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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 market research 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:, 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 services, as well as information that we collect through our website at (“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 market researches or use our Website, you are agreeing to this Policy.

Safeguarding your privacy is of the utmost importance

  1. Realeyes leaves you in charge in terms of your Personal Data. 
  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 your data collected during market research 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 market research 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 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 (data processors we engage such as website hosting and content management services providers, technology and communications platform providers, providers of website analytics) may 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 collect other information that you choose to provide when using our Website or our services. 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 etc.)

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

Information collected during market research

This category of personal data includes all data we collect during a market research (including any media analysis carried out for the benefit of Realeyes’ customers and software improvement)

Such personal data includes the following

  • Assignment of unique identifiers during Services engagements, including via cookies.
  • Survey responses and market research study data explicitly provided by the subjects of the survey or market research data.
  • 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.
  • Facial recordings of you as you interact with the media content, via your device’s front-facing camera:

If you have given us permission to use the front-facing camera of your device then, while you are interacting with the content, we access the data from the camera and process it in our cloud environment using our software to derive the following separate data-points:

  • 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 have accessed from the camera will be used strictly for reporting to our customers and for enhancements in the use of software.
  • Realeyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless (i) applicable local data protection legislation provides for a lower threshold age; or (ii) we obtain the required parental consent. Should we discover that any data has been collected from a participant under the age of 18, without meeting either conditions under points (i) or (ii) above, we will immediately delete it.

How we will use your Personal Information?

We use your Personal Information for the following purposes.

Most of the Personal Information we collect is related to purposes of conducting market research. In our use, market research covers different activities, based on two different legal basis: a) market research for media analysis carried out for the benefit of customers of Realeyes (including quality assurance); and b) software improvement purposes intended to enhance, extend and develop features and functionalities of the proprietary software we use and our market research services we provide to our customers.

Realeyes specialises in market research and we analyse 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 test participants in the market research. The legal basis for such analysis is our legitimate interest in order to facilitate the improvement of our clients’ creative materials through analysis of attentiveness, engagement and emotional responses of the test subjects. Broadly speaking legitimate interests means that we process your personal information (i.e. facial image, device data and other data that you share with us) based on our genuine and legitimate reason and on condition that we are not harming any of your rights and freedoms during such use. In our assessment, we have taken into account considerations of the risks present in our processing, your likely response to those risks and the benefits you are likely to receive from such processing.

With regard to software improvement purposes, we collect Personal Information only from participants who have given their explicit consent. In this case, we access the same information collected during market research as applicable to the access based on the legitimate interest assessment.

For software improvement purposes, we do not collect any biometric data of you besides your facial image on the video. However, our machine learning models are being trained to be able to tell if the same individual appears on two separate photos or not. These models are built and trained on datasets of real data, such as your facial data that we collect.

Facial images as such can be considered as biometric data, if the following three conditions are met:

a) data relating to physical, physiological or behavioural characteristics of a natural person (including facial images);

b) such personal data results from specific technical processing of data set out in a); and

c) personal data is used to uniquely identify a natural person.

Our purpose is to improve our machine learning model in a way that it will be capable of uniquely differentiating one natural person from another one, but currently, our purpose for using your facial images is not to uniquely identify you, but to properly train our machine learning models.

Our research and development team don’t have any other information about you and does not intend to uniquely identify you in any other way.

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. Further use is also specified in this Policy under the Cookies section.

Realeyes will not share your Personal Information with third parties for marketing purposes.

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

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 the following tasks on our behalf and we may need to disclose Personal Information to them so that they can perform these tasks. These tasks include website hosting, content management services, technology and communications platform providers and providers of website analytics, annotation service providers. 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, where appropriate and where we have the necessary legal basis, with any member of our group of companies, any of our affiliates or direct or indirect licensees. Any disclosure will be in accordance with data protection regulations and you consent to share your Personal Information with our group companies and affiliates.
  • 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.


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

If you take part in a market research, 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 a market research, 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 market researches 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.

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 beyond incorporating such third-party plug-ins to our website. The collection, use, and disclosure of your personal and other information will also be subject to the privacy policies of the third party websites or services, and not only this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.

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 stated above and as required by law. Unless you have consented to our processing for software improvement purposes we will delete your video recordings and unique IDs collected for market research purpose after it is no longer required to support a market research for a customer, but anyways not longer than 90 days after being recorded for such purpose. When Personal Information is no longer required, we will delete it from our systems.

If you request deletion of any of your Personal Information (see right to erasure as set out below), we will delete that particular data within 30 days of receipt of your request.

Child Protection

Realeyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless (i) applicable local data protection legislation provides for a lower threshold age; or (ii) we obtain the required consent under applicable law. Should we discover that any data has been collected from a participant under the age of 18, without meeting either conditions under points (i) or (ii) above, 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.

Details of personal data processing activities specifically related to RealDepth application

Details of processing set out in this Section are only and exclusively applicable to our data collections carried out through RealDepth application. Rest of this Policy, that does not contradict with the provisions under this heading, is continuously applicable to the processing activities relating to RealDepth application (e.g. information concerning your rights under GDPR or complaints).

a) Personal data categories processed

The following categories of personal data are processed on your device during any test a part of which consists of the use of RealDepth mobile application (collectively referred to as ‘RealDepth Data’):

  • RGB Video Stream (practically this means the video recording itself);

  • Audio Stream (meaning the audio of the video recording);

  • Depth Stream and Mesh and Head transform stream (in simple terms this covers the in-depth data of your face, and your 3D facial landmark data);

  • RGB Camera Metadata (covering the meta data of your device’s camera);

  • Depth Camera Metadata (this is meta data related to the in-depth camera);

  • Application Metadata concerning device environment and specifications (including device name, operating system version).

b) Purpose of processing

Provided that you share RealDepth Data with us outside of RealDepth mobile application, RealDepth Data listed under point (a) above is processed for software improvement purposes. Software improvement means both software improvement, software development and related research (R&D) purposes as well. Such purposes may serve the benefit of either Realeyes or any of its direct or indirect licensees (as further detailed in the given information notice provided to you on a case-by-case basis).

    If we want to use your RealDepth Data for specific purposes materially different from those specified above, we will request your consent.

    c) Storing and sharing of RealDepth Data

    Unless you specifically consent to such disclosure, we do not share your RealDepth Data with any third parties. In fact, as RealDepth Data is stored locally on your device, even Realeyes has no access to such data.

    d) Retention of RealDepth Data

    Retention periods are exclusively determined by you, as Realeyes has no direct access to the RealDepth Data once those are recorded. RealDepth Data is retained as long as you do not delete them from the local storage of your device.

    Access to changes to your Personal Information

    If you want to see, change or delete your Personal Information, contact us at 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 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 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

    Right of Erasure

    You can request to delete your personal data at any time by contacting us at

    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

    Right to object

    At any given time, you have a right to object to the processing of your personal data. Please follow the instructions for erasure.


    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 (you may find their contact details here:

    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 under the subject heading “Privacy Policy”
    Write to us at Realeyes, Brook House, 19 Langham Street, London, W1W 6BP

    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 website or during the use of the software or other service we provide. You are bound by any changes to our Privacy Policy when you use our service after you are notified of these changes (by an announcement on our website or in the software or during other service).

    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: 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 the operation of 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, annotation service providers.


    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 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.


    Last updated: 8th May 2023

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