Version: 2025.04.11

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 Participants in relation to their use of the Platform, through which they can access and take part in Studies.

Personal data we collect

Here’s the personal data we may collect in relation to your use of the Platform as a Participant:

We may collect account information, such as your name, email address, date of birth, mobile number, address, other contact details and login information.

We may collect profile information of your account on the Platform in response to any profile or screening questions. We use your responses to these questions to determine your eligibility for different Studies (including when a Researcher has asked us to screen for Participants meeting specific requirements from time to time). This profile information could include a range of data, depending on which profile or screening questions you have chosen to answer, but could include (as a non-exhaustive list) gender, relationship status, interests, hobbies, educational details and employment status. It could also include special categories of data, like data about your race, ethnic origin, politics, religion, health, sex life or sexual orientation. All profile or screening questions are optional.

We (or our third-party verification providers) may collect verification information about you:

Identity checks: As part of your onboarding process on the Platform, we may conduct certain identity checks.

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.

We may collect activity data about your use of the Platform. This includes basic records of Studies you have participated in (including frequency, title(s), start and end times, and your location) and log files generated through your use of the Platform.

We may collect transaction data such as paid rewards you have earned on the Platform.

We may collect certain limited payment information about you such as your cryptocurrency wallet address.

We may collect user-generated content such as the information you choose to post publicly regarding the Platform in a user forum.

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.

We may collect third-party account data. If you use a third-party application like Facebook to log into your account on the Platform then we may receive and process account data from the relevant third-party used to verify your login.

From time to time we may collect general or specific feedback and testimonials from you. For example, this might include written comments and quotes, and information you share with us in interviews.

We may collect and generate 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’).

Mobile Sensing Data: For Studies involving Mobile Sensing, we or the Researcher may collect health-related data (e.g., heart rate, sleep patterns, physical activity) and device metadata (e.g., device ID, timestamps) from your Wearable Devices, typically on a continuous basis until the Study concludes. This applies to both External Studies (where data goes directly to the Researcher) and Peira-native Studies (where we process it on the Researcher’s behalf).

For Studies that are created by Researchers on third-party platforms and listed on Peira (“External Studies”), as they take place outside of Peira, Peira does not usually have access to your Study responses, except in limited circumstances such as where we need to resolve a dispute. Instead, you provide your Study responses direct to the Researcher and they act as the data controller in relation to that data.

For Studies that are created by Researchers on our Platform (“Peira-native Studies”), Peira will have access to your Study responses. Where this is the case, the Researcher will still act as the data controller in relation to your Study responses, and their privacy notice - and not ours - will apply. We will act as a data processor of the data comprising your Study responses, because we are handling it on the Researcher’s behalf.

What we do with your personal data

We may use your personal data for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

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; and (7) facilitate Mobile Sensing Studies by collecting and transmitting data from your Wearable Devices to Researchers, where applicable.

Research and development

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.

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.

Analytics and service improvement

We may utilize your usage data to gain insights into how you interact with the Platform and participate in 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.

Occasionally, we may also use your data for staff training and development purposes.

Marketing and advertising

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 (including Studies and select Participant groups) and to promote different features and services.

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.

Compliance and protection

We may use your personal data to: (1) confirm your identity to prevent fraud and document the verification steps we’ve taken; (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.

Resolving disputes

In rare situations, a Researcher may provide us with a small portion of a Study response - for instance, to address a disagreement between the Researcher and a Participant that we’ve been asked to mediate, or in response to a user complaint about the Study or its responses, or during an investigation into potential fraud, or if a response triggers safeguarding or legal issues. These cases are uncommon, and we prefer they be handled without us accessing any part of a Study response whenever possible. Should we need to review a portion of a Study response for these reasons, we will use your personal data solely to address that specific matter.

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:

- where we need to perform a contract that we are about to enter into or have entered into with you (“Contractual Necessity”);
- 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”);
- where we need to comply with a legal or regulatory obligation (“Compliance with Law”); and
- where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

What personal data is shared with Researchers?

We may share personal data with Researchers in the following ways:

Account Information: We may share your account information with Researchers for Study-related purposes. Researchers receiving this data act as data controllers, and their privacy notices govern its use. We are not responsible for their actions or misuse of your data once shared.

Profile and Performance Data: We share profile information (e.g., demographic data) and performance data (e.g., Study completion metrics) linked to your Peira ID with Researchers for screening and Study purposes.

Study Responses: For External Studies, you provide responses directly to Researchers, who act as data controllers. For Peira-native Studies, we process responses on the Researcher’s behalf as a data processor and share them with the Researcher, who remains the data controller.

In limited cases (e.g., fraud, misconduct, or breach of confidentiality under the Study Terms), we may disclose direct identifiers to Researchers without additional consent to enable them to pursue remedies.

If you participate in Studies requiring additional data (e.g., Mobile Sensing data like heart rate), Researchers may collect this directly from you, governed by their privacy notice. We encourage you to review each Researcher’s privacy notice before consenting to share any data.

What third parties (other than Researchers) do we share your personal data with?

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.

Third-Party Payment Providers: Our third-party payment providers may directly collect and process your personal data, or we may disclose it to them.

Linked third-party services: If you log into the Platform with, or otherwise link your Platform account to, a social media or other third-party service, we may share certain of your personal data with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

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.

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.

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.

We may also disclose certain data about you on an aggregated, de-identified and/or anonymised basis to selected third parties for research and development purposes.

How long we keep your personal data

We only retain your personal data for as long as we need it for the purposes described above and as permitted by law.

However, there are some reasons that we need to keep Participants’ data for longer. For example:

- to comply with the law or to fulfil any financial reporting obligations;

- to demonstrate our compliance with relevant laws, legal terms and policies (for example, if payment of a reward is suspended or a Participant’s account is terminated, we may keep some account information and evidence of the reason for the suspension/termination);

- in connection with an outstanding issue, complaint, dispute or claim (for example, we may keep relevant correspondence, extracts of any Study responses we have access to, and other information which is necessary for evidential purposes);

- where it’s necessary for our legitimate business interests, such as preventing fraud or illegitimate activity and enhancing security for other Participants and Researchers on the Platform (for example, we keep some account information and verification information where a Participant has been banned from the Platform to prevent them from registering for a new account).

Your rights

You may have rights under certain data protection laws to the extent they apply. In summary, these may include:

- 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;

- the right to rectification: you may have the right to have any inaccurate or incomplete personal data about you rectified or completed;

- 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);

- 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;

- 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;

- 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

- 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.

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.).

Security

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.

Revisions

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.