procedures.

11. Children’s Privacy

The Service is intended only for users aged 18 or older. Scrambly does not knowingly permit individuals under 18 to create or use a Scrambly account.

We may use the date of birth provided by a user and, where identity verification is carried out, may receive a verified date of birth from our identity-verification provider.

If we become aware that you are under 18, or if the date of birth you provided is false, inaccurate or inconsistent with information obtained through identity verification, we may restrict or close the account and take appropriate steps in relation to the Personal Data associated with that account.

Providing false or misleading information about your age may also constitute a breach of our Terms and Conditions and may result in your account being blocked or terminated.

If you believe that an individual under 18 is using the Service, please contact us using the details provided in the “HOW TO CONTACT US” section.

12. Your Privacy Rights

At any given time, subject to any applicable conditions or exceptions as applicable by law, you may have the right to:

1) obtain from Scrambly confirmation of the existence of Personal Data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;

2) request the erasure, anonymization or restriction of the processing of Personal Data processed in breach of applicable laws;

3) object in whole or in part, on legitimate grounds, to the processing of the Personal Data;

4) object at any time to the processing of your Personal Data for direct marketing purposes, including profiling to the extent that it is related to such direct marketing;

5) withdraw the consent to the processing of the data (if and to the extent such a consent is necessary);

6) request Scrambly to limit the processing of your Personal Data where:

You contest the accuracy of the Personal Data until Scrambly has taken sufficient steps to correct or verify its accuracy;
The processing is unlawful, but you do not want us to erase your Personal Data;
Scrambly no longer needs your Personal Data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; or
You have objected to processing justified on legitimate interests, pending verification as to whether Scrambly has compelling legitimate grounds to continue processing;

7) object to the processing of your Personal Data in case of processing based on legitimate interest, unless Scrambly demonstrates the existence of compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims;

8) request the erasure of your Personal Data without undue delay;

9) receive an electronic copy of your Personal Data, if you would like to port your Personal Data to yourself or a different provider, when Scrambly is relying upon your consent, or the fact that the processing is necessary for the provision of the Service and the Personal Data is processed by automatic means; and

10) lodge a complaint with the relevant data protection supervisory authority.

You can submit a privacy request using the contact details provided in the “HOW TO CONTACT US” section.

We may request information reasonably necessary to verify your identity and protect Personal Data against unauthorised access or disclosure. We will respond within the timeframe required by applicable law.

Where Italian law applies, the rights relating to the Personal Data of a deceased person may be exercised in the circumstances and by the persons provided for under Article 2-terdecies of the Italian Privacy Code, subject to the limitations established by that provision.

13. Additional Information For UK Residents

This section supplements the rest of this Privacy Policy where the UK GDPR, the Data Protection Act 2018 and other applicable UK privacy laws apply.

References elsewhere in this Privacy Policy to GDPR legal bases should be read, for UK users, as references to the corresponding provisions of the UK GDPR where applicable.

Marketing and tracking

Where the UK Privacy and Electronic Communications Regulations 2003 (“PECR”) apply, Scrambly will use electronic marketing and cookies, SDKs or similar storage and access technologies in accordance with the applicable PECR requirements.

For unsolicited electronic marketing to individual subscribers, this generally means obtaining consent unless the requirements of an applicable soft opt-in are satisfied.

Your rights in the UK

UK users have the rights provided by the UK GDPR, including the rights described in the “YOUR PRIVACY RIGHTS” section above. You may also lodge a complaint with the UK Information Commissioner’s Office (“ICO”).

International transfers

Where Scrambly makes a restricted transfer subject to the UK GDPR, it will rely on an applicable UK adequacy regulation, appropriate safeguard or other transfer mechanism permitted by UK law.

14. Additional Information For U.S. Residents

This section supplements the rest of this Privacy Policy for residents of U.S. states whose privacy laws apply to Scrambly.

The sections above describe the categories of Personal Data we collect, the sources from which we collect it, the purposes for which we use it, the categories of third parties with whom we share it, and how long we retain it.

Depending on your state of residence and the applicability of the relevant law, you may have some or all of the rights described below.

Your U.S. privacy rights:

confirm whether we process your Personal Data and access certain Personal Data we hold about you;
request correction of inaccurate Personal Data;
request deletion of Personal Data, subject to applicable exceptions;
obtain a portable copy of certain Personal Data;
opt out of the sale of Personal Data, sharing for cross-context behavioural advertising, targeted advertising or certain profiling, where applicable;
limit certain uses or disclosures of sensitive Personal Data, or withdraw or provide consent for certain processing of sensitive Personal Data, where applicable;
use an authorised agent to exercise certain rights on your behalf;
appeal certain decisions relating to your privacy request, where applicable; and
exercise your privacy rights without unlawful discrimination.

Sale, sharing and targeted advertising

Scrambly does not sell Personal Data in exchange for monetary payment.

We may, however, disclose certain information, such as device or advertising identifiers, online activity, offer attribution information and advertising or measurement information, to advertising, attribution, measurement or similar partners as described elsewhere in this Privacy Policy.

Depending on the applicable U.S. state privacy law, some of these disclosures may be considered a “sale” or “sharing” of Personal Data or processing for “targeted advertising”, even where Scrambly does not receive money specifically in exchange for the information.

Where applicable law provides a right to opt out of these activities, you may exercise that right through the or by contacting us using the details provided in the “HOW TO CONTACT US” section.

How to exercise your privacy rights under U.S. state laws

You may submit a U.S. privacy request using the contact details provided in the “HOW TO CONTACT US” section. We may request information reasonably necessary to verify your identity or, where applicable, the authority of an authorised agent.

We will respond to your request within the timeframe required by applicable law and will provide any applicable appeal mechanism where required.

How to exercise your rights to opt-out

To exercise your rights to opt out of the sale or sharing of Personal Data or targeted advertising, where applicable, you may submit a request using the contact details provided in the “HOW TO CONTACT US” section or through any .

Applicable U.S. state privacy laws may also permit you to exercise certain opt-out rights through a browser- or device-based opt-out preference signal, such as the Global Privacy Control (“GPC”). Where Scrambly is required by applicable law to recognise and process such signals, we will process them in accordance with applicable legal requirements.

How and when we handle your request

We will respond to your request without undue delay and within the timeframe required by applicable law. If we need more time, we will explain why and how much additional time is needed. If we deny your request, we will explain the reasons for the denial and, where applicable, you may contact the relevant authority to submit a complaint. We do not charge a fee to process or respond to your request unless it is manifestly unfounded or excessive, or otherwise permitted by applicable law. In such cases, we may charge a reasonable fee or refuse to act and will explain our decision.

15. Additional Information For Canada Residents

This section supplements the rest of this Privacy Policy for users in Canada. Depending on where you reside and the circumstances of the processing, federal or provincial Canadian privacy laws may apply.

How we handle your Personal Data

Scrambly is responsible for Personal Data under its control. We identify the purposes for which we collect, use and disclose Personal Data and limit our collection, use, disclosure and retention of Personal Data in accordance with applicable Canadian privacy law.

Where applicable Canadian privacy law requires consent, we will seek a form of consent appropriate to the nature and sensitivity of the Personal Data and the reasonable expectations of the individual.

You may withdraw your consent where applicable, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide a product or feature where the relevant processing is necessary to provide it.

Your Canadian privacy rights

Depending on applicable law, you may have the right to request access to Personal Data Scrambly holds about you and information about how it has been used or disclosed, and to request correction of Personal Data that is inaccurate or incomplete.

Applicable provincial privacy laws may provide additional rights in certain circumstances, including rights relating to automated processing, profiling or the portability of Personal Data.

You may exercise your rights or raise a question or complaint about our privacy practices by using the contact details provided in the “HOW TO CONTACT US” section.

You may also have the right to make a complaint to the Office of the Privacy Commissioner of Canada or the competent provincial privacy authority, depending on which law applies.

Processing outside Canada

Scrambly operates internationally and uses service providers located in other countries. Personal Data relating to Canadian users may therefore be processed outside Canada, including in the United States and the European Economic Area.

Where Scrambly transfers Personal Data to a service provider for processing on its behalf, Scrambly takes appropriate contractual or other measures designed to require an appropriate level of protection for that information. Personal Data processed in another country may also be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, or other authorities in accordance with applicable law.

Commercial electronic messages

Where Scrambly sends commercial electronic messages to users in Canada, we will do so in accordance with applicable Canadian electronic-marketing laws, including applicable requirements relating to consent, sender identification and unsubscribe mechanisms.

16. Third-Party Services And Links

The Service may contain links to, or enable you to interact with, third-party websites, applications, games and services, including offers made available by advertisers and other business partners.

Where Scrambly processes or shares Personal Data in connection with those interactions, that processing is described in this Privacy Policy.

Once you access or use a third-party service, that third party may also collect and process Personal Data for its own purposes in accordance with its own privacy notice and terms. Scrambly does not control the independent privacy practices of third-party services.

We therefore recommend that you review the privacy information provided by the relevant third party before providing Personal Data directly to it.

17. Changes To This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the Service, our processing activities or applicable law.

When we make changes, we will update the “Last updated” date at the beginning of this Privacy Policy.

Where required by applicable law or appropriate because of the nature of a material change, we may also provide additional notice through the Service, by email or by another appropriate method.

The current version of this Privacy Policy will remain available on our Website at https://scrambly.io.