Upinion has created this privacy statement in order to demonstrate our firm commitment to privacy.
Upinion respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy applies to all products, services, websites and mobile Apps (hereinafter: ‘Services’) offered by Upinion. All references within this Privacy Policy to ‘you/your’ refer to the person accessing, browsing and/or making use of our Services. All references within this Privacy Policy to ‘we/us/our’ refer to Upinion.

Upinion is headquartered in Amsterdam, in the Netherlands (Upinion Netherlands BV, John M. Keynesplein 12-46, 1066EP Amsterdam). You may contact Upinion’s internal data protection resource if you have any questions or concerns about Upinion’s policies or practices regarding Personal Data. You can contact our Data Protection Officer (Mr. Sean A. Yakoub MSc CISSP CISM CEH) via [email protected].

Data locations: Since our servers are located in the European Union, your personal information will be stored and processed by us in the European Union.


Our Services offer you the opportunity to initiate Groups and invite people(Respondents) to join these
Groups and receive conversations. “Conversations” can consist of messages and questions, which may be answered by respondents. One person is allowed to be both a “Group User” and a “respondent” at the same time. Conversations are initiated by Group Users in order to collect your answers for research and feedback purposes. Participating in Conversations is at your own discretion. The group user is the controller of your personal data. And therefore is he/she responsible for the processing of your personal data.


Your account details as a Group User: When you create a personal account you provide us with the following information: your name, company name, address, email address, (mobile) phone number, financial information (e.g. a credit card number and expiration date or a bank account number). If you provide us with a billing address, we will register this as the location of the account holder.
Your account details as a Respondent: You will be able to use some features of our app without registering. However, in order to use certain features within our app we may ask you to register your account first. When this occurs we may ask for your email address, mobile phone number and, in some cases, your name.
Your content: We collect the content and other information you provide when you use our Services, including the questions you ask, the given answers, group information, reward information and contextual data (e.g. testimonials and feedback).
Device information: We collect personal information from or about the computers, phones or other devices where you install or access our Services. This information includes IP addresses, the type of your (mobile) device, device locations, including specific geographic locations, time zones and durations of use.
Asking questions as Group User: With our Services you will be able to create Groups (Group Administrator), invite people to join these Groups (Respondents), ask them questions in Conversations, collect their answers/data, create your own Rewards and give certain users rights to view and/or edit Conversations (Group Users).
Your answers as a Respondent: We collect and store the answers you submit in the Conversations in our app on behalf of the Group Users. The Group User(s) is/are responsible for these data and the management thereof. If you have any questions about a Group, a Conversation or the use of your personal information and answers in these conversations, we advise you to view the information on the specific Group Page in the mobile app or contact the Group Administrator directly.
Upinion is not responsible for this content. You can find the contact details in your Group Page. You can always choose not to answer, skip a question, leave a group or delete our app. Answering questions is on a voluntary basis.
Information from third-­party partners: We may receive information about you from third parties when you gave them permission to do this. We also use a variety of services hosted by third parties that help us understand and improve the use of our Services. These services may collect (aggregated and anonymized) information and statistics about visitors and users. Upinion does not accept any responsibility or liability with regard to how these third parties deal with your personal data. For further information, please read the privacy policy of the party providing these services.
Additional information: We also collect additional information such as your default language, time zone and communication preferences (e.g. if you want to receive our newsletter).


We do not disclose or sell your personal information to third parties, except in the limited circumstances described here:
Your consent: We may share or disclose your (personal) information with your expressed
Service Providers: We engage certain trusted third parties (i.e. payment processors) to perform functions and provide services to us. We may share your personal information with these third parties, but only to the extent necessary to perform these functions and such services. These third parties will not use your personal information for any other purposes than what we agreed upon. We request those third parties explicitly to implement adequate levels of security in order to safeguard your personal information.
Law and harm: We may disclose your personal information if we believe that it is reasonably necessary to comply with a law, regulation or legal request.
Corporate objectives: We may disclose your personal information to protect our rights and property or in a corporate restructuring or acquisition context. If we intend to do this you will be informed in advance.


You are entitled to know which personal information Upinion holds in relation to you. If you wish to know which data we have registered about you or if you wish to change your data you can visit your My Account page.
Download/backup your Conversation data: It is possible to export, share and publish your own (Conversation) data in a variety of formats. This allows you to create your own backups or conduct offline data analysis.


Delete your account: In order to stop us from collecting and using your personal data you can delete your account. Please contact our Customer Support team to cancel and delete your account. Once your account has been deleted all your personal data will be deleted as well. As a result thereof all Conversation data is disconnected from your personal account.

We will respond to any appropriate request to delete your personal information within the time period specified by law (if applicable) or without excessive delay. Once your identity has been verified by us we will promptly fulfill requests to delete personal data; unless the request is technically not feasible or such data is required to be retained by law (in which case we will block access to such data).


We generally retain your data for as long as you have an account with us, to comply with our legal obligations, resolve disputes and enforce our agreements. Data that has been deleted from our servers may remain temporarily as residual copies on offsite backup media in order to complete certain Conversations in a reliable manner, such as giving the Respondents the Rewards they have earned.


If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:

(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
(ii) If the processing of your personal data is necessary for the performance of a contract between you and Upinion or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b)..). If this data is not processed, Upinion will not be able to execute the contract with you.
(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of tax law.
(iv) And where the processing is necessary for the purposes of Upinion’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.


Our website(s) make use of cookies. A cookie is a small text file that is sent together with a website page and stored via your browser on the hard drive of your computer, tablet or phone. Each cookie expires after a certain period of time depending on what we use it for.
You may be able to configure your web browser to prevent the use of cookies, although this may prevent you from using (certain parts) of our Services.
We use cookies for several reasons:
Site features and services: Cookies or similar technologies help you log in by pre-­filling the username field or help store your preferences. For example, when you use the ‘Remember me’ feature when you sign into your account.
Security: We use cookies to authenticate your identity, such as confirming whether you are
currently logged into Upinion.
Personalized content: With the use of cookies we may store user preferences, such as your default language, in order to personalize the content you see.
Measurements: We use cookies to provide you with the best experience possible. Certain cookies measure your usage of our Services and track referral data. We may occasionally display different versions of content to you in order to help us develop and improve our Services and optimize the content we display to our users.
Advertising: We make use of cookies to deliver personalized marketing content to you and analyse and evaluate products/services and the use of those products/services. For example, we may evaluate how often users click on certain advertisements and if those clicks lead users to make better use of our tools, features and services.
Google Analytics: We implemented certain Google Analytics features on our website that support Display Advertising, including re-­targeting. You are able to opt-­out of certain types of Google Analytics tracking by downloading the Google Analytics opt-­out browser add-­on. In addition, you can also customize the Google Display Network advertisements by using the Google Ad Preferences Manager.


We are committed to the principles for electronically collecting personal information recorded in the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”). We are also committed to ensuring that consumer rights as recorded in the Consumer Protection Act 68 of 2008 are respected (“CPA”). Insofar as any of our marketing strategies may be construed to amount to direct marketing as contemplated in the CPA you confirm that the ability to deregister or stop using the Services and excuse us from any adverse consequence contemplated by the CPA.


In the US there are exceptions to the opt-­out rule. For example, consumers cannot opt out when nonpublic personal information is shared with a nonaffiliated third party to respond to judicial process or to comply with federal, state, or local legal requirements.


Our Services are not intended for and may not permissibly be used by individuals under the age of 13. Upinion does not knowingly collect personally identifiable data from persons under the age of 13 of COPPA (The Children’s Online Privacy Protection Act). If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you are a parent of a child under 13, and you believe that your child has provided us with information about him or herself, please contact us at [email protected].


We are committed to handle and store your personal information with integrity and care. For this reason we maintain technical and organizational security measures in order to guarantee your personal information is protected from loss, incorrect modifications and unauthorized third-­party access. We ensure, to the greatest extent possible, that only authorized persons have access to your personal information and only to the extent that it is necessary in the scope of the aforementioned purposes. If you want more information about our security measures please contact us via [email protected].


This Privacy Policy may be changed by Upinion. The most up-­to-­date version of our Privacy Policy can be found on our website: https://upinion.com.


If you have any questions or concerns about this Privacy Policy, please contact Upinion at: [email protected].