Privacy Policy

Effective Date: April 24, 2026

1. INTRODUCTION AND ROLES

1.1. This Privacy Policy describes how we collect, use, and disclose your personal data when you use our Apps, including but not limited to MultiPolls, Golden Surveys, RewardRoo and any affiliated Services. Capitalized terms used in this Privacy Policy but not defined herein shall have the same meanings as set forth in our Terms of Service (available here).

1.2. We act as a data controller only for information related to your account management, data collected directly by the App (not after you are redirected to a third-party website within the App) and information provided through the Profiling Survey.

1.3. We and the Clients act as independent data controllers for our respective purposes. We control the data for matching and rewards, while the Client independently determines the purposes and means of the Survey content and research. When you are redirected to a Survey, the Client conducting the survey becomes the independent data controller of any answers or personal data you provide directly to them. We do not access or process your specific survey responses while you are engaged in a third-party Survey. However, we do process technical participation data, such as entry identifiers and survey results (e.g., completion status), to facilitate our rewards system and manage the Services.

1.4. The App is a global service. Regardless of where you reside, by using the Services, you acknowledge that your personal data may be transferred to, stored, and processed in countries outside of your home country, primarily the United States, and other jurisdictions where our service providers maintain facilities. We ensure that such transfers are protected by appropriate legal safeguards (such as Standard Contractual Clauses).

1.5. We rely on valid legal bases to process your personal data, primarily contractual necessity (to provide you with the App, including profiling for Survey matching, and rewards), legitimate interest (for fraud prevention and basic analytics), and your consent (specifically for precise geolocation, device tracking and associated analytics, and special categories of data such as political affiliations where applicable).

2. INFORMATION WE COLLECT AND RECEIVE

2.1. To make the App work, we need to collect certain information at different stages of your journey. We collect and process personal data to provide our matching services and ensure the integrity of our rewards system.

2.2. This is the information you share to set up your account and enable our matching algorithms to set you up with Surveys:

a) Registration: Email address and basic profile info from your Google, Apple, or email login.

b) Profiling Survey: Your self-declared demographic data (e.g., age, gender, education, income, number of children, household status). As per our Terms, completing basic profiling tasks is a mandatory prerequisite to access Client Surveys and ensure proper matching. This category also includes optional internal polls managed by us; while these are not required to access the platform, they offer additional reward opportunities.

c) Sensitive Attributes: In specific regions (like the USA), you may choose to share your political affiliation. We only collect this with your explicit consent to provide you with targeted research opportunities.

2.3. While you use the App, we collect technical data to keep things running smoothly and prevent fraud:

a) Identifiers: Your Firebase User ID, Device ID, and a unique App Instance ID used to manage your specific installation.

b) Technical Specs: IP address, Timezone, OS name and version, phone model, and screen resolution.

c) System Permissions: Firebase tokens (for push notifications) and, subject to your explicit permission, your Advertising ID (IDFA/AAID) and precise Geolocation (Latitude, Longitude, and Accuracy).

2.4. We track the progress of your earning opportunities without spying on your private answers:

a) Redirection: When you click a Survey, we generate a unique Entry ID. We pass this ID, basic demographic attributes, and a pseudonymized (hashed) identifier derived from your email address to the Client. This data allows the Client to perform deduplication and verify your eligibility without directly identifying you. While the information shared by us is pseudonymized to protect your identity, the Client may collect your personal information if you choose to provide it voluntarily within their Survey. That is, however, your sole decision, and any provision of personal information through the Survey is governed by the Client's own terms of service and privacy policy. Once you are redirected to the Client’s external platform, we do not access, collect, or store your specific survey responses or private answers within Client Surveys. Our tracking is strictly limited to the technical participation metadata (Entry ID and status) required to manage your rewards. We do not receive or have access to such personal data provided to third parties.

b) Return: When you return from a Survey via our tracking subdomains, we receive the Survey ID and your completion status (complete, terminated, in progress, or overquota) to update your balance. We also receive the identification of the Client you completed the Survey for.

c) Gaming Feature: We receive activity data (such as time played or goals reached in third-party games) from our respective third-party partners (such as adjoe GmbH) or through our own offerwall infrastructure within the App. This data is collected only after you grant the necessary system permissions to the App. Where a third-party partner is involved in providing a specific offer, your participation is further conditional upon your review and acceptance of that partner’s respective terms of service and privacy policy, as identified within the App interface.

2.5. When you interact with our customer service teams via email or third-party support platforms (such as Zendesk), we collect your contact information and the content of your communication to resolve your request.

2.6. To enable specific features and ensure the integrity of our rewards system, the App requires access to certain functions of your device. These are only processed if you explicitly grant permission:

a) Geolocation: We use your precise geographic coordinates to prevent fraud (identifying VPN or proxy usage) and to provide you with location-specific Surveys. Accessing your location can significantly increase the number of available earning opportunities.

b) Usage Access (Android) / App Tracking (iOS): This permission is essential for the Gaming Feature. It allows us (via our respective third-party partners or our own infrastructure) to verify that a Game was correctly installed and to track your progress (time played or milestones) to award your bonuses.

c) Notifications: We use notifications to provide real-time updates about newly available Surveys, Games, or critical account alerts (e.g., successful reward redemption). Disabling notifications may result in missing time-sensitive earning opportunities.

2.7. You can manage, grant, or revoke the permissions described in Article 2.6 at any time through your device’s system settings. While these permissions are not required to access the App itself, they are essential for the core purpose of the Services, which is to provide you with relevant, location-specific earning opportunities and to track your progress. If you deny or revoke these permissions, we might be technically unable to provide you with localized Surveys or track your Gaming milestones, which will significantly impair your ability to earn rewards and may result in no available opportunities being displayed.

2.8. We may collect any other personal data that you voluntarily choose to share with us, such as when you participate in a promotion, respond to a survey about the App itself, or communicate with us through any other channel not explicitly mentioned above.

3. HOW WE USE INFORMATION

3.1. We process the information collected for the following business and legal purposes:

a) to provide and maintain the Services, manage your account, and ensure the core functionality of the App;

b) to utilize automated profiling and algorithms that connect your demographic data with specific Survey criteria provided by our Clients;

c) to track your milestones, calculate rewards from Surveys and Games, and facilitate the processing and redemption of your rewards;

d) to ensure platform integrity and security by detecting VPNs, bots, multiple accounts, or technical manipulation through IP and geolocation analysis;

e) to provide customer assistance via Zendesk and send real-time operational updates, such as new Survey alerts or reward status, via push notifications and email;

f) to improve our matching logic and personalize your user experience based on your engagement with different types of Surveys or Games;

g) to monitor for security incidents, prevent fraud or abuse, and protect the rights, property, and safety of our Users and Bohemian Research;

h) to comply with applicable tax and legal obligations, and to respond to valid requests from public authorities;

i) to meet regulatory requirements for documented evidence of interactions and preserve evidence in case of disputes;

j) to perform marketing attribution and measure the effectiveness of our advertising campaigns (e.g., via Singular);

k) to analyse user feedback regarding survey performance (e.g., reasons for survey drops) to improve the quality of our offerings and detect broken or non-compliant surveys;

l) to conduct internal reporting and statistical analysis using anonymized or aggregated data to optimize our business operations;

m) to process any other personal information for the specific purposes for which it was provided or as otherwise described at the time of collection or in this Privacy Policy or in our Terms.

4. DATA SHARING AND DISCLOSURE

4.1. We believe in transparency and do not sell your personal data in exchange for monetary compensation. We only share limited information with trusted service providers, Survey Clients, and partners when it is strictly necessary to provide our Services, ensure the core functionality of the App, prevent fraud, process rewards, or measure the effectiveness of our Services. Certain limited disclosures may be treated as a “sale,” “sharing,” or use for “targeted advertising” under applicable U.S. Privacy Laws, as further described in Article 14.

4.2. When you choose to participate in research, we share your unique Entry ID, specific demographic attributes, and a pseudonymized email identifier with our Survey Clients as detailed in Article 2.4.

4.3. To enable the Gaming Feature, we process your Device ID and usage data to track your progress and verify task completion. This allows for calculating the milestones and enables us to award your bonuses correctly. When a third-party partner is utilized for a specific offer, we might share this technical information with them and the respective game providers to facilitate milestone calculations. However, we apply data minimization and do not provide these parties with directly identifying information, such as your name or email address. Please be aware that third-party game providers may independently link this technical data with information they already hold about you (such as your store account details) subject to their own terms of service and privacy policies. If an offer is managed directly via our own infrastructure, all tracking and calculations are performed internally by us, and no such data is shared with third-party gaming partners for milestone tracking purposes.

4.4. To maintain our technical infrastructure and app performance, we utilize several specialized third-party providers. This includes the use of Firebase and Google Analytics 4 for hosting and stability, while Customer.io and Mailgun are used to manage and deliver our communications to you. We analyse marketing attribution through Singular and manage our customer support and user interactions via Zendesk and Pipedrive. Additionally, we use Superset for internal data visualization, Trophy for our reward infrastructure, and specialized security tools to verify IP and location integrity for fraud prevention purposes.

4.5. We may disclose your information to public authorities if we believe in good faith that such disclosure is reasonably necessary to comply with a law, regulation, or a valid legal process such as a subpoena or warrant. If we are required to release your data to legal authorities, we will do our best to provide you with prompt notice via email, unless we are legally prohibited from doing so.

4.6. All our partners and service providers are contractually obligated to safeguard any data they receive from us to the same high standard that we maintain. They are strictly prohibited from using your personal data for any purpose other than performing their specific tasks for us.

5. INTERNATIONAL DATA TRANSFERS

5.1. Our Services are provided globally. To operate efficiently, we host our primary infrastructure and databases in the United States. By using our App, you acknowledge and agree that your personal information will be transferred to and processed in the United States, as well as in other jurisdictions where our trusted service providers maintain their facilities.

5.2. To ensure your data remains protected when it leaves your country, we rely on recognized legal safeguards. For users in the European Economic Area (EEA), the United Kingdom and Switzerland, this includes the use of Standard Contractual Clauses (SCCs). These mechanisms contractually obligate our partners to provide a level of data protection equivalent to European standards, ensuring your privacy is respected regardless of geographical location.

6. DATA RETENTION

6.1. We keep your personal information only as long as your account is active. You can delete your account at any time via the App settings. Upon deletion, your personal data, including your profile and device information, is deleted without undue delay from our databases. Because we share only pseudonymized identifiers with our third-party service providers, the deletion of your primary account data destroys the link between those identifiers and your identity. This ensures that any residual technical data held by those third parties can no longer be traced back to you, effectively rendering it anonymous.

6.2. Please note that even after you delete your account, we may retain certain information for legitimate business and legal purposes:

a) Demographic data and responses provided through our Profiling Surveys and internal polls may be retained in an aggregated or permanently anonymized format to preserve the historical integrity of our research and analytics. Once anonymized, this data can no longer be linked back to you.

b) We retain necessary transaction and payout records as strictly required by applicable laws for tax, audit, and accounting purposes.

6.3. This deletion process does not apply to personal data you provided directly to our Clients during external Surveys, nor to any pseudonymized identifiers that the Client may have linked to your Survey responses on their own platforms. We do not have access to or control over data held by independent Survey controllers. To exercise your rights regarding that data, you must contact the respective Client directly.

7. YOUR RIGHTS

7.1. Depending on your location, you may have specific rights regarding the personal data that we control as a data controller. These include:

a) the right of access to your personal data;

b) the right to correct or rectify any inaccurate personal data;

c) the right to restrict or oppose the processing of your personal data;

d) the right to erase or delete your personal data;

e) the right to personal data portability;

f) the right to opt-out of the sale of personal information;

g) the right to opt-out of the use of your personal data for targeted advertising purposes, including the sharing of your data with third parties for cross-context behavioral advertising;

h) the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable under relevant law; and

i) the right to limit the use and disclosure of sensitive personal data, where such right is provided under applicable law.

For users located in the United States, additional rights and disclosures are provided in Article 14 of this Privacy Policy.

7.2. You can exercise your rights over your personal data in the following ways:

a) You can access, review, and update your demographic profile and account information directly within the App settings.

b) You can permanently delete your account and all associated data via the App settings as described in Article 6.

c) You can opt-out of marketing communications by adjusting your notification settings in the App or using the “unsubscribe” link in our emails.

d) If you are unable to access your account or perform these actions yourself, you may reach out to our privacy team via email at privacy@bohemianresearch.com.

e) For users located in the United States, you may also exercise your right to opt-out of the sale or sharing of your personal data, or its use for targeted advertising, by contacting us at privacy@bohemianresearch.com. Where technically feasible, we may also provide additional in-app mechanisms to manage these preferences. We will process such requests in accordance with applicable law.

7.3. To protect your account from unauthorized access, we require you to be logged into your password-protected account to initiate account deletion. For other manual requests via email, you must contact us using the email address registered to your account. We reserve the right to verify your identity through additional means.

7.4. You have the right to lodge a complaint with a competent supervisory authority, particularly in the jurisdiction of your habitual residence, place of work, or the place of the alleged infringement.

8. SENSITIVE DATA

8.1. In certain regions (such as the United States), we may ask you to voluntarily provide information regarding your political affiliation. We only collect this sensitive data with your explicit consent within the Profiling Survey.

8.2. We process this information specifically to match you with relevant research opportunities. Many Survey Clients seek participants with a specific political background or require a representative sample across the entire political spectrum to ensure balanced research results. Providing this information allows us to show you more Surveys that match your profile.

8.3. You are never required to provide this information to use the App. You may withdraw your consent at any time by deleting your account or by requesting a profile update via email at privacy@bohemianresearch.com.

9. TRACKING AND ANALYTICS

9.1. As detailed in our Terms, we use tracking technologies to provide the core functionality of our App. This includes monitoring Survey progress and verifying Gaming milestones through our respective third-party partners or our own infrastructure. To enable the Gaming Feature, the App requires specific system permissions (such as Usage Access on Android or App Tracking Transparency on iOS) to verify Game installs and play duration. These permissions are used solely to verify your participation in these optional modules. Without this tracking, we are technically unable to verify your activity or issue rewards specifically earned through the Gaming Feature.

9.2. We also use specialized tools to ensure App stability and measure our growth. This includes Firebase and Google Analytics 4 for performance monitoring, and Singular for marketing attribution. These tools collect technical identifiers (such as your Advertising ID and IP address).

9.3. We track technical data, including geolocation and network information, to detect and prevent the use of VPNs, proxies, bots, or other fraudulent activities as outlined in Article 4.5 of our Terms.

9.4. You can manage or limit tracking through your mobile device’s system settings at any time. However, please be aware that disabling these permissions will impair or disable associated features, particularly the tracking and issuance of rewards for Surveys and Gaming.

10. BUSINESS TRANSFERS AND RESTRUCTURING

10.1. In the event that we are involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction.

10.2. This also applies to internal corporate restructuring or the migration of our operations between affiliated entities and jurisdictions. We will notify you via email or a prominent notice in the App if a different entity becomes the data controller of your information. The core promises in this Privacy Policy will continue to apply to your data following any such transfer or migration.

11. CHILDREN

11.1. The App is not intended for children. You must be at least 18 years old (or the minimum legal age in your jurisdiction) to use our Services. If we learn that we have inadvertently collected data from a child under the required legal age, we will delete it without undue delay.

12. SECURITY

12.1. We have implemented comprehensive technical and organizational security measures to protect your data within our infrastructure. Furthermore, we carefully select our service providers based on their ability to provide a high level of data protection.

12.2. The App contains links to third-party Clients, survey platforms, game publishers, and advertisers. We are not responsible for the privacy policies, data practices, or the content of such external sites. We encourage you to read the privacy policies of any third-party service you visit through the App.

12.3. While we secure the App, the security of your account also depends on you. We strongly advise against using “jailbroken” or “rooted” devices, as these can bypass critical system security features and expose your data to risks.

12.4. While we follow industry standards to protect your personal data, no transmission over the internet or method of electronic storage is 100% secure.

13. CHANGES TO THIS PRIVACY POLICY

13.1. We may unilaterally update this Privacy Policy from time to time to reflect changes to the Services, the App, the used technology, or legal requirements.

13.2. We will notify you of any material changes by sending an email to your registered email address or through a prominent notice within the App at least fifteen (15) days before the changes take effect.

13.3. By continuing to use the App after these changes become effective, you acknowledge and agree to the updated Privacy Policy. If you do not agree with the new version, you must stop using the App and may delete your account.

14. SUPPLEMENTAL NOTICE FOR U.S. RESIDENTS

14.1. This Supplemental Notice for U.S. Residents applies to individuals residing in U.S. states with applicable privacy laws, including but not limited to California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana (“U.S. Privacy Laws”). This section supplements the information contained in this Privacy Policy.

14.2. In the preceding twelve (12) months, we have collected the following categories of personal data as defined under U.S. Privacy Laws:

a) Identifiers, such as email address, device identifiers (including Firebase User ID, Device ID, and App Instance ID), IP address, and pseudonymized identifiers derived from your email;

b) personal information categories described in applicable statutes, including demographic information such as age, gender, education, income, number of children, household status, and household characteristics;

c) internet or other electronic network activity information, including interactions with the App, Survey participation status, Gaming Feature participation, and engagement with features;

d) geolocation data, including precise location data where you have provided consent;

e) commercial information, including records of rewards earned and redeemed;

f) inferences drawn from your personal data, such as profile attributes used for Survey matching;

g) sensitive personal data, such as political affiliation, which is collected only with your explicit consent where permitted by law.

14.3. We collect, use, and process the categories of personal data described in Article 14.2 for the business and commercial purposes described in Article 3 of this Privacy Policy, including to provide the Services, match you with relevant Surveys and earning opportunities, process rewards, prevent fraud, provide customer support, improve the Services, perform analytics and attribution, and comply with legal obligations.

14.4. We may disclose the categories of personal data described in Article 14.2 to the categories of third parties described in Article 4 of this Privacy Policy, including:

a) Survey Clients acting as independent data controllers;

b) service providers supporting our infrastructure, communications, analytics, attribution, rewards, and customer support;

c) third-party partners involved in the Gaming Feature or other earning opportunities, where applicable;

d) fraud prevention and security providers;

e) public authorities where required by law.

14.5. We do not sell personal data in exchange for monetary compensation.

14.6. However, certain limited disclosures of identifiers, demographic information, pseudonymized identifiers, device information, advertising identifiers, usage data, or attribution data to Survey Clients, service providers, analytics providers, attribution partners, Gaming Feature partners, or other partners may be considered a “sale,” “sharing,” or use for “targeted advertising” under applicable U.S. Privacy Laws.

14.7. These disclosures are limited to what is necessary to:

a) match you with relevant Surveys and earning opportunities;

b) verify eligibility and prevent duplicate participation;

c) track Survey participation, Gaming Feature milestones, and reward eligibility;

d) prevent fraud, abuse, and technical manipulation;

e) measure the effectiveness of our Services and advertising campaigns.

14.8. We collect sensitive personal data only with your explicit consent where required by applicable law.

14.9. We use sensitive personal data solely for the purposes described in this Privacy Policy, including matching you with relevant research opportunities, preventing fraud, and providing the Services.

14.10. Depending on your state of residence, you may have the following rights under applicable U.S. Privacy Laws:

a) the right to confirm whether we process your personal data and to access such data;

b) the right to correct inaccuracies in your personal data;

c) the right to request deletion of your personal data;

d) the right to obtain a copy of your personal data in a portable format;

e) the right to opt-out of the sale of personal data;

f) the right to opt-out of the sharing of personal data for targeted advertising;

g) the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable;

h) the right to limit the use and disclosure of sensitive personal data, where applicable;

i) the right not to be discriminated against for exercising your rights.

14.11. You may exercise your rights by:

a) using the in-App settings where available; or

b) contacting us at privacy@bohemianresearch.com.

14.12. We may require verification of your identity before processing your request, consistent with applicable law. For requests submitted by email, we may require you to contact us using the email address registered to your account or provide other information reasonably necessary to verify your identity.

14.13. We will respond to your request within the timeframes required by applicable law.

14.14. If we deny your request, you may appeal our decision by contacting us at privacy@bohemianresearch.com with the subject line “Privacy Request Appeal.”

14.15. We will review and respond to your appeal in accordance with applicable law.

14.16. If you are a California resident, you may also have the right to request information regarding the categories of personal information we have collected, the categories of sources from which such information was collected, the purposes for collecting, using, selling, or sharing such information, the categories of third parties to whom we disclose such information, and the specific pieces of personal information we have collected about you, subject to applicable exceptions.

14.17. We do not knowingly sell or share the personal information of individuals under the age of sixteen (16). The App is not intended for children, and you must be at least eighteen (18) years old, or the minimum legal age in your jurisdiction, to use the Services.

15. CONTACT US

15.1. For any questions or concerns regarding this Privacy Policy, or to exercise your rights as a data subject, please contact our privacy team at privacy@bohemianresearch.com.

15.2. Inquiries from users located in the European Union or from supervisory authorities regarding our data processing practices can be directed to our EU Representative, Bohemian Research s.r.o., with its registered office at Rybná 716/24, Staré Město, 110 00 Prague 1, Czech Republic, at eu_privacy@bohemianresearch.com.