Eatpol Privacy Policy
Table of Contents
- 1. Introduction
- 2. Data Controller
- 3. Personal Data We Collect
- 4. How We Use Your Personal Data
- 5. Legal Basis for Processing (GDPR)
- 6. Data Sharing and Disclosure
- 7. Data Retention
- 8. Your Rights Under GDPR
- 9. International Data Transfers
- 10. Data Security
- 11. Cookies and Tracking
- 12. Children's Privacy
- 13. Changes to This Policy
- 14. Contact Information
- 15. Supervisory Authority
1. Introduction
Eatpol.com ("we," "us," "our," or "Eatpol") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you use our food testing platform services.
This policy applies to all users of our website and food testing services, including registered testers and visitors to www.eatpol.com.
2. Data Controller
Eatpol.com is the data controller for the personal data we process. Our contact details are provided at the end of this policy.
3. Personal Data We Collect
3.1 Registration Information
When you sign up as a tester, we collect:
- Full name
- Email address
- Phone number
- Postal address (for shipping food samples)
- Date of birth (to verify age eligibility)
- Dietary restrictions and food allergies
- Payment information for compensation
3.2 Testing Data
During food testing activities, we collect:
- Video recordings of you consuming food products
- Facial expressions and reactions (processed by AI)
- Audio recordings of your comments and feedback
- Written feedback and survey responses
- Timestamps and duration of testing sessions
- Emotions, cooking, and preparation activity
3.3 Technical Data
We automatically collect:
- Browser type and version
- Operating system
- Website usage patterns and analytics
- Cookies and similar tracking technologies
- Google Analytics data (page views, session duration, bounce rate)
- Anonymized IP addresses
- Device type and screen resolution
3.4 Communication Data
- Email correspondence with our support team
- Chats via WhatsApp Business (if mobile support is required)
- Feedback about our services
4. How We Use Your Personal Data
4.1 Service Provision
- Match you with appropriate food testing opportunities
- Ship food samples to your address
- Process compensation payments using your bank account details
- Provide customer support
4.2 AI Analysis and Facial Masking
- Facial Recognition: We use AI to analyze facial expressions and reactions for research purposes
- Privacy Protection: AI facial masking technology anonymizes your identity in recordings that preserve your privacy
- Data Processing: Your reactions are converted to anonymized analytical data
- Storage: Original recordings from preparation, cooking, and storage do not include faces and are recorded without applying the masking technology. Videos from sensory tests and eating activities, as well as all videos where we ask you to record yourself showing your face, are securely stored and your identity is masked before any analysis.
Important Notice: For preparation, cooking, and storage videos, testers are required to record in POV (point-of-view) format without showing their face. If testers do not follow these instructions and show their face in these POV-required videos, Eatpol is not liable for any privacy concerns as the facial masking technology is only applied to videos where we specifically require frontal face recording (sensory tests and eating activities). Testers are responsible for following recording instructions to ensure their privacy protection.
4.3 Business Operations
- Improve our platform and services
- Ensure compliance with our terms and conditions
- Prevent fraud and maintain security
- Conduct market research and analytics
4.4 Legal Compliance
- Comply with applicable laws and regulations
- Respond to legal requests and court orders
- Protect our rights and interests
5. Legal Basis for Processing (GDPR)
We process your personal data based on:
- Contract Performance: To provide food testing services and process payments
- Consent: For video recordings and AI analysis (you can withdraw consent anytime)
- Legitimate Interests: For business operations, security, and service improvement
- Legal Obligation: To comply with tax, accounting, and other legal requirements
6. Data Sharing and Disclosure
6.1 Food Companies
We share anonymized, aggregated data with food companies, including:
- Overall reaction trends and statistics
- Anonymized feedback and comments
- Demographic insights (without personal identifiers)
We DO NOT share:
- Your name, contact information, or personal identifiers
- Unmasked video recordings
- Individual personal data
6.2 Service Providers
We may share data with trusted third parties who help us operate our business:
- Payment processors (for compensation)
- Shipping companies (for sample delivery)
- Cloud storage providers (for secure data storage)
- AI technology providers (for facial masking and analysis)
All service providers are contractually bound to protect your data and use it only for specified purposes.
6.3 Legal Requirements
We may disclose your data if required by law, court order, or to protect our legal rights and safety.
7. Data Retention
- Registration Data: Retained while you're an active tester, deleted within 2 years of account closure
- Video Recordings: Stored securely for up to 5 years for research purposes, then deleted
- Anonymized Analytics: May be retained indefinitely as it cannot identify you
- Payment Records: Retained for 7 years for tax and accounting purposes
8. Your Rights Under GDPR
You have the following rights regarding your personal data:
8.1 Access Rights
- Request copies of your personal data
- Receive information about how we process your data
8.2 Correction and Deletion
- Correct inaccurate personal data
- Request deletion of your data (subject to legal obligations)
8.3 Processing Rights
- Object to processing based on legitimate interests
- Restrict processing in certain circumstances
- Data portability (receive your data in structured format)
8.4 Consent Withdrawal
- Withdraw consent for video recording and AI analysis at any time
- Note: Withdrawal doesn't affect previously processed data
8.5 Complaints
- File complaints with your local data protection authority
- Contact us directly with privacy concerns
9. International Data Transfers
If we transfer your data outside the EU/EEA, we ensure adequate protection through:
- EU Commission adequacy decisions
- Standard Contractual Clauses
- Other approved transfer mechanisms
10. Data Security
We implement robust security measures:
- Encryption: All data encrypted in transit and at rest
- Access Controls: Strict employee access limitations
- AI Facial Masking: Automatic identity protection in recordings
- Secure Storage: GDPR-compliant cloud infrastructure
- Regular Audits: Security assessments and updates
12. Children's Privacy
Our services are not intended for individuals under 18. We do not knowingly collect data from minors. If we discover such collection, we will delete the data immediately.
13. Changes to This Policy
We may update this privacy policy periodically. Significant changes will be communicated via:
- Email notification to registered users
- Prominent website notice
- Updated "Last Modified" date
Continued use of our services after changes constitutes acceptance of the updated policy.
14. Contact Information
Data Protection Officer: Michele Tufano
Email: mtufano@eatpol.com
Address: Bronland 10, 6708WH, Wageningen, The Netherlands
Phone: +31 (0) 611 61 22 01
For privacy-related questions or to exercise your rights, please contact us using the above information.
15. Supervisory Authority
If you're located in the EU, you can contact your local data protection authority if you have concerns about our data processing practices.
GDPR Compliance: This privacy policy complies with the General Data Protection Regulation (GDPR) and ensures transparency about how we handle your personal data.
Data Subject Rights: You have comprehensive rights over your personal data. Contact us to exercise these rights or if you have any privacy concerns.