PAID PERSPECTIVES PRIVACY NOTICE

Updated 1 June 2026

We respect the privacy rights of survey participants and other individuals whose personal information we process. This Privacy Notice explains how we process your personal information when you join Paid Perspectives, create an account, participate in surveys, receive incentives, or otherwise interact with us.

This Privacy Notice should be read together with the Paid Perspectives Terms and Conditions.

Subject to where you are based, you may have additional privacy rights or there may be more stringent notice requirements. For country specific information, please use the link(s) below.

• California, USA: Schedule 1

Paid Perspectives (“we”, “us”, “our”) is a trading name of Walr Group Ltd. We act as a controller of the personal information we collect in order to operate our panel, manage your account, prevent fraud, run quality and verification checks, and deliver incentives.

When we route you to surveys hosted for our clients, or host surveys created by them, we may also process additional categories of your personal information provided in your responses and in those cases we act as a processor of our clients. Your survey responses are typically anonymised (unless otherwise stated in the survey) and results are created in aggregated formats for the purpose of market research. To understand how our clients may use your personal information, please refer to our client’s privacy notice as may be provided from time to time. If you require additional information about how to contact our client please email support@paidperspectives.com.

2. How to Contact Us

Any comments, complaints, questions or requests may be emailed to: support@paidperspectives.com.

Alternatively, you may contact our Data Protection Officer by email to: privacy@walr.com.

3. What Personal Information We Collect and Process

We may collect, use, disclose and process the following categories of personal information:

*Under Data Protection Laws, certain categories of information are considered more sensitive, and we require your explicit consent in order to collect and use it. We will clearly identify registration information and/or survey questions in which the response may include sensitive categories of personal information. If you do not want us to collect this information, you can choose not to provide a response and move to the next question. You will not be penalised or disqualified from participating in a survey if you do not provide this information.

For California residents, our required disclosures under CCPA/CPRA are as described in our California Statement.

4. How We Collect Your Personal Information

We collect personal information about you through your registration processes, and thereafter from surveys which you choose to participate in and complete. We collect information from the following sources:

• Directly from you when you register for an account/membership and you complete a survey;
• The device you are using to complete surveys;
• Our clients (where we are acting as their service provider); and
• Publicly available sources.

5. How We Use Your Personal Information

The table below includes details of the purposes for which we use your personal information. It also stipulates the legal basis for processing your personal information and the categories of personal information we process in relation to each purpose.

6. Who We Share Your Personal Information With

We may share your personal information with:

• Clients who have commissioned the relevant survey typically receive pseudonymised or aggregated survey responses. We do not share identifiable personal information with clients unless necessary for a specific project, and only under strict contractual controls. We will inform you in advance if such identifiable personal information is to be shared with a client.
• Third-party business partners that support our business, such as web hosting service providers, fraud-detection partners (that provide device verification and quality scoring tools), payment providers, and other third parties we engage.
• Affiliates within the Walr group of companies involved in processing panel or survey information.
• Competent authorities in order to comply with any law, court order, legal request or other legal process.
• Professional advisors such as legal advisors or accountants.
• Professional advisers, potential buyers, and their representatives where necessary for the purposes of valuing our business or facilitating its sale, merger, or restructuring. Any such sharing will be limited to what is strictly required, and recipients will be bound by confidentiality and data protection obligations.

We will never sell your Personal Information.

7. International Transfers

Your personal information may be transferred outside the UK or EEA, including to Walr group entities or service providers. Where we transfer personal information internationally, there is a risk that we may transfer your personal information to countries that provide less protection than the UK’s data privacy laws. Due to this, we use legally required safeguards such as the International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs).

8. How We Keep your Personal Information Secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

9. How Long We Keep Your Personal Information

We calculate the retention period based upon the time the personal information is needed to fulfil the purposes set out in this Privacy Notice, taking into account any timelines required or recommended by regulators or applicable laws.

Ordinarily, we keep your personal information for the duration of your Paid Perspectives membership and for 24 months after your account becomes inactive. However, this retention period may vary depending on the factors outlined above.

Personal information relating to incentive payments made to you will be kept for 6 years (for tax and audit purposes).

10. Your Rights

Under applicable data protection laws, you have the following rights in relation to the personal information we process.

California residents may have the rights as described in our California Statement.

If you want to review, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact privacy@walr.com in writing.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your membership with us. You may update your records directly through your account. If you need further information on how to do this please contact privacy@walr.com.

11. Cookies and Similar Technologies

A cookie is a small text file that is placed on your device when you visit our website. Cookies allow the website to recognise your device and store information about your preferences or past actions. We use cookies and similar tracking technologies to operate and secure our website; improve functionality and user experience; and support fraud-prevention and quality assurance.

For further details of the categories of cookies used on our website, the specific cookies used on our website and how you can enable, disable or delete cookies, please refer to our Cookie Policy which can be found here: https://walr.com/cookie-policy-uk/.

When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies. You may change your cookie preferences at any time by accessing the cookie settings on our website. You may also configure your browser settings to refuse all or some cookies or to alert you when cookies are being set. Please note that if you disable or refuse cookies, some parts of our website may become inaccessible or not function properly.

12. Complaints

We welcome the opportunity to resolve any complaints in the first instance. Please email any complaints to: privacy@walr.com.

If you would prefer, or if we have not been able to resolve your complaint, you have the right to complain to the relevant data protection supervisory authority in your jurisdiction. For details of how to identify the relevant data protection supervisory authority in your jurisdiction, please refer to clause 10 ‘Your Rights’ above.

13. Updates

We may update this Privacy Notice from time to time. If changes are material, we will use reasonable efforts to notify you through your Paid Perspectives account.

SCHEDULE 1 – ADDITIONAL COUNTRY SPECIFIC PRIVACY NOTICE INFORMATION

Supplemental Privacy Statement for California consumers under CCPA/CPRA 

Supplemental Privacy Statement for persons residing in the State of California (each, a “consumer,” and collectively, “California consumers”) under CCPA/CPRA (“California Statement”) includes additional notices required under applicable United States privacy laws, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA/CPRA). The California Statement supplements our Privacy Notice and further explains required disclosures about how we collect, disclose, and sell or share the personal information of California consumers and the rights that California consumers may have under CCPA/CPRA where we act as a business under CCPA/CPRA. When we use the term “personal information” in this California Statement, we are using that term as defined in CCPA/CPRA, which generally includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, de-identified, or aggregate consumer information, which are all defined in CCPA/CPRA.

1. What personal information we collect and who we share it with

Our Privacy Notice sets out in general the categories of personal information we collect, sources of that information, business and commercial purposes for why we collect and use it and who we share it with, as well as our personal information retention practices.

However, California law requires we restate some of this information for specific categories that are defined in CCPA/CPRA. We may use the categories of personal information listed within this Notice to operate, manage and maintain our business, to provide our products and services, for vendor management purposes and to accomplish our business purposes and objectives, including, for example, using personal information to develop, improve and maintain our products and services; personalize, advertise and market our products and services; conduct research, analytics, and data analysis; maintain our offices and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims and for the purposes as further described in Section 5: “How We Use Your Personal Information” in our Paid Perspectives Privacy Notice.

We may use the categories of personal information for certain business purposes (as specified in the CCPA/CPRA). We do not use or disclose sensitive personal data for any purpose not permitted by the CCPA/CPRA.

In general, we have collected, disclosed for a business purpose or commercial purpose, the following categories of personal information and sensitive personal information from California consumers within the last 12 months:

In the preceding 12 months, we have not sold or shared any personal information of California consumers, as those terms are defined under the CCPA/CPRA.

2. Your Rights  

Depending on your state of residence in the USA, you may have rights to know/access, correct, delete, portability, limit the use and disclosure of sensitive personal information, and to opt out of sales, sharing or targeted advertising.

If you are a California consumer, you may have one or more of the following rights under CCPA/CPRA:

Additionally, California Civil Code Section 1798.83 may permit you the right to request information regarding the personal information about you that we disclose to third parties for the third parties’ direct marketing purposes.

3. How to Exercise Your Rights

You can submit a request by email at privacy@walr.com, by web form at paidperspectives.com or by post to Privacy at Walr, 450 Lexington Ave WEWORK, 4 098 New York, NY 10017-3904. We will verify your request using reasonable methods, which may include matching information you provide with records we maintain. If you are an authorised agent submitting a request on behalf of a consumer, we may require proof of authorisation and verification of the consumer’s identity.

These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. We are only required to honor these rights to the extent that they have been granted to you and apply to you under CCPA/CPRA.

Please consult CCPA/CPRA to determine which rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us, and you have the right to lodge a complaint with the California Privacy Protection Agency or the California Attorney General if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to contact us first so we can address your concerns directly.

4. How We Use Your Personal Information and Who We Share Your Personal Information With

In general how we use your personal information and who we share it with is set out in our Privacy Notice.

We do not sell personal information or share it for cross-context behavioural advertising; if this changes, we will provide required notice and opt-out mechanisms, including updating the Global Privacy Control in supported browsers.

Where U.S. laws apply, we rely on your consent or your direction for participation in surveys, and on our legitimate interest for fraud prevention, security and service improvement. We process personal information for “business purposes” and, where applicable “commercial purposes.” as those terms are defined in CCPA/CPRA.

5. Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than those permitted by law or disclosed, such as service delivery, security and integrity, short-term transient use, and quality assurance.

6. California Shine the Light Act and Financial Incentives

Under California Civil Code Section 1798.83, California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties' direct marketing purposes. If we offer loyalty or incentive programmes related to your participation, we will provide a notice of financial incentive describing the material terms, how the value is calculated, and how you may opt in or withdraw without discrimination. Incentive programmes are voluntary, and we will obtain your consent before enrolment.

7. Do Not Sell or Share / Targeted Advertising Opt-Out

If we engage in activities deemed “sale”, “sharing” or “targeted advertising”, you can opt out by using the “Do Not Sell or Share My Personal Information” link and by enabling Global Privacy Control in supported browsers.

8. Children’s Data

Paid Perspectives is not intended for anyone under the age 13. We do not knowingly collect personal information from anyone under the age 13, and if we discover such data we will delete it promptly. If we allow participation by individuals aged 13-17, we will do so in compliance with market research industry standards, CCPA, CPRA, and any other applicable laws, and obtain any required consents or permissions. If a participant is between 13 and 16 years of age, we will not sell any personal information without affirmative authorization (opt-in consent).