Privacy Policy

Last update: 26/03/2018

We are OPIÑON Limited, a company registered with Companies House in England and Wales under number 11073750 whose principal place of business is at Kemp House,160 City Road, London, EC1V 2NX, United Kingdom (“OPIÑON”/“we”/“us”/“our”). 

OPIÑON Limited ("us", "we", or "our") operates the website and the OPIÑON mobile applications (the "Service").

We are committed to protecting and respecting your privacy.


The principle we keep in mind is simple: we don't sell your personally identifiable data. We don’t need to because we are building a Pro (paid-for) version of the app with super-duper features (and we hope you’ll love it so we can keep the lights on).


When sharing information with 3rd party service providers in accordance to this Privacy Policy, we do it transparently, with your consent so to provide and improve the Service. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

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Jargon Buster & Definitions

 

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

The Details

What type of data do we collect?


We collect several different types of information for various purposes to provide and improve our Service to you. Personal Data While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: - Email address - First name - Gender - Occupation - Education - Address, State, Province, ZIP/Postal code, City - Cookies, Identifiers and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. Usage Data We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. Location Data We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your device settings. Motion Data We may use and store information about the motion sensors in your device (such as the accelerometer, gyroscope, pedometer, barometer) if you give us permission to do so (“Motion Data”). We use this data to provide features of our Service, control onscreen interactions, to improve the user experience and customize our Service. You can enable or disable motion services when you use our Service at any time, through your device settings. Tracking Cookies Data We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website. Examples of Cookies we use: - Session Cookies. We use Session Cookies to operate our Service. - Preference Cookies. We use Preference Cookies to remember your preferences and various settings. - Security Cookies. We use Security Cookies for security purposes. Social Networking Data In order to enable particular features within the Service, OPIÑON Limited may ask the user to connect to social networks to add information. For example, when registering as a user with OPIÑON, or throughout the Service, you may be given the option to sign in using your LinkedIn or Facebook login credentials - we do so to provide you with content that is more relevant to you and and to give you additional aggregated statistics about your progresses. We do not share or sell such Social Networking Data to any 3rd party or outside the scope of your usage of the Service within the framework of this Privacy Policy.
If you decide to connect your social networks, you authorize us to access certain LinkedIn or Facebook account information, such as your public profile (consistent with your privacy settings in Facebook or LinkedIn), your email address, gender, birthday, current role, current city, list of friends who also are OPIÑON users and have authorised the Service. You can control settings and remove apps and services connected to your social networks following the relevant instructions provided by the different social networking platforms:
LinkedIn You can control your LinkedIn privacy settings by following the instruction on this page: https://www.linkedin.com/help/linkedin/answer/66/managing-your-account-and-privacy-settings-overview. In addition you can remove LinkedIn access to apps and serviced by visiting this page: https://www.linkedin.com/psettings/permitted-services Facebook: You can control your Facebook Basic Privacy Settings by following the instruction on this page: https://www.facebook.com/help/325807937506242 You can check the apps and services connected to your Facebook account by following the instructions on this page: https://www.facebook.com/help/100754513412802 You can edit the privacy and settings for the apps and services connected to your Facebook account following the instructions on this page: https://www.facebook.com/help/218345114850283 In addition you can remove access to apps and services connected to your Facebook accounts by following the instructions on this page: https://www.facebook.com/help/170585223002660




What use do we make of the data?


OPIÑON Limited uses the collected data for various purposes: - To provide and maintain our Service. - To notify you about changes to our Service. - To allow you to participate in interactive features of our Service when you choose to do so. - To provide customer support. - To gather analysis or valuable information so that we can improve our Service. - To monitor the usage of our Service. - To detect, prevent and address technical issues. - To evaluate candidates applying for a job position in the company. - To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.




How long do you retain the data for?


OPIÑON Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. OPIÑON Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.




Where are data stored and transfered to?


We are a growing company with users and operations in multiple countries. We have developed data practices designed to assure information is appropriately protected but we cannot always know where personal information may be accessed or processed. While our primary data centers are in the European Economic Area, we may transfer personal information or other information to our offices and Services outside of the European Economic Area. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose personal information to a third party or to our employees outside of the European Economic Area, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by OPIÑON Limited from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.




When are we required to disclose the data?


Business Transaction If OPIÑON Limited is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. Disclosure for Law Enforcement Under certain circumstances, OPIÑON Limited may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Legal Requirements OPIÑON Limited may disclose your Personal Data in the good faith belief that such action is necessary to: - To comply with a legal obligation. - To protect and defend the rights or property of OPIÑON Limited. - To prevent or investigate possible wrongdoing in connection with the Service. - To protect the personal safety of users of the Service or the public. - To protect against legal liability.




What measures do we have in place to keep the data secure?


The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to these systems.
While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.




What are my rights?


OPIÑON Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the right: - To access and receive a copy of the Personal Data we hold about you. - To rectify any Personal Data held about you that is inaccurate. - To request the deletion of Personal Data held about you.
You have the right to data portability for the information you provide to OPIÑON Limited. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.




What Service Providers do we work with?


We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used and improve it. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Analytics Solutions We may use third-party Service Providers to monitor and analyze the use of our Service. Google Analytics for Firebase Google Analytics is an analytics service offered by Google that tracks and reports website and application traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page (http://www.google.com/intl/en/policies/privacy), the Google Firebase Terms (https://firebase.google.com/terms/analytics) and this help article that summarises how Google uses data when you use partners' sites or apps: https://policies.google.com/privacy/partners. Amplitude Amplitude is provided by Amplitude Inc, Amplitude is a quantitative data analytics tool that allows us to understand the usage of our Service and its performances. You can prevent Amplitude from using your information for analytics purposes by opting-out. To opt-out of Amplitude service, please follow the instructions on this page: https://amplitude.com/privacy For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Amplitude: https://amplitude.com/terms Mixpanel Mixpanel is provided by MIxpanel Inc, Mixpanel is a quantitative data analytics tool that allows us to understand the usage of our Service and its performances and send tailored communications about our Service. You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of all Mixpanel service, please follow the instructions on this page: https://mixpanel.com/legal/privacy-policy For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/legal/terms-of-use AppsFlyer AppsFlyer is provided by AppsFlyer Inc, Mixpanel is a quantitative data analytics tool that allows us to understand the usage of our Service and the performances of our marketing messages across the various channels used to promote our Service. You can prevent AppsFlyer from using your information for analytics purposes by opting-out. To opt-out of all AppsFlyer service, please follow the instructions on this page: https://www.appsflyer.com/services-privacy-policy For more information on what type of information AppsFlyer collects, please visit the Terms of Use page of Appsflyer: https://www.appsflyer.com/terms-of-use Smartlook Smartlook is provided by Smartsupp.com, s.r.o. Smartlook is a qualitative data analytics tool that allows us to understand the user interactions with the Service, bugs or app crashes, usage of our Service and its performances via session recordings. You can prevent Smartlook from using your information for analytics purposes by opting-out. To opt-out of Smartlook service, please visit this page: https://www.smartlook.com/opt-out
For more information on what type of information Smartlook collects, please visit the Smartlook Privacy Policy: https://www.smartlook.com/help/privacy-statement Segment Segment is provided by Segment.io Inc. Segment is used as data hub for integration with Service Providers and it's used exchange data without slowing the delivery of our Service down. You can prevent Segment from using your information for analytics purposes by opting-out. To opt-out of Segment service, please visit this page: https://segment.com/docs/legal/privacy For more information on what type of information Segment collects, please visit the Terms of Use page of Segment: https://segment.com/docs/legal/privacy Advertising and Marketing Solutions OPIÑON Limited uses marketing and remarketing services to advertise on third party websites or apps to you after you visited our Service so to market our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service. If you wish to opt out of interest-based advertising, click here (or if located in the European Union click here ). Please note you will continue to receive generic ads. In addition, in the following section you can find specific information about the Service providers we use: Google AdWords Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/ Twitter Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy Facebook Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation Pinterest Pinterest remarketing service is provided by Pinterest Inc. You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
Email Marketing Solutions OPIÑON Limited uses the following email marketing solutions to communicate with you:
SendGrid SendGrid is provided by SendGrid Inc. We use SendGrid to manage newsletter content and transactional emails.
You can view their privacy policy at the following page: https://sendgrid.com/policies/privacy Privy Privy is provided by Privy Inc. We use Privy to personalise our website and to allow you to subscribe to direct marketing and newsletter content.
You can view their privacy policy at the following page: https://privy.com/privacy-policy Cloud Computing and Hosting OPIÑON Limited uses multiple Cloud Computing service providers in order to maintain and deliver the Service:
Google Cloud Platform Google Cloud Platform is provided by Google. We use it for running selected database management, cloud computing, storage, archiving, application programming interfaces (APIs) to deliver the Service. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page (http://www.google.com/intl/en/policies/privacy), the Google Cloud Terms (https://cloud.google.com/terms) and this help article that summarises how Google uses data when you use partners' sites or apps: https://policies.google.com/privacy/partners. Heroku Heroku is a service provided by Salesforce.com Inc. We use it for running selected database management, cloud computing, storage, application programming interfaces and services. For more information on the privacy practices of Heroku, please visit the Salesforce Privacy Terms web page: https://www.salesforce.com/company/privacy Amazon Web Services (AWS): Amazon Web Services (AWS) is a service provided by Amazon Inc. We use it for running selected database management, cloud computing, storage, archiving, application programming interfaces and services. This data may be shared with other Amazon services and can be controlled by following the instructions on this page: https://www.amazon.com/gp/help/customer/display.html?nodeId=468496.
For more information on the privacy practices of Amazon Web Services, please visit the Amazon Web Services Privacy Terms web page: https://aws.amazon.com/privacy Algolia Algolia is a service provided by Algolia Inc. We use it for providing predictive search and content filtering features in our Service. For more information on the privacy practices of Algolia, please visit the Algolia Privacy Terms web page: https://www.algolia.com/policies/privacy Perspective API
Perspective is a service provided by Google Inc. It was created by Jigsaw and Google’s Counter Abuse Technology team in a collaborative research project called Conversation-AI. Perspective API is in the early days of research and development, and we use it for user generated content moderation purposes, filtering spam or offensive content, and for features that encourage positive conversations within our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page (http://www.google.com/intl/en/policies/privacy), and this help article that summarises how Google uses data when you use partners' sites or apps: https://policies.google.com/privacy/partners. Neuroscience Research We may collaborate and use specialised 3rd party research labs in order to monitor the performances of the training exercises, collaborate to the accademic research, analyze the use of our Service, and improve the Service. Banissy Lab Banissy Lab is a social neuroscience lab specialised in understanding how humans perceive and interact with others. We share data with Banissy Lab to monitor the usage of the training exercises, the experience of the Service, to analyse its benefits, and improve the its design. For more information please visit https://banissylab.com. Goldsmiths' College Goldsmiths' College collaborates with us and help us to understand how humans perceive and interact with others, and and to improve the Service. We share data with Goldsmiths' College to monitor the usage of the training exercises, the experience of the Service, to analyse its benefits, and improve the its design. We may also jointly pusblish Research Whitepapers and aggregate stats to contribute to the Accademic Research in the field. For more information please visit https://www.gold.ac.uk Payments We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are: Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
Google Play In-App Payments Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy PayPal or Braintree Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full




Do we provide links to other websites or apps?


Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.




Do we aggregate data?


Aggregate information are data combined from several measurements. When data are aggregated, groups of observations (including observations generated from processing of Personal Data or Usage Data) are replaced with summary statistics based on those observations. OPIÑON may collect and analyze Aggregate Data about the performance of its Service. From time to time, OPIÑON may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its Service.




What happens to my data when I apply for a job with you?


If your Personal Information is submitted when applying for a position with OPIÑON Limited, the information will be used solely in connection with considering and acting upon your application. We may retain your Personal Information, but only for the purpose of considering your application for current or future available positions. This information, which may include your name and contact information, prior education and experience, and other information you provide to us, may be shared with third-party service providers retained by us to collect, maintain and analyze candidate submissions for job postings. In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us.




What measures do we have in place to address children's privacy?


Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.




Do we update this Privacy Policy?


We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.




How can you get in touch about data or privacy policy enquires?


If you have any questions about this Privacy Policy, please contact us by email: privacy@getopinon.com





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© 2019 OPIÑON Limited. All rights reserved.
Kemp House, 160 City Road, EC1V 2NX, London, UK.
Registered in England: 11073750 VAT: GB289051087
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