Privacy & Cookies

Our Privacy

Realeyes OÜ (“Realeyes”) conducts market research to help improve web content and online advertising for its customers. Our proprietary software is used to track facial features of people who choose to participate in our studies and to analyse their emotional response to on-screen media.

While Realeyes is committed to making the participant experience as natural and as unobtrusive as possible, we also take seriously the privacy of participants in our studies. Realeyes is established in Estonia (at Vahe 15, Tallinn 11615, Estonia, registry code: 11730664, contact: [email protected]), and we comply with the Estonian and European Union data protection requirements.
Our Privacy Policy tells you how we look after and use the Personal Information (see definition below) that we collect from participants through our Realeyes service, as well as information that we collect through our website at www.realeyesit.com (“Website”). Realeyes is the data controller for the data we collect. Please read this Privacy and Cookies Policy (“Policy’) carefully. When you participate in one of our studies and/or use our Website, you are agreeing to this Policy.

Safeguarding your privacy is of the utmost importance.

  1. Realeyes has a strict opt-in research policy. We only collect study data (including facial recordings) from participants who have given their explicit consent by allowing access to their webcam prior to each media viewing session.
  2. Any Personal Information that we collect from you will be treated as confidential through the implementation of security measures.
  3. We do not share study data with our customers in a way that allows for the identification of any specific individual who participates in our studies.

What does Personal Information mean?

Personal Information means anything that can be used to identify you, including facial recordings and IP addresses that we collect as you participate in our study or information that we collect from users of our website or our services.

If you do not agree with our Policy, please do not participate in Realeyes market research studies at this time or use our website.

Data security is our priority

All Personal Information will be stored in a secure location within the EU. We use industry standard technical and organizational security measures to protect your data against unauthorized disclosure or processing. These measures vary depending on the sensitivity of the information we have collected from you.

However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

What Personal Information do we collect?

Website Information 

When you use our Website, we and third parties may also use automated means to collect information about you, your computer or other device and your use of our Website. For instance, our web servers may collect and log information such as the type of device, operating system and browser you use when accessing our Website, and other system settings, such as language your system uses and the country and time zone where your device is located. Our web server may also record the address of the web page that referred you to our Website and the IP address of the device you use connect to our Website.

We also may collect any other information that you choose to provide when using our Website or our services. For instance, if you choose to create an account on our website, we will collect your name, company name, job title and email address. Creating an account will provide you the possibility to access advanced content which can include viewing our white papers presentations and to demo the Realeyes services.

If you create an account on our website and if you provide your consent for Realeyes to contact you, Realeyes may use your personal information to contact you and to ensure that the Website and services work correctly and to offer you support. The personal information might be needed also in case our registered users have issues with the Realeyes services or website.

Realeyes will not use users’ personal information for any other purpose without your consent or legal obligation to do so.

How we will use your Personal Information?

Realeyes specialises in market research and measures how people feel when they view on-screen media. We analyse these reactions to help our customers improve their content and advertising. Your participation in our studies is voluntary and highly valued.


The information that we share with our customers is anonymized and does not individually identify any study participants. Unless you consent, Realeyes will not share your Personal Information with third parties for marketing purposes. If you consent, Realeyes may use your data to assess quality assurance and to help improve software and reporting capabilities. Realeyes may use information collected from users of our Website to analyse the effectiveness of our Website.

If you create an account on our website and if you provide your consent for Realeyes to contact you, Realeyes may use your personal information to contact you and to ensure that the Website and services work correctly and to offer you support. The personal information might be needed also in case our registered users have issues with the Realeyes services or website.

Realeyes will not use users’ personal information for any other purpose without your consent or legal obligation to do so.

Services Information 

If you consent to participate in our Services, then we will collect the following personal information relating to you:
● Assignment of unique identifiers during Services engagements, including via cookies. 
● Your device environment and specifications:
○ Platform (mobile/tablet/desktop).
○ Browser name and version.
○ Operating System name and version.
○ Anonymised IP address with the last subnet discarded.
● Your interactions with the content via the device:
○ Whether a video loads and is in focus.
○ How you engage with a video.
○ Video metadata such as content ID, title, and category.
○ Percentage of video content that has been viewed. 
● Your interaction with the content, via the front-facing camera on your device:
If you have given us permission to use the front-facing camera on your device then, while you are interacting with the content, we access the data from the camera and process it on your device using our software to derive the following separate data-points:
The ○ Whether a face is detected and, if so, the position and orientation of the face relative to the screen. Our software does not engage in facial recognition of any kind. 
○ The extent to which you appear to be paying attention to the content.
○ Your apparent reaction to the content (levels of overall emotion displayed, such as happiness, surprise, sadness, feat, confusion, contempt or disgust). 
● Data we’ve accessed from the camera will be used strictly for client reporting and algorithmic enhancements.   
Realeyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless we obtain the required parental consent. Should we discover that any data has been collected from a participant under the age of 18, without the required consent, we will immediately delete it.

Who do we share your Personal Information with?

Realeyes may share your information in limited ways in order to provide our services:

  • We work with trusted partners to perform tasks on our behalf and we may need to disclose Personal Information to them so that they can perform these tasks. However, these companies are bound by confidentiality obligations and do not have any independent right to use Personal Information beyond what is necessary to assist us in order to provide our services.
  • We may share your Personal Information when we believe that doing so is necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of Realeyes, our employees or agents or users, or to comply with applicable law or legal process, including responding to requests from public and government authorities.
  • You agree that, if there is a change in the ownership of Realeyes or any of our assets, such as in connection with a merger, acquisition, reorganization, dissolution or liquidation), or if we take steps in anticipation of such a transaction, we may transfer and disclose Personal Information we have collected to the new or prospective company, subject always to the data protection regulations.
  • We may share anonymized, aggregated or de-identified data without restriction.
  • In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

How long do you keep this Personal Information for?

We store Personal Information for as long as it is required for our research and business purposes and as required by law. When Personal Information is no longer required, we will delete it from our systems.

With respect to information collected through our Services, we retain unique IDs for as long as is required to support our client market research programs, or until you request to be deleted or opt out of the Services.   

Cookies

Cookies are small text files that we place on your computer or device to allow us to track our research and assess participant behaviour information. We use third party service providers to track usage and interaction with the media players that are used to measure responses to advertisements. Our cookies are deleted after 13 months.

We also may use service providers like Google Analytics and Hubspot to help us analyse how users use our Website. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

To find out more about cookies and how to delete them, please visit http://www.aboutcookies.org.uk/managing-cookies

If you consent to taking part in our study, we will place a cookie on your browser containing a Participant ID which enables us to identify you in case you wish to see the data we hold of you. We require you to provide us the Participant ID in case you wish to access the participant records we hold of you.

If you opt out of participating in our study, we will place a cookie on your computer as it is required to remember your choice (the sole purpose of that cookie). If you delete your cookies from your browser, you will also be deleting your opt out and you may be asked to participate in our study again.

We do not have access to and this Policy does not govern the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below.

Do-Not-Track Signals and Similar Mechanisms

We do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

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Our website may contain links to third-party websites such as social media sites, and may also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Our media player may be placed on third party websites as part of their services to their users.
As these third-party websites and services are not operated by Realeyes, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and other information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.

Child Protection

Realeyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless we obtain the required consent. Should we discover that any data has been collected from a participant under the age of 18, without the required consent, we will immediately delete it.

International Transfer of Personal Information

We may transfer your Personal Information to countries outside of the European Economic Area EEA (such as the US). We do this for our data management and business purposes, in particular, for outsourced data processing by organisations on our behalf and in accordance with the stated aim of the data processing. We take appropriate steps to ensure your information is adequately protected. If you do not agree to this, please do not use our services.

Access to changes to your Personal Information

If you want to see, change or delete your Personal Information, contact us at [email protected] under the subject heading “Privacy Policy”. In certain jurisdictions, you may be entitled to request access to Personal Information we hold, by writing to us. A small fee may be charged for this service, to cover administrative costs.

Your rights under the GDPR

Please contact [email protected] for applications regarding your personal data. If you took part in our surveys, we can only identify your personal data using a Participant ID that was shown to you after the survey and which was also stored in a cookie on your device. Please keep record of your participant ID for future reference. If the Participant ID cannot be identified, Realeyes is not able to identify your data to fulfil your request.

Right of Access

The GDPR gives you the right to access information that we held about you. If you want to access that information, please send you request to [email protected] Any request for access of your information shall be a subject to providing the acceptable proof of identification. In relation to our studies we also require you to provide us the Participant ID shown to you when taking part in the study and which is also stored in a cookie on the device used to participate in our study. If all complies, you will be provided with the copy of your personal data. If a person’s request for information or measures is clearly unjustified or excessive, a reasonable fee may be asked, or the action taken may be refused.

Right of Rectification

You can have your personal data rectified at any time, in case it is inaccurate or incomplete. You should notify us to correct or update your personal data. You can notify us at any time at [email protected]

Right of Erasure

You can request to delete your personal data at any time by contacting us at [email protected]

Right to Restrict Processing

In certain circumstances, you have a right to restrict or block us from processing your personal data.

Right to Withdraw your Consent

If the processing is done based on your consent, you have the right to withdraw your consent to processing of your personal data at any time by contacting us at [email protected]

Right to object

At any given time, you have a right to object to the processing of your personal data. Services participants may opt-out through the settings included with the content engagement tools presented to them at the time of engagement, or potentially through our clients or partners who assisted with the consent request.  For all other Services objection requests, please follow the  deletion instructions.      

Complaints

The Policy is governed by legislation of Republic of Estonia. Any disputes regarding the in connection with this Policy shall be settled through negotiations. If the Parties fail to resolve the dispute through negotiation, the disputes shall be settled by Harju Maakohus (Harju County Court), pursuant to the procedure provided by the law of the Republic of Estonia.
If you have any concerns with the way we process or handle your data, we would encourage you to contact us directly to resolve your concerns. However, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate.

Contacting us

Please contact us if you have any comments or questions about information that we hold or about our Privacy Policy.

  • Send an email to [email protected] under the subject heading “Privacy Policy”
  • Write to us at 151 Wardour Street, London W1F 8WE, UK

Changes to our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of changes by posting an announcement on our service or website. You are bound by any changes to our Privacy Policy when you use our service after you are notified (by an announcement on our service or website) of these changes.
Last updated: 22 February 2021

California Consumer Privacy Disclosure

DefinitionsThe terms “Business Purpose(s)”, “Personal Information”, “Sell” (or “Sale”), “Service Provider(s)” and “Third Parties” have the meanings given in the California Consumer Privacy Act of 2018 (CCPA). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers.
Categories of collected Personal Information

Website visitors: Names, professional titles and company affiliations, email addresses, cookie IDs, IP addresses.

Market Research Services: Proprietary unique identifiers, IP addresses, cookie IDs, coded facial expressions, device heuristics, behavioral information associated with use of our software.  

Purposes for collection and use of Personal InformationWe use personal information to facilitate our website, conduct market research, and for marketing or communications.
Categories of sources from which Personal Information is collected Website, proprietary market research software, marketing activities and customer support services.
Categories of Personal Information we sellWe do not sell personal information.
Purposes for selling personal informationWe do not sell personal information.
Categories of Third Parties to whom Personal Information is soldWe do not sell personal information.
Categories of third parties to whom information was shared for a business purpose

Website hosting and content management services, technology and communications platforms, website analytics.

 

California Consumer Rights & Options
Access or Delete Your Personal Information

You have the ability to access or delete your personal information by emailing us at [email protected] under the subject heading “Privacy Policy”.

 

Please note we may not accept a request to access or delete your personal information where we can not verify your personal information or California residency, where we require it to comply with a legal obligation or in relation to a legal claim.

 

 

Thank you.

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