Privacy Policy

At a Glance

• Scope: This Privacy Policy applies to the processing of data by Cashly Rewards as the Data Controller.
• Contact details of the Data Controller: Cashly Rewards, support@cashlyrewards.com
• Source of the processed data: Data provided automatically or actively, publicly available information, and data provided by third parties (e.g. social networks).
• Purposes of processing: Access to services, authentication, security and improvement of services, contract management, legal requirements, business administration, product development, communication and marketing, and matching and enabling optional surveys where you have consented.
• Recipients: Service providers, government agencies, consultants, auditors, and other contractual partners bound by confidentiality obligations, and survey providers where you participate in surveys.
• Legal basis: Consent; contractual purposes; compliance with legal obligations; protection of our legitimate interests following a balancing of interests; and, for special categories of personal data (e.g. in connection with surveys), your explicit consent.
• Retention period: Data is stored for as long as necessary for the purposes listed above, or longer if required by law or otherwise necessary and permissible.

Your Control

Withdrawal of your consent: You may withdraw your consent at any time and without providing a reason. Upon withdrawal, processing based on consent will cease for the future.

Objection to processing based on legitimate interests: You may object to data processing based on legitimate interests by providing reasons. Processing will cease unless compelling legitimate grounds override your interests, rights, and freedoms, e.g. if the processing serves to establish, exercise, or defend legal claims. Any processing of personal data for direct marketing purposes will cease immediately upon notification by the data subject.

Rights of the data subject: access, rectification, erasure, restriction, right to object, data portability, and the right to lodge a complaint with a supervisory authority. To exercise these rights, you may contact us at any time and free of charge, without the need for any specific form or justification.

1. Contact information for the data controller

You can reach us at support@cashlyrewards.com. If you have any questions regarding the protection of your personal data, you may contact us at the same address.

2. Source of personal data processed by Cashly

Cashly is a platform that offers various tasks to users. When users complete the tasks, the previously announced rewards are distributed. We process personal data of users in connection with our services. The data processed by Cashly comes from the following sources:

• Automatically collected data: technical data collected when you interact with our Services (e.g. IP addresses, browser information, cookies, device information).
• Data actively provided by users: registration data (e.g. name, email, phone number), newsletter sign-ups, and data provided via the contact form or other communications. Where you choose to participate in surveys, this also includes the survey profile and qualification information described in Section 3.2b.
• Information from publicly available sources to the extent necessary to fulfill legal and contractual obligations.
• Third-party services or platforms: data from social networks or services linked to Cashly accounts.

3. Purposes and legal basis for the processing of personal data

We process personal data for limited purposes and only when we are contractually or legally authorized or obligated to do so, or when you have expressly consented.

3.1 Security and Operation

We process your personal data to technically provide you with our services and to ensure their security at all times. For technical reasons, every time you visit or interact with our services, your browser or device sends technical information to us, which is stored in server logs. This includes connection and access data such as the date, time, and duration of your visit, your device's IP address, the referrer URL, the subpages visited, and other information about your device (device type, browser type and version, settings, operating system, logins, tasks performed).

We use this data to enable interaction with our service and to secure, operate, and improve our system operations, to prevent abuse, and to detect, prevent, and correct errors. We also process data to determine whether a request comes from you or from a bot or other automated request; for this bot protection we rely on external service providers described in our Cookie Policy. The legal basis is our legitimate interest in the protection and functionality of the services.

3.2 Provision of our Services

This includes registration data, contact information, and login credentials so that you can create an account and access it regularly, and so we can inform you about updates to the terms and conditions.

To ensure that rewards can be distributed, we ask you for your payout information. This may include your bank account details or your PayPal, Cash App, or Venmo account information. If you link digital wallets to your account, we also process the necessary wallet identifiers.

We may process identity verification data where necessary, including government-issued identification documents, selfies or liveness checks, and related verification data (such as verification status and risk indicators). This data is used to verify your identity, enable secure payouts, prevent fraud, and comply with legal or partner requirements.

We process transaction and rewards-related data in connection with your participation in offers, surveys, and other activities on the platform, including information about completed offers, earned rewards, and related payout or redemption activity. For identity verification and fraud prevention we also use external service providers acting on our behalf. The legal bases are the performance of our contract with you and our legitimate interests.

3.2a Optional device-data features (installed apps and app usage)

If you use our mobile app, we offer two optional features that rely on device permissions you control. With your permission (consent), we read the list of apps installed on your device to select and personalise the offers we show you. Separately, on Android, if you enable "PlayTime" you grant us the usage-access permission, with which we measure your use of the apps and games that are part of Cashly offers in order to verify your participation and credit your rewards. We do not collect usage of apps that are not part of the Cashly offer list, and we do not sell this data or share it with third parties.

Both features are optional and off until you enable them. You can withdraw either permission at any time in your device or app settings, and declining does not prevent you from creating or using your Cashly account. We process this data on the basis of your consent, to perform our contract with you where the data is used to select offers and to calculate and credit rewards, and our legitimate interest in preventing fraud and abuse. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

3.2b Surveys and special category data

We offer optional surveys as one of the ways in which you can earn rewards. Surveys are available only to users who are 18 years of age or older, and they are switched off until you actively enable them by giving your consent.

To match you to surveys for which you may be eligible, we ask you to answer a short set of profile questions (the profiler), e.g. your gender, date of birth, postal code, and, where applicable, your household income.

Some survey providers ask additional qualification questions before a survey begins. These questions, and the answers you provide, may relate to special categories of personal data, for example your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, or data concerning your sex life or sexual orientation. Where such questions are answered on our Services, your answers are relayed to the relevant survey provider so that it can determine whether you qualify; we do not store or log these answers.

We process the profile information and any special category data described above only on the basis of your explicit consent. Before surveys are enabled, we ask you to confirm that you are 18 or older and to provide your date of birth. If the information you provide indicates that you are under 18, we do not enable surveys for you.

We use this information solely to identify, match, and enable surveys for you — not for games, advertising, analytics, or the training of models. Your profile answers are stored in encrypted form, and access to the decryption key is restricted to a limited group of authorized persons. Where a survey is conducted on the survey provider's own platform, the survey provider processes your responses as an independent controller under its own privacy policy. Participation is optional and you can withdraw your consent at any time in your settings.

3.3 Improving our Services

We continuously improve our services, which includes data analysis to improve our website. To this end we use cookies or similar technologies, described in our Cookie Policy. To the extent you have consented to the analysis of your personal data, we base the analysis on your consent; otherwise we rely on our legitimate interest in continuously improving our services. We do not use the profile information or survey answers described in Section 3.2b for these analysis and improvement purposes.

3.4 Direct Marketing

From time to time, we may contact you by email or phone for commercial purposes, such as to inform you about available upgrades, new products, promotions, or special offers. If you are not an existing customer, we will only use your contact information for direct marketing purposes if you have previously given us your explicit consent. As an existing customer, we process your contact information and usage history based on our legitimate interest in providing you with commercial information related to the products you use, unless you have objected. You may opt out of receiving marketing communications at any time at no additional cost and without providing a reason.

3.5 Communication and Support

If you are a business contact or a prospective customer, we process the personal data provided to us to communicate with you, to take steps at your request prior to entering into a contract, and to follow up on previous business discussions or provide additional information about our services. When users contact us requesting technical or other support, we process the data necessary to respond to the request and provide assistance.

3.6 Compliance with Legal Obligations

We also process personal data for other purposes, e.g. when we are legally obligated to do so, for tax purposes, or based on our legitimate interests, such as when necessary to assert or defend legal claims.

3.7 Audits and M&A Transactions

During the review or negotiation of mergers, financings, acquisitions, bankruptcies, or similar transactions, we may analyze personal data and, after balancing the interests of the involved and affected parties, disclose it to external auditors, consultants, or attorneys, as well as other third parties, in connection with such a transaction. The legal basis is our legitimate interest in demonstrating compliance and ensuring necessary business functionality.

4. Recipients

We do not sell personal data to third parties; however, we may disclose personal data to others if you have given your explicit consent, if this is necessary for the performance of a contract with you, or where there is a legal obligation to disclose such data. Recipients include, in particular:

• Service providers: carefully selected and contractually bound providers that help us operate our services, including hosting, analytics, identity verification and fraud prevention, and payment processing.
• Authorities: only where we are legally obligated to disclose data.
• Advisors, auditors, and other third parties subject to statutory or contractual confidentiality obligations.
• Survey providers: where you have enabled surveys, we share the profile information necessary to determine your eligibility for, and to deliver, surveys, and we relay any qualification answers you provide, on the basis of your consent. We do not permit survey providers to use this information for their own independent marketing purposes.

Information about providers used in connection with cookie services can be found in our Cookie Policy. Upon request, we can provide you with additional information regarding recipients of your personal data.

5. Data Transfers to Third Countries

We transfer your personal data to countries outside your region only if the recipient provides adequate safeguards for the protection of personal data (including all necessary additional measures, for example standard contractual clauses), you have expressly consented to the transfer after we have informed you of the risks, the transfer is necessary for the performance of the contractual obligations between you and us, or another statutory exception applies. Where survey providers that receive your data are located in such a country, we rely on the safeguards described in this Section or on your explicit consent.

6. Retention and Deletion

In general, we process personal data only until the specified purposes have been fulfilled. Afterward, we anonymize or delete personal data, unless we are legally required to retain and document the data for a longer period for tax or commercial law reasons, you have consented to further storage, or we have a legitimate interest in further processing that outweighs your interest in deletion — for example because the processing is necessary to assert or defend legal claims.

We store the personal data processed during registration and login for the duration of the contractual relationship with us and beyond, to the extent the data is necessary to demonstrate compliance with contractual or legal obligations or to assert and defend legal claims. Where you have enabled surveys, we retain your encrypted profile answers for as long as your consent remains active and the data is needed to match and enable surveys for you. If you withdraw your consent or delete your account, we delete or anonymize this data. Answers to survey providers' qualification questions are not stored by us.

7. Your control options

You may withdraw any consent you have given us at any time without providing a reason. As a result, we will cease processing the data that was based on your consent going forward. In particular, you can withdraw your consent to the processing of survey and profile data (including special category data) at any time in your settings, after which surveys will no longer be shown to you.

You also have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you that is carried out in the public interest or on the basis of a balancing of interests; this also applies to profiling based on those grounds. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims. If your objection is directed against processing for direct marketing purposes, we will cease processing immediately.

8. Your rights as a data subject

In addition, you have the right:

• to request access to your personal data processed by us, including the purposes of the processing, the categories of personal data and recipients, the intended retention period, the origin of your data, and the existence of automated decision-making including profiling;
• to request the immediate rectification of inaccurate or incomplete personal data;
• to request the erasure of your personal data stored by us, unless processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims;
• to request the restriction of the processing of your personal data in the cases provided by law;
• to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, or to request its transmission to another controller; and
• to lodge a complaint with a competent supervisory authority.

Residents of certain regions (including the EEA, the UK, and California) may have additional rights, including the right to opt out of the sale or sharing of personal information — we do not sell personal information. If you have any questions regarding data protection, contact support@cashlyrewards.com.

9. Children

Our Services are not directed at children under 16, and we do not knowingly collect personal data from them. Surveys are available only to users aged 18 or older.