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Reviews & loyalty

Awin and the GDPR: agreement, role and data location.

Awin is a reviews & loyalty tool. Its role depends on the activity, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.

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In short

Category
Reviews & loyalty
Usual role
Depends on the activity
Data location
Set per account or project
Agreement
Published by the vendor

What does Awin do with personal data?

Collect customer reviews, run loyalty, referral or affiliate programs and send related messages. That is how Privacyboard describes a typical use of Awin, as a starting point you can edit.

The data usually involved: customer names, email addresses, order details, reviews, points or rewards, referral and engagement data.

Is Awin a processor or a controller?

the DPA makes Awin a joint controller with the advertiser for tracking, cross-device tracking and reporting.

Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.

Where does Awin store personal data?

Awin does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.

How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.

Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.

Which legal basis usually applies to Awin?

For the usual use of Awin, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest.

The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).

Publishing a review with the author’s name needs their agreement, and review requests must be easy to refuse. The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.

This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.

Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest

Does Awin have a data processing agreement?

Checked on 5 November 2026. Vendors change their pages, so check the date.

Yes. Awin publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.

What we noted when we opened the page: Advertiser Data Processing Addendum (no date shown). Awin and advertiser are joint controllers for tracking and reporting; Awin is processor for lead generation and some services. No hosting location; non-EEA transfers under an SCCs Addendum.

A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.

Read the Awin agreement

How to declare Awin

  1. 1

    In your privacy policy

    Name Awin as a recipient, say what it is used for (collect customer reviews, run loyalty, referral or affiliate programs and send related messages) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.

  2. 2

    In your vendor list

    Add Awin with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.

  3. 3

    In your processing register

    Link Awin to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.

What to check before relying on Awin

  • Check which emails the tool sends and that each one offers an easy way to stop them.
  • Decide how reviews are published: first name only, initials, or full name with agreement.
  • Check how long points, reviews and referral data are kept.
  • Record the region and any transfer outside the EEA.
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FAQ

Questions, answered.

Is Awin GDPR compliant?

Privacyboard does not certify vendors. Compliance depends on how Awin is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.

Does Awin have a DPA?

Yes. Awin publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://awin.com/gb/legal/advertiser-dpa.

Is Awin a data processor?

It depends on the activity. the DPA makes Awin a joint controller with the advertiser for tracking, cross-device tracking and reporting.

Which legal basis applies when I use Awin?

For the usual use of Awin, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest. The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).

Where does Awin store data?

Awin does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.

Do I need to mention Awin in my privacy policy?

Yes, if Awin handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.

How do I add Awin to my vendor list?

In Privacyboard, pick Awin from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.

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Privacyboard is not affiliated with Awin. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.

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