Operated by REPLUG GmbH
Last Updated: 23.08.2026
This Privacy Policy explains how REPLUG GmbH collects, uses, discloses and protects personal data when you use Bento Rewards, including the Bento Rewards mobile application, website, reward programme, support services and related features (together, the “Platform”).
Please read this Privacy Policy together with the Bento Rewards Terms of Service and any privacy information presented for a particular Offer, Campaign Partner, permission or feature.
1. Data controller
The controller responsible for the processing described in this Privacy Policy is:
REPLUG GmbH
Oranienburger Str. 23
10178 Berlin
Germany
Commercial Register: Amtsgericht Charlottenburg, HRB 215435 B
Email: privacy@bento-rewards.com
In this Privacy Policy, “Bento Rewards,” “REPLUG,” “we,” “us” and “our” refer to REPLUG GmbH.
Some third parties involved in an Offer or Reward may process personal data for their own purposes as independent controllers. Their processing is governed by their own privacy notices as well as applicable law.
2. Scope and important definitions
This Privacy Policy applies to personal data processed through the Platform. It does not govern the independent processing activities of third-party applications, games, websites, advertisers, Campaign Partners or reward providers that you choose to use.
For purposes of this Privacy Policy:
- “Account” means your personal Bento Rewards account.
- “Advertising ID” means a resettable advertising or attribution identifier made available by your device or operating system.
- “Campaign Partner” means an advertiser, advertising network, offer provider, application or game publisher, survey provider, attribution provider or other third party involved in providing or validating an Offer.
- “Device ID” means a device, installation or app-instance identifier used by Bento Rewards or its service providers. It does not necessarily identify the hardware device permanently.
- “Offer” means an opportunity made available through the Platform to complete specified activities in return for Coins.
- “Reward Provider” means a third party that processes or fulfils a Reward redemption.
3. Sources of personal data
We obtain personal data from the following sources:
3.1. Directly from you
We receive information that you provide when you create or update an Account, participate in Offers, request a Reward, contact support, submit evidence or otherwise communicate with us.
3.2. From your device and use of the Platform
The Platform and its technical components generate information about the device, installation, network connection and Platform activity used to access the service.
3.3. From Campaign Partners and attribution providers
Campaign Partners, mobile measurement providers and attribution systems may provide information about Offer clicks, installations, registrations, purchases, gameplay milestones, survey completion, advertising engagement, refunds, chargebacks, rejection reasons and other campaign events.
3.4. From Reward Providers
Reward Providers may provide information about the status of a redemption, delivery, rejection, returned payment, compliance review or other fulfilment event.
3.5. From fraud-prevention, security and infrastructure providers
Our providers may generate or return technical, network, device-integrity, duplication, attribution or fraud-risk indicators used to protect the Platform and validate activity.
We do not currently require or collect government-issued identity documents, selfie images or biometric templates for Bento Rewards. If we introduce identity or biometric verification in the future, we will provide appropriate information and update this Privacy Policy before collecting that data.
4. Categories of personal data we process
Depending on how you use the Platform, we process the following categories of personal data.
4.1. Account and eligibility data
- Email address;
- username;
- country of residence;
- date of birth and age eligibility;
- Account creation date, Account status and settings;
- records of acceptance of the Terms of Service and Privacy Policy; and
- communication and notification preferences.
4.2. Device, app and technical data
- Device ID;
- Advertising ID;
- Expo push token;
- device model;
- operating system, operating-system version and app version;
- IP address;
- network and connection information;
- timestamps, session information and technical logs;
- app installation, app-instance and attribution information;
- security information made available by the Platform or its providers.
Device IDs, Advertising IDs and push tokens may change when a user resets an identifier, changes a device, reinstalls the app, changes app settings or when the operating system or provider rotates the identifier.
4.3. Location and territory data
We use IP addresses and related network information to infer an approximate country or region. We may compare this inferred territory with the country associated with your Account and the territory for which an Offer is available.
Bento Rewards does not collect precise GPS coordinates or continuously track your physical movements. IP-derived location can be inaccurate and is treated as a risk or eligibility signal rather than conclusive proof by itself.
4.4. Platform usage data
- Screens, features and Offers viewed or opened;
- clicks, interactions and navigation events;
- dates and times of activity;
- referral information;
- notification-delivery and interaction information; and
- support and account-management activity.
4.5. Campaign and attribution data
- Offer viewed, clicked, started or completed;
- click identifiers, campaign identifiers and publisher identifiers;
- installation and first-open information;
- registration, purchase, subscription, refund and chargeback events;
- game or app progress, milestones and event timestamps;
- advertising engagement and survey-completion events;
- attributed source, campaign and country;
- Coins associated with an event;
- partner validation, rejection or reversal status; and
- Campaign Partner rejection reasons or fraud indicators made available to us.
We normally receive campaign-event information rather than the complete contents of your activity inside a Campaign Partner’s app or service.
4.6. Coins, redemption and payment-destination data
- Coins earned, pending, held, reversed, expired or redeemed;
- redemption requests and history;
- selected Reward, amount, currency and delivery status;
- payment or Reward destination identifiers, such as a PayPal email address;
- Reward Provider transaction or reference identifiers; and
- returned, rejected or failed redemption information.
We do not normally receive full payment-card or bank-account credentials when a Reward Provider handles delivery directly.
4.7. Communications and support data
- Support requests and correspondence;
- information you provide to explain an Offer, Account or redemption issue;
- screenshots, receipts or other evidence you voluntarily submit;
- survey or feedback responses; and
- records of our response and resolution.
Please do not send identity documents, selfies, complete payment-card details or other sensitive information unless we specifically request it through an approved secure process.
4.8. Fraud-prevention and investigation data
We may create, receive and compare:
- risk indicators and risk scores;
- device-to-Account, identifier-to-Account and Reward-destination associations;
- changes or inconsistencies involving Device IDs, Advertising IDs, IP addresses, countries, installations, timestamps or attribution information;
- indicators of multiple Accounts, repeated Offers, manipulated attribution or duplicated campaign events;
- VPN, proxy, Tor, emulator, rooted-device, cloned-app or other device-integrity indicators where made available by our systems or providers;
- refund, chargeback and partner-rejection patterns;
- records of reviews, investigations, supporting evidence, decisions and appeals; and
- limited records necessary to prevent a suspended or terminated user from creating replacement Accounts.
A technical inconsistency does not automatically establish fraud. We review the available information and context before materially restricting an Account, rejecting a Reward or terminating access.
5. Why we process personal data and our legal bases
We process personal data only where we have a legal basis under applicable law.
| Purpose | Personal data generally involved | Legal basis under the GDPR |
|---|---|---|
| Create, authenticate and administer your Account | Account, Device ID, technical and usage data | Performance of the contract, Article 6(1)(b) |
| Determine age, country and Offer eligibility | Account, age, IP-derived territory, device and campaign data | Performance of the contract, Article 6(1)(b) |
| Present, attribute, track and validate Offers | Device ID, Advertising ID, IP-derived territory, click, installation and campaign-event data | Performance of the contract, Article 6(1)(b) |
| Calculate, credit, hold, reverse and display Coins | Account, campaign, attribution and Coin-ledger data | Performance of the contract, Article 6(1)(b) |
| Review and fulfil Reward requests | Account, Coin, redemption and payment-destination data | Performance of the contract, Article 6(1)(b) |
| Provide transactional and service communications | Email, Account, support and notification data | Performance of the contract, Article 6(1)(b), or our legitimate interests under Article 6(1)(f) for service and security notices |
| Detect and prevent multiple Accounts, manipulated attribution, location misrepresentation, invalid activity, abuse and fraud | Account, device, identifier, IP-derived territory, campaign, redemption and risk data | Our legitimate interests under Article 6(1)(f) in protecting users, partners, campaign budgets, Rewards and the integrity and security of the Platform |
| Secure, troubleshoot and maintain the Platform | Technical logs, device, network, crash, security and usage data | Our legitimate interests under Article 6(1)(f) in providing a secure, reliable service |
| Handle support, disputes and appeals | Account, communications, campaign, redemption and investigation data | Performance of the contract under Article 6(1)(b), and our legitimate interests under Article 6(1)(f) in resolving disputes and establishing or defending claims |
| Meet accounting, tax, sanctions, regulatory and other legal obligations | Account, transaction, redemption and compliance data | Compliance with legal obligations, Article 6(1)(c) |
| Send optional promotional messages or use optional analytics or similar technologies | Contact, push token, consent, device and usage data | Consent, Article 6(1)(a), where consent is required |
| Improve features and understand aggregated Platform performance | Usage, technical and campaign data | Our legitimate interests under Article 6(1)(f), where the processing is necessary and does not require consent; otherwise consent under Article 6(1)(a) |
Where processing is based on legitimate interests, we consider the necessity of the processing, its effect on users and appropriate safeguards. Those safeguards include limiting the signals collected, restricting access, applying retention periods, treating technical inconsistencies as indicators rather than conclusive proof and requiring human review before material enforcement decisions.
Where we are required to access or store information on your device, we also comply with applicable rules concerning terminal equipment, including obtaining consent where required. Consent to optional technology can be withdrawn through the relevant app, device or consent settings.
6. Data required to use Bento Rewards
Account, device, attribution and campaign-event information is necessary to provide the core reward service. Without this information, we may be unable to:
- create or secure an Account;
- determine eligibility;
- connect an Offer click with an installation or later milestone;
- validate an Offer;
- credit Coins;
- prevent duplicate or manipulated participation; or
- approve and deliver a Reward.
If you disable or reset an identifier or permission required for an active Offer, the relevant activity may no longer be reliably attributable or eligible for Coins. Disabling optional analytics or promotional notifications does not prevent use of the core Platform, although some optional features may be unavailable.
7. Offer attribution and continuity checks
Offers are commonly subject to new-user, first-install, country, device, installation and attribution requirements. To validate these conditions, we may compare the Device ID, Advertising ID, Account, IP-derived territory, installation, click and campaign-event information recorded when an Offer begins with the information received for later milestones.
Examples of inconsistencies that may require review include:
- the Offer beginning and completing under materially different device or installation information;
- an Advertising ID or Device ID changing while an Offer is active;
- the Account country, IP-derived country and campaign country being inconsistent;
- the same device, identifier, Reward destination or campaign event being associated with multiple Accounts;
- events arriving in an impossible, duplicated or materially abnormal sequence; or
- the Campaign Partner reporting that the installation or event was attributed elsewhere, rejected, refunded or invalid.
These checks protect legitimate users and ensure that Rewards correspond to valid, partner-approved activity. We may ask for additional information or place Coins or a redemption under review where information is inconsistent. We do not disclose exact fraud thresholds or detection rules where doing so would undermine Platform security or fraud prevention.
8. Fraud scoring, profiling and human review
We use automated rules to organize information, identify inconsistencies and generate fraud or eligibility indicators. This may constitute profiling because the system evaluates aspects of Account activity, device consistency, location consistency, attribution reliability or fraud risk.
Automated indicators may lead to:
- additional validation;
- a temporary hold on Coins or a redemption;
- a request for supporting information; or
- referral of the Account or activity for human review.
Bento Rewards does not reject a Reward, suspend an Account or terminate an Account solely on the basis of an automated fraud indicator. An authorized person reviews the relevant information before such a material decision is made.
You may contest an enforcement decision, explain a legitimate device or location change and provide relevant information by contacting support@bento-rewards.com. We may withhold details that would expose confidential security controls, information about another person or methods that could be used to evade fraud detection, but we will provide a meaningful explanation of the principal reason for the decision where legally required and reasonably possible.
9. Push notifications and communications
If you enable push notifications, we process the Expo push token associated with your app installation to deliver notifications through Expo’s push service and Google Firebase Cloud Messaging.
We may send:
- service and security notifications;
- information about Account, Coin, Offer or Reward status;
- responses to support requests; and
- promotional notifications where you have provided any consent required by law.
You can disable push notifications in your device settings. We stop using a token when it is reported as invalid, when notifications are disabled and this is communicated to us, or when the associated data is deleted under our retention rules.
We may still send essential service, security, legal or transaction-related communications by email where necessary to operate your Account or comply with law. You can unsubscribe from promotional email through the unsubscribe mechanism provided in the message.
10. Cookies, SDKs and similar technologies
The Platform uses software development kits, local storage, cookies and similar technologies to operate the service, maintain security, remember settings, attribute Offers, validate campaign events, deliver notifications and, where permitted, understand Platform performance.
Some technologies are necessary to provide a feature that you expressly request. Other technologies, including optional analytics or marketing technologies, are used only where an applicable legal basis and any required consent exist.
Where consent is required, you can make or change your choice through the consent interface, app settings, website cookie settings or device settings made available to you. Withdrawing consent does not affect processing that occurred lawfully before withdrawal.
Operating-system privacy settings and identifier resets can affect attribution. If the necessary event connection is lost, we may be unable to validate an Offer even where an activity occurred.
11. Recipients of personal data
We disclose personal data only where necessary for the purposes described above, where you request it, or where disclosure is required by law.
11.1. Campaign and offer providers
We exchange Account reference, Device ID, Advertising ID, click, installation, territory and campaign-event information with Campaign Partners to present Offers, attribute activity, validate completion, investigate discrepancies and process reversals. Campaign Partners may operate as our processors, as separate controllers, or in another legally defined role depending on the service and data flow.
When you use a Campaign Partner’s application, game, survey, website or service, that partner independently processes information under its own privacy policy.
11.2. Swaarm GmbH
We use Swaarm GmbH for reward-platform infrastructure, Account and campaign administration, attribution, event processing, reward-ledger operations and related technical services.
11.3. Google Firebase and Google Cloud
We use Google Firebase and Google Cloud for app and cloud infrastructure, technical operation, security, performance, notifications and related services, depending on the configured feature.
11.4. Mobile measurement and attribution providers
Depending on the relevant campaign and partner integration, attribution and campaign information may be processed through mobile measurement platforms, including Adjust, AppsFlyer and Singular. These providers help connect Offer clicks, installations and later campaign events.
11.5. Push-notification providers
Where push notifications are enabled, the Expo push token and notification-delivery information may be processed through Expo’s push-notification service and Google Firebase Cloud Messaging.
11.6. Tremendous, Inc.
We use Tremendous, Inc. to provide and fulfil certain Rewards. When you request a Reward, we may provide the information necessary to process and deliver it. Tremendous may request additional information under its own terms and privacy notice where required for delivery, sanctions screening, compliance or fraud prevention.
11.7. Fraud-prevention, hosting and technical providers
We may use providers that assist with hosting, database operation, security, network analysis, customer support, email delivery, fraud detection, logging and technical maintenance. These providers receive only the data reasonably necessary to perform their services and are subject to applicable contractual and confidentiality obligations.
11.8. Professional advisers and corporate transactions
We may disclose information to auditors, accountants, lawyers, insurers and other professional advisers where necessary. If REPLUG or the Bento Rewards business is involved in a merger, financing, acquisition, reorganization, insolvency or sale of assets, relevant personal data may be disclosed subject to appropriate safeguards and applicable law.
11.9. Authorities and legal recipients
We may disclose information to courts, regulators, supervisory authorities, tax authorities, law-enforcement bodies or other authorized recipients where required by law or necessary to establish, exercise or defend legal claims.
We do not disclose exact security associations, fraud rules or investigation methods where disclosure would undermine the rights of others, trade secrets, security or fraud prevention.
12. International data transfers
Some Campaign Partners and service providers are located outside Germany or the European Economic Area (“EEA”), including in the United States and other countries whose data-protection laws may differ from those in the EEA.
Where personal data is transferred outside the EEA and no applicable adequacy decision exists, we use an approved transfer mechanism where required, such as the European Commission’s Standard Contractual Clauses, together with supplementary technical, contractual or organizational safeguards where appropriate. Where a provider is validly covered by an applicable adequacy framework, we may rely on that framework.
You may contact privacy@bento-rewards.com for more information about the safeguards applicable to a particular transfer and, where available and legally required, to request a copy of the relevant safeguards. Confidential and commercially sensitive information may be redacted.
13. Data retention
We retain personal data only for as long as necessary for the purpose for which it was collected, including providing the Platform, validating Offers, resolving disputes, preventing fraud and meeting legal obligations. The following periods apply unless a longer or shorter period is required by law or justified by the circumstances:
| Category | Normal retention period or criterion |
| Account and profile data | For the life of the Account and normally deleted or anonymized within 30 days after closure, except for data covered by another retention category |
| Device IDs, Advertising IDs and Account-device associations | For the life of the Account and up to 3 years after closure or the last relevant fraud or security event where needed to prevent multiple Accounts, re-registration abuse or disputed reward claims |
| Expo push token | Until the token becomes invalid, notifications are disabled and that status is received, the relevant installation is replaced, or the Account is deleted; normally removed within 30 days after it is no longer required |
| IP addresses, technical logs and security logs | Normally up to 12 months, unless needed for an active security incident, fraud investigation, dispute or legal claim |
| Campaign, attribution, Coin and Offer-validation records | For the Account’s life and up to 3 years after the end of the calendar year in which the Account was closed or the relevant transaction was finally resolved |
| Fraud indicators, investigation records and enforcement history | Up to 3 years after Account closure or the last relevant incident, whichever is later; longer only where necessary for an active dispute, repeat-abuse prevention, legal claim or legal obligation |
| Redemption and Reward-delivery records | For the period necessary to complete and support the Reward, followed by any applicable accounting, tax, sanctions, fraud-prevention or legal retention period |
| Support correspondence and submitted evidence | Normally 3 years after the support matter is closed, unless the information is no longer needed earlier or must be retained for an unresolved dispute or legal claim |
| Consent and privacy-request records | For as long as the relevant processing continues and normally up to 3 years afterward to demonstrate compliance and handle disputes |
| Accounting, tax and legally required business records | For the retention period required by applicable German or EU law; the applicable period depends on the type of record |
| Backups | Removed or overwritten in accordance with our backup cycle, normally within 90 days, unless preservation is required for security, disaster recovery or legal reasons |
When a retention period expires, we delete or anonymize the data unless continued storage is legally required. Anonymized information that can no longer reasonably be linked to an identifiable person may be retained for statistical, security or business-analysis purposes.
14. Account deletion
You may request Account and personal-data deletion by:
- emailing privacy@bento-rewards.com; or
- using the deletion request form available through the Bento Rewards contact page.
When you request deletion, we delete or anonymize personal data unless continued retention is required or permitted by law or remains necessary to:
- complete a pending redemption or resolve an open support matter;
- comply with accounting, tax, sanctions or other legal obligations;
- investigate or prevent multiple Accounts, fraudulent activity, security incidents or circumvention of an Account restriction;
- handle a Campaign Partner reversal, refund, chargeback or validation dispute; or
- establish, exercise or defend legal claims.
Data retained after an Account deletion request is restricted to the applicable purpose and deleted or anonymized when that purpose and the relevant retention period end.
Deleting the app from your device does not automatically delete your Account or personal data.
15. Your data-protection rights
Subject to the conditions and limitations of applicable law, you may have the right to:
- receive information about how we process your personal data;
- request access to your personal data and receive a copy;
- correct inaccurate or incomplete personal data;
- request deletion of personal data;
- request restriction of processing;
- receive personal data you provided in a structured, commonly used and machine-readable format and, where technically feasible, request its transmission to another controller;
- object to processing based on legitimate interests;
- withdraw consent at any time where processing is based on consent; and
- lodge a complaint with a competent data-protection supervisory authority.
Withdrawal of consent does not affect the lawfulness of processing performed before consent was withdrawn.
15.1. Right to object
Where we process personal data on the basis of legitimate interests under Article 6(1)(f) GDPR, you may object on grounds relating to your particular situation. We will stop the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or the processing is necessary to establish, exercise or defend legal claims.
You may object to direct marketing at any time. We will stop using your personal data for direct marketing after receiving and implementing your objection.
15.2. Exercising your rights
Send requests to privacy@bento-rewards.com. Please describe your request and identify the Account concerned. We may request additional information reasonably necessary to verify your identity and protect the Account. We will not request more information than necessary for verification.
We normally respond within one month. Where permitted by law, that period may be extended by up to two additional months because of the complexity or number of requests. We will inform you of an extension and its reasons within the initial one-month period.
Rights may be limited where an applicable exemption applies, including where disclosure would adversely affect another person’s rights, reveal protected security information or trade secrets, or interfere with the prevention, detection or investigation of fraud. We will explain any refusal or limitation where legally required.
16. Complaints and supervisory authority
You may contact us first at privacy@bento-rewards.com so that we can investigate your concern.
You also have the right to lodge a complaint with the supervisory authority in the EEA country of your habitual residence, place of work or the alleged infringement. The supervisory authority responsible for REPLUG’s Berlin establishment is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61
10555 Berlin
Germany
Website: https://www.datenschutz-berlin.de
Complaint portal: https://kontakt.datenschutz-berlin.de/
17. Security
We use technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. Depending on the risk and system, these measures may include access controls, encryption in transit, encryption or other protection at rest, logging, authentication controls, provider security reviews, backups, data minimization and incident-response procedures.
Access to Account, fraud and investigation information is limited to personnel and providers who require it for their assigned responsibilities.
No online service can guarantee absolute security. You should use a unique password, protect your email Account and device, and notify support promptly if you believe your Bento Rewards Account has been compromised.
18. Children
The Platform is intended only for individuals aged 18 or older. We do not knowingly permit individuals under 18 to create or use an Account.
If we learn that an individual under 18 has provided personal data or created an Account, we will take appropriate steps to close the Account and delete the data, subject to any information that must be retained for security, legal or compliance purposes. A parent or guardian who believes a minor has used the Platform may contact privacy@bento-rewards.com.
19. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in the Platform, data processing, providers or applicable law. We will publish the revised version with a new “Last updated” date.
Where a change materially affects how we use personal data or users’ rights, we will provide additional notice through the Platform, email or another appropriate channel before the change takes effect where required by law. If a new processing activity requires consent, we will request consent before beginning that activity.
Previous versions may be requested from privacy@bento-rewards.com.
20. Contact
For questions, privacy requests or complaints concerning this Privacy Policy or our processing of personal data, contact:
REPLUG GmbH – Bento Rewards Privacy
Oranienburger Str. 23
10178 Berlin
Germany
Email: privacy@bento-rewards.com