may withdraw consent at any time, but this does not affect processing already carried out lawfully before
withdrawal.
3.4. Legal obligations. We may process personal data where necessary to comply with legal obligations, court
orders, lawful requests of authorities, accounting and tax requirements, sanctions rules, retention duties, or
verification obligations imposed by payment providers or other regulated partners.
3.5. Vital interests and other lawful bases. Where exceptionally required, we may rely on other lawful bases
recognised by applicable law.
4. How we use reward and payout data
4.1. We use reward-related data to determine qualifying minutes, apply the disclosed coefficients and campaign
rules, calculate Coin balances, monitor payout thresholds and maintain an audit trail of reward events.
4.2. We use viewing, device and event data to validate genuine human viewing, detect invalid traffic, prevent
duplicate-account abuse, investigate manipulative behaviour and protect the integrity of ad-supported reward
mechanisms.
4.3. We use payout and compliance data to process withdrawal requests, screen transactions against fraud or
sanctions concerns, respond to chargebacks or disputes, and comply with payment-provider requirements.
4.4. We may retain reward and payout records after an account is closed where reasonably necessary to
investigate abuse, defend claims, satisfy recordkeeping obligations or comply with law.
5. Disclosure and sharing of personal data
5.1. Service providers. We may share personal data with providers that help us operate the Service, including
cloud hosting providers, content delivery services, analytics and crash-reporting providers, customer support
tools, communication vendors, anti-fraud and security vendors, payment processors, verification providers, and
professional advisers such as lawyers, auditors or accountants.
5.2. Advertising and measurement partners. Because the Service may be ad-supported, we may share technical
identifiers, event data or measurement information with advertising, attribution and anti-fraud partners to deliver,
measure or protect advertising functionality, subject to applicable law and your device or consent settings.
5.3. Business partners and licensors. We may share limited data with content licensors, promotional partners or
other business counterparties where reasonably necessary to manage rights, campaigns, reporting or contractual
obligations.
5.4. Authorities and legal disclosures. We may disclose personal data where required by law, court order,
regulatory request or to protect the rights, safety and property of the Company, users, partners or third parties.
5.5. Corporate transactions. If we undergo a merger, acquisition, financing, restructuring, asset sale or similar
transaction, personal data may be disclosed to counterparties and advisers and may be transferred as part of that
transaction, subject to applicable law.
5.6. We do not sell personal data for monetary consideration. If applicable law treats certain advertising-related
disclosures as "sharing" or a similar concept, you may use available privacy controls, cookie settings or device
settings to limit such processing where those controls are available.
6. International transfers
6.1. The Company and its service providers may process personal data in countries other than the country where
you reside. Those countries may not provide the same level of legal protection as your home jurisdiction.
6.2. Where applicable law requires safeguards for international transfers, we will use appropriate measures such
as contractual protections, adequacy mechanisms, or other lawful transfer tools recognised under the relevant
legal framework.
7. Retention of personal data
7.1. Account and profile data are generally retained for the life of the account and for up to 24 months after
account closure or the last meaningful interaction, unless a longer period is required or justified.
7.2. Reward, payout, fraud and dispute records may be retained for up to 5 years after the relevant event or
account closure, and tax or accounting records may be retained for up to 7 years where required by law or by a
payment provider.
7.3. Security logs, technical diagnostics and device-level troubleshooting data are generally retained for up to 12
months, unless we need a longer period to investigate security incidents, abuse or legal claims.
7.4. Consent records, suppression lists and marketing preference data are retained for as long as needed to
honour your choices and to demonstrate compliance with applicable law.