Privacy Policy

Last updated: October 19, 2025

This Privacy Policy explains how Opinion (OPN) (“Company,” “we,” “us,” or “our”) collects, uses, shares, and protects information when you access or use our websites, documentation, applications, and related services (collectively, the “Services”). This Privacy Policy is incorporated into and forms part of our Terms of Use.

Contents

Introduction

Opinion (OPN) (the “Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this Policy. This Privacy Policy (the “Policy”) describes how we processes personal information that we collect through our digital or online properties or services that link to this Policy (including, as applicable, the Opinion platform, our website opinion.trade , social media pages, marketing activities, live events, etc.) and other activities described in this Policy (collectively, the “Services”). Capitalized terms not defined in this Policy are defined in our Terms of Use. This Privacy Policy does not apply to personal data about the Company’s employees and candidates, and certain contractors and agents acting in similar roles. Please read carefully and fully this Policy before using or continuing to use our Services and, if necessary, make appropriate choices in accordance with the guidelines in this Policy. If you do not provide certain personal data to us, we may not be able to provide the Services to you, or the use of the Services may be restricted, or the Services may not function to achieve the results we intend to provide. Changes. We may update this Policy from time-to-time to reflect changes in legal, regulatory, operational requirements, our practices, and other factors. Please check this Policy periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy. Any modifications to this Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates you’re acknowledging that the modified Privacy Policy applies to your interactions with the Services and our business.

Information We Collect

Information you provide to us. Certain features of our Services may necessitate the provision of specific information. While you have the option not to provide this information, doing so might restrict your ability to use or access these features. The types of information you may directly provide to us through the Services or other means include:

• Contact information: such as your first and last name, email address, billing and mailing addresses, and phone number.

Demographic information: such as your city, state, country of residence, postal code, and age.

• Profile information: such as the username and password you create to register an Account on our Services, the date of Account registration, redemption codes, biographical details, photographs or pictures, links to your social media profiles, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other details you add to your Account profile.
• Communication information: based on our exchanges with you, including when you contact us through the Services or communicate with us via social media or otherwise.
• Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them.
• Networks and connections: such as information about the people and accounts you are connected to and how you interact with them on the Services, such as the accounts of other users that you follow.
• Payment and subscription information: necessary to complete transactions and process your subscription, such as your payment card or bank account information (collected by our payment processors on our behalf) and transaction history.
• Financial Information. If applicable to your use of the Services, in order for us to process payments of any fees owed to us in connection with your use of the Services, you will be required to provide certain bank account online login information, bank account and routing numbers, credit card information (e.g., card brand, expiration date, and credit-card numbers) and other data related to your payment method. You authorize our third-party payment vendors and wallet providers to collect, process, and store your financial information in accordance with their respective privacy policies. For the purposes of this Policy, an “account connection” with such a third party is a connection you authorize or enable between your account and a payment instrument, or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal information and other information directly with such third-party. Examples of account connections include, without limitation: linking your account to a social media account or social messaging Services; connecting your account to a third-party data aggregation or financial Services company, if you provide such company with your account log-in credentials; or using your account to make payments to a merchant or allowing a merchant to charge your account. If you connect your account to other financial accounts, directly or through a third-party Services provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party’s Services. For example, if you connect your account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Policy.
• Other information: any additional data you provide to us, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may collect or receive personal information from sources other than you directly, including:

• Marketing and event partners: such as joint marketing partners and event co-sponsors.

Login integration partners: when you choose to access our Services through third-party platforms, these partners may provide us with data like your name, username, email address, profile picture, and other publicly accessible account information.

• Other sources: such as social media services, public records, service providers, and other publicly available sources.

Automatic data collection. We, along with our service providers and business partners, may automatically gather information about you, your computer or mobile device, and your interactions over time with our Services, communications, and other online services. This includes:

• Device information: This includes details about your computer or mobile device, such as the operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G/4G/5G), and approximate location information like city, state, or geographic area.
• Online activity information: This includes information about your interactions with our Services, such as the pages or screens you viewed, the duration of your visits to each page or screen, the website you visited before coming to our Services, navigation paths between pages or screens, details about your activities on a page or screen, access times and duration, and whether you have opened our emails or clicked on links within them.
• Communication interaction data: This includes information about your interactions with our emails, texts, or other communications, such as whether you open and/or forward emails.

Cookies and similar technologies. Some of the automatic collections described above are facilitated by the following technologies:

• Cookies: These are small text files that websites store on user devices. They allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. The cookies used on our sites include: “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies: Technologies like HTML5 provide functionality similar to cookies but can store larger amounts of data on your device outside of your browser, in connection with specific applications.
• Web beacons: Also known as pixel tags or clear GIFs, these are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Data about others. We may provide features that allow users to invite others to use the Services. In such cases, we may collect contact information about the invitees in order to send them the invitations. Please ensure that you have obtained the invitee’s permission before referring them to us or sharing their contact details with us.

How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Services delivery and operations. We may use your personal information to:

• Compare information for accuracy and verify it with third parties.
• Compile anonymous statistical data and analysis for our use internally or with third parties.
• Provide, operate, and improve the Services (including training our artificial intelligence models) and our business.
• Personalize our products and services, such as remembering the devices you have previously logged in from and retaining your selections and preferences as you navigate the Services.
• Establish and maintain your user profile on the Services.
• Enable user-to-user communications.
• Facilitate your invitations to contacts you wish to invite to join the Services and enable you to connect with and interact with content posted by other users.
• Communicate with you about the Services, including sending service-related announcements, updates, security alerts, and support and administrative messages.
• Enable security features, for example, by sending you security codes via email or SMS and remembering devices from which you have previously logged in.
• Inform you about events or contests in which you participate.
• Provide support for the Services and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business and to develop new products and services.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect, receive and use your personal information for marketing and advertising purposes.

• Direct marketing. We may send you direct marketing communications, which may be personalized based on your needs and interests. You have the option to opt-out of our marketing communications, as described in the Opt-out of communications section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interactions with the Services, our communications, and other online services over time (including the data described in the Automatic data collection section). They use this information to serve online ads that they believe will interest you. This practice is known as interest-based or targeted advertising. Additionally, we may share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Improvement and analytics. We may utilize your personal information to conduct analyses on your usage of the Services. This helps us enhance the Services and other aspects of our business. Specifically, it enables us to gain insights into user activity, such as identifying which pages are most and least visited, understanding how visitors navigate through the Services, and examining user interactions with our emails. Additionally, this information is instrumental in aiding us to develop new products and services.

Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal processes: This includes responding to subpoenas, investigations, or requests from government authorities.
• Protect rights, privacy, safety, or property: This extends to safeguarding the rights, privacy, safety, or property of ourselves, you, or others (including by making and defending legal claims).
• Audit internal processes: To ensure compliance with legal and contractual requirements or our internal policies.
• Enforce terms and conditions: To enforce the terms and conditions that govern the Services.
• Prevent, identify, investigate, and deter fraudulent or harmful activities: This includes addressing unauthorized, unethical, or illegal activities, such as cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may also aggregate, de-identify and/or anonymize your personal information so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used, to improve and add features to them, to train our proprietary algorithms and other machine learning purposes, to promote our business, and to conduct research. We will maintain and use de-identified information in de-identified form and not attempt to reidentify the information, unless required by law.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation: To facilitate the technical operation of the Services, such as remembering your selections and preferences as you navigate the site, and to determine whether you are logged in when you visit password-protected areas of the Services.
• Functionality: To enhance the performance and functionality of our Services.
• Advertising: To assist our third-party advertising partners in showing you ads on other online services that they believe will interest you, and to measure and analyze the performance of these ads.
• Analytics: To help us understand user activity, including which pages are most and least visited, how visitors move around the Services, and user interactions with our emails.

Retention. We generally retain personal information for as long as necessary to fulfill the purposes for which it was collected. This includes meeting any legal, accounting, or reporting requirements, establishing or defending legal claims, and preventing fraud. When determining the appropriate retention period for personal information, we consider several factors, such as: (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; (iv) the applicable legal requirements. We may store aggregated, de-identified, and/or anonymized data for as long as needed to support our lawful business purposes. Regarding biometric data, we will retain it only for as long as necessary to fulfill the initial purpose for which it was collected or until three years after the deletion of your account, whichever comes first.

How We Disclose Your Personal Information

We may disclose your personal information with the following parties and as otherwise described in this Policy, in other applicable notices, or at the time of collection. Affiliates. Our corporate parent, subsidiaries, and affiliates. Services providers. Third parties that provide services on our behalf or help us operate the Services or our business (such as artificial intelligence providers, hosting, information technology, customer support, email delivery, marketing, consumer research, cookie providers and website analytics). Payment processors. Any payment card information you use to make a purchase on the Services is collected and processed directly by our payment processors. Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. Third parties designated by you. Where you have instructed us or provided your consent or authorization to do so, or as otherwise necessary to provide the Services. We will disclose personal information that is needed for these third parties to provide the services that you have requested. Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you. Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. Authorities and others for legal, compliance and security purposes. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. We may also disclose information for fraud detection or prevention. Business transferees. In the context of actual or prospective business transactions (e.g., investments in or financings of the Company, public stock offerings, the sale, acquisition, transfer or merger of all or part of our business, assets or shares, or similar transactions) and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets). For example, we may need to share certain personal information with prospective counterparties and their advisers, an acquirer, successor, or assignee of the Company.

Other Sites And Services

Our Services may include links to websites, mobile applications, and other online services operated by third parties. Additionally, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations do not imply endorsement or affiliation with any third party. We do not control third-party websites, mobile applications, or online services, and we are not responsible for their actions or content. We encourage you to review the privacy policies of any third-party websites, mobile applications, or online services you use to understand their data practices and how they protect your information.

Security

We implement a variety of commercially reasonable technical, administrative, and organizational measures designed to protect personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or electronic storage is ever fully secure or error free. Therefore, you should take special care in deciding what information you provide to the Services. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third-party websites.

International Data Transfer

Your personal information may be transferred to locations where privacy laws may not be as protective as those in your state, province, or country.

Children

Our Services does not address anyone under the age of 18. If you are under the age of 18, please do not use any of the Services and do not provide any information, including without limitation, your name, address, contact information, email address, user name, etc., to us. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data in a manner prohibited by law, please contact us. If we learn that we have unknowingly collected personal information through the Services from a minor under the age of 18, we will comply with applicable legal requirements and make commercially reasonable efforts to delete their personal information. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Residents Of Certain U.S. States

This section applies if you are a resident of California, Colorado or another U.S. state that has passed a privacy law similar to the California Consumer Privacy Act, as amended (“CCPA”) and requires specific privacy notice disclosures. For purposes of this section, references to “personal information” shall also include “sensitive personal information” as those terms are defined under the CCPA. We collect, and, in the preceding 12 months we collected, the following categories of personal information and sensitive personal information (denoted by *): (1) identifiers, such as name, email address, IP address, other device identifiers; (2) personal information listed in the California Customer Records statute such as name and billing address; (3) commercial information, such as subscription status and history; (4) Internet and similar network activity information, such as information regarding your interaction with the Services; (5) geolocation information, such as IP address and billing address; (6) visual information such as images that you upload to the Services; and (7) Account access credentials, such as username and password*. For details on the purposes for collecting and disclosing your information, and the sources from which we collect it, refer to the “How we use your personal information” and “How we disclose your personal information” sections. Our personal information retention practices are outlined in the “Retention” section. We handle sensitive personal information as specified by the CCPA or with your consent. We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we sell or share personal information of residents under 18 years of age. California residents under the age of 18 who have registered and posted content to the Services can request its removal by contacting us. They must verify their authorship of the content and specify where it is posted. We will make reasonably good faith efforts to remove or anonymize the content so the minor is not individually identifiable in relation to the content, but we cannot guarantee complete or comprehensive removal. For instance, third parties may have copied or republished the content (and any user output generated as a result), and it may remain in archives beyond our control.

Your Choices

‍In this section, we describe the choices available to all users of the Services.

• Opt-out of communications. You can opt-out of marketing-related emails by following the opt-out or unsubscribe instructions provided at the bottom of the email, or by contacting us directly. Please be aware that opting out of marketing emails will not affect the receipt of service-related and other non-marketing communications.
• Cookies and web beacons. Most browsers are set to accept cookies by default, but you can remove or reject cookies by following the instructions in your browser settings. However, please note that disabling cookies may affect the proper functioning of the Services. For more information on cookies, including how to view, manage, and delete them, you can visit www.allaboutcookies.org. Additionally, you can configure your device to prevent images from loading, which can help prevent web beacons from functioning. Some internet browsers allow you to send “Do Not Track” signals to the online services you visit. Please be aware that we currently do not respond to “Do Not Track” signals.
• Advertising choices. You may be able to limit the use of your information for interest-based advertising through the following settings, options, and tools:

Browser Settings and Privacy Browsers/Plug-ins: Block third-party cookies via your web browser settings or by using privacy-focused browsers or ad-blocking plugins. Mobile Settings: Adjust your mobile device settings to restrict the use of your advertising ID. You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

• Linked third-party platforms. If you choose to connect to the Services through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
• Close your account. If you wish to request to close your account, please contact us.

Your Rights

Depending on your location, you may have certain rights in relation to your personal information. These rights may not be absolute and may only apply in specific circumstances. The rights you may have include:

• Right to Know/Access Your Personal Information: You may have the right to request access to the personal information we hold about you. This includes details about how we use and share your personal information, as well as how it has been or may be used or disclosed in the past.
• Right to Delete Your Personal Information: You may have the right to request that we delete the personal information we maintain about you.
• Right to Correct Your Personal Information: You may have the right to request that we correct any inaccurate personal information we hold about you.
• Right to Object to Targeted Advertising: You have the right to opt-out of the processing of your personal information for the purposes of targeted advertising, as defined under applicable law.

To exercise any of these rights, you can email us or delete your Account through the platform. We will not discriminate against you for exercising these rights. Verification and Authorized Agents To protect your privacy and security, we may need additional information to verify your identity before we can process your request. This may include the email addresses used for Account registration on our platform. You may designate an authorized agent to make requests on your behalf. To do this, you must provide written authorization or a power of attorney document. Before we accept a request from an agent, we will require proof that the agent is authorized to act on your behalf. We may also need you to verify your identity directly with us. Appeals If we deny your request, you have the right to appeal our decision. You can contact us to initiate the appeal process.

Changes To This Privacy Policy

We may update this Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make updates, we will post the revised Privacy Policy on this page and update the “Last updated” date at the top of the policy. We may also notify you of material changes via email and/or a prominent notice on our Services, prior to the change becoming effective. We encourage you to review this Policy periodically to stay informed about how we are protecting the personal information we collect. Changes to this Policy are effective when they are posted on this page or otherwise indicated in this Policy.

How To Contact Us

If you have any questions about our practices or this Policy, please email us at info@opinionlabs.xyz

Contact

If you have questions about this Privacy Policy, contact us at info@opinionlabs.xyz.