Version: 2025.05.23
Peira Network Limited ("Peira", "we", "us" or "our") provides a platform ("Platform") that: (i) connects researchers (“Researchers”) with participants (“Participants”) for research studies, questionnaires or experiments (“Studies”); and (ii) enables Researchers to create and conduct Studies on our Platform using our proprietary tools.
This Privacy Notice describes how we process personal data of Researchers in relation to their use of the Platform.
1. Personal data we collect
1.1. Here’s the personal data we (and selected third parties acting on our behalf) may collect in relation to your use of the Platform as a Researcher:
(a) We may collect account information, such as your name, email address, date of birth, mobile number, address, other contact details and login information.
(b) We (or our third-party verification providers) may collect verification information about you:
(i) Identity checks. As part of your onboarding process on the Platform, we may conduct certain identity checks. This includes liveness and deduplication checks, which involve collecting biometric data such as facial images, iris scans, voice recordings, or retina scans to verify your identity and ensure you have not registered multiple accounts. These checks are conducted at account registration and before commencing a Study (where applicable) to prevent fraud and ensure data integrity.
(ii) Other verification information. We may collect, generate and use certain information about you such as your name and email address, and information about how you interact with the Platform in connection with our fraud detection and prevention procedures. This may include biometric identifiers derived from liveness and deduplication checks, which are securely stored and used solely for fraud prevention and account verification purposes.
(c) We may collect activity data about your use of the Platform. This includes basic records of Studies you have published, your account balance, payments and top-ups and log files generated through your use of the Platform.
(d) We may collect transaction data such as rewards you have issued for Studies, payments and top-ups you have made on the Platform, and your account balance.
(e) We (or our third-party payment provider) may collect billing information relating to you.
(f) We may collect user-generated content such as the information you choose to post publicly regarding the Platform in a user forum.
(g) We may collect correspondence with you related to your use of the Platform (such as when you contact us) and information contained in messages you have sent and received through the messaging features of the Platform. This information may include metadata and social media usernames.
(h) From time to time we may collect general or specific feedback and testimonials from you. For example, this might include written comments and quotes or photos, and information you share with us in video interviews.
(i) We may collect general usage data in relation to your use of the Platform, including data which we obtain through our, or our service providers’, analytics tracking systems. This might include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, and other interactions with and uses of the Platform, including information about the timing, frequency and pattern of those interactions and that use. We may associate this data with an advertising identifier that we generate or use which distinguishes you as a user (or, more typically your browser or device) from others (e.g. a ‘click ID’ or ‘cookie ID’).
(j) If you conduct Studies involving Mobile Sensing, we may collect data related to your configuration of Wearable Device integrations (e.g., device types specified, data collection settings) to facilitate Study administration.
2. What we do with your personal data
2.1. We may use your personal data for the following purposes or as otherwise described at the time of collection:
(a) Service delivery and operations
(i) We may use your personal data to: (1) operate the Platform and our operations; (2) tailor the Platform to your needs, such as recalling the devices you’ve used to log in and keeping track of your choices and preferences while you use the Platform; (3) set up and manage your account and profile on the Platform; (4) keep you informed about the Platform and Studies, including sending announcements related to services, updates, security notifications, and support or administrative messages; (5) gain insight into your preferences and interests to customize your experience with the Platform, Studies, and our communications; (6) assist with the Platform and Studies, addressing your inquiries, concerns, and feedback; (7) perform liveness and deduplication checks using biometric data to verify your identity and prevent multiple account registrations, ensuring the integrity of the Platform and Studies ; and (8) enable and support Mobile Sensing Studies by facilitating the integration and collection of data from Participants’ Wearable Devices, where applicable.
(b) Research and development
(i) We may employ your personal data for research and development efforts, such as evaluating and enhancing the Platform, Studies, and our business, as well as creating new offerings and services. In doing so, we might generate aggregated, de-identified, or anonymized data from the personal information we gather. This process involves stripping away details that could link the data back to you personally. We may utilize this aggregated, de-identified, or anonymized data and share it with third parties for legitimate business or research purposes. Neither we nor any third parties we share this data with will attempt to trace it back to you.
(ii) Occasionally, we might reach out to invite you to participate in user research, using the personal data you provide during these opportunities for the purposes outlined here. As part of this user research, we may leverage AI tools to compile and summarize feedback from Participants and Researchers (e.g., from interview transcripts or open-ended survey responses). Any data used in this process will always be de-identified or anonymized to ensure our users remain unidentifiable.
(c) Analytics and service improvement
(i) We may utilize your usage data to gain insights into how you interact with the Platform and list or offer Studies. This helps us refine the Platform and our overall business by supporting various research and analytical efforts. Additionally, we could use your data to experiment with new technologies and methods aimed at improving the experience for you and other users when engaging with the Platform and our services.
(ii) Occasionally, we may also use your data for staff training and development purposes.
(d) Marketing and advertising
(i) Direct marketing communications: we (and our service providers acting on our behalf) may send you direct marketing by email which are personalised based on your needs and interests if you have signed up to receive these emails or otherwise consented. You can opt out of our email marketing communications at any time. We may also display pop-ups on our Platform to let you know about new opportunities and to promote different features and services.
(ii) Online marketing and advertising to others: if we have gathered feedback or testimonials from you (such as in videos, photos, or quotes), we might incorporate them into our marketing and advertising efforts (like ads or social media posts) to promote our brand.
(e) Compliance and protection
(i) We may use your personal data to: (1) confirm your identity to prevent fraud and document the verification steps we’ve taken; this includes using biometric data for liveness and deduplication checks to ensure you are a unique user and to prevent fraudulent account creation; (2) adhere to relevant laws, legitimate requests, and legal proceedings, such as addressing subpoenas, investigations, or demands from government bodies, as well as for tax reporting; (3) safeguard the rights, privacy, safety, or property of ourselves, you, or others (including by pursuing or defending against legal claims); (4) review our internal procedures to ensure compliance with legal, contractual, or internal policy standards; (5) uphold the terms and conditions that regulate the Platform and Studies; and (6) prevent, detect, investigate, and discourage fraudulent, harmful, unauthorized, unethical, or illegal actions, including cyberattacks and identity theft.
2.2. In the table below, we have set out our purposes for using your personal data and the legal basis on which we do it (where such legal basis is required by applicable law, such as the General Data Protection Regulation 2016/679, the “GDPR”). Where required, our legal bases for processing your personal data are:
(a) Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
(b) Where it is necessary for our (or a third party’s) legitimate interests, and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal data for is set out in the table below.
(c) Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
(d) Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
|
Purpose |
Categories of personal data involved |
Legal basis |
|
Service delivery and operations, including to: · enable you to register to use the Platform; · provide you with the use of the Platform; · perform liveness and deduplication checks to verify identity and prevent multiple accounts · communicate with you in relation to your use of the Platform; and · perform our obligations under the Researcher Terms. |
· Account information · Transaction data · Billing information · Usage data · Correspondence · Activity data · Biometric data (e.g., facial images, iris scans, voice recordings, retina scans) |
Contractual Necessity
Where Contractual Necessity does not apply: Legitimate Interests We have a legitimate interest in conducting our business.
For special categories of personal data (where the GDPR applies): Consent |
|
Verification checks to confirm your identity or authenticate your use of the Platform. |
· Verification information · Biometric data
|
As part of our general fraud detection and prevention procedures: Legitimate Interests We have a legitimate interest in preventing fraud on, and maintaining the security of, the Platform, as well as ensuring data quality and reliability.
To conduct identity checks: Legitimate Interests We a have a legitimate interest in verifying the identity of Researchers to ensure data quality and reliability, and to prevent fraud.
For biometric data (where the GDPR applies): Consent
To keep a record of identity checks (but not any biometric data): Legitimate Interests We have a legitimate interest in maintaining a record of Researchers’ identity checks and associated documentation to prevent fraud on the Platform. |
|
Research and development, including to analyse performance and data in relation to Studies you have published in order to improve the Platform and other content based on analysing user feedback, and for fraud prevention purposes. |
· User research data · Usage data · Correspondence · Activity data |
Legitimate Interests We have a legitimate interest in improving our Platform.
Consent, where consent is required under applicable data protection or privacy laws, e.g., where non-essential cookies are used for this purpose. |
|
Direct marketing communications, including to send (and display) to you content related to Peira. |
· Account information |
Legitimate Interests We have a legitimate interest in promoting our products and services and sending or displaying marketing communications (including via pop-ups) for that purpose.
Consent, in circumstances or in jurisdictions where consent is required under applicable data protection or privacy laws for the sending of any given marketing communications. |
|
Our online marketing and advertising to you, including to ensure you only see ads for Peira which are relevant to you. |
· Account information · Usage data |
Legitimate Interests We have a legitimate interest in promoting our products and services, including ‘generating leads’, and ensuring our advertising is relevant to you and your requirements.
Consent, where consent is required under applicable data protection or privacy laws, e.g., where non-essential cookies are used for this purpose. |
|
Using your feedback and testimonials in our marketing and advertising materials. |
· Feedback and testimonials
|
Legitimate Interests We have a legitimate interest in promoting our products and services, and where possible we’ll give you the opportunity to ‘opt out’. |
|
Creation of aggregated, de-identified and/or anonymised data. |
Any and all other data types |
Legitimate Interests We have a legitimate interest in using privacy-preserving techniques to analyse user behaviour |
|
Compliance and protection, including to comply with applicable laws and legal processes, protect ours and others’ rights, audit our processes for legal and contractual compliance, and identify and prevent harmful, unauthorised or illegal activity. |
Any and all other data types |
Compliance with Law
Where Compliance with Law is not applicable: Legitimate Interests We have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property and/or safety. |
|
Enable Mobile Sensing Studies, including configuring and supporting Wearable Device data collection
|
· Mobile Sensing Configuration Data · Account Information |
Contractual Necessity To provide the Platform services under the Terms
Legitimate Interests We have a legitimate interest in supporting Researcher Studies
|
3. How we share your personal data
3.1. Published information: Any information which you choose to include in a Study listing will be visible to Participants. Any user-generated content which you choose to include in any forum post will be visible to other users, or browsers, of that forum.
3.2. Your organisation or institution: We may disclose certain details such as your name and email address associated with your account to your organisation or institution if requested by them to do so, as well as details of any Studies you have conducted, payments made and any other activity data (or similar) related to you which is undertaken in or connected with your organisation or institution’s name. Biometric data will not be shared with your organisation or institution unless explicitly required for fraud prevention or identity verification, and only with your consent where required by law.
3.3. Service Providers, Suppliers, and Contractors: We may disclose your personal data to other service providers, suppliers or contractors in connection with the uses described above. This includes third-party verification providers who process biometric data for liveness and deduplication checks on our behalf. These providers are bound by strict data protection agreements to ensure your biometric data is processed securely and only for the specified purposes.
3.4. Third-Party Payment Providers. Our third-party payment providers may directly collect and process your personal data, or we may disclose it to them.
3.5. Professional advisors: We may disclose your personal data to our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
3.6. Authorities and others: We may disclose your personal data to law enforcement, government authorities, and private parties as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. This may include biometric data where required by law or to prevent fraud, subject to strict safeguards and, where applicable, your consent.
3.7. Business transferees: We may disclose personal data in the context of actual or prospective business transactions (e.g., investments in Peira, financing of Peira, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares); for example, we may need to share certain personal data with prospective counterparties and their advisers. We may also disclose your personal data to an acquirer, successor, or assignee of Peira as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal data is transferred to one or more third parties as one of our business assets.
4. How long we keep your personal data
4.1. We only retain personal data for as long as is necessary for the purposes for which we use it.
4.2. We may retain your personal data longer:
(a) to comply with law;
(b) to protect the vital interests of any individual; or
(c) in connection with any legal claims (to the extent those claims are continuing after the end of the relevant retention period). This may include retaining biometric identifiers for a limited period to prevent fraudulent re-registration, but such data will be deleted as soon as it is no longer needed for this purpose.
4.3. Finally, we may create anonymised or aggregated records relating to demography or the use of the Platform, from which no individual is identifiable, and we may keep those records indefinitely.
5. Your role as controller
5.1. This Privacy Notice provides you, the individual Researcher, with information about how we use your personal data. However, you should bear in mind that as a Researcher using the Platform you may have access to personal data relating to Participants, and when you do you will be a data controller in relation to that personal data
6. Your right
6.1. You may have rights under certain data protection laws to the extent they apply. In summary, these may include:
(a) the right to access: you may have the right to confirmation as to whether or not we process your personal data and, where we do, to access the personal data, together with certain additional information;
(b) the right to rectification: you may have the right to have any inaccurate or incomplete personal data about you rectified or completed;
(c) the right to erasure: in some circumstances you may have the right to the erasure of your personal data (for example, if the personal data are no longer needed for the purposes for which they were processed or if the processing is for direct marketing purposes);
(d) the right to restrict processing: you may have the right to restrict the processing of your personal data to limit its use. Where processing has been restricted, we may continue to store your personal data and will observe the restrictions on processing except to the extent permitted by law;
(e) the right to object to processing: you may have the right to object to our processing of your personal data on the basis of legitimate interests (discussed above) or for direct marketing purposes and if you do so we will stop processing your personal data except to the extent permitted by law;
(f) to withdraw your consent: where we rely on consent as the legal basis to process your personal data, you can withdraw that consent at any time. (Please note that withdrawing your consent does not impact the lawfulness of any processing of your personal data based on that consent prior to you withdrawing it); and
(g) the right to complain to a supervisory authority: if you consider that our processing of your personal data is unlawful, you may have a legal right to lodge a complaint with your local data protection authority.
6.2. You can submit requests to exercise these rights by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfil any request you make will depend on a number of factors (e.g., why and how we are processing your personal data, where you are located, etc.).
7. Security
7.1. We use various technical, organizational, and physical measures to safeguard the personal data we gather, in line with relevant laws. Nevertheless, all internet and information technologies carry inherent security risks, and we cannot fully ensure the safety of your personal data.
8. Revisions
8.1. We continuously track legal developments, add new product features, and work to enhance our processes, which may lead us to update this Privacy Notice periodically. Where required under applicable law, we will obtain your consent to such changes, otherwise, your continued use of our services after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this privacy notice, you should stop using our services.