Privacy policy

Last updated December 29, 2025
Effective Date: January 5, 2026

This version of this Privacy Policy will enter into force on January 5, 2026.

Until that date, the current version of the Privacy Policy continues to apply to your use of the Website and Application. You may review the current version here: https://pawns.app/privacy-policy-08-01-2025

If you access or use the Website or Application on or after January 5, 2026, this updated version will apply to your use from that date onward.

You are encouraged to review this updated version in advance and decide whether you wish to continue using Pawns.app under the updated terms. If you do not agree with the updated Privacy Policy, please refrain from installing or using the Application, stop accessing the Website or Dashboard, remove the Application from your devices, and do not provide content or personal data through our services.

This Privacy Policy explains how Pawns.App Ltd (“Pawns”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal data when you use the Pawns mobile application and the https://pawns.app/ website (together referred to as the “Website” and the “App”), and any related features, content, communications (including emails), or other online or digital functionalities that we make available.

By accessing or using the Website and/or App, or by otherwise confirming your acceptance of this Privacy Policy where we ask you to do so, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Website or the App.

If this Privacy Policy is provided in a language other than English, the English version shall prevail in case of any inconsistency or dispute regarding interpretation.

1. General Provisions and Definitions 

1.1 Company Information

Pawns.App Ltd is a company incorporated in England and Wales under Company number 16043795, with its registered office at c/o Tax Partners, 60 Gray’s Inn Road, London, WC1X 8LU, United Kingdom.

1.2 How to Contact Us

If you have questions about this Privacy Policy or about how we process personal data, you can contact our designated privacy contact point at legal@pawns.app.

You may also reach us through the on-site chat function available on the Website or by writing to our registered office address provided above.

1.3 Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or operational needs.

• Non-material updates (such as editorial changes or clarifications that do not affect your rights) become effective once published on the Website and/or the App.
• Material changes (such as changes to how we use personal data, what data we collect, or how we share personal data) will take effect only after we provide prior notice through appropriate means, which may include email (where feasible), notices within the App, and/or announcements on the Website.

The latest version of this Privacy Policy will always be available at: https://pawns.app/privacy-policy/.

If you do not agree with an updated version, you should stop using the Website and/or App. You may also exercise any rights available to you under applicable data protection law, including the right to request deletion of your personal data.

1.4 Relationship to the Terms of Use

Your use of the Website and the App is governed by our Terms of Use (the “Agreement”), available at https://pawns.app/terms-of-use/.
This Privacy Policy should be read together with the Agreement. Nothing in the Agreement limits any rights you may have under applicable data protection law. Where consent is required for specific processing activities, we will request it separately.

1.5 Users Covered by This Privacy Policy

This Privacy Policy applies to any natural person who accesses or uses the Website or the App (the “user”, “you”, or “your”), including users who browse the Website without creating an account.

1.6 Functionalities of the App

The App provides access to certain optional features (collectively, the “Functionalities”), including:

• “Surveys” – optional activities within the App that may involve providing information, opinions, or feedback in response to survey questions delivered through third-party partners.
• “Offers” – optional in-application features made available by Pawns, which consist of activities provided by third-party partners, such as games, tasks, or other activities that users may choose to participate in.

A general description of currently available Functionalities is provided on the Website. Functionalities may be added, modified, or removed from time to time.

The App may include an optional Profile Survey that allows you to provide certain information. Completing the Profile Survey may help ensure that Surveys are shown to you in a more relevant manner based on the information you choose to provide.

Third-party partners may also ask additional eligibility questions within their own environments, which they collect and process under their own terms and privacy policies.

1.7 Principles of Personal Data Processing

We process personal data in accordance with the data protection laws that apply to us, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Additional protections may apply depending on your location, as described in this Privacy Policy.

In particular, we process personal data:

• lawfully, fairly, and in a transparent manner;
• for specified, explicit, and legitimate purposes;
• only to the extent necessary for those purposes;
• ensuring personal data is accurate and kept up to date;
• for no longer than is necessary;
• with appropriate technical and organisational measures to ensure integrity, security, and confidentiality.

1.8 Applicable Definitions Under the UK GDPR

Terms used in this Privacy Policy but not defined herein (such as “personal data”, “processing”, “controller”, or “processor”) have the meanings given to them in the UK GDPR.

2. Applicability

2.1 Applicability of This Privacy Policy

In addition to the users described in Section 1.5, this Privacy Policy also applies to individuals acting in a business capacity when their interactions with Pawns relate to our Website, App, Functionalities, or other aspects of our business operations.

2.2 Children’s Data

Pawns does not knowingly collect or process personal data from children. Our Website and App are not intended for children who are below the minimum age required to consent to the processing of personal data for online services in their country of residence.

If we become aware that we have collected personal data from a child without the legally required consent of a parent or guardian, we will promptly delete such data.

If you are a parent or legal guardian and believe that your child has provided us with personal data, please contact us at legal@pawns.app. 

2.3 Representatives of Legal Persons

Where you engage with Pawns on behalf of a company, organisation, or other legal person, we may process your personal data for purposes such as maintaining the business relationship, managing communications, and fulfilling contractual or operational requirements. This may include basic contact details and related information.

2.4 Voluntary Provision of Personal Data

You are not required to provide personal data to Pawns. However, if you choose not to provide certain information, we may be unable to provide you with access to some or all of the Functionalities or to ensure the proper operation of the Website or the App.

3. Controller, its Obligations and Scope 

3.1 Role as Data Controller and Data Processor

Pawns.App Ltd is the data controller for the personal data described in this Privacy Policy. This means that Pawns determines the purposes and means of processing your personal data.

In some circumstances, Pawns may act as a data processor, for example when processing personal data strictly on behalf of another organisation and in accordance with their written instructions. Where Pawns acts as a processor, the processing will be governed by a valid data processing agreement that meets the requirements of applicable data protection law.

When you choose to participate in Surveys, Offers, or other activities provided by third-party partners, those partners collect and use your personal data under their own terms and privacy policies. Pawns is not responsible for how these partners handle your personal data once you leave the Pawns environment or interact with them directly. Partners are responsible for their own processing activities under their privacy policies. We encourage you to review the applicable privacy policies of any partner before participating in their activities.

3.2 Scope of Processing

This Privacy Policy applies to the processing of personal data by Pawns as a controller, regardless of whether the data subjects are located inside or outside the United Kingdom.

3.3 International Transfers of Personal Data

Your personal data may be transferred to and processed in countries whose data protection laws may differ from those in your country of residence.

When we transfer personal data internationally, we do so in accordance with the requirements of applicable data protection law. Depending on the circumstances, this may involve relying on an adequacy regulation, entering into standard contractual clauses or other contractual safeguards, or applying specific derogations permitted by law.

You may contact us at legal@pawns.app for more information about international transfers or the safeguards we rely upon.

3.4 Records of Processing Activities

Pawns maintains records of its processing activities where required by applicable data protection law. These records describe the categories of personal data processed, the purposes of processing, the categories of recipients, and other elements necessary to demonstrate compliance with applicable data protection law.

3.5 Data Breach Notification

Pawns implements technical and organisational measures intended to protect personal data against unauthorised access, loss, alteration, or disclosure. However, no system can be guaranteed to be fully secure, and personal data breaches may occur.

If Pawns becomes aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required by applicable law, within the applicable statutory timeframe.

Where the personal data breach is likely to result in a high risk to your rights and freedoms, Pawns will also notify the affected users without undue delay, providing information about the nature of the breach, its potential consequences, and the measures taken or proposed to mitigate possible adverse effects.

3.6 Agreements with Data Processors

When Pawns engages third-party service providers to process personal data on its behalf, those providers act as data processors and may process personal data only in accordance with Pawns’ documented instructions. Pawns uses appropriate contractual or other safeguards with processors, as required by applicable data protection law.

4. Data Categories and Sources 

4.1 Overview

Pawns processes personal data that you provide directly when you create or use an account, use the Website or the App, contact us, or otherwise communicate with us. We may also collect certain data automatically when you access the Website or the App, as described in this Section.

Where we receive personal data from third parties (for example, payment providers or authentication providers), we process it only for the purposes described in this Privacy Policy or as otherwise notified to you at the time.

Pawns does not access or store the detailed answers or response content you provide within Surveys, Offers, or other third-party activities. Those responses are collected and processed by the respective third-party partners under their own privacy policies. We may receive limited information from partners (for example, whether your participation was completed and whether a reward is due) to operate the App.

For clarity, the optional “Profile Survey” described in Sections 1.6 and 4.2.6 is provided by Pawns within the App and is not part of third-party Surveys or Offers.

4.2 Data You Provide Directly

4.2.1 Contact and account data

When you create or manage an account, or when you contact us, we may process basic account and contact details, such as:

• email address;
• internal account identifier;
• registration date and account status;
• login timestamps and related account records.

Your email address is required to operate your account and to send service-related communications. We may also send optional updates where permitted by law and subject to your preferences. You can opt out at any time.

4.2.2 Financial and payout data

If you request a payout, we may process limited financial data necessary to complete the transaction, such as:

• payout method and account identifier (e.g., PayPal email address or cryptocurrency wallet address, where applicable);
• transaction ID and payout history;
• limited payment service provider information needed to confirm or process the transaction.

Payment or payout service providers process your information under their own terms and may use it for purposes such as completing the transaction or meeting their legal obligations.

We do not store full payment card numbers or other sensitive payment credentials.

4.2.3 Support interaction data

If you contact our support team, we may process:

• the content of your messages;
• related correspondence necessary to respond to your request.

4.2.4 Third-Party Authentication Data (Google and Apple)

If you choose to sign in to the Pawns Website using a third-party authentication provider (such as Google or Apple), Pawns receives the information made available by the provider in accordance with the permissions you grant and the authentication method used. This may include:

• your email address;
• your name (where provided by the provider);
• a basic identifier used to verify your Google or Apple account;
• your profile image (Google only, where applicable).

Pawns does not receive your password, phone number, or access to your full Google or Apple profile. The information received through social login is used solely for authentication, account creation (where applicable), and account management.

4.2.5 Verification Data (Phone Number)

In certain cases, we require phone number verification via SMS to help protect the service and reduce misuse and fraud, including in connection with payouts.

SMS verification is required for all users who request a payout, before the payout can be processed, and for new users located in the United States, regardless of whether a payout is requested at that time. Existing users located in the United States are not required to verify just because they are existing users. SMS verification will be required if a payout is requested.

When SMS verification is triggered, we ask you to provide your phone number. Our systems generate a one-time verification code, which is sent to you via SMS. You enter the code in the App or on the Website to complete verification.

For verification purposes, the country code of the phone number provided must correspond to the country determined by Pawns in connection with your account or access to the App or Website (for example, based on technical information such as IP address).

Where this correspondence cannot be established, SMS verification may not be completed and the related action (such as payout processing) may be unavailable until a compliant phone number is provided.

For SMS verification, we may process the following personal data, which may include:

• phone number;
• one-time verification code, together with its creation and expiration time;
• verification status (e.g., verified / not verified);
• limited technical and security records related to the verification attempt (such as timestamps).

Our SMS delivery provider acts only as a communications intermediary that transmits the SMS message and may provide delivery status and related technical logs. The provider does not perform verification decisions. Verification is completed in our systems based on whether the correct code is entered. We maintain the phone number and verification status in our own systems.

Verification codes are time-limited and are used solely for the verification process. We do not use your phone number for marketing communications.

4.2.6 Profile Survey Data

The App may offer an optional Profile Survey to help identify Surveys or Offers that may be more relevant to you. The Profile Survey may include information that you choose to provide, such as your age or date of birth (where provided), your general location (such as region), your education level, employment status, household characteristics, or other relevant information. The specific questions may vary depending on factors such as your country or our partners’ requirements.

Where possible, we store your responses using internal question and answer identifiers rather than free-text responses (for example, by associating your account with internal identifiers that represent specific questions and response options). This information helps us suggest Surveys that may be suitable for you.

To support the availability and operation of Surveys within the App, we may share limited Profile Survey-related information with third-party partners that provide Surveys. This may include internal identifiers associated with your account together with internal question and answer identifiers, which enable partners to assess whether their Surveys may be appropriate to offer, without receiving your original response text.

In limited cases, and only where strictly necessary for operational purposes required by a specific Survey partner, we may share your email address in an encoded (for example, hashed or otherwise pseudonymised) form to help manage eligibility or prevent repeated participation. 

In exceptional circumstances where a partner requires a non-encoded version of the email address for these same purposes, it may be shared only to the extent strictly required and where we have no reasonable alternative. Any such use of your email address is restricted to these purposes and is handled in accordance with the partner’s privacy policy.

We retain Profile Survey information for as long as needed to suggest relevant Surveys and to support the operation of the App.

If you prefer that this information is not used in this way, you should refrain from completing the Profile Survey and from participating in Surveys.

Any information collected or processed by third-party partners within their own environments, including any additional eligibility questions or responses you provide directly to them, is handled in accordance with their respective privacy policies.

4.2.7 Review invitation data

After you use the Website and/or the App, we may process limited personal data in order to invite you to provide feedback or leave a review on independent review platforms. This data may include your name and email address associated with your account. The purpose of this processing is to collect genuine user feedback and improve the quality of the Website, the App, and the Functionalities. Review invitation data is transmitted via third-party tools used to support the review invitation workflow and is stored only for as long as necessary for the invitation process. Review invitations are sent primarily to request feedback about service quality and user experience, and are not intended as promotional marketing.

4.3 Identity Verification Data

Identity verification may be required in certain cases (e.g., suspicious activity, specific payout requirements, or legal obligations).

Verification is performed by our third-party provider, Idenfy UAB. As part of this process:

• you may be asked to provide verification data directly to Idenfy;
• Pawns receives only the verification result (e.g., verification successful / unsuccessful).

In exceptional cases, authorised Pawns personnel may view identity information stored within our identity verification provider’s system when necessary to verify an account or investigate suspected misuse. Pawns does not store copies of such documents in its own systems.

For details about Idenfy’s processing, see: https://www.idenfy.com/privacy-policy/.

4.4 Data We Collect When You Use the Website or App

4.4.1 Usage data

We collect limited usage information necessary to operate and secure your account and the App, such as:

• session date and time;
• duration of use;
• basic activity indicators necessary for service operation and security.

When you use the Website, certain browsing information may also be collected through cookies and similar technologies, as described in Section 13.

4.4.2 Technical and log data

This may include:

• IP address and inferred approximate location (such as country or region);
• device ID and type, operating system, and browser information;
• internal identifiers and security log records;
• unique identifiers associated with your device or operating system (for example, identifiers used for app functionality, analytics, or security purposes);
• data related to login attempts, account creation, and session validity.

4.4.3 Cookies and similar technologies

We use cookies and similar technologies on the Website for various purposes. Details are provided in Section 13.

4.4.4 Location data

The App may collect approximate location information (such as country or region) when you grant the relevant device permission. Approximate location is used primarily to determine your eligibility for certain Surveys, Offers, or other location-dependent Functionalities.

Pawns does not intentionally collect or store precise (GPS-level) location data. Precise location could be used only if you choose to grant the relevant device permission and only in exceptional cases where it is necessary to diagnose a technical issue or ensure proper service operation.

You can adjust or withdraw location permissions at any time through your device settings. The App does not collect location data if you deny the location permission.

4.4.5 Mobile Identifiers and App Activity Data

The App may use mobile identifiers and technologies provided by your device, operating system, or third-party service providers. These technologies may support functions such as maintaining App performance, preventing misuse, determining whether certain in-App activities have been completed, or helping us understand general usage patterns. We may use limited activity and technical information (such as device identifiers, event logs, or anonymous event IDs) to help operate the App, measure usage, and detect misuse. Depending on your device and platform settings, certain identifiers made available by your device or operating system may be used for purposes such as analytics, measuring App installs, confirming whether certain in-App actions have occurred, security, and preventing misuse. On platforms that require permission for the use of certain identifiers (for example, iOS), we will request your consent where applicable.

4.5 Data Relating to Business Contacts

If you interact with Pawns for business-related purposes, we may process:

• basic identification and business contact details (name, business email, role);
• contractual and communication data necessary to manage the relationship;
• financial or billing information where applicable.

4.6 No Access to Personal Device Content

The App is not intended to access or read the personal content stored on your device, such as your contacts, photos, videos, messages, or other personal files, except where you actively choose to share such content with us (for example, if you attach a screenshot when contacting support). Access to your device’s location is requested only if you choose to grant the relevant permission and is used solely for the purposes described in this Privacy Policy.

4.7 Permissions and Device Settings

The App respects your device’s permission settings and does not attempt to bypass or override them. Some permissions are optional, and core account features generally remain available even if optional permissions are not granted.

4.8 Sources of Personal Data

Depending on how you interact with Pawns, we may obtain personal data from the following sources:

• Directly from you, for example when you register, use the App, or contact support (see Sections 4.2 and 4.5);
• Automatically collected data, such as technical logs and usage information when you use the Website or App (see Section 4.4);
• Identity verification provider, which provides us with verification results where verification is required (see Section 4.3);
• Payment and payout providers, which may share limited information about transaction status;
• Third-party authentication providers, such as Google or Apple, where you choose to use social login (see Section 4.2.4);
• Social media platforms, when you interact with our official pages (see Section 6).

We do not use external sources to build detailed profiles about you beyond what is described in this Privacy Policy.

5. Purpose and Legal Basis

Pawns processes personal data only where a valid legal basis applies under applicable law. We collect and process only the personal data necessary for the relevant purposes and features of the App.

If Pawns requests personal data not described in this Privacy Policy, we will inform you of the purpose and legal basis for such processing at the time the data is collected.

5.1 Performance of a Contract

We process personal data where it is necessary to perform the Agreement between you and Pawns or to take steps at your request before entering into the Agreement.

This includes:

• creating and managing your account;
• providing the core functionality and technical operation of the Website, the App, and your account; 
• authenticating your identity and enabling access to your account when you sign in using Google or Apple.

5.2 Consent

We rely on your consent only where required by law or where consent is the appropriate legal basis.

Pawns may request your consent:

• before placing non-essential cookies or similar tracking technologies;
• before processing audio, video, or photographic content that identifies you (for example, your image) for marketing or representational purposes;
• before using optional permissions (such as location access or other permissions that you may choose to enable through your device’s operating system). 

Where processing is based on consent, it will occur only for the purposes described at the time consent is requested.

You may withdraw your consent at any time with effect for the future. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

5.3 Compliance with Legal Obligations

We process personal data where necessary to comply with legal obligations, including:

• maintaining accounting, tax, and financial records;
• responding to lawful requests from courts, regulators, or law enforcement authorities;
• meeting record-keeping and compliance requirements under applicable law;
• establishing or defending legal claims where required by law.

5.4 Legitimate Interests

Pawns may process personal data where it is necessary for the legitimate interests of Pawns or a third party, provided such interests are not overridden by your rights and freedoms.

Our legitimate interests include:

Ensuring proper operation of the Website, the App, and the Functionalities:

• making sure the Functionalities of the Website and the App work properly and as intended.

Security, misuse prevention, and service integrity beyond what is strictly necessary to deliver the service:

• detecting, preventing, and investigating fraud, misuse, or suspicious activity by analysing account activity patterns;
• preventing automated misuse and ensuring genuine user activity;
• maintaining the security and integrity of our systems, accounts, and the App.

Service operation and improvement in a way that does not disproportionately affect your privacy, for example by using aggregated or pseudonymised information where possible:

• identifying and fixing bugs or errors;
• monitoring and analysing service performance and reliability;
• reviewing aggregated or anonymised usage trends to improve the App.

Customer service and communication:

• responding to general user inquiries that are not directly related to the performance of the Agreement;
• sending non-essential operational and non-promotional updates (not marketing).

Limited marketing communications:

• sending service-related communications and, where permitted by law (for example, to existing users who have not opted out), occasional information about updates or services that may be of interest. Every such email includes a clear and easy way to unsubscribe. 

Customer feedback and quality improvement:

• sending review or feedback invitations to users who have used the Website and/or the App in order to collect genuine feedback and improve the Website, the App, and the Functionalities. These invitations are sent primarily to request feedback about service quality and user experience and are not intended as promotional marketing.

Legal rights and claims:

• establishing, exercising, or defending legal claims that are not based on a legal obligation.

When relying on legitimate interests, we consider the potential impact on your privacy and take steps to limit or minimise the use of personal data where reasonably possible.

5.5 Processing of Publicly Available Data

Where you intentionally make personal data publicly available (such as through public comments on our social media pages), Pawns may process such data to the extent permitted by applicable law and only where relevant to the purposes described in this Privacy Policy.

5.6 No Processing for Unrelated Purposes

We do not process personal data for purposes other than those described in this Privacy Policy unless permitted by law or you provide additional consent. If we intend to use personal data for a new purpose that is incompatible with the original purpose, we will inform you in advance and obtain consent where required.

6. Social Media

6.1 Pawns’ Social Media Presence

Pawns maintains official pages on various social media platforms to communicate with users, potential users, and the wider public. When you visit or interact with our social media pages, the privacy policies and terms of the respective platform providers also apply. These providers may independently process your personal data, including outside your country of residence, in accordance with their own practices. Pawns does not control this processing.

The list of our current social media profiles is available through the social media icons displayed on our Website.

6.2 Data Processing on Social Media Platforms

When you visit or interact with our pages on social media platforms, the platform provider may collect and process information about your activity in accordance with its own terms and privacy policies. Pawns does not control how social media platforms collect, use, or share data about you.

We may receive aggregated or statistical information from some platforms (for example, general data about visits or interactions with our page), which helps us understand how users engage with our content. This information does not allow us to identify you directly.

For details on how each platform processes your data and how you can exercise your rights with them, please refer to the privacy policy of the relevant platform.

6.3 Communications via Social Media

If you contact us through social media (for example, using direct messages or public comments), we may process the information you provide for the purpose of responding to your inquiry. For account-related or sensitive matters, we recommend contacting us directly at hello@pawns.app or through the communication tools available on the Website, as social media messaging channels may involve reduced confidentiality.

7. Third-Party Websites and External Services

7.1 Third-Party Websites and Services

The Website and the App may contain links or provide access to third-party websites, platforms, services, or content that are not operated or controlled by Pawns. When you follow such links or interact with external services, the collection and processing of your personal data is governed solely by the privacy policies and terms of those third parties. Pawns does not control and is not responsible for the privacy practices, security standards, or content of these third-party services.

We encourage you to review the applicable privacy policies of any third-party service before providing personal information or engaging with their features.

When you use a social login option (such as “Sign in with Google” or “Sign in with Apple”), you are redirected to the provider’s environment to authenticate. Pawns does not have access to the information you enter on the provider’s login page (such as your password). Pawns only receives limited account information necessary to authenticate your account, as described in Section 4.

7.2 No Endorsement or Responsibility

The inclusion of links or access to external services within the Website or the App does not constitute an endorsement, recommendation, or verification by Pawns. Except where required by applicable law, Pawns is not responsible for the privacy practices, security, or content of third-party websites or services. Your use of such services is subject to their own terms and privacy policies.

7.3 Security Precautions

When using external websites or services, be careful when submitting personal or account-related information. If you are unsure whether a communication, website, or service is associated with Pawns, you may contact us at hello@pawns.app for verification.

8. Your Rights

Depending on your location and the laws that apply to Pawns, you may have certain rights regarding your personal data. Pawns will facilitate the exercise of these rights to the extent required by applicable law and to the extent such laws apply to us.

The availability and scope of these rights depend on the data protection laws that apply to your personal data and on the legal basis on which we process it. Not all rights listed below apply in every situation or to every user.

8.1 Right to Withdraw Consent and Right to Object

Where we rely on your consent to process personal data, you may withdraw that consent at any time.
Where we rely on our legitimate interests, you may object to the processing of your personal data on grounds relating to your particular situation.

You may opt out of receiving marketing communications at any time by:

• clicking the “Unsubscribe” link included in any marketing email we send;
• adjusting your marketing preferences in your account settings on the Website or in the App (where available); or
• contacting us at hello@pawns.app. 

Where applicable, you may also withdraw certain optional consents (for example, analytics or tracking) through in-app privacy settings, through the settings available on the Website, or through your browser or device settings. Withdrawing consent or changing your preferences will not affect the lawfulness of processing carried out before the withdrawal. 

8.2 Right to Information and Access

You have the right to request confirmation as to whether we process your personal data and, if so, to receive a copy of your personal data and certain other information about how we process it.

8.3 Right to Rectification

If any of your personal data is inaccurate or incomplete, you have the right to request correction or completion of that data.

8.4 Right to Erasure (“Right to Be Forgotten”)

You may request the deletion of your personal data in certain circumstances, including where:

• the data is no longer necessary for the purposes for which it was collected;
• you withdraw consent and no other legal basis applies;
• you object to processing and no overriding legitimate grounds exist;
• the data has been unlawfully processed; or
• erasure is required to comply with a legal obligation.

You may delete your account at any time through the App or by contacting us at hello@pawns.app. 

Please note that deleting your account may prevent us from providing you access to the App’s Functionalities and to features available through the Website. 

8.5 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data where:

• you contest the accuracy of the data;
• the processing is unlawful and you prefer restriction over deletion;
• the data is no longer needed for our purposes but is required for legal claims; or
• you have objected to our processing and we are assessing whether we have legitimate grounds to continue.

8.6 Right to Data Portability

Where processing is based on your consent or on a contract and carried out by automated means, you may have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit that data to another controller where technically feasible and where this does not affect the rights of others.

8.7 Rights Relating to Automated Decision-Making

Pawns uses automated processing and limited profiling for service-related purposes, including determining eligibility for Surveys or Offers (for example, by categorising users based on country or other basic account attributes) and detecting or preventing fraudulent, suspicious, or abusive activity.

This processing is carried out to provide and operate the services available through the App and the Website, and to protect their integrity and security. The lawful basis for this processing is Pawns’ legitimate interests in providing and safeguarding its services and, where applicable, the performance of a contract with users.

Pawns’ automated processing and profiling is not intended to produce legal or similarly significant effects for users within the meaning of applicable data protection laws. Where such processing contributes to decisions or actions by Pawns that may affect users’ access to, or use of, the App or the Website, appropriate safeguards are applied, including human involvement where appropriate and consideration of the relevant circumstances.

Where automated decision-making within the meaning of applicable data protection laws were to apply, users would have the right to request human intervention, to express their point of view, and to contest the decision. Users also have the right to object to processing carried out on the basis of Pawns’ legitimate interests.

8.8 Right to Lodge a Complaint

If you believe that your personal data has been processed in violation of applicable law, you have the right to lodge a complaint with the supervisory authority that is competent for the processing of your personal data. In the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO). Information is available at: https://ico.org.uk/.

We encourage you to contact us first at legal@pawns.app, and we will do our best to resolve your concerns.

8.9 How to Exercise Your Rights

You may exercise any of the rights described in this Privacy Policy by contacting us at legal@pawns.app or by writing to:

Pawns.App Ltd
c/o Tax Partners
60 Gray’s Inn Road
London, WC1X 8LU
United Kingdom

We will respond to your request within one month of receipt. Where permitted by applicable law, this period may be extended if your request is particularly complex or if we receive multiple requests.

8.10 Identity Verification for Rights Requests

To protect your personal data, Pawns may request reasonable additional information (such as limited identification details) when necessary to verify your identity before fulfilling certain rights requests under applicable data protection laws. Any such information will be processed only for verification purposes and will be deleted once the verification process is complete.

8.11 Fees

You will not be required to pay a fee to exercise your rights unless your request is clearly unfounded, repetitive, or excessive. In such cases, we may charge a reasonable fee or refuse to act on the request.

9. Data Security

Pawns implements appropriate technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration, or destruction.

9.1 Secure Communication

We use secure encryption technologies (such as TLS) to help protect data transmitted between your device and our services.

9.2 Access Management and Personnel Responsibilities

Access to personal data is limited to employees, contractors, agents, and service providers who have a legitimate business need to access it. Such personnel are required to process personal data only in accordance with Pawns’ instructions and are subject to confidentiality obligations. Access controls are implemented to help ensure that personal data is available only to those who require it for their duties.

9.3 Infrastructure and Hosting

Our services are hosted by third-party providers that are required to maintain technical and organisational measures designed to protect the security and reliability of their infrastructure. 

9.4 Third Parties

Where we engage third parties to support the operation of the App or the Website, such third parties are required to implement appropriate technical and organisational measures and to process personal data only in accordance with Pawns’ documented instructions.

9.5 Application Security and Maintenance

We take reasonable steps to keep the App, the Website, and our systems updated and secure. This may include applying patches and implementing upgrades where appropriate.

9.6 Incident Management

If we become aware of a security incident involving personal data, we will investigate the matter and take reasonable steps to mitigate any potential adverse effects. Where required by applicable law, we will notify the relevant supervisory authority and affected users.

9.7 User Responsibilities

We encourage users to take reasonable steps to protect their accounts and devices, such as using strong passwords, keeping software up to date, and avoiding the use of unsecured networks.

9.8 Device Resource Use

The App is designed to use device resources (such as battery, CPU, and data) in a way that is consistent with normal application operation. It is not intended to run unnoticed or to consume device resources in a way that is disproportionate to its features. 

10. Recipients of Personal Data

10.1 Internal Recipients

Your personal data may be accessed within Pawns only by those employees, contractors, or other authorised personnel who require such access to perform their duties. This may include activities such as customer support, service delivery and operations, or the maintenance and improvement of our services. 

10.2 Service Providers (Data Processors)

We engage certain third-party service providers to support the operation of the Website and the App. These providers act as data processors and may process personal data only in accordance with Pawns’ instructions and subject to confidentiality obligations.

These processors may assist with:

• data hosting and cloud infrastructure;
• IT and security services;
• customer support;
• analytics and performance monitoring;
• marketing and communication tools;
• accounting and payment facilitation;
• supporting user feedback collection and review invitation workflows;
• professional advisory services such as legal, audit, or insurance support.

Processors receive only such information as is necessary to perform their services and may not use personal data for their own purposes.

10.3 Survey and Offer Partners

If you choose to participate in Surveys or Offers, some information may be shared with the third-party partners that provide these activities. These partners are responsible for their own use of any personal data they collect from you or process as part of your participation. Any such processing is subject to their own privacy policies, which we encourage you to review before participating. 

To support the availability and operation of Surveys within the App, we may share limited information with Survey partners, as described in Section 4.2.6. Partners use this information to determine whether their Surveys may be appropriate to offer. Any personal data processed by partners within their own environments is handled in accordance with their respective privacy policies.

10.4 Legal and Regulatory Disclosures

We may disclose personal data where required or permitted by law, including where necessary to:

• comply with legal obligations, court orders, or regulatory requests;
• prevent or investigate suspected unlawful activity, fraud, or security incidents;
• establish, exercise, or defend legal claims;
• protect Pawns, our users, or the public from harm.

Such disclosures are made only to the extent permitted by applicable law.

10.5 Business Transfers

We may transfer your personal data in connection with a corporate transaction, such as a merger, acquisition, restructuring, reorganisation, or sale of assets.
If such a transaction occurs, the acquiring or successor entity will be permitted to use your personal data only in accordance with this Privacy Policy or as otherwise permitted by applicable law.

10.6 Disclosures at Your Request or With Your Consent

We may share your personal data where you request or authorise us to do so, for example when you ask us to transmit information to another service or provider. In such cases, we will disclose information only in accordance with your request or consent.

10.7 Independent Review Platforms

When you choose to leave a review on an independent review platform, that platform processes your personal data under its own terms and privacy policy. 

11. Retention Period

We apply retention practices designed to ensure that personal data is kept only for as long as necessary for the purposes described in this Privacy Policy or as required by applicable law. After that period, the data is deleted or otherwise handled in a manner that prevents further use.

The specific retention period depends on the type of personal data and the purpose for which it is processed.

When determining how long to retain personal data, we take into account:

• the amount, nature, and sensitivity of the data;
• the potential risk of harm from unauthorised access, use, or disclosure;
• the purposes for which the data is processed and whether those purposes can be achieved through other means;
• applicable legal, regulatory, tax, accounting, or reporting requirements; and
• our operational needs and the need to maintain appropriate records, including for the establishment, exercise, or defence of legal claims.

Unless a longer retention period is required or permitted by law, we generally apply the following principles:

11.1 Active Use

We retain your personal data for as long as your account remains active and you use the Website and/or the App.

11.2 Account Deletion

If you delete your account, we may retain certain personal data for a limited period where necessary for security, fraud-prevention, legal, or compliance purposes, or as otherwise required by applicable law.

11.3 Anonymised Data

We may retain anonymised or aggregated data (which no longer identifies you) for analytics, research, or other business purposes.

Once the applicable retention period has expired, personal data will be deleted, anonymised, or stored in a way that prevents further processing. 

12. Users in Various Jurisdictions

Privacy and data protection laws vary by jurisdiction. Depending on where you reside, you may have additional rights regarding your personal data, and we may be subject to additional obligations when processing such data.

You may contact us using the details provided in this Privacy Policy to request information or exercise your rights. We will review and respond to requests in accordance with applicable law and may request reasonable information to verify your identity and, where necessary, your place of residence.

13. Cookies and Similar Technologies

13.1 Use of Cookies and App Tracking Technologies

The Website uses cookies and similar technologies (“cookies”) to enable core functionality, enhance performance, understand how users interact with the Website, and support marketing activities. Where cookies are not strictly necessary for the operation of the Website, we will ask for your consent before placing them on your device.

The App may use certain technologies that rely on device-level or event-level information for various purposes, such as recognising your device, supporting App features, confirming whether certain in-App activities have been completed, or for other purposes consistent with this Privacy Policy. Where your device or platform requires permission to use particular technologies (for example, tracking permissions on iOS), we will request your permission where applicable. You can change or withdraw such permissions at any time in your device settings.

13.2 What Are Cookies

Cookies are small text files stored on your device when you visit a website. They allow the website to recognise your device and remember certain information about your visit.
In this section, the term “cookies” also refers to other technologies that function similarly by storing or accessing information on your device, where applicable.

Cookies may be:

• Session cookies: expire when you close your browser;
• Persistent cookies: remain on your device until deleted or until their set expiration date.

Cookies may also be:

• First-party cookies: set by Pawns;
• Third-party cookies: set by third parties whose services appear on our Website (e.g., analytics).

13.3 Categories of Cookies We Use

The Website uses the following categories of cookies. These reflect the purposes for which cookies are used and correspond to the consent options available in our cookie banner.

a) Necessary Cookies (Strictly Necessary)
These cookies are essential for the Website to function correctly. They enable core features such as page navigation, secure login, fraud prevention, and remembering your cookie consent settings.
These cookies are always active and do not require your consent.

b) Preference Cookies (Functionality)
These cookies allow the Website to remember choices you make, such as language preferences or regional settings, to provide a more personalised experience.

c) Statistics Cookies (Analytics)
These cookies help us understand how visitors use the Website by collecting information in an aggregated or de-identified form where possible. This allows us to improve the Website’s functionality, content, and user experience.

d) Marketing Cookies
These cookies track your browsing habits to provide more relevant advertising, measure campaign effectiveness, and support personalised marketing on our Website and third-party websites.

Some cookies may appear as “unclassified”. This means that their categorisation is still being determined by our consent management platform and will be updated once assessed.

13.4 Third-Party Cookies

Some cookies on the Website are set by third parties, such as analytics providers or embedded service providers (e.g., video hosting platforms).
These third parties may collect information about your browsing activities across websites, where applicable. Their processing of personal data is governed by their own privacy policies.

Some third-party cookies may involve international data transfers subject to appropriate safeguards.

You can view the most up-to-date list of cookies in use by opening the cookie banner on our Website and selecting “Details”, where Cookiebot displays and updates the cookies detected on your device.

Some advertising or analytics partners may use their own identifiers to measure the effectiveness of our advertising campaigns or to understand general engagement with our Website or App. These identifiers do not directly identify you to us.

13.5 Cookie Consent and Management

Our legal basis for using non-essential cookies is your consent. You can manage your cookie preferences at any time through the cookie banner or settings panel available on the Website.
Through this interface, you may:

• accept all cookies,
• reject non-essential cookies, or
• customise your preferences by category.

Withdrawing consent does not affect the lawfulness of processing carried out before such withdrawal.

13.6 Browser Settings

Most web browsers allow you to control cookies directly through browser settings, including blocking or deleting cookies.
Please note that blocking necessary cookies may impact the functionality of the Website and prevent certain features from working properly.13.7 Updates
Our use of cookies may change over time. The detailed cookie information available in the cookie banner (under “Details”) will always reflect the most current information provided by our cookie management platform.