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Playback Rewards Privacy Policy

1. INTRODUCTION

This Privacy Policy describes how Playback (hereinafter “Application” or “App”) and its owner Digital Media Technology, S.L.U. (hereinafter “Adwake”) collect and use Personal Data process your Personal Information when you visit our Website, http://playbackrewards.com (“Website”), use our mobile or web applications (“App” or “Apps” and together with the Website “Services”), and when you interact with us via email or other communication method. 

This Privacy Policy is in compliance with the current data protection regulations, such as the European General Data Protection Regulation (GDPR), the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (2020) and the Organic Law 3/2018 of December 5 on Protection of Personal Data and Guarantee of Digital Rights.

Please read this Policy carefully to understand our privacy practices when you use our Services. By creating a Playback user account, or by otherwise accessing, using, or interacting with the Services, you expressly consent to our collection, use, disclosure, sharing and retention of your information as described in this Policy. We may modify this Policy at any time at our discretion. Material changes will be conspicuously posted on the Website or otherwise communicated to you. All changes will be effective immediately upon posting to the Website.

2. WHAT IS PERSONAL INFORMATION?

For purposes of this Privacy Policy, “Personal Information” or “Personal Data” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect specific categories of Personal Information. When you access our Services, we may collect certain information to complete your request. The information we collect varies depending on the Services you are using.

We describe how we collect information on our Services below:

• Identifiers

• Examples: Full name, email address, Internet Protocol (IP) address, email address, account user ID, device ID, and advertising ID
• Retention Period: For as long as is needed to provide the Services to you, or as required by law or for fraud prevention purposes.
• Commercial Information

• Examples: Records of products or services you purchased or received, or considered, other purchasing history.
• Retention Period: For as long as is needed to provide the Services to you.
• Internet Activity

• Examples: Browsing or application usage history, information regarding your interactions with the Website, applications, or advertisement, electronic device identifier, hardware information, operating system version, browser type and version, browser language, media access control (MAC), screen resolution, cookie information, system type, access times, referring Website URLs.
• Retention Period: For as long as is needed to provide the Services to you or to obtain general statistics on Website traffic and use of Apps.
• Geolocation Data

• Examples: City, State, Zip Code, and/or Country (based on IP Address).
• Retention Period: For as long as is needed to provide the Services to you or to obtain general statistics on Website traffic and use of Apps.

4. WHO IS THE DATA CONTROLLER?

A data controller is the natural or legal person who determines the purposes and means of the processing of Personal Data.

• Data Controller: Digital Media Technology, S.L.U. 
• CIF. B66459660
• Headquarters:  C/ Diputació 303 Tercera Planta. 08009 Barcelona – Spain.
• Email: privacy@adwake.ai

5. WHAT DOES THIS PRIVACY POLICY COVER?

The privacy practices and policies that we outline in this Privacy Policy will apply to the way that we use your Personal Data. To such extent, you can fall, as a Data Subject, into one of the following categories:

“Clients”: requesting the provision of Services from us.

“End User”: it refers to the Data Subjects using our Services. 

6. DATA PROTECTION OFFICER

A Data Protection Officer (DPO) is the person in charge of safeguarding the fundamental right to the protection of Personal Data at ADWAKE as well as ensuring that we process such Personal Data in compliance with the applicable data protection laws and regulations.

Our Data Protection Officer can be accessed to the following online and post addresses:

• Email: privacy@adwake.ai
• Address: ADWAKE, C/ Diputació 303 Tercera Planta. 08009 Barcelona – Spain

You can contact our Data Protection Officer if you want to exercise any of your Data Protection Rights (refer to section 11), or if you have any questions concerning this Privacy Policy.

8. USE OF YOUR PERSONAL DATA

We process data from our End Users to:

Purpose	Activity	Legal Base
USER LOGIN OR REGISTRATION	To register you as a new customer or user	Performance of a Contract
USE OF OUR SERVICES	To enable you to use our Website or the app so you can participate in our rewards program.	Performance of a Contract
DEVELOPMENT AND IMPROVEMENT OF OUR SERVICE	To improve and enhance our Website or the app and services	Legitimate Interest
SECURITY AND DEBUGGING	To administer and protect our business and this Website  or the app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Legitimate Interest
LEGAL AND REGULATORY	Compliance with Legal requests and litigation response	Legal Obligation

In particular, we process data from our Clients to:

Purpose/Activity	Description	Legal Base
PROVIDING SERVICES	To fulfill your requests for using services	Performance of a contract or adoption of pre-contractual measures
	To provide Services based on your request	Performance of a contract or adoption of pre-contractual measures
COMPLIANCE WITH LEGAL REQUESTS AND LITIGATION RESPONSE	Ensure compliance with anti-bribery and anti-corruption.	Legal Obligation

9. MEANS OF COLLECTION OF YOUR PERSONAL DATA

You may provide us with Identity Data and Contact Data by filling in forms or by corresponding with us by post, email, or otherwise. This includes personal data you provide when you create an account on our Website or contact us. We collect data automatically via Software Development Kits (SDKs) and APIs integrated into the Application. These tools allow our reward partners (Offerwalls) to communicate your task progress back to our servers.

10. RETENTION OF YOUR PERSONAL DATA

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

11. DISCLOSURES OF YOUR PERSONAL DATA 

In general, we will not disclose your personal data to third parties, except in the following cases:

• to competent authorities and bodies, courts, tribunals or any other third parties entitled to do so in accordance with the applicable regulations;
• to linked Third Party Websites When you use third-party services or websites that are linked through our services, the providers of those services or products may receive information about you that we, you, or others share with them. Please note that when you use third-party services which are not governed by this privacy policy, their own terms and privacy policies will govern your use of those services and products
• to Service Providers we have contracted the provision of certain services (e.g. virtual infrastructure services, cloud computing, customer relationship management, organization of games and contests, management of loyalty programs, sending e-mails for marketing purposes, etc.) to suppliers, who may have access to and/or process personal data in their capacity as data processors.

12. WHERE WILL COLLECTED PERSONAL DATA BE PROCESSED?

Based on the Services provided by ADWAKE, and depending on the user's location, data transfers to other countries may occur. In such a case, your personal data may be transferred internationally to third parties located outside the European Economic Area (“EEA”), provided that ADWAKE has the authority to do so and subject to compliance with the appropriate safeguards set out in Articles 44 to 50 of the GDPR. Such Third Parties shall only access the data to perform their services on behalf and for the account of ADWAKE, under an obligation of confidentiality and always following ADWAKE's instructions and without at any time using such data for their own purposes and/or unauthorized purposes.

Whenever we transfer Personal Data out of the EU, EEA, Switzerland & UK we ensure that adequate safeguards are implemented. Those safeguards include among others:

• Adequacy decision: declaration by the European Commission that a non-EU State, offers an adequate level of data protection equivalent to that provided by European data protection legislation, making international data transfer to a third party established in that State outside the EU possible;
• Binding Corporate Rules (also known as “Binding Corporate Rules”): these are applicable to corporate groups or the union of companies engaged in a joint economic activity, which enables the flow of personal data on the basis of a self-regulation accepted and assumed by each of the signatory entities;
• Standard Contractual Clauses: this is a mechanism signed between the exporter of Personal Data from any of the EEA countries and a third country. It is a contractual agreement whose model has been approved and published by the European Commission and aligned with the precepts of the GDPR.
• Code of Conduct or a certification mechanism, together with binding and enforceable commitments made by the recipient regarding the implementation of appropriate safeguards for the protection of the transferred data.
• In the absence of the above, your personal data may exceptionally be transferred to a third country or international organization, in application of the mechanisms that may be recognized in this respect by data protection legislation.  

ADWAKE, in order of preference, will carry out international transfers under the following guarantees:

Guarantee	Criteria used by ADWAKE
Adequacy Decision	Measure included as preferred by ADWAKE. You can find the list of countries subject to an adequacy decision at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
Binding Corporate Rules	In the absence of an Adequacy Decision, it will be the preferred security measure that ADWAKE will request to the importer of the personal data. You can find the list of entities that have BCR here: https://edpb.europa.eu/our-work-tools/accountability-tools/bcr_en?page=1
Standard Contractual Clauses	As a secondary guarantee mechanism in the absence of the above, we will proceed to subscribe and/or request a copy as appropriate from the importer of the personal data of the signed version of the Standard Contractual Clauses aligned with the European Commission models, available here: https://eur-lex.europa.eu/legalcontent/ES/ALL/?uri=CELEX%3A32021D0914.

13. YOUR PERSONAL DATA RIGHTS

Our advertising technology does not collect any information that directly identifies you as an individual, and instead only collects certain digital identifiers that may identify your device or your Internet browser.

As such, in order for us to give you access to Personal Data connected with your digital identifiers, you will need to provide us with additional information, as explained below, to enable us to locate relevant records.

Your rights

If you are a resident within the European Economic Area (EEA), UK and Switzerland you will have the following rights: 

• The right to be informed. You have the right to be informed about how we collect and use your Personal Data, how long we plan to keep that data, and who we will share it with. 
• The right of Access. You have the right to know exactly what information ADWAKE has collected about you, how we are storing and processing that data, and what we are going to do with it. The right to access the Personal Data that is processed by the Data Controller in accordance with Article 15 GDPR.
• The right to rectification (correction). You have the right to have incomplete data completed and incorrect data corrected. in accordance with Article 16 GDPR.
• The right to erasure. You have the right to have Personal Data permanently deleted, in accordance with Article 17 of the GDPR.  This is also known as the “right to be forgotten.” Please note that this right doesn’t apply if the processing of data that’s subject to an erasure request is necessary to comply with a company’s legal obligations or while the commercial and/or contractual relationship that we have with you remains in force. In that case, there is a series of Personal Data that is necessary for us to process in order to comply with the contract, so while it lasts, we cannot delete them, block them or cancel them, because otherwise it would prevent us from complying with the contract.
  Mobile App Users: You can exercise your right to erasure directly within the Application by navigating to Your account > Profile > Delete Account. This process permanently removes your account and triggers the deletion of your personal data from our active databases.
• The right to restrict or to the limitation of processing. If you can´t require that we erase your Personal Data, you have the right to restrict our ability to process that data, under certain circumstances indicated in article 18 GDPR.
• The right to data portability. Individuals have the right to obtain and reuse their Personal Data for their own purposes across different services in accordance with Article 20 GDPR. Data subjects can request that data controllers send their Personal Data files electronically to third parties. If technically feasible, companies must provide the data in commonly used, machine-readable formats.
• The right to object. You have the right to object to the processing of your Personal Data in certain circumstances, in particular, to those Processing operations that are based on consent or on the existence of a legitimate interest (including, but not limited to, the sending of commercial communications) in accordance with article 21.2 GDPR. For example, if an organization uses Personal Data for direct marketing, scientific and historical research, or to perform a task in the public interest. However, we may still process the data to establish or defend legal claims, or if we can demonstrate there are legitimate grounds that override individuals’ interests and rights. In those cases in which the Processing is based on the existence of a legitimate interest, the Data Subject shall be entitled to request the weighting report carried out by the Data Controller. In addition, in cases where the Processing is for the purpose of sending own or third party commercial information, the Data Subject may opt-out free of charge and voluntarily to an advertising opt-out mechanism. 
• Right to withdraw consent: given for the performance of the Processing identified in the section Processing based on the Data Subject's consent, without such revocation having retroactive effect, in accordance with Article 7.3 RGPD. 
• The right to not be subject to automated decision making. You have the right to demand human intervention, rather than having important decisions made by algorithms. Companies are required to inform people that they will be subject to algorithmic decision-making and let them know that they can opt out of it.

To exercise any of these individual Privacy Rights, refer to section 12.3 below. 

We will respond to your request as soon as possible and, in any case, within the established legal deadline. You may also withdraw your consent at any time through the email address: privacy@adwake.ai without, in any case, the withdrawal of the same condition to ensure proper management of the business relationship.

If you make a Data Subject Rights request as set out in this Privacy Policy, we will provide you with any information we might have concerning your data identifier, including where available transaction logs reflecting where we have used our technology in order to deliver an advertisement to you, and we will follow your instructions concerning the correction, removal and processing of such data.

Please note, however, that we have a very short retention period for most files with digital identifiers that we store or process. Therefore, we may not be able to give you any files at all. In these cases, we will inform you that we have not been able to locate any records associated with your digital identifiers.

Finally, we remind you that in the event that you provide us with data relating to another natural person you must, prior to their inclusion, inform them of the points contained in this Policy.

If you are a resident of California, you may have the following additional rights with regard to the Personal Data we maintain about you:

Shine the Light	California residents are entitled to request and obtain from ADWAKE a list of all the third parties to which we have disclosed certain Personal Data (as defined by California´s Shine the Light Law) during the preceding year for those third parties´ direct marketing purposes. To request this information, please contact us at privacy@adwake.ai. In the subject of the email include “California Shine the Light Request” and include your mailing address, state of residence and email address so we can provide a response.
Privacy Rights for California Minors in the Digital World	If you are a California resident under the age of 18, and a registered user of our Website or app, you can request and obtain removal of content or information you have publicly posted. To make such a request, send an email with a detailed description of the specific content or information to privacy@adwake.aiPlease be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
California Individual Privacy Rights (California residents can exercise these privacy rights with respect to their Personal Data)	Right to Access Personal Data. You have the right to know (i) the categories of Personal Info we have about you; (ii) the categories of sources from which that Personal Data was collected (iii) Our business or commercial purpose for collecting, selling, or sharing your Personal Data (iv) the categories of third parties to whom we disclose Personal Data(v) the specific pieces of Personal Data we have collected about you.Right to Know What Personal Data is Sold or shared and to Whom. You have the right to know what Personal Data of yours is being sold or shared, and with whom. Right to Deletion: You have the right to request that we delete the Personal Data that we have collected or maintain about you. There may be circumstances under which we will be unable to delete such Personal Data, such as if we need to comply with our legal obligations. Right to Correct Inaccurate Personal Data. You have the right to request us if we maintain inaccurate Personal Data about you, taking into account the nature of this Personal Data and the purposes of the processing. To such extent, we shall use commercially reasonable efforts to correct the inaccurate Personal Data.Right to Opt Out of Sale or sharing your Personal Data. You have the “right to opt-out” of sale or sharing of your Personal Data. If you do not affirmatively opt out, and you are not a minor (under 16), your Personal Data may be sold as disclosed in this Privacy Policy. You can submit your request to opt out of the sale or sharing of your Personal Data by completing our “California Right to Opt-Out of the Sale or Sharing Personal Data” request form available here.Right to Limit Use and Disclosure of Sensitive Personal Data. You have the right to limit, at any time, the use and disclosure of your sensitive Personal Data, except when we use such Personal Data in a way reasonably expected by an average consumer.For information purposes, “sensitive Personal Data”  includes any private information that divulges any of the following: i) personal identification numbers, including social security, driver’s license, passport, or state ID card number; ii) account or debit or credit card numbers combined with passwords or codes that would enable access to the accounts; iii) a user´s exact geolocation; iv) a user’s racial origin, religious beliefs, or union membership; v) a user’s mail, email, or text message content unless the information was intentionally sent to the business; a user´s consumer’s genetic data, such as DNA simples; vi) the processing of any biometric data to identify a consumer, and vii) Personal Data concerning a user’s health or sexual orientation.Right of No Retaliation. If you choose to exercise any of these rights, Entravision will not discriminate against you in anyway.

To exercise your California rights, complete our “California Consumer Request” form available here.

If we are unable to comply with your requests, we will let you know the reason why.

We will take steps to verify your identity before processing your request, which may include requesting information from you to match with information we already have about you. 

You can also make a subject access request by mail, by sending a written request with all of the above-listed information to the following address:

Data Protection Officer
ADWAKE
C/ Diputació 303 Tercera Planta
08009 Barcelona
Spain

You also have the right to lodge a complaint with our Data Protection Supervisory Authority, the Agencia Española de Protección de Datos (Spanish Agency for Data Protection) at www.aepd.es. 

14. YOUR CONSUMER PRIVACY CHOICES

• Update your Personal Information. You may update your Personal Information by contacting us using the information in the “Contact Us” section below, submitting a support request in the App, or by contacting us at privacy@adwake.ai.
• Delete Your Account. If you no longer wish to use the Services or access your account or account information, you may request us to delete your account by submitting a support request in the App or by contacting us at privacy@adwake.ai. This will result in the full, permanent deletion of your account and associated information (except information retained for fraud prevention or legal compliance purposes), and you will no longer be able to use the Service and will lose any of the points you have earned but not yet redeemed. We will not be able to recover your account after it has been deleted. ALL ACCOUNT DELETIONS ARE FINAL AND CANNOT BE UNDONE. YOU WILL ALSO NOT BE ABLE TO CREATE OR VERIFY ANOTHER ACCOUNT ON THE SERVICE.
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:

• Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance: https://optout.aboutads.info, which lets you opt-out of interest-based ads on websites.
• AppChoices mobile app: available at https://www.youradchoices.com/appchoices, which lets you opt-out of interest-based ads in mobile apps.
• Opt Out of Marketing Messages. If you sign up to receive marketing communications and materials, you consent to receive such communications at the location or contact information you provide.

• Email. If you no longer wish to receive email marketing messages from Playback, you should use the “unsubscribe” option that can be found in each marketing email we send or contact us using the information provided below. Within 10 days of receipt of your unsubscribe request, we will remove you from our distribution list unless you resubscribe.
• Push Notifications. You may elect to receive push notifications from the App. If you wish to no longer receive push notifications, you may adjust your notification settings in your App account or through your mobile device’s notifications settings page.
• Global Privacy Control. You may opt out of the sale or sharing of your Personal Information by broadcasting a Global Privacy Control (“GPC”) signal, an opt-out preference signal, using a browser and/or browser extension that supports the GPC signal. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Adjust your Cookie Consent Preferences

15. LEAVING OUR WEBSITE AND/OR LINKING TO THIRD PARTIES

We strive to ensure that any information you send us is safe. When you leave this Website and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that we do not represent either the third party or you if you enter into a transaction on the third-party website. Further, the privacy and security policies of the linked website may differ from those practiced by us. The inclusion of any link does not imply our endorsement of any other company, its website(s), or its product(s) and/or services(s). We are not responsible for the privacy practices or content of any other website.

16. LINKS 

This Site  or the app may include, display or display links to other websites for your convenience and information. Such websites may operate independently of us. These linked sites may have their own privacy policies, which we strongly encourage you to read when you visit them. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for the content of such websites, their use or their privacy practices.

17. HOW LONG IS THIS PRIVACY POLICY UPDATED?

This Policy may be updated periodically to reflect changes in our processing of personal data. We will post a prominent notice on the Site to notify you of any significant changes to our Policy and will indicate at the bottom of the Policy when it was last updated. 

Last update: March 2026. 

© 2026: Digital Media Technology, S.L.U - Reproduction in whole or in part is prohibited. All rights reserved.

Email: help@playbackrewards.com