Privacy Policy

Flow Group AB, a Swedish company with company organization number 559183-6027 ("Flow Group", "Rewly", "we", "our" or "us"), is responsible for the processing of your personal data as described below. This privacy policy concerns you who register an account and become an Rewly user.

Rewly, a platform built by Flow Group under the PollFlow project, is a company based in Sweden with organization number 559183-6027

We care about and value your privacy. Through this privacy policy we therefore wish to provide you with information on how we process your personal data as well as what rights you have in relation to our processing of your personal data.

We process your personal data for the following general purposes:

  • To create and administer your account at Rewly;
  • To create and administer your profile at Rewly;
  • To match your profile with surveys that are relevant for you;
  • To provide surveys;
  • To provide cashback services for online shopping;
  • To provide mobile game offers and rewards;
  • To provide skill-based quiz games;
  • To administer your withdrawal of virtual currency via Swish;
  • To provide customer service and improve our website by analyzing feedback;
  • To administer your interactions with us on our social media account;
  • To detect and prevent fraud and misuse of our services; and
  • To comply with our legal obligations and handle possible legal claims.

Below you can read more about how we process your personal data. Should you have any questions regarding our processing of your personal data, or if you wish to exercise any of your rights under data protection legislation, please contact us via our email address [email protected]. Our postal address is Flow Group AB Luntmakargatan 54B, 113 58, Stockholm.

Age requirement

You must be at least 13 years of age to use Rewly, in accordance with Swedish data protection legislation. If you are under 18 years of age, you must have your parent or legal guardian's permission to access and use the service. Please note that registration requires Swedish BankID, which may have its own age requirements. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will take steps to delete that information.

From where do we collect your personal data and are you required to provide personal data to us?

We collect your personal data directly from you, for example when you register an account and answer our profiling questions.

When you register an account, we collect identity information through Swedish BankID, including your full name, social security number (personnummer), and date of birth. Your social security number is required for secure identity verification and is necessary under Swedish law for processing Swish payments. We also collect your email address, phone number, and postal code during the registration process.

We automatically collect certain technical data from your device, including your IP address, device model and type, operating system version, app version, timezone, advertising identifier, and country of origin. This data is collected through our app and is used for service delivery, fraud prevention, and analytics purposes.

When you use our cashback service, we collect data about your clicks and transactions through our affiliate network partners. This includes click timestamps, the store visited, and transaction details provided by the affiliate networks.

In some of our profiling questions you can choose to share sensitive personal data (e.g. data about your health) with us. Answering these questions is optional and we will process the data you share with us only if you give your explicit consent.

Generally, you are free to choose if you want to provide your personal data to us. It is however in some instances necessary for you to provide personal data to us, e.g. to register an account. What exact personal data we require from you can be found in the tables below in relation to the legal bases "fulfilment of contract" and "legal obligation". The data we require from you is never sensitive data.

If you don't provide us with certain requested personal data, you will not be able to participate in the surveys or games we provide or create and use an account. Furthermore, we will not be able to comply with bookkeeping and accounting law and handle possible legal claims.

Who can gain access to your personal data and why?

Your personal data is primarily processed by Flow Group AB under the PollFlow project. However, in certain instances, we share your personal data with third parties in accordance with below.

If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.

No matter the purpose for our processing of your personal data, we will share your personal data with our IT-suppliers who will process these on our behalf and on our instructions in order to ensure good and secure IT-operations. We only share your personal data with our IT-suppliers if it is necessary in order for them to fulfil their obligations towards us according to the contract that we have with them.

If you participate in surveys

  • In order to provide you with surveys that are relevant for you, we share your personal data with our survey partners who match your profile to available surveys. Our partners act as intermediating parties between us and the companies looking for participants in surveys by matching your profile to the needs of the survey companies.
  • Any information you provide directly within a survey is processed by the third-party survey provider, not by Rewly. We do not have access to your individual survey responses. The survey provider is a separate data controller for the data you provide within their surveys.

If you use our cashback service

  • In order to track your purchases and attribute cashback, we share data with our affiliate network partners. These networks process click and transaction data to verify purchases and calculate commissions.
  • Each store you shop at through our cashback service is subject to its own terms and conditions. We are not a party to the agreement between you and the store. The store is a separate data controller for data you provide during your purchase.

If you use mobile game offers

  • In order to provide mobile game offers and verify completion of offer requirements, we share data with our game offer partners. These partners receive your device identifier, advertising ID, IP address, and information about your progress in the offered games.

If you withdraw your earnings via Swish

  • In order to process your Swish withdrawal, we share your full name, social security number, Swish phone number, and withdrawal amount with our payment processing service to complete the transaction.

Where are your personal data processed?

We, as well as our processors, mainly process your personal data within EU/EEA. When we process your personal data outside of the EU/EEA we do so because our partner, which help us match your profile to surveys you find interesting and relevant, will store your personal data outside of the EU/EEA.

Some of our affiliate network partners and game offer providers may also process data outside of the EU/EEA.

When we transfer your personal data outside of the EU/EEA, we do so based on either a decision from the Commission, standard contractual clauses or other appropriate safeguards as required by applicable data protection legislation.

If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.

What rights do you have in relation to our processing of your personal data?

According to applicable data protection legislation, depending on the circumstances, you are entitled to a number of different rights which are set out below.

If you have any questions regarding these rights or if you want to use any of your rights, you are welcome to contact us. Our contact details can be found in the beginning of this privacy policy.

Right to information and access

You have the right to obtain a confirmation on whether we process your personal data. If we process your personal data, you also have a right to receive information about how we process the personal data and to receive a copy of your personal data.

Right to rectification

You have a right to have inaccurate personal data corrected and to have incomplete personal data completed.

Right to erasure ("right to be forgotten") and restriction of processing

You have the right to have your personal data erased in certain instances. This is the case e.g. when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed and where we process your personal data on the basis of our legitimate interest and we find, following your objection (see below under Right to object), that we do not have an overriding interest in continuing to process it.

You also have a right to request that we restrict our processing of your personal data. For example, when you question the accuracy of the personal data, when you have objected to our processing of your personal data based upon our legitimate interest, or where the processing is unlawful, and you oppose to the erasure of your personal data and instead want us to restrict our processing.

Right to data portability

In certain instances, you have a right to be provided with such personal data (concerning you) that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to in certain instances have such personal data transferred to another controller, where technically feasible.

Right to object

You have the right to object to our processing of your personal data if we use it for marketing purposes.

You also have a right to object to our processing of your personal data when the processing is based on the legal basis "legitimate interest". The situations when we base our processing on our legitimate interest are stated in the below charts and you can read more about our balancing of interest assessments in the end of this privacy policy. In some instances, we may continue to process your personal data even if you have objected to our processing. This can be the case if we can show compelling legitimate reasons for the processing that outweigh your interests or if it is for the purpose of establishing, exercising or defending against legal claims.

Right to withdraw consent

You have the right to withdraw a given consent at any time. The withdrawal will not affect the lawfulness of processing based on your consent before the withdrawal.

Right to lodge a complaint to a supervisory authority

You have the right to lodge a complaint to a supervisory authority concerning our processing of your personal data.

Such a complaint can be filed with the authority in the EU/EEA member state where you live, work or where the alleged infringement of applicable data protection legislation has occurred. In Sweden, the supervisory authority is The Swedish Data Protection Authority.

Virtual currency

All balances, earnings, and amounts displayed within the Rewly app represent virtual currency. Although values may be displayed using the denomination "SEK" or "kr" for ease of understanding, all in-app balances constitute virtual points without monetary value until a withdrawal is successfully completed via Swish. Virtual currency cannot be transferred between users, exchanged outside of the app, or considered as stored monetary value. We reserve the right to adjust conversion rates and virtual currency balances in accordance with our terms of service.

This includes virtual currency used in our skill-based quiz games, where users can wager virtual points against other users. These wagers do not constitute real-money gambling, as the wagered amounts are virtual currency without monetary value.

Detailed description on how we process your personal data

The below chart describes in detail why we process your personal data, which personal data we process, the lawful basis for the processing and for how long we process your personal data.

If you register an account and become an Rewly user

To administer your account
What processing we perform
  • To create and enable you to securely use your account, including to communicate with you regarding your account
  • To give you the benefits of having an account, including e.g. enable you to manage your settings and gain access to your survey history
  • To keep track of the points you receive from various completed surveys
  • To calculate your ranking compared to other Rewly users based on your points
What personal data we process

Information you provide to us and information collected via BankID, e.g.:

  • Name (collected via BankID)
  • Social security number (collected via BankID)
  • Date of birth (collected via BankID)
  • Contact information (email)
  • Phone number (Swish number)
  • Postal code and city
  • Gender
  • The number of surveys you have completed and points you have collected
  • Other information you choose to provide to us, such as street address
Our lawful basis for the processing
Performance of contract

The processing is necessary for us to fulfil the contract concerning your registration at Rewly.

Legitimate interest

It is not necessary for you to provide us information about your street address to fulfil any contract. This information is instead processed on the basis of our legitimate interest to process your personal data in order to administer your account.

Storage period: We will store your personal data until you choose to delete your account at Rewly.
To administer your account — Referrals
What processing we perform
  • To keep track of when you have referred a friend to Rewly and how many points they have collected in order to reward you with extra points
What personal data we process
  • The points you collect
  • Name of the friend you have referred
  • The number of points your friend has claimed
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to reward you with the extra points for recruiting one of your friends to Rewly.

If you are the referred friend and register an account, we will process your personal data based on the performance of contract, please see above.

Storage period: We will store your personal data until you choose to delete your account at Rewly.
To administer your profile
What processing we perform
  • To ask you questions in order to create a profile for you that can be matched to relevant surveys
  • To give you surveys that are matched to your interests and persona

Note that it is optional to answer these questions and that you choose what information you want to share with us.

What personal data we process

Information you provide to us, e.g.:

  • Information about your household, education and occupation, car, food and beverages, hobbies and interests, electronics, computer and video gaming, media, travel and what research surveys you are willing to participate in
  • Information about your ethnicity, smoking and tobacco habits, healthcare and eventual children
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data that you choose to give us to be able to create and administer your profile.

Explicit consent

Sensitive information will be processed based on your explicit consent. You can withdraw such consent at any time. You can also change some of the answers you have given to "I prefer not to declare this".

Storage period: We will store your personal data until you choose to delete your account or until you change your answers to "I prefer not to declare this". We will stop storing your sensitive personal data immediately if you withdraw your consent.
To send you notifications
What processing we perform
  • To send you push notifications about new surveys, cashback offers, game rewards, and other service updates
  • To send you email notifications about your account and available opportunities
  • To send you SMS notifications when applicable
What personal data we process
  • Device push notification token
  • Email address
  • Phone number
  • Your notification preferences (push, email, SMS)
Our lawful basis for the processing
Consent

Push notifications are only sent if you have granted notification permission on your device and opted in to receive them. You can withdraw your consent at any time by disabling notifications in your device settings or in the app.

Legitimate interest

For service-related communications that are essential for the use of the platform, such as account-related messages.

Storage period: We will store your notification token until you choose to delete your account or disable notifications. Notification history is retained until account deletion.

If you participate in the surveys we provide

To enable your profile to be matched with relevant surveys
What processing we perform
  • To enable your profile to be matched with surveys you find relevant and interesting we share information with our partners
  • Our partner matches your profile to companies that have surveys both within the EU and outside of EU
What personal data we process

Information you provide to us, e.g.:

  • Name
  • Contact information (email)
  • Postal code and city
  • Gender
  • Date of birth
  • The number of surveys you have completed and points you have collected
  • Other information you choose to provide to us, such as street address and phone number
  • Other information from the profiling questions you have chosen to answer
  • Other information that might have technical administration purposes such as IP address or country location
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to enable your profile to be matched with surveys you find relevant and interesting.

Explicit consent

Sensitive information will be processed based on your explicit consent. You can withdraw such consent at any time. You can also change some of the answers you have given to "I prefer not to declare this".

Storage period: We will store your personal data for survey matching purposes until you choose to delete your account. This is essential for providing you with targeted and relevant survey opportunities. We will stop storing your sensitive personal data immediately when you withdraw your consent or change your answers to "I prefer not to declare this".
To provide surveys
What processing we perform
  • To provide you with surveys that you can participate in
  • To award you points for each survey you partake in

Note that we provide the opportunity for you to participate in surveys, but the actual surveys are managed by third parties. Any information you provide directly within a survey (your survey responses) is processed by the third-party survey provider and not by Rewly. We do not have access to your individual survey responses. If you choose to state your name or any other information about yourself in a survey, the survey company might be able to tie your answers to you as a person. In such cases, the survey company is a separate data controller. If you want to know more about how they process your data you can contact the relevant company.

What personal data we process

Information you provide to us, e.g.:

  • Name
  • Contact information (email)
  • Postal code and city
  • Gender
  • Date of birth
  • Other information you choose to provide to us, such as street address and phone number
  • The number of surveys you have completed and points you have collected
  • Information you have provided to us through your profile
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to provide you with surveys that you can participate in.

Storage period: We will store your personal data until you choose to delete your account.

If you use our cashback service

To provide cashback for online shopping
What processing we perform
  • To track your clicks when you visit a store through our app and attribute any resulting purchases to your account
  • To calculate and credit cashback based on your verified purchases
  • To display pending and approved cashback balances in your account
  • To verify and validate transactions with our affiliate network partners
  • To reject or reverse cashback earnings in cases of returned, cancelled, or manipulated orders

Cashback is calculated on the order value excluding VAT, taxes, and shipping costs, and is rounded down to the nearest whole number. Cashback rates are set by the individual stores and may vary.

Modified, cancelled, or returned orders do not generate cashback. If cashback has already been credited for a transaction that is subsequently returned or reversed, we reserve the right to deduct the corresponding amount from your balance.

We reserve the right to reject or reverse cashback earnings in cases of suspected fraud, manipulation, or violation of store terms. This includes but is not limited to: use of unauthorized discount codes, splitting purchases to maximize cashback, or any other form of abuse.

Each store is subject to its own terms and conditions. We are not a party to the purchase agreement between you and the store, and we are not responsible for the store's products, services, or campaigns.

Cashback tracking requires that you access the store through our app. Purchases made directly on a store's website or app without clicking through our service cannot be tracked or credited.

What personal data we process

Information collected through our service and affiliate partners:

  • Click data (timestamp, store visited, IP address, device information, referrer URL)
  • Transaction data received from affiliate networks (order value, commission, currency, transaction date, validation status)
  • Store and product category information
  • Decline reasons for rejected transactions
Our lawful basis for the processing
Performance of contract

The processing is necessary for us to fulfil the contract concerning your use of the cashback service within Rewly.

Legitimate interest

Our legitimate interest to process transaction data to verify purchases, detect fraud, and prevent manipulation of cashback earnings.

Storage period: We will store your cashback transaction data until you choose to delete your account. Transaction records may be retained longer where required for bookkeeping and accounting obligations.

If you use mobile game offers or play quiz games

To provide mobile game offers
What processing we perform
  • To display available mobile game offers that you can complete for rewards
  • To track your installation and progress in offered games
  • To verify completion of offer requirements and credit rewards to your account

Mobile game offers are provided through third-party partners. When you install and interact with an offered game, these partners collect data about your device and in-game activity to verify offer completion. These partners act as separate data controllers for the data they collect through their SDKs.

What personal data we process

Information collected through our game offer partners:

  • Device identifier and advertising ID
  • App installation status and progress events
  • IP address and country of origin
  • Device type and operating system
  • Reward levels achieved and amounts earned
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to provide you with mobile game offers, verify completion of offer requirements, and credit rewards to your account.

Storage period: We will store your game offer data until you choose to delete your account.
To provide skill-based quiz games
What processing we perform
  • To provide you with quiz games where you can play against other users
  • To match you with opponents and manage game sessions
  • To calculate scores based on correct answers and response time
  • To process virtual currency wagers and payouts for each game
  • To calculate your ranking compared to other players

Quiz games involve wagering virtual currency (displayed as SEK) against other users. These wagers are made with virtual points that have no monetary value. Game outcomes are determined by skill (knowledge and response speed), not by chance.

What personal data we process
  • Name and profile avatar
  • Quiz answers and response times
  • Virtual currency balance and wager amounts
  • Win/loss record and ranking
  • Duel credits balance
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to allow you to play skill-based quiz games, compete against other users, and manage virtual currency wagers and payouts.

Storage period: We will store your personal data until you choose to delete your account.

If you withdraw your earnings

To administer withdrawal of your virtual currency via Swish
What processing we perform
  • To convert your virtual currency balance into a Swish payment
  • To process and send the Swish payment to your registered phone number
  • To keep track of your withdrawal history and payment status
What personal data we process

Information you provide to us, e.g.:

  • Name
  • Social security number
  • Swish phone number
  • Withdrawal amount
  • Payment status and transaction reference
Our lawful basis for the processing
Performance of contract

The processing is necessary for us to fulfil the contract concerning your membership in Rewly which means you receive points that can be withdrawn as Swish payments in exchange for participating in surveys and other activities.

Storage period: We will store your withdrawal data until you choose to delete your account. Transaction records may be retained longer where required for bookkeeping and accounting obligations.

If you interact with us on social media

To communicate with you on social media
What processing we perform
  • To communicate with you on our social media account (Facebook), e.g. if you communicates with us on our page
What personal data we process
  • Information from your profile on the social media in question (user name and any picture you have chosen for your account)
  • Information which you provide on our page
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to communicate with you on our social media platform.

Storage period: Your personal data will be removed if you ask us to remove it or if you yourself delete the content, but we will otherwise store the personal data on the social media platform until further notice.

Other processing activities

To provide customer service
What processing we perform
  • Answer and administer customer service matters
What personal data we process
  • Name
  • Contact information you provide in our contact
  • Other information you provide regarding the matter, e.g. a problem with a function
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to answer and administer customer service matters.

Storage period: We will store your personal data until the account is removed.
To improve our services
What processing we perform
  • To improve our services and website's functions based on your feedback
What personal data we process

Information you provide to us, e.g.:

  • Name
  • Contact details (e-mail)
  • Other information you provide to us when sending us feedback
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to handle your feedback and improve our services.

Storage period: We will store your personal data until account is removed
To detect and prevent fraud
What processing we perform
  • To verify your identity and prevent fraudulent account creation
  • To check your IP address against known proxies, VPNs, and suspicious sources
  • To monitor for suspicious patterns of activity such as manipulation of cashback, surveys, or game offers
  • To enforce country restrictions and verify your geographic location
What personal data we process
  • IP address
  • Device identifier and advertising ID
  • Country and geographic location data
  • Proxy and VPN detection results
  • Login history and activity patterns
  • Transaction and earnings history
Our lawful basis for the processing
Legitimate interest

Our legitimate interest to process your personal data to detect and prevent fraud, protect the integrity of our services, and ensure fair use for all users.

Storage period: We will store fraud prevention data until you choose to delete your account. IP and proxy check logs may be retained for up to 12 months for security purposes.
To handle any claims and rights
What processing we perform
  • Handle any consumer rights such as your right to make complaints
  • Defend ourselves against claims and complaints
  • Initiate any claims
What personal data we process
  • Name
  • Contact details you have chosen to use, e.g. email address and/or phone number
  • Information from our communication with you in relation to the claim, e.g. information about the relevant booking or information about your stay
Our lawful basis for the processing
Legal obligation

The processing is necessary to comply with legal obligations to which we are subject, i.e. comply with a legal obligation that we are subject to.

Legitimate interest

Our legitimate interest to process your personal data to defend ourselves against a possible legal claim and to initiate any claim.

Storage period: We will store your personal data until we have processed the complaint, until we have handled the right or for the duration of the dispute.
To comply with bookkeeping and accounting legislation
What processing we perform
  • Store information in bookkeeping and accounting
What personal data we process
  • Name
  • History regarding withdrawals and payments made
  • Other information that constitutes accounting records
Our lawful basis for the processing
Legal obligation

The processing is necessary to comply with legal obligations to which we are subject, i.e. bookkeeping and accounting legislation.

Storage period: We will store your personal data until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

Analytics and tracking technologies

We use the following analytics and tracking services to improve our service, measure performance, and understand how users interact with our app:

App analytics

We use third-party analytics services to track app usage events, screen views, and user engagement. These services collect device information, app usage data, and custom events that we define. Analytics data helps us understand how our app is used and improve our services.

Advertising and attribution

We use third-party SDKs for conversion attribution and event tracking. These SDKs may collect data about your app activity including registration, purchases, and engagement events. This data may be used by third-party advertising platforms in accordance with their respective privacy policies.

Deep linking and referral attribution

We use third-party deep linking services for referral attribution. These services collect data about how you arrived at our app, including referring links, click timestamps, and device information. This is used to attribute referrals and measure marketing effectiveness.

Error monitoring

We use third-party error monitoring services to track and resolve technical issues. These services collect technical error logs, stack traces, and limited device information when errors occur in the app. This is used solely for identifying and fixing technical issues.

App Tracking Transparency (iOS)

On iOS devices, we request your permission to track your activity across other companies' apps and websites through Apple's App Tracking Transparency framework. You can grant or deny this permission, and you can change your choice at any time in your device settings. If you deny tracking, we will not share your device's advertising identifier with third parties.

Browser extension

If you use our Safari browser extension for cashback tracking, authentication data is shared between the app and the extension via a secure iOS App Group. This is necessary for the extension to attribute your purchases to your Rewly account. No additional personal data is collected through the extension beyond what is described in this privacy policy.

Do Not Track

Our service does not currently respond to "Do Not Track" browser signals. However, you can control tracking through your device settings, including the App Tracking Transparency prompt on iOS.

Automated decision-making

We use automated processing to match your profile with relevant surveys. This matching is based on the demographic and profiling information you have provided, such as age, gender, location, interests, and other profile attributes. The outcome of this automated matching determines which surveys are shown to you. This processing does not produce legal effects or similarly significant effects on you — it only affects which survey opportunities are displayed to you.

We also use automated processing for fraud detection, including checking IP addresses against known proxy and VPN databases and monitoring activity patterns for suspicious behaviour. In some cases, this automated processing may result in restrictions on your account. Under GDPR Article 22, you have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you. If you believe such a decision has been made about you, you have the right to obtain human intervention, express your point of view, and contest the decision by contacting our Data Protection Officer.

Account deletion and data retention

When you delete your account, we take the following steps to protect your privacy:

  • Your personal identification data (name, email, social security number, phone number, postal code) is scrambled and anonymized so that it can no longer be linked to you as a person.
  • Your profiling answers and active game data are permanently deleted.
  • Your data is deleted from our third-party survey partners where technically possible.
  • Your push notification tokens are permanently deleted.
  • Your notification preferences are disabled.

Please note that certain anonymized records are retained even after account deletion for the following purposes:

  • Survey completion records, cashback transactions, withdrawal history, and game completion records are retained in anonymized form for bookkeeping, accounting, and fraud prevention purposes.
  • We are legally required to retain certain financial records for up to seven years after the end of the relevant fiscal year, in accordance with Swedish bookkeeping and accounting legislation.

After anonymization, the retained records cannot be linked back to you as an identifiable person.

Business transfers

If Flow Group AB or its assets are acquired by or merged with another company, or in the unlikely event that we go out of business or enter bankruptcy, personal data may be among the assets transferred to the acquiring party. In such a case, you will be notified before your personal data is transferred and becomes subject to a different privacy policy. The acquiring party will be required to continue to process your personal data in accordance with applicable data protection legislation.

Data breach procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Swedish Data Protection Authority (IMY) without undue delay and no later than 72 hours after becoming aware of the breach, in accordance with GDPR Article 33. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, in accordance with GDPR Article 34.

Cookies and similar technologies

When you use our app and related services (such as our Safari browser extension for cashback), we and our partners may use cookies and similar tracking technologies to enable essential functionality, measure performance, and attribute transactions.

Essential cookies

These are necessary for the service to function and include session management, authentication tokens, and security tokens (e.g. CSRF protection). These cannot be disabled.

Analytics cookies

We use analytics cookies and SDKs to understand how users interact with our service, measure feature usage, and improve the user experience. These are activated based on your consent.

Advertising and attribution cookies

We use advertising SDKs and attribution tools to measure the effectiveness of marketing campaigns and attribute app installs and registrations. On iOS, these are subject to your App Tracking Transparency choice.

Affiliate tracking cookies

When you use our cashback service, tracking technology is placed on your device to document your transaction and attribute your purchase. This is necessary for the cashback service to function. The tracking is initiated when you click through to a store via our service and is used solely for cashback attribution.

You can manage your cookie preferences through your device or browser settings. Please note that disabling certain cookies may affect the functionality of our services, particularly cashback tracking.

Balancing of interests assessments

As we state above, for some purposes, we process your personal data based upon our "legitimate interest". By carrying out a balancing of interests assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data.

Below is a summary of the key balancing assessments we have conducted:

  • Profile administration and survey matching: We have a strong interest in providing you with relevant surveys based on your profile. The data processed is information you have voluntarily chosen to provide, and the impact on your privacy is limited since the processing primarily benefits you through more relevant survey opportunities.
  • Referral tracking: We have an interest in rewarding users who refer friends. Only minimal data is processed (names and points), and the processing directly benefits both the referrer and the referred user.
  • Fraud detection: We have a strong interest in protecting the integrity of our platform for all users. The data processed (IP addresses, activity patterns) is necessary to identify and prevent abuse. The impact on legitimate users is minimal as the monitoring is automated and only results in action when suspicious patterns are detected.
  • Cashback transaction verification: We have an interest in verifying that cashback transactions are legitimate. Transaction data is processed to prevent manipulation and ensure fair use. This protects both us and other users from the consequences of fraudulent activity.
  • Service improvement: We have an interest in improving our services based on user feedback. The data processed is information voluntarily provided to us, and the processing benefits all users through an improved service.
  • Customer service: We have an interest in providing effective support. The data processed is information you provide when contacting us, and the processing directly benefits you.

If you want more information in relation to our balancing of interests assessments, please do not hesitate to contact us. Our contact details can be found in the beginning of this privacy policy.

Data Protection Officer

Our Data Protection Officer is Oliver Weitman, who can be reached via [email protected] for any questions or concerns regarding the processing of your personal data.

This privacy policy was last updated on 2026-04-01. Originally established by Flow Group AB on 2021-08-18.