Terms and Conditions

Last updated: 7 October 2026

1. Who We Are and When These Terms Apply

These Terms and Conditions (“Terms”) apply when you access or use the Scrambly.io website, the Scrambly mobile applications, and other consumer products operated by Scrambly that link to or otherwise make these Terms available. This includes, where available, Scrambly Play to Earn, Scrambly Walk to Earn, PenguPace and Spendback, as they may be renamed, updated or replaced from time to time (together, the “Service”).

The Service is operated by Scrambly S.r.l. (“Scrambly”, “we”, “us” or “our”), with registered office at Via della Zecca 1, Bologna, 40121, Italy.

By creating an account, accepting these Terms when asked, or otherwise accessing or using the Service, you agree to be bound by these Terms. If you do not agree to these Terms, you must not use the Service.

Our Privacy Policy explains how we use your personal data, and our Cookie Policy explains how we use cookies, SDKs and similar technologies. Those policies provide important information about the Service but do not form part of these Terms unless expressly stated otherwise.

2. Who Can Use The Service and Your Account

You must be at least 18 years old to create or use a Scrambly account. By creating or using an account, you confirm that you are at least 18 and that the information you give us is accurate and up to date.

You may have only one Scrambly account unless we allow otherwise. Your account is personal to you and must not be sold, transferred, shared, rented or used by anyone else. You are responsible for keeping your login details secure. If you think someone else has accessed your account or login details, please let us know as soon as possible.

Some Scrambly products share the same account and reward balance. This means that your account, profile and balance may be used across different Scrambly products, although the features, offers and rewards available may vary depending on the product, device, platform or location.

You may be able to view or start an offer before creating or signing in to an account. To receive a reward, however, the activity must be linked to an eligible Scrambly account and meet the applicable offer requirements. Activity completed before registration may not be rewarded if we cannot reliably link it to your account.

3. How The Service and Rewards Work

Scrambly is an app-discovery and rewarded-engagement platform. Through the Service, you may see a personalised selection of apps, games, services, advertisements, offers, tasks, promotions or other earning opportunities made available by Scrambly or by third-party advertisers, app developers, advertising networks or other business partners (“Partners”). The selection of opportunities displayed to you may differ from the selection displayed to other users.

You may earn rewards by completing qualifying activities through the Service (“Rewards”). For example, you may earn a Reward by installing or using an app, reaching a game or offer milestone, making a qualifying purchase or subscription, viewing eligible advertising, participating in a referral programme, or completing another activity shown in the Service.

A Reward is earned when the relevant qualifying conditions are met, and the Reward has been successfully tracked, attributed, and validated or, where applicable, claimed. Once validated, Rewards may be credited to your Scrambly account and included in your Reward balance.

Offer eligibility may depend on factors such as your location, device, operating system, acquisition source, previous interaction with the relevant app or service, and Partner campaign rules. Unless we say otherwise, an offer is intended only for users who are eligible for it and have not previously completed the same qualifying activity in a way that makes them ineligible.

As part of the Service, Scrambly personalises the selection of offers made available or displayed to you. We may use information associated with your account, including your age, gender, preferences expressed during onboarding and applicable offer eligibility criteria, to determine what to show you and how they are presented. This personalisation is an integral part of the Service and is necessary to provide you with an appropriate selection from the broader catalogue available through Scrambly.

The requirements, reward amount, time limits, and other conditions applicable to an offer or feature are those displayed in the Service when you participate, together with these Terms and any additional offer-specific or promotion-specific conditions. You are responsible for reviewing those conditions before participating.

4. How Offers and Reward Tracking Work

Rewards depend on the qualifying activity being correctly tracked, attributed, and validated. To determine whether you have met the conditions of an offer, we may use information from Partners, app stores, attribution or measurement providers, the Scrambly SDK, and other technical systems.

You must follow the offer instructions and complete the qualifying activity genuinely using the tracking path provided through the Service. Changing devices, resetting advertising identifiers, disabling required tracking, using a different account, reinstalling an app, using a VPN or proxy, or otherwise interfering with the tracking process may prevent your activity from being tracked or make it ineligible for a Reward.

Tracking may not always happen immediately, and delays can occur on the Partner’s side. Any progress shown in the Service is for information only and does not guarantee a Reward until the qualifying activity has been validated.

If your activity is not tracked or credited, you can contact Customer Support. We may ask you for information to help us investigate, such as screenshots, timestamps, receipts, or device information, and we may also check the activity with the relevant Partner. We will review the available information and, where appropriate, take reasonable steps to resolve the issue.

A Partner’s failure to report or pay for an activity does not automatically mean that you are or are not eligible for a Reward. We will assess your claim based on the applicable offer conditions and the information available to us. We do not have to credit a Reward if we cannot reasonably verify that the qualifying activity took place or that the offer conditions were met. Nothing in this section affects any mandatory rights you have under applicable law.

5. Your Reward Balance and Withdrawals

Your Reward balance shows the Rewards credited to your Scrambly account. Depending on the Scrambly product and your location, your balance may be displayed in USD, Scrambly Coins or another unit or currency.

Rewards are not bank deposits, electronic money, cryptocurrency or a general-purpose payment instrument. They can only be redeemed using the withdrawal or reward options available through the Service and are subject to these Terms, including any applicable withdrawal thresholds, verification requirements and provider conditions.

Where Scrambly Coins are used, they are an internal unit used to represent Rewards and have no independent cash value outside the Service.

We may set or change minimum withdrawal amounts, available payout methods and reasonable operational limits. The options available to you may depend on your location, account status and the payout providers available in your region.

Before allowing a withdrawal, we may ask you to verify your identity, age, location, account ownership or other eligibility information. We may delay a withdrawal where reasonably necessary to complete verification, investigate suspected fraud or abuse, resolve a technical issue, comply with the law or confirm that the relevant Rewards are valid.

You are responsible for providing accurate payout information and making sure that the account you choose can receive the payout. If a payout fails because the information you provided is incorrect or the selected account cannot receive the payment, we will take reasonable steps to help where practicable. However, we are not responsible for losses caused by incorrect information or restrictions outside our control, except where required by applicable law.

6. Currency Conversion

Scrambly may use USD as the base currency to record certain Rewards and transactions. If your balance, Reward or withdrawal is displayed or processed in another currency, we may apply a conversion rate derived from third-party financial-market information and adjusted by a reasonable conversion rate.

The rate shown in the Service may therefore differ from a real-time market. Where a conversion applies to a withdrawal or transaction, the applicable rate or resulting amount will be shown or made available to you before the transaction is completed, where required by applicable law.

We may update our conversion methodology from time to time to reflect market conditions, provider costs, and operational risk. Changes will apply prospectively and will not reduce a withdrawal that has already been completed.

7. How Specific Service Features Work

The Service may include features that operate differently from standard third-party offers. The availability and mechanics of these features may vary by product, platform, device, and location.

Walk-to-Earn. Where available, you may receive Rewards based on eligible step activity measured through supported device or health-platform functionality. Rewards are subject to the limits, validation rules, and anti-abuse controls displayed in the relevant App. You must not falsify, simulate, or manipulate step or activity data.

Daily Rewarded Playtime. Where available, you may receive Rewards based on eligible time spent using specified apps. Only activity that can be validly measured and attributed under the feature rules qualifies. Automated, simulated, or otherwise non-genuine usage is prohibited.

Spendback. Where available, Spendback may provide expense-tracking or related functionality and may allow you to enter information about expenses. Unless expressly stated otherwise, Spendback is a consumer product feature and does not provide financial, accounting, or tax advice.

Linked games and Scrambly SDK integrations. A participating game or app may report gameplay, milestones, purchases, subscriptions, or other qualifying events to Scrambly through the Scrambly SDK or a similar integration. The relevant Partner remains responsible for its own app, game, content, and independent services.

8. Promotions, Referrals and Additional Rules

We may offer sign-up bonuses, cashback, referral Rewards, daily or recurring Rewards, streaks, Reward chests, check-in Rewards and other promotional or limited-time benefits (“Promotions”).

Promotions may have specific and additional rules about how and when Rewards can be earned or claimed, including eligibility requirements, thresholds, time limits, geographic restrictions, withdrawal requirements or other conditions shown in the Service. A Reward offered through a Promotion is earned only when the applicable requirements have been met and, where required, the Reward has been successfully claimed and credited to your account. The availability, mechanics and Reward amounts of Promotions may vary by user, product, platform, location or experiment. Promotions may also be introduced, changed or discontinued from time to time.

A promotional headline or short message may only summarise a Promotion, so you should check the applicable conditions before participating. A reference to a monetary amount does not mean that it is immediately available for withdrawal upon registration unless we expressly say so.

Referral Rewards are available only for genuine referrals that meet the conditions shown in the Service. Self-referrals, fabricated referrals, duplicate or linked accounts created to obtain referral Rewards, misleading promotion of referral links, or other attempts to manipulate the referral programme are not allowed.

We may change or end a Promotion, correct display or technical errors, and withhold or reverse a promotional Reward if the applicable conditions were not met or there is reasonable evidence of fraud, abuse or manipulation.

Some offers, Promotions or features may have additional terms or rules shown to you before or when you participate. These apply together with these Terms. If there is a conflict, the specific terms will apply to that offer, Promotion or feature to the extent of the conflict.

Any important eligibility requirement, time limit, price or other condition affecting your right to a Reward will be clearly disclosed before it applies to you.

9. Subscriptions and Premium Features

Some parts of the Service may offer subscriptions or premium features. Before you subscribe, we will show you the price, billing period, included features, whether the subscription renews automatically, any trial terms, and how to cancel.

If you purchase a subscription through the Apple App Store, Google Play, or another app store or payment platform, its rules may also apply to billing, renewals, cancellations, and refunds. You will be able to manage or cancel your subscription as required by applicable law and the relevant platform rules.

Cancellation will normally take effect at the end of your current paid period, unless the applicable law, purchase terms or platform rules provide otherwise. Any refund, cancellation or withdrawal rights provided by applicable law will continue to apply.

We may change subscription prices or features for future billing periods. Where required by applicable law or platform rules, we will give you advance notice and the opportunity to cancel before the change takes effect.

10. How You Can and Cannot Use The Service

You must use the Service lawfully, genuinely and in accordance with these Terms. You must not attempt to obtain Rewards for activity that is fabricated, duplicated, automated, manipulated or otherwise ineligible.

Without limiting the above, you must not:

1) create or control multiple Scrambly accounts without our permission;

2) use, buy, sell, transfer or share another person’s account;

3) use bots, scripts, automation, emulators or similar tools to simulate or manipulate eligible activity;

4) use a VPN, proxy, or other method to misrepresent your location or eligibility in connection with an offer, Promotion or Reward for the purpose of circumventing eligibility requirements or fraudulently obtaining such Rewards;

5) manipulate device identifiers, attribution data, tracking, offer progress, steps, playtime, referrals, purchases or other qualifying events;

6) provide false or misleading identity, age, residence, account or payout information;

7) interfere with the security, integrity or operation of the Service;

8) exploit bugs, errors or unintended product behaviour to obtain an improper benefit; or

9) use the Service in a way that violates applicable law or the rights of Scrambly, a Partner or another person.

The fact that more than one person uses the Service from the same household, network or IP address does not by itself constitute a breach. Still, each person must have their own eligible account, and we may conduct additional checks where accounts appear linked, or activity indicates possible duplication or abuse.

A material or repeated breach of this Section may result in the suspension, restriction or termination of your account in accordance with Section 17 (Suspension and Termination) of these Terms. Where a breach affects the validity or eligibility of any Rewards, those Rewards may also be withheld, cancelled, reversed or deducted in accordance with Section 11 (Reward Validation, Verification, Fraud Prevention and Account Reviews) of these Terms.

11. When We May Review Your Account or Rewards

We may review your account or Rewards if we identify or receive signals indicating possible fraud, abuse, manipulation, duplicate or ineligible activity, misuse of an error, a reversal or cancellation of qualifying activity, a chargeback, a security issue, or another serious breach of these Terms that could affect your Reward eligibility.

Fraud-prevention or security signals may be generated by our systems, identified by our team, or received from Partners or other relevant sources. Based on these signals, we may automatically place a temporary hold on your account, withdrawals, or Reward balance while the activity is assessed. We may also restrict withdrawals, freeze all or part of your Reward balance, limit access to certain features, or ask you to complete additional verification.

We may review the relevant activity ourselves or in response to information you provide. We may ask you for information to help us verify your identity, age, location, account ownership, purchase, transaction, or qualifying activity, including receipts, screenshots, timestamps, device information, or other relevant evidence. If we do not receive the requested information, we may make a decision based on the information available to us.

When assessing your account, we may consider account activity, attribution data, transaction history, information from Partners, fraud-prevention and security signals, and other relevant evidence. We do not have to establish that each Reward was obtained improperly where the available evidence reasonably demonstrates fraud, abuse or manipulation affecting your account or Reward activity.

If we determine that your account was involved in fraud, abuse, manipulation or another serious breach of these Terms, we may permanently restrict or close your account. Where the breach affects your account or Reward activity, we may also cancel, reverse or forfeit all or part of your outstanding Reward balance.

If we notify you that your account has been permanently restricted or closed, or that your Rewards have been cancelled or forfeited, you may contact Customer Support within 30 days of that notification to challenge our decision and provide any relevant information. We will consider the information you provide and may confirm, modify, or reverse our decision.

If you do not challenge our decision within those 30 days, or if you challenge it and we confirm our decision following review, we may treat the determination as final. Any outstanding Rewards subject to that determination are then permanently cancelled and forfeited.

To help protect the Service and prevent fraud, we do not have to disclose specific fraud signals, thresholds, models, rules, or detection methods where doing so could compromise our security or help someone bypass our controls.

12. What Happens If Your Account is Inactive

If you have not logged into your account for at least 12 months, we may treat your account as inactive. Before closing an inactive account, we will provide notice using the contact details associated with your account and give you at least 30 days to log in, reactivate your account, and, where applicable, redeem any available Rewards. The notice will inform you that your account may be closed and that any remaining unredeemed Rewards may expire if you do not take action before the stated deadline.

If you do not take action within that period, we may close your account and, to the extent permitted by applicable law, any unredeemed Rewards remaining in your account will expire and will no longer be available for redemption.

13. Customer Support and Reward Issues

If you have a question or believe a Reward has not been correctly credited, please contact Customer Support through the support channel available in the Service. We aim to respond within a reasonable timeframe, but some issues may take longer to investigate depending on their complexity, the information needed and whether we need input from a Partner.

We may ask you for information to help us investigate. Please provide the requested information within the timeframe we give you. If we do not receive the information needed to review your claim, we may close the support request. You can contact us again if you later obtain the relevant information.

If your claim relates to a third-party offer, we may need to check it with the relevant Partner. We will consider any evidence you provide, but we may be unable to confirm your eligibility if the available information does not show that the offer conditions and tracking requirements were met.

14. Third-Party Apps, Games and Other Services

The Service may contain links to, advertisements for, or integrations with third-party websites, apps, games, app stores, payout providers, and other services. Those third parties may have their own terms, privacy notices, eligibility rules, and technical requirements.

Except where Scrambly expressly states otherwise, Scrambly does not own or control a Partner's app, game, content, products, or independent services and is not responsible for their availability, functionality, content, or independent acts or omissions. This does not affect Scrambly's obligations in relation to the Service or any rights you have against Scrambly under mandatory law.

You are responsible for complying with applicable third-party terms when using third-party services in connection with Scrambly.

15. Intellectual Property and Your Right to Use the Service

The Service, including its software, design, text, graphics, branding and other content made available by Scrambly, is owned by or licensed to Scrambly and is protected by applicable intellectual-property laws.

Subject to these Terms, Scrambly grants you a limited, personal, non-exclusive, non-transferable, non-sublicensable and revocable licence to access and use the Service for your own lawful, non-commercial use. This licence does not permit you to copy, modify, distribute, sell, lease, reverse engineer or create derivative works from the Service except where such restriction is prohibited by applicable law.

Third-party apps, games, advertisements and content remain the property of their respective owners and are subject to any applicable third-party rights and terms.

16. Changes to Features and Availability

Features, offers, Rewards, payout methods, Promotions and other parts of the Service may differ depending on the Scrambly product, platform, operating system, device, location, regulatory requirements, Partner availability, product testing and other operational factors.

We may introduce, test, modify, suspend or discontinue features or offers at any time. We do not guarantee that a particular offer, feature or Reward will always be available or will be available on every product or platform.

Where a change materially affects a paid subscription or a Reward you have already validly earned, we will apply any notice, refund or other protection required by applicable law.

17. When Your Account May Be Suspended or Closed

You may stop using the Service at any time and may close your account using the functionality made available in the Service or by contacting us. Account closure does not necessarily result in immediate deletion of all associated Personal Data; our Privacy Policy explains applicable retention.

We may suspend, restrict or terminate your account or access to all or part of the Service if:

(a) you materially or repeatedly breach these Terms;

(b) we reasonably suspect or determine fraud, abuse, manipulation or a material security threat;

(c) information reasonably required to verify your eligibility, identity or account ownership is materially false or cannot reasonably be verified;

(d) we are required to do so by law, a regulator, a court, an app store or another competent authority; or

(e) continued access would create a material legal, security or operational risk that cannot reasonably be addressed through a less restrictive measure.

On termination, your right to use the Service ends. The treatment of Rewards and any remaining balance is governed by section 11, When We May Review Your Account or Rewards.

18. Our Communications To You

We may send you communications reasonably necessary to operate your account or the Service, including communications relating to Rewards, withdrawals, account security, verification, fraud reviews, subscription administration, changes to the Service or these Terms, and other transactional or administrative matters. These service communications are separate from marketing communications.

Nothing in this section permits us to send marketing communications without any consent or other legal basis required by applicable law. Our Privacy Policy explains how we use your contact information and the choices available to you.

19. Taxes

You are responsible for determining whether Rewards you receive or redeem are subject to any taxes, duties or reporting obligations applicable to you and for complying with those obligations.

Where required by applicable law, we may request information reasonably necessary to comply with our own tax, reporting or withholding obligations and may make any reporting or withholding required by law. Nothing in these Terms constitutes tax advice.

20. Your Consumer Rights and Our Responsibility

We aim to provide the Service with reasonable care and skill. However, the Service relies on internet connectivity, devices, app stores, Partners, attribution systems and other third-party services, so we cannot guarantee that it will always be available, uninterrupted or error-free.

To the extent permitted by law, the Service is provided on an “as available” basis and we do not provide warranties beyond those set out in these Terms or required by law.

If you are a consumer, you may have rights under applicable consumer law in relation to digital content, digital services and subscriptions. These may include rights to refunds, price reductions, repair or re-performance, cancellation or withdrawal. Nothing in these Terms limits any consumer right or remedy that cannot legally be limited or excluded.

We do not exclude or limit our liability where the law does not allow us to do so, including liability for fraud or fraudulent misrepresentation, wilful misconduct, or death or personal injury caused by negligence where applicable.

To the extent permitted by law, we are not responsible for indirect or consequential losses that were not reasonably foreseeable when you agreed to these Terms. We are also not responsible for business losses resulting from use of the Service for commercial purposes, as the Service is intended for personal consumer use.

We remain responsible for losses that are a foreseeable result of our breach of these Terms or our failure to use reasonable care and skill, and for any other liability that applicable consumer law requires us to bear.

21. Additional Terms for Apple Users

If you access the Service through a Scrambly mobile application downloaded from the Apple App Store (the “iOS Application”), the following terms apply to your use of that iOS Application. The iOS Application may allow you to discover, access, or download third-party apps, games, or services. Those third-party apps, games, and services are provided by their respective third parties, who are responsible for their content, operation, and functionality.

These Terms are between you and Scrambly, not Apple. Scrambly, and not Apple, is responsible for the iOS Application and the content that forms part of the iOS Application, including any maintenance, support and claims relating to the iOS Application, to the extent required by applicable law. Apple has no obligation to provide maintenance or support.

Your licence to use the iOS Application is non-transferable and limited to Apple-branded products that you own or control, subject to the applicable Apple usage rules.

If the iOS Application fails to conform to an applicable warranty, you may notify Apple and Apple may refund any purchase price paid for it. To the maximum extent permitted by law, Apple has no other warranty obligation.

Scrambly, and not Apple, is responsible for any third-party intellectual-property claim relating to the iOS Application. Nothing in this Section makes Scrambly responsible for the operation, content or independent acts or omissions of third-party apps, games or services that you discover, access or download through the Service, except as required by applicable law.

You must comply with applicable third-party terms and represent that you are not subject to applicable U.S. Government embargoes or restrictions.

Apple and its subsidiaries are third-party beneficiaries of these Terms as they relate to the iOS Application and may enforce the applicable provisions against you.

22. Governing Law and How Disputes Are Handled

These Terms are governed by Italian law. If you are a consumer, you may also benefit from mandatory consumer protections under the laws of the country where you live. Nothing in these Terms takes away those protections where they apply.

If you have a concern or dispute, please contact us first so that we can try to resolve it informally. You can still use any complaint, regulatory, court or other dispute-resolution process available to you under applicable law.

If you use the Service for business or professional purposes and consumer jurisdiction rules do not apply, the courts of Milan, Italy will have exclusive jurisdiction, to the extent permitted by law.

23. Changes to These Terms

We may update these Terms from time to time to reflect changes to the Service, our business, applicable law, security requirements or other legitimate operational reasons.

When we make changes, we will update the “Last updated” date. Where required by applicable law, or where a change materially affects your rights or obligations, we will provide reasonable advance notice through the Service, by email or by another appropriate method and, where required, obtain your consent.

Changes will apply prospectively and will not retrospectively remove Rewards already validly earned or rights already accrued, except where required by law or where an adjustment is permitted under the Reward Validation provisions because the underlying activity was invalid. If you do not agree to updated Terms, you may stop using the Service and close your account. Continued use after the effective date constitutes acceptance.

24. Other Legal Terms

If any part of these Terms is found to be invalid or unenforceable, the rest of the Terms will continue to apply. The affected provision will be interpreted or adjusted only as much as necessary to make it valid and enforceable under applicable law.

If we do not enforce a provision of these Terms straight away, we can still enforce it later.

We may provide translations of these Terms. If there is any inconsistency between a translation and the English version, the English version will apply where permitted by law. This does not affect any right you may have to receive these Terms or other contractual information in a language required by law.

We may transfer our rights and obligations under these Terms as part of a merger, reorganisation, financing, sale of our business or assets, or another corporate transaction, provided that this does not affect your mandatory rights. You may not transfer your account or your rights under these Terms to someone else without our consent, unless applicable law allows otherwise.

These Terms, together with any additional terms that apply to a specific offer, Promotion, subscription or feature, form the agreement between you and Scrambly for your use of the Service. Nothing in this paragraph limits any rights or liability that cannot legally be limited or excluded.

25. How to Contact Us

If you have questions about these Terms or the Service, please contact Scrambly through the Customer Support channel available in the Service.

For privacy questions or requests, contact [email protected].

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