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We are Element Human Limited, a company registered in England and Wales with company number 08587003 and registered address at 7 Savoy Court, London, WC2R 0EX.

You can get in touch with us at any time to discuss how we use your personal data either by email at [email protected] or by writing to us at 7 Savoy Court, London, WC2R 0EX.

Our data protection officer is Phil Davison. You can contact him by emailing [email protected] or by writing to 7 Savoy Court, London, WC2R 0EX.

On what basis do we process your personal data?

You are in control of your personal data. Element Human will only collect and use your personal data provided where you take part in an activity run on our platform and where the law permits us to.

Where you have given your consent to our processing of your personal data, we may use your personal data to provide information to the partner whose activity you participated in and, where you have consented, for research purposes. You may withdraw your consent at any time by emailing [email protected].

We may also collect and process certain types of data, for example your IP address and any unique respondent ID, when:

  • it is necessary for our legitimate interests, namely to administer and protect our business and the platform, for example for network security purposes or to anonymise your data; or

  • when we need to comply with a legal obligation, for example by managing the information we hold about you.

What information do we collect (including sensitive information) and how will we use your personal data?

We may collect the following sensitive information from you where you have consented:

  • racial and ethnic origin as revealed by the video;

  • health information, if revealed by the video; and

  • biometric (e.g. facial images) data collected from the video.

We may collect the following information from you:

  • the video recordings from your webcam during the course of the activity only;

  • your response to activities and questions we ask you;

  • information you specifically provide to us, for example if you email us; and

  • technical data and background data we take from your device, for example your IP address, the time you take the activity, how quickly you respond to questions, the page of the activity you are on and the type of device you are using.

In addition, we may collect information provided to us by the organisation that puts you in contact with us for the purpose of the activity. The information we collect may include:

  • a unique respondent ID, to ensure that individuals do not undertake activities multiple times and to reward participants for their participation, where relevant; and

  • biographical details about you, for example your country, the age bracket into which you fall and your gender.

Element Human then analyses this data in order to extract information such as facial expressions and where your attention is. This analysis of personal data includes both automated and manual (human) methods of processing. We use this data to help measure and understand how you experience the activity. This data is provided to our partners in order to help individuals and businesses better understand how people experience their world.

In addition, we may use your data:

  • where you have consented, to develop and improve our services including to improve the ability of our computer algorithms to measure and understand people;

  • to administer and protect our business and the platform, for example for fraud detection and platform security purposes;

  • where we need to comply with a legal obligation.

When do we share your personal data with third parties?

We do not provide your personal data to any third parties except:

  • to other members of the Crowd Emotion group of companies including Element Human Research Ltd, a British Columbia incorporated company;

  • to the partner whose activity it is, although we will never share the videos we take from your webcam;

  • to the sample provider who put you in touch with us, only to inform them whether or not you have completed the activity so they may reward you (where appropriate);

  • our research partners;

  • to our service providers (including Sentry, Google and Amazon Web Services), only when they need to have access to the personal data to provide the specific services to us;

  • where required to meet any applicable law, regulation, legal process or enforceable governmental request;

  • if we buy or sell any business or assets, when we may share your data with the prospective buyer or seller; and

  • if all or substantially all of our company assets are acquired by another party, in which case your data will be one of the transferred assets.

When do we transfer your personal data outside of the EEA?

  • We share your personal data within the Element Human Group. This will involve transferring your data outside the European Economic Area (EEA) including to Canada.

  • In addition, your personal data may be transferred out of the EEA as some of our service providers are either based outside of the EEA or provide certain services to us from outside the EEA.

  • Finally, where you have been put in touch with us by a third party who is based outside the EEA, we may provide personal data to such third party.

  • Your personal data will only be transferred outside the EEA:

(a) to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

(b) under an agreement which covers the EU requirements for the transfer of personal data outside the EEA, specifically the European Commission approved standard clauses or the EU-US Privacy Shield.

Please email us at [email protected] if you would like more information on, or a copy of, the safeguards in place - we will always be happy to hear from you!

Please also bear in mind, if you are from a country outside the above countries or regions, by providing us with your personal data through your participation in a survey run on our platform, you have explicitly consented for us to store your personal data in the above countries or regions where we normally store the data.

While in that jurisdiction, your information may be subject to lawful access requests by the authorities in that country.

How long will we keep your personal information?

We will only keep your data for as long as is necessary for the purpose for which we collected it or until you ask us to erase it, whichever is earlier.

You can choose at any point to change how you want your personal data handled - just get in touch!

How do we protect your personal data?

We only retain your personal data for the purposes described in this Policy and we're strongly committed to keeping your personal data safe. And to do this we design our services with your safety in mind.

In order to ensure the security of your personal data, we take reasonable and necessary measures to protect your personal data under the existing technical level, and adopt reasonable physical, technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and changes of your personal data.

Your rights

You have the right to:

  • request access to any personal data we hold about you;

  • ask to have any inaccurate information held about you amended;

  • ask for your personal data to be erased under certain conditions;

  • restrict or object to your information being processed in certain circumstances;

  • receive your personal data which you have provided to us and to send such data to another organisation;

  • and withdraw your consent to your personal data being processed.

If you would like any further information about any of these rights or would like to exercise any of them, please email [email protected]

Supervisory authority

Should you ever feel the need to, you have the right to complain to the data protection supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred. The ICO is the UK data protection supervisory authority and their website can be accessed at

Website Usability

We also use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

Changes to this policy

We may update this policy sometimes and we recommend that you regularly review this policy to keep up to date with such changes.

If you don't agree to the changes, then you can always stop using our services and stop giving us any more personal information. We’d be sorry to see you go.

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