Effective Date: 25 March, 2026
1. Introduction
This Privacy Policy describes how Operyn collects and uses the information, which may include personal data, you provide on our websites operyn.ai (“Websites”). our web application available on the Website (the “Services“) and other interactions (e.g. Client service inquiries, live chat etc.) you may have with Operyn.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services, or any other third party products, services or businesses, where we are not the controller of your personal data.
The collection and processing of information, including Personal Information, in the course of other contractual or commercial engagements that we may enter into with you, will be done in accordance with the specific terms applicable thereto, and not by this Privacy Policy.
By using/ accessing/ browsing the Website and/or Services, or by otherwise giving us your information, you confirm that you have the capacity to enter into a legally binding contract and that you have read, understood and agreed to the practices and policies outlined in this Privacy Policy and our Terms of Service. You hereby consent to our collection, use, sharing, and disclosure of your information, including Personal Information, as described in this Privacy Policy.
2. How we handle information
Personal information may be shared with our processors. Each of these processors will be bound by an agreement we have in place, which will limit their processing capabilities and mandate security measures for your personal data. Your personal information will never be sold by us.
Additionally, we may disclose your personal information in the following situations: (a) when required by law or legal process; (b) in response to legitimate requests from public authorities, such as those pertaining to national security, law enforcement, or other requests; (c) in order to look into possible violations of any terms or policies that apply to our products or the services that we, our affiliates, or third party providers provide; (d) in the event that we reasonably determine that doing so is necessary for defending, exercising, or establishing our legal rights; (e) to look into allegations of fraud, misrepresentation, or other misconduct; (f) in connection with a potential sale, merger, change of control, bankruptcy, or similar transaction; and (g) to other third parties with your express consent.
3. Information we collect
3.1. Personal data
(a) We collect personal data about you when you voluntarily submit such data directly to us through our Service. This can include information you provide to us when you register with us, edit your profile, upload content, purchase services, correspond with us, respond to a survey, enter a promotion or use some other feature of our Service.
(b) At various places on our site you may be requested to enter certain personal information. Personal information that must be provided in order to use the requested services will be indicated at the time of collection. If you choose not to provide this personal information, we may not be able to provide some or all of the features and functionalities of the Service to you or respond to your other requests. Other personal information that you are not required to provide in order to receive our services may be voluntarily given and you are free to decide not to give such personal information.
(c) The policy sets out the categories of personal data we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information. Please also refer to the “Cookies” in Section 5.
(d) Additionally, we automatically gather information about your device and how you access and use the Service, as well as personal data.
(e) We may link or combine the personal data we collect directly from you and the personal data we collect automatically from you. This allows us to provide you with a personalised experience regardless of how you interact with us.
(f) We may also link or combine the personal data we collect directly from you and other personal data we collect about you using publicly-accessible sources such as Google. All additional personal data collected from these third-party sources has been made public by you.
(g) Any personal information we gather about you may be aggregated and anonymized (such that it does not directly identify you). Such anonymized information may be used by us for research, data analysis, IT system testing, website enhancement, and the creation of new features and products.
3.2. Participant Data
(a) Participant Data is not gathered by us for personal use. Rather, the client who registered you as a participant on the Service provides us with this Participant Data, or we obtain it directly from you on their behalf and per their instructions. Clients can create screen recordings of Participant activity on a Operyn-compliant website or application (“Recording“). The information that the client will collect must be disclosed to participants, and the client is in charge of getting the required consents from them.
(b) We use Participant Data to provide the Service to the client who signed you up as a participant on the Service. We do not use Participant Data for any other purposes.
(c) If you would want additional details regarding the types of Participant Data that we gather on behalf of the client who registered you as a participant on the Service, and/or regarding the rationale behind the collection of such Participant Data, kindly get in touch with them.
3.3. Browser Data
We collect the basic user information through common internet technologies, such as web server logs. This information is collected from all users who visit our Website, whether they have an account or not. The browser type, preferred language, referring website, and the date and time of each visitor request are among the details we collect from every user on our website. Additionally, we gather information that could be used to identify a specific person, such as IP addresses.
Based on the location and prospective use of our products and services, this is done to enhance the visitor experience and offer better content and service to both our present and potential users.
3.4. Uploading files
If you use our Services to login, upload files, or source participant files, we gather your email address, contact information, location, and filename or URL. We collect this information so that we can provide you the requested services.
3.5. Information we do not collect
We do not collect or keep any specific categories of personal data, such as genetic information, health information, or religious information. Although Operyn does not seek or collect any special categories of personal data, we understand that you may save such information in your account through the files you submit. If you ask us to upload or keep any files containing special categories of personal data on our servers, we will only do so at your request as a data processor and service provider, and in accordance with our Terms of Service with you.
4. How do we use this information?
We use the information you provide, some of which may be personal data, for the following purposes:
(a) Registration and account administration: We use the information to register your property and to allow you and Operyn to administer and manage the Service offered to you.
(b) Providing our Services: We use the information, which may include personal data, to provide our Services, facilitate their performance, and improve the Services and Websites’ content related to their usage.
(c) Analyze the use of the Service: We use the information, which may include personal data, to analyze the volume and history of your use of our Services. We use the derivatives of such analyses to conduct monitoring and reporting of your use of our Services to comply with our Terms of Service and Service Level Agreement.
(d) Client Service: We use the information to provide you with Client support and Client success services, such as responding to your requests, questions, and concerns, providing you with best practices for using the Services, and engaging in Client success communications when encountering unusual activities (e.g., spikes) in usage of the Service.
(e) Marketing/Communications: We use the information to provide you with information that you request, to send our newsletter, marketing communications, and updates about new products and services or other news or offers that we believe will be of interest to you. Where we use your personal data for direct marketing purposes, such as newsletters and marketing communications on new products and services or other offers that we believe will be of interest to you, we include an unsubscribe link that you can use if you don’t want us to send messages in the future. We may invite you to attend events we believe may be of interest to you. We may also use your personal data to invite you to participate in referral programs.
(f) Certain Services may offer you means to deliver media to your end-users, which always includes Operyn as a source of that media. Operyn has access to these media and uses automated systems to analyze them for security purposes, fraud prevention, compliance with legal and regulatory requirements, investigations of potential misconduct, product development and improvement, research, and Client or technical support.
(g) Analytics, improvements, and research: We use the information, which may include personal data, to conduct research and analysis. We may involve a third party to do this on our behalf. We may share or disclose the results of such research, including to third parties and our affiliates, in an anonymous, aggregated form. We also use the information, which may include personal data, to assess the needs of your business, to determine suitable products, and to improve the Service and marketing efforts. We may invite you to take part in surveys, such as market research, and to analyze how to improve your experience and the functionality and quality of the Service.
(h) Security, fraud detection and prevention: We use the information, which may include personal data, in order to prevent fraud and other illegal or infringing activities when using the Websites as well as our Services. We also use this information to investigate and detect fraud. Operyn can use personal data for risk assessment and security purposes, including the authentication of users. For these purposes, personal data may be shared with third parties, such as law enforcement authorities, as permitted by applicable law and external advisors.
(i) Legal and compliance: In certain cases, Operyn needs to use the information provided, which may include personal data, to handle and resolve legal disputes or complaints, for regulatory investigations and compliance, to enforce agreement(s), or to comply with lawful requests from law enforcement insofar as it is required by law.
If we use automated means to process personal data that produces legal effects or significantly affects you, we will implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention.
5. Cookies
As a general rule, Operyn uses cookies to improve and personalize its Websites and Services and/or measure its audience. Cookies are files saved to your local storage when browsing on the internet and, in particular, on the Websites. A cookie is not used to gather your personal data without your knowledge but instead to record information on site browsing, which can be read directly by Operyn on your subsequent visits.
You can choose to decline acceptance of all cookies, but your ability to browse certain pages of Websites may be reduced. The cookies used by Operyn are intended to enable or facilitate communication, to enable the Services requested by users to be supplied, to recognize users when they re-visit the site, to secure payments that users may make, or other preferences necessary for the service requested to be supplied and to enable Operyn, internally, to carry out analyses on hit rates and browsing experience so as to improve content, to track email open rates, click rates, and bounce-back rates at individual levels.
By default, cookies are not installed automatically (except for those cookies needed to run the Websites and Services, and you are informed of their installation by a clickable banner with a text description). In accordance with the regulations that apply, Operyn will require your authorization before implanting any other kind of cookie to your local storage. To avoid being bothered by these routine requests for authorization and to enjoy uninterrupted browsing, you can configure your device to accept Operyn cookies, or we can remember your refusal or acceptance of certain cookies. By default, browsers accept all cookies.
When you access third-party sites on the Websites or when you read integration or social media links, cookies can be created by the companies disseminating these links. These third parties may be able to use cookies in the context of the Services (partners or other third parties supplying content or services available on the Websites) and are responsible for the cookies they install, and it is their conditions on cookies that apply. Operyn assumes no liability regarding the possible use of cookies by third parties. For more information, you are advised to check the cookie policy directly on these third-party sites concerning their use of cookies.
6. Data Sharing
6.1. Data sharing
We do not share, sell, rent or trade your email address with any third parties for any commercial purposes. We may share Personal Information with a limited number of third-party vendors who process it on our behalf to provide or improve our Services, and who have agreed to privacy restrictions and security obligations consistent with this Privacy Policy.
We may share Personal Information where it is in our legitimate interests to do so to run, grow and develop our business if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure it is under terms that preserve the confidentiality of Personal Information, and we will notify you on our Website or by email before any transfer of your Personal Information.
6.2. Transfer to the Third-party
We may transfer personal data to third-party agents or service providers who perform functions on our behalf. We enter into written agreements with those third-party agents and service providers that require them to provide the same level of protection that the GDPR requires and limit their use of the data to the specified services provided on our behalf.
We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal data in accordance with our data privacy obligations and to stop and remediate any unauthorized processing.
6.3. Legal disclosures
Operyn may disclose personally-identifying information or other information we collect about you in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. This may include exchanging Personal Information with other organisations for the purposes of fraud protection and credit risk reduction.
We will also disclose your Personal Information to third parties in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.
7. Data Storage, Transfer and Security
7.1. Data Security
We implement appropriate and reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. All personal information we collect will be stored on our secure servers. We also limit access to your personal information to those employees and other staff who have a business need to have such access. We have put in place procedures to deal with any actual or suspected personal data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances, we may notify you of breaches affecting your personal information where we are legally required to do so. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. Operyn will use strict procedures and security features to prevent unauthorised access to it.
7.2. Data Retention and Deletion
We will maintain your Personal Information for as long as your account remains operational or as necessary to serve you with the Services you have requested. Once your account is deleted, we will permanently delete any files related to it (in compliance with our Terms of Service).
We will not store any files that you upload or source using the service for the purpose of testing the Service, including their converted format, on our systems. We will keep Personal Information, such as your IP address, email address, contact information, and browser details, for no more than 90 days after request of deletion of account.
If you have a question about a specific retention period for certain types of personal data we process about you, please contact us at [email protected].
7.3. Data transfers
By using our services and giving us your personal information, you agree that Operyn may receive and process that information. Your personal information might be sent to other nations where our service providers and affiliates are located. It is crucial to remember that the data protection regulations in some of these nations can differ from those in your own and might not provide the same level of security. We will make sure that these providers sign an agreement that includes suitable safeguards for your information.
Operyn may transfer your personal data to countries other than the one in which you live, including to our hosting servers with reputed suppliers located in Singapore. If we provide any Personal Information about you to any such non-EEA entities, we will take appropriate measures to ensure that the recipient protects your Personal Information adequately in accordance with this Privacy Policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation (GDPR).
Further details on the steps we take to protect your Personal Information, in these cases, are available from us on request by contacting us by email at [email protected] at any time.
8. User’s rights
As a starting point and depending on the specific situations, you have the following rights:
(a) Right to withdraw consent: Where you have given your consent for our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us (see contact details above). If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out based on your consent.
(b) Right of access: You have the right to have confirmed whether collection or processing of your personal data has taken place, and, if so, you have the right to request a copy of your personal data in a digital format.
(c) Right of rectification: You have the right to require that we correct any inaccurate personal data, and that we complete incomplete personal data.
(d) Right of erasure: In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes in which it was originally collected.
(e) Right to restrict processing: In certain circumstances, you have the right to request that we restrict the processing of your personal data, for example, if you believe that the personal data is not accurate or lawfully processed.
(f) Right to object to the processing: In certain circumstances, you have the right to request that we stop processing your personal data.
(g) Right to data portability: In certain circumstances, you have the right to receive the personal data you have provided us with in a structured, commonly used, machine readable format, and the right to have us transmit the data to another entity, where technically feasible.
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information subject to applicable law.
We rely on you to ensure that your personal information is complete, accurate, and current. Please do inform us promptly of any changes to or inaccuracies of your personal information by contacting
[email protected]. Your applications will be processed within 30 days. We may require your application to be accompanied by a photocopy of proof of identity or authority.
In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.
9. Governing law
This Privacy Policy shall, in all respects, be governed by and construed in accordance with the laws of Singapore. The courts in Singapore shall have exclusive jurisdiction in connection with any dispute arising out of or in connection with these terms.
10. Disclaimer
Although we are committed to maintaining your privacy, we cannot guarantee that any of the information you provide, including Personal Information, will remain private at all times or that it will not be subjected to uses that are not outlined by this Privacy Policy.
You assume all responsibility and risk for: (i) your use of the Website and/or Services; (ii) use of the internet generally; (iii) the information you provide or access; and (iv) your conduct on and off the Website.
Additionally, we disclaim all liability for any actions taken by third parties with respect to your information or personal information that you may have given them by accessing or visiting third party links, or by using integrations. You can get apps and custom apps through the marketplace or other forums where applications are developed for the Service(s). In the event that you use third party links or have any other interactions with such third parties, Operyn will not be held liable.
11. Policy Updates
We may update this Privacy Policy from time to time, in order to clarify it, to reflect any changes to our website, or to comply with legal obligations. The “Last Updated” mention at the top of the policy indicates the last revision, which is also the effective date of those changes. We give you access to archived versions of this policy, so you can review the changes.
12. Contacting
If you have any question regarding this Privacy Policy, or any enquiry about your personal data please contact us via email at [email protected].