Flipp Operations Inc., with registered office at 350-3250 Bloor St. W, Toronto, ON, M8X 2X9 (hereinafter “Flipp”), is committed to protecting the privacy of all those who participate in the tests (the “Tests”) that it conducts on third-party testing platforms  (the “Platform”). This document (the “Notice”) has been prepared, in accordance with Article 13 of Regulation (EU) 2016/679 (“GDPR”), in order to help you understand how your Personal Data, as defined below, will be processed in connection with your participation in the Tests and to allow you to provide explicit and informed consent to the processing activities described below, if you so choose. In general, any information or Personal Data you provide to Flipp will be processed in accordance with internationally recognized principles of lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity, and confidentiality.

 

1. 1. Data Controller 

Flipp, as identified at the beginning of this Notice, is the Data Controller with regard to the Personal Data processed in the context of the Tests, as specified in Section 2 below.

You may contact Flipp at the following address: privacy@flipp.com

 

2. 2. Personal Data Subject to Processing

In the context of the Tests, Flipp will process your personal data through the Platform – namely your voice/audio and screen recordings – only if you provide your explicit consent, as specified in Section 3 below. You can allow Flipp to use your voice/audio and screen recordings  by giving your consent through the Platform. 

By participating in the Tests, you acknowledge that you are aware that Flipp may use your voice for the purposes outlined in Section 3 below.

Please note that Flipp will process your personal data as specified under item a) below (hereinafter referred to simply as “Personal Data”). The Personal Data processed are as follows:

• • Profile and Demographic Data: Flipp will process the following data as Independent Controller with the third-party offering the Platform: username (which may contain identifying information), age, gender, income range, country of residence, device information (manufacturer, mobile carrier, device type, operating system, OS version);

• • Voice/Audio and Screen recordings  and Other Personal Data: With your consent, Flipp will process your voice and audio responses and any other audio material generated during the Tests (“Recordings”).
    
    

3. 3. Purpose of Processing

Flipp will use your Personal Data for the following purposes:

• • to select and screen appropriate participants for the Tests based on demographic and profile criteria (“Participant Selection”)

• • to allow you to participate in the Tests (“Participation”);

• • to collect and analyze the content and opinions collected during the Tests for research and market analysis purposes (“Market Analysis”);

• • to comply with legal obligations requiring Flipp to collect and/or further process certain types of Personal Data (“Compliance”);

• • to prevent or detect any abuse or fraudulent activity against Flipp and thus enable Flipp to defend itself in legal proceedings (“Abuse/Fraud Prevention”);

• • to communicate your Personal Data to Flipp’s Affiliates meaning any entity (including commercial branches) that directly or indirectly controls, is controlled by or is under common control with Flipp and its Affiliates’ subsidiaries, meaning any entity which is directly or indirectly controlled by the Affiliates  for purposes related to the management and analysis of Tests (“Intra-group Communications”).
    
    

4. 4. Legal Basis and Mandatory or Optional Nature of Processing

The legal bases used by Flipp to process your Personal Data, according to the purposes listed in Section 3 above, are as follows:

• • Participant Selection: processing for this purpose is based on Flipp’s legitimate interest in selecting appropriate Test participants, pursuant to Article 6.1.f of the GDPR;

• • Participation: processing of your Recordings is based on your explicit consent. You are free to provide or withhold your consent. If you don’t consent, the Tests will not include your Recordings and Flipp may not be able to proceed with your participation.

• • Market analysis: processing for this purpose is based on Flipp’s legitimate interest in evaluating the content collected in order to carry out market analysis, pursuant to Article 6.1.f. of the GDPR.

• • Compliance: Processing for this purpose is necessary for Flipp to comply with legal obligations. When you provide Personal Data to Flipp, such data must be processed in accordance with applicable laws, which may include retention and disclosure to authorities.

• • Abuse/Fraud Prevention: Information collected for this purpose will be used solely to prevent and/or detect potential fraudulent activity or abuses against Flipp and thereby enable Flipp to defend itself in legal proceedings.

• • Intra-group Communications: the processing for this purpose is based on Flipp’s legitimate interest in managing the Tests.
    
    

5. 5. Recipients of Personal Data

Your Personal Data may be shared with the entities listed below (the “Recipients”):

• • entities typically acting as data processors, such as persons, companies, or professional firms providing accounting, administrative, legal, tax, financial, debt collection, our testing platform provider or other providers that offer tools for managing, recording, archiving, and analyzing Tests;

• • entities responsible for technical maintenance activities (including maintenance of network equipment and electronic communications networks);

• • persons authorized by Flipp to process Personal Data, who have committed to confidentiality or are under a proper legal obligation of confidentiality (e.g., Flipp employees);

• • Flipp’s Affiliates;

• • entities, bodies, or authorities to whom it is mandatory to communicate your Personal Data for purposes of Compliance, Abuse or Fraud Prevention, or based on orders from authorities.
    
    

6. 6. Transfers of Personal Data

Flipp is headquartered in Canada and uses Suppliers located in several jurisdictions, including the United States and other countries outside the European Economic Area (“EEA”). Whenever your Personal Data is transferred outside the EEA, Flipp ensures that this transfer takes place in accordance with applicable laws. Indeed, such transfers are made using appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or others. More information is available from Flipp by writing to: privacy@flipp.com.

7. 7. Retention of Personal Data

Personal Data processed for the purposes of Participant Selection, Participation and Market analysis will be retained for the time strictly necessary to complete the management of the Tests and to analyze the recordings and related outputs. 

Personal Data processed for the purpose of Compliance will be retained by Flipp for the period required by specific legal obligations or applicable laws.

Personal Data processed to prevent Abuse/Fraud will be retained by Flipp for the time strictly necessary to fulfill such purpose and therefore until Flipp is required to retain them to defend itself in legal proceedings or to disclose such data to competent authorities.

Personal Data processed for the purpose of Intra-group Communications will be retained for the time necessary to manage the Tests for which a given Intra-group Communication takes place.

8. 8. Data Subject Rights

You have the right to request from Flipp, at any time:

• • access to your Personal Data (or a copy of such Personal Data), as well as additional information on the ongoing processing;

• • rectification or update of your Personal Data if incomplete or not current;

• • deletion of your Personal Data from Flipp’s databases;

• • restriction of the processing of your Personal Data by Flipp;

• • to receive your Personal Data in a structured, commonly used, and machine-readable format;

You also have the right to:

• • object to the processing of your Personal Data by Flipp for the purpose of Abuse/Fraud Prevention;

• • withdraw your consent for the purposes of using your Recordings.

You can exercise your rights by writing to Flipp at the following address: privacy@flipp.com or by filling out the form here. Please see Flipp’s Privacy Policy for more information.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority if you believe that the processing of your Personal Data is in breach of the applicable legislation.

Last update: December 3, 2025