Eatpol Tester Privacy Policy

This Privacy Policy explains how Eatpol B.V. collects, uses, stores, shares, and deletes personal data relating to members of the Eatpol tester panel who sign up through the Eatpol app or otherwise participate in Eatpol-managed tester studies.

This Privacy Policy applies to testers. It does not by itself describe every data flow in studies where participants are recruited or managed directly on a client's instructions outside the Eatpol tester panel model.

The information below is intended to be clear, transparent, and specific as to purposes, categories of data, and key processing operations, in line with the principles of transparency, purpose limitation, minimisation, and storage limitation.

1. Who we are

Eatpol B.V. ("Eatpol", "we", "us" or "our") operates the Eatpol tester panel and related research platform.

The controller of your personal data for the Eatpol tester panel is: Eatpol B.V., Bronland 10, Wageningen, 6708WH, The Netherlands
Privacy contact: info@eatpol.com

2. What data we collect

Depending on how you use the Platform and which studies you join, we may collect the following categories of personal data.

2.1 Account and sign-up data

• first name and last name;
• email address;
• account confirmation status and related timestamps;
• sign-up log information such as IP address and confirmation-related log data;
• anti-fraud and bot-detection results.

2.2 Device and app data

• device identifiers used for push notifications;
• app interaction and access logs;
• technical metadata relevant to security, delivery, and troubleshooting.

2.3 Profile data

• age range;
• gender;
• nationality;
• occupation;
• city and country;
• dietary preferences;
• food allergies;
• postal address;
• phone number, where needed for delivery or coordination.

Food allergy information is health-related information and is treated with additional care. Eatpol seeks to minimise collection and sharing of such information and not to disclose it to clients unless strictly necessary for the relevant study setup.

2.4 Study participation data

• study invitations;
• screening answers;
• study acceptance records;
• consent records and version history;
• interview participation records;
• survey and questionnaire answers;
• reusable profile attributes derived from prior screening answers where relevant for future study matching.

2.5 Interview data

• audio-based interactions with the AI interviewer;
• turn-by-turn statements made during the interview;
• transcripts;
• AI-generated summaries.

Because interviews are open-ended, transcripts may contain information that you volunteer spontaneously, including information that was not specifically requested.

2.6 Video data

In some studies, we collect short participant-recorded videos showing product use at home.

For such studies, we may hold:

• the uploaded source video;
• a masked version of the video;
• technical metadata relevant to storage and processing;
• related internal analysis outputs.

We use face masking as a privacy measure. Face masking may not work with 100% accuracy in every situation, especially if the participant records from a side angle, under poor lighting, or in other challenging conditions. For that reason, participants may be instructed to record front-facing video where feasible.

We do not use these videos for facial recognition and do not create facial templates to identify participants. The mere collection of video does not by itself make the processing biometric identification; biometric processing requires additional technical extraction and matching for unique identification.

2.7 Payment and reward data

• credits earned;
• voucher or payment redemption records;
• payment provider-related identity details needed to issue rewards;
• accounting and audit records.

2.8 Panel responses, poll answers and support communications

• answers you provide in daily in-app polls, panel questions, questionnaires and similar activities;
• study responses, including text, audio and video responses where a study includes those formats;
• messages you send to us through support, email or in-app communications;
• notifications sent;
• community comments or similar app interactions, if enabled.

3. How we collect your data

We collect personal data:

• directly from you when you sign up, complete your profile, answer questions, join studies, upload videos, or contact us;
• automatically from your device or app usage for functionality, security, and notification purposes;
• from service providers assisting us with sign-up security, notifications, email delivery, AI interviewing, cloud infrastructure, or rewards;
• from internal processing of study answers where certain screening responses are stored as reusable panel attributes.

4. Why we use your data

We use personal data for the following purposes.

4.1 Operating the tester panel

• creating and maintaining your account;
• verifying your email;
• administering your membership in the panel;
• managing study invitations and participation.

4.2 Fraud prevention and security

• detecting duplicate or abusive accounts;
• preventing reward abuse;
• protecting the app and systems;
• maintaining logs, access records, and security monitoring.

4.3 Study management and research execution

• selecting relevant testers;
• running surveys and interviews;
• collecting and analysing participant responses;
• generating summaries and research outputs;
• creating client reports with aggregated or otherwise restricted participant outputs.

We may also combine your answers with those of other participants to create de-identified example profiles ("personas") that the study team may explore with AI. A persona is not your profile and does not show your name or contact details.

4.4 Handling video submissions

• receiving, storing, masking, and reviewing participant videos;
• quality control;
• preparing pseudonymised or de-identified materials for restricted client viewing where applicable;
• ensuring study integrity and evidence of participation.

4.5 Rewards and accounting

• calculating and issuing credits or rewards;
• processing redemptions through the relevant provider;
• maintaining accounting and audit records.

4.6 Support and communications

• sending service notifications;
• responding to support requests;
• improving user experience and app reliability.

4.7 Optional AI training and model improvement

If you separately opt in before a recording, we may use the relevant study video and related labels or annotations to develop, train, test and improve AI models and related technology used to analyse consumer behaviour and consumer-product interactions. This optional use is separate from participation in the study itself.

This training is for computer-vision models that recognise consumer actions in video, such as opening a pack, pouring, taking a bite, chewing or taking a sip. Your interview transcripts and survey answers are not used for it.

For this optional AI training purpose, Eatpol uses the masked version of the relevant video rather than the raw source video. However, face masking is automated and is not 100% accurate in every case. In some situations, including certain recording angles, lighting conditions or movement, the masked version may still contain occasional unmasked frames or other imperfect masking. This training use therefore still involves personal data.

A video is used for this training only if you have opted in and the client that commissioned the study has also agreed. Training runs on Eatpol's own infrastructure in the EU, and your videos are not sent to an external AI model provider for training.

Eatpol may use models trained through this optional programme in its internal tools and in commercial products or services provided to business customers.

This use is limited by the scope of the permission requested. It is distinct from the core study itself and is not a condition for study participation or reward eligibility.

Eatpol does not use this process to identify you, perform facial recognition, or conduct emotion recognition.

4.8 Aggregated benchmarks and published insights

To combine study responses and daily poll answers into aggregated statistics, benchmark datasets and insight materials that are designed not to identify any individual tester.

4.9 Use of aggregated insights for product development and marketing

To use the aggregated statistics, benchmarks and insight materials described above for improving our services, developing our products, creating market insights, and producing business-facing publications, case studies, sales materials and other marketing content. These materials are not intended to identify you personally.

4.10 Optional use of video clips in Eatpol marketing

If you separately opt in before a recording, we may use face-masked clips or still images from the relevant study video in Eatpol's own marketing, such as LinkedIn and other social media, our website, case studies, sales presentations, newsletters and events. We may edit clips, for example by trimming, cropping, adding captions or music, or blurring backgrounds.

We use only the masked version of the video, do not show your name, username, contact details or location, and remove your original voice unless you separately agree. A clip is used only if the client that commissioned the study has approved it. Marketing content is public and, because face masking is not 100% accurate, you may occasionally be recognisable.

This use is based on your consent. It is optional, requested separately from the AI-training opt-in, and does not affect your participation or rewards. See Sections 7.4, 9.3 and 10.

5. Legal bases

Depending on the activity, Eatpol relies on one or more of the following legal bases.

5.1 Contract / steps at your request

Where needed to create and manage your tester account, run the panel relationship, deliver study participation, and issue rewards.

5.2 Consent

Where we rely on consent, this includes in particular:

• marketing communications where applicable;
• participation elements requiring specific consent in the study flow;
• optional use of eligible participant materials for AI training and model improvement;
• optional use of face-masked study video clips in Eatpol marketing (Section 4.10).

Where consent is used, it must be specific, informed, and distinguishable from other matters.

We rely on your consent where required by law, including for the optional AI-training use of your study videos described in Section 4.7. If we ask for consent, you can refuse it and you can withdraw it later as described in Section 10.

5.3 Legitimate interests

Where necessary for:

• panel administration;
• fraud prevention;
• app security;
• service improvement;
• internal record-keeping;
• creating de-identified example profiles ("personas"), aggregated statistics, benchmark datasets and insight materials from study responses and daily poll answers;
• using those personas, aggregated statistics and insight materials for research analysis, study exploration, product development and business-facing marketing, provided they are designed not to identify you;
• limited quality assurance.

Any legitimate interest-based processing must remain necessary, proportionate, and consistent with your reasonable expectations.

When we rely on legitimate interests, we consider the impact on your rights and interests and apply safeguards such as aggregation, de-identification, access controls and measures designed to reduce the risk of identification. You may have the right to object to processing carried out on this basis in certain circumstances. Where personas are used, they are designed as example profiles for research exploration and not as profiles used to make decisions about you as an individual tester.

5.4 Legal obligations

Where required for accounting, tax, compliance, legal claims, or related record-keeping.

5.5 Special categories of data

Food allergy information may constitute health-related data. Eatpol treats it as particularly sensitive and seeks to restrict its collection, access, use, and sharing to what is genuinely necessary. Where required, Eatpol will rely on an appropriate additional legal basis or explicit consent depending on the study context and applicable law.

6. What clients see

Eatpol's clients do not receive your ordinary account identifiers such as your name, email address, postal address, or phone number in ordinary client reports.

Clients generally receive:

• aggregated findings;
• counts and summaries;
• selected quotations attributed only by limited descriptive labels where relevant;
• where the study design includes them, de-identified example profiles ("personas") derived from combined participant responses and designed not to identify any individual tester.

Where participant videos or transcripts are made available to a client, they are made available only through controlled access and not as unrestricted downloads. Eatpol applies masking and/or redaction measures designed to reduce the risk of direct identification. Such materials remain personal data in pseudonymised form rather than anonymous data.

Where videos are shown to clients, Eatpol applies automated face masking designed to reduce the risk of direct identification. However, face masking is not 100% accurate, and a client reviewer may occasionally see unmasked frames of your face.

Client access is limited by contractual and technical controls, and clients are not permitted to use participant materials to try to identify testers.

Eatpol may decide not to share food allergy information or dietary preference data with clients except where strictly necessary for safe and proper study execution.

6.1 Important information about video privacy

If you take part in a video-based study, please remember:

• your video may be shared with the relevant client through controlled viewing access if the study requires that;
• Eatpol uses automated face masking to reduce identification risk;
• masking is not perfect and may fail in some frames;
• as a result, a client reviewer may occasionally see unmasked frames of your face;
• Eatpol does not provide unrestricted public access to participant videos, except face-masked clips you have separately agreed may be used in Eatpol marketing under Section 4.10;
• the optional AI-training use of your video only happens if you separately opt in before recording and the client that commissioned the study has also agreed; and
• the optional marketing use of your video only happens if you separately opt in before recording and the client that commissioned the study has approved it.

7. Who we share data with

We share tester personal data only where necessary and for defined purposes.

7.1 Service providers

Current service providers may include providers used for:

• AI interview functionality and transcript/summary generation;
• push notifications and sign-up verification;
• cloud infrastructure and storage;
• email delivery;
• reward or voucher issuance.

Where these providers process personal data on our behalf, we require appropriate contractual protections consistent with applicable data protection law.

Where we send personal data to service providers, we seek to limit that data to what is reasonably necessary for the relevant purpose and apply appropriate technical and organisational protections.

7.2 Clients

Eatpol shares study outputs with clients in accordance with the relevant study design and contractual controls, typically in aggregated or otherwise restricted form. Where a study includes personas, clients may also receive or access de-identified example profiles derived from combined participant responses, designed not to identify any individual tester.

7.3 Authorities and legal claims

We may disclose data where required by law, legal process, or to establish, exercise, or defend legal claims.

7.4 Public marketing channels

If you opt in under Section 4.10, face-masked clips of your video may be published on Eatpol's website and on social media platforms such as LinkedIn, Instagram, YouTube and TikTok. Content published there is public. These platforms process it as independent controllers under their own terms and may process it outside the EU/EEA.

8. International transfers

Eatpol seeks to keep tester data within the European Union where possible. However, some providers may involve processing or access outside the EU/EEA.

Where personal data is transferred outside the EU/EEA, Eatpol uses an appropriate transfer mechanism, such as the European Commission's Standard Contractual Clauses, and supplementary measures where appropriate.

Material sent to Anthropic after removal of direct identifiers remains pseudonymised personal data, not anonymous data.

9. Storage and retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, taking into account the nature of the data, the purpose of the processing, legal obligations, dispute handling, and security needs.

If we no longer need personal data for an identifiable purpose, we may delete it, aggregate it or anonymise it.

9.1 Panel profile

Retained while you remain an active tester, unless earlier deleted at your request or otherwise removed.

9.2 Interviews and transcripts

Retained for up to 2 years, unless earlier deleted on account deletion or where longer retention is required for a specific lawful reason already disclosed.

9.3 Video recordings

Retained for up to 5 years, unless deleted earlier due to account deletion, a valid deletion request, withdrawal where applicable, or where a shorter retention period applies operationally.

Where you delete your account, Eatpol may delete associated videos linked to your account rather than waiting for the standard storage expiry.

Marketing clips used under Section 4.10 are kept for up to 3 years from the recording date, or until you withdraw your consent, whichever comes first.

9.4 Payment records

Retained for up to 7 years or such other period as required by applicable accounting or tax obligations. These may not be deleted immediately upon an ordinary deletion request where legal retention is required.

9.5 Superseded file copies

Retained for up to 90 days in line with system handling.

9.6 Sign-up and security logs

Retained only as long as reasonably necessary for anti-fraud, security, troubleshooting, and audit purposes, after which they are deleted or minimised. Verification or confirmation-code logs are retained only for as long as reasonably necessary for security, troubleshooting and fraud-prevention purposes, and then deleted or anonymised.

9.7 Poll answers and panel responses

Poll answers and similar panel-response data may be retained for analytics, benchmarking and service improvement where appropriate safeguards are applied.

9.8 Consent records

Consent records are kept for as long as necessary to demonstrate the consent collected and to manage withdrawals.

10. Account deletion and withdrawal

You may request deletion through the app or through Eatpol's deletion request page.

When you delete your account or make a valid deletion request, Eatpol will delete or de-link relevant account data in accordance with its operational processes, including deletion of associated videos where applicable, while keeping only those records that must lawfully be retained, such as payment records or limited legal-defence records.

If we rely on your consent, you may withdraw that consent at any time. For the optional AI-training consent, you can do this in the app. For the optional marketing consent, you can do this in the app or by emailing info@eatpol.com. Withdrawal does not affect processing already carried out before withdrawal.

If you have separately opted in to AI training use and later withdraw that permission:

• Eatpol will stop using the relevant video and related labels or annotations for any future training runs;
• Eatpol will remove those source materials and related labels or annotations from future training datasets under its operational process;
• models already trained are not retrained or untrained, and already trained model weights may not be reversible on an individual-source basis, but Eatpol will not continue to use the withdrawn source materials for future model training.

If you have separately opted in to marketing use and later withdraw that permission:

• Eatpol will stop any new marketing use of your video immediately;
• Eatpol will remove your clips from channels it controls, such as its website, its own social media posts and current sales materials, as soon as reasonably practicable and in any event within 30 days; and
• Eatpol cannot recall copies that others have already shared, reposted or downloaded, or printed materials already distributed.

11. Security

Eatpol uses technical and organisational measures intended to protect personal data, including encryption in transit and at rest, access logging, cloud security controls, monitoring, and internal access restrictions.

Because no system can guarantee absolute security, Eatpol cannot promise that every measure, including face masking, will work perfectly in every case. Measures are designed to reduce risk materially, not to make identification impossible in every circumstance.

12. Your rights

Subject to applicable law, you may have the right to:

• access your personal data;
• request correction;
• request deletion;
• object to certain processing;
• request restriction;
• withdraw consent where processing is based on consent;
• request portability where applicable;
• lodge a complaint with a competent supervisory authority.

Eatpol will facilitate the exercise of these rights and respond in a concise, transparent, and accessible manner.

To exercise your rights, contact us at info@eatpol.com.

13. Children

The Platform is not intended for testers below the minimum required age. If Eatpol learns that personal data was collected from someone not eligible to participate, Eatpol may delete the account and related data subject to legal retention needs.

14. Changes to this Privacy Policy

Eatpol may update this Privacy Policy from time to time. If the changes are material, Eatpol may notify you through the app, by email, or by another appropriate method.

15. Contact

If you have questions about this policy or want to exercise your privacy rights, contact: Eatpol B.V., Bronland 10, 6708WH Wageningen, The Netherlands
info@eatpol.com