Privacy Policy

Last updated: 1 September 2026 · Effective: 1 September 2026 · Version 1.0

This Privacy Policy explains how Opinyn collects, uses, records, stores, analyses, shares and protects personal data when you use the Opinyn mobile application, website and related services (collectively, the “Service”).

It also explains your rights regarding your personal data.

Data controller

The controller responsible for the processing of personal data through Opinyn is:

Jan Nik Jesenovec – Manumed s.p.

Kokošnje 13

1233 Dob

Slovenia

Email: info@opinyn.com

In this Privacy Policy, “Opinyn”, “we”, “us” and “our” refer to Jan Nik Jesenovec – Manumed s.p.

Questions or requests concerning your personal data may be sent to info@opinyn.com.

Scope of this policy

This Privacy Policy applies when you:

Third-party services may process personal data under their own privacy policies when you interact directly with them.

Personal data we collect

Depending on how you use Opinyn, we may process the following categories of personal data.

3.1 ACCOUNT AND IDENTIFICATION DATA

This may include:

We do not store your password in plain-text form.

3.2 APPLE AND GOOGLE SIGN-IN DATA

If you register or sign in using Sign in with Apple or Google Sign-In, we may receive information authorised by you and provided by the relevant service.

Depending on your settings, this may include:

If you use Apple’s email-hiding functionality, we may receive an Apple-generated relay email address instead of your personal email address.

Opinyn does not receive your Apple or Google password.

Apple and Google independently process personal data according to their own terms and privacy policies.

3.3 PROFILE DATA

This may include:

Some profile information may be visible to other users.

3.4 USER CONTENT

We process content that you create, upload, submit or share through Opinyn, including:

If you publish content publicly, it may be accessible to other users and may be copied, captured or shared by them.

You should not publish personal, confidential or sensitive information unless you have carefully considered the consequences and have the legal right to publish it.

3.5 VOTING DATA AND DILEMMA STATISTICS

Opinyn records information about dilemmas, available answer options and votes submitted through the Service.

For each dilemma, we may record and maintain information including:

A vote is generally connected internally to the user account or unique internal user identifier that submitted it. This allows Opinyn to:

Even where an individual voter’s identity is not displayed publicly, Opinyn may retain an internal record connecting the vote to the relevant account.

Unless a feature clearly states otherwise, other ordinary users will generally see aggregated voting results rather than a complete internal list connecting every vote to every voter.

Where Opinyn displays individual voting activity publicly, the user will be informed through the relevant interface, feature description or privacy setting.

Opinyn may maintain general and aggregated statistics, including:

Aggregated statistics may continue to exist after individual content or an account is deleted, provided that the statistics no longer identify the deleted user.

3.6 OTHER INTERACTION DATA

We process information about how you interact with Opinyn, including:

3.7 ANONYMOUS-POSTING DATA

Where Opinyn allows you to publish anonymously, your public profile identity may not be displayed to ordinary users in connection with that post.

However, Opinyn may still process:

Anonymous posting does not mean that the content is anonymous to Opinyn.

We may use this information to operate the feature, prevent abuse, investigate violations, protect users and comply with legal obligations.

3.8 REPORTS, COMPLAINTS AND APPEALS

When you report content, submit a complaint or appeal a decision, we may process:

Depending on the circumstances and applicable law, the identity of a reporting person may be kept confidential from the reported user.

Reports must be submitted honestly and in good faith.

3.9 COMMUNICATION AND SUPPORT DATA

When you contact us, we may process:

3.10 DEVICE AND TECHNICAL DATA

We may automatically process technical information such as:

We do not use IP-based approximate location as precise real-time location.

3.11 ANALYTICS DATA

Where enabled and legally permitted, we may process product-usage information through PostHog, Firebase or similar services.

This may include:

We configure analytics to avoid collecting passwords, private message contents, unnecessary personal data or the complete contents of text fields.

Where possible, general analytics and voting statistics will be aggregated or pseudonymised.

Non-essential analytics will be used only where we have an appropriate legal basis. Where consent is legally required, analytics will not be activated until consent is provided.

3.12 PUSH-NOTIFICATION DATA

If you allow push notifications, we may process:

Push notifications may concern:

Receiving push notifications requires permission through your device’s operating system.

You may disable or change push notifications at any time through:

Disabling push notifications does not delete your account and does not prevent you from using essential Opinyn features.

Essential legal, safety or account-security information may still be provided inside the Service or by email where necessary.

3.13 MARKETING DATA

If you choose to receive marketing communications, we may process:

Marketing consent is optional and is not required to create an Opinyn account.

Promotional push notifications will be sent only where permitted by law and consistent with your notification and marketing settings.

3.14 INFORMATION FROM OTHER USERS

Other users may provide information concerning you when they:

We may review such information where necessary to operate, secure and moderate the Service.

Sensitive personal data

Opinyn does not require users to provide special categories of personal data, such as information concerning:

However, users may voluntarily reveal such information through questions, dilemmas, answer options, votes, comments, photographs or videos.

A user’s vote may reveal or allow inferences concerning opinions, beliefs, health, sexual orientation or other sensitive characteristics, depending on the subject of the dilemma.

You should avoid publishing sensitive personal data or voting on sensitive matters unless you understand the potential consequences.

Do not publish another person’s sensitive data without a valid legal basis or permission.

Where required by law, we will process special-category data only with an appropriate legal basis under Article 9 GDPR.

We will not use sensitive voting inferences for targeted advertising.

How and why we use personal data

We process personal data for the following purposes.

5.1 PROVIDING AND MANAGING THE SERVICE

We use personal data to:

Legal basis: performance of a contract and steps taken at your request before entering into a contract.

5.2 RECORDING VOTES AND PRODUCING STATISTICS

We process voting data to:

Legal basis: performance of a contract and legitimate interests.

Our legitimate interests include preserving vote integrity, preventing manipulation, understanding Service usage and producing reliable aggregated results.

5.3 SAFETY, SECURITY AND FRAUD PREVENTION

We use personal data to:

Legal basis: legitimate interests, compliance with legal obligations and, where applicable, protection of vital interests.

Our legitimate interests include maintaining a safe, authentic and secure platform.

5.4 CONTENT MODERATION

We use personal data to:

Legal basis: performance of a contract, legitimate interests, compliance with legal obligations and, in urgent cases, protection of vital interests.

5.5 PERSONALISING AND RANKING CONTENT

We may use information about your activity, including general voting and interaction patterns, to:

Legal basis: performance of a contract or legitimate interests, depending on the feature.

Where required, you will be given appropriate controls or information regarding personalised recommendations.

5.6 ANALYTICS AND PRODUCT IMPROVEMENT

We may use analytics, voting and participation data to:

Legal basis: consent where required for non-essential analytics, or legitimate interests where processing is strictly necessary and permitted without consent.

You may withdraw consent through the privacy settings where analytics relies on consent.

Withdrawal of non-essential analytics consent does not prevent Opinyn from processing voting information necessary to record your vote and provide voting results.

5.7 PUSH NOTIFICATIONS AND COMMUNICATIONS

We use contact and notification information to:

Legal basis: performance of a contract, legitimate interests, legal obligations or consent, depending on the communication.

You may disable push notifications at any time in your device settings.

5.8 LEGAL COMPLIANCE

We may process personal data to:

Legal basis: legal obligation, legitimate interests, substantial public interest or protection of vital interests, as applicable.

Legal bases under the GDPR

Where the GDPR applies, we rely on one or more of the following legal bases.

A. Contract

Processing necessary to:

B. Legitimate interests

Processing necessary for legitimate interests such as:

We consider the nature of the data, users’ reasonable expectations and potential effect on rights before relying on legitimate interests.

C. Consent

We rely on consent for activities such as:

You may withdraw consent at any time. Withdrawal does not affect processing performed before consent was withdrawn.

D. Legal obligation

We process data where necessary to comply with obligations under applicable law.

E. Vital interests

In exceptional circumstances, we may process or disclose information where reasonably necessary to protect someone’s life or physical safety.

F. Legal claims and substantial public interest

Where applicable, we may process information necessary to establish, exercise or defend legal claims or for substantial public-interest reasons recognised by law.

Public information

The following may be public, depending on your settings and use of the Service:

An individual voter’s identity will not be publicly displayed unless the relevant feature, interface or privacy setting clearly indicates that the vote or voting activity is public.

Public information may be viewed, copied, captured, indexed or shared by other users or third parties.

Opinyn cannot control information copied or shared outside the Service by another person.

Who we share personal data with

We do not sell personal data.

We do not sell individual voting histories.

We do not use sensitive voting inferences for targeted advertising.

We may share personal data with the following categories of recipients only where reasonably necessary.

8.1 SERVICE PROVIDERS

We may use providers supporting:

These providers may process personal data only for the agreed purposes and subject to applicable data-protection obligations.

8.2 GOOGLE FIREBASE

Opinyn uses or may use Firebase services provided by Google for functions such as:

The exact data processed depends on the Firebase services enabled in the application.

This may include:

8.3 POSTHOG

Opinyn uses or may use PostHog for product analytics, including understanding application usage, feature engagement, general voting activity and technical performance.

PostHog may process:

PostHog should not receive passwords or complete text contents of private input fields.

Where legally required, non-essential PostHog analytics will be disabled until the user provides consent.

Opinyn will use the European-hosted PostHog environment where available and appropriate.

8.4 APPLE AND GOOGLE AUTHENTICATION

When you choose Sign in with Apple or Google Sign-In, the relevant provider processes authentication information independently and shares authorised account information with Opinyn.

Your use of these authentication services is also governed by the provider’s terms and privacy policy.

8.5 PUSH-NOTIFICATION PROVIDERS

Push notifications may be delivered through services provided by:

These providers may process device tokens, technical delivery information and other information necessary to deliver notifications.

8.6 OTHER USERS AND THE PUBLIC

We share public profile information, public User Content and aggregated voting results according to the Service’s functionality and your settings.

Anonymous posts do not display the author’s ordinary public profile identity unless required for moderation, safety or legal reasons.

8.7 AUTHORITIES AND SAFETY ORGANISATIONS

We may disclose personal data to courts, law-enforcement agencies, regulators, child-protection organisations, emergency services or other competent bodies where:

We assess requests for data and disclose only information that we reasonably believe is legally required or justified.

8.8 BUSINESS REORGANISATION

If Opinyn or relevant assets are reorganised, transferred, sold or merged, personal data may be disclosed to professional advisers and prospective or actual successors, subject to appropriate confidentiality and data-protection safeguards.

Users will be informed where required by law.

International data transfers

Some service providers may process personal data outside Slovenia or the European Economic Area.

Where personal data is transferred to a country not recognised as providing adequate protection, we use appropriate safeguards where required, such as:

Where available and appropriate, Opinyn will select European data-hosting regions, including an EU-hosted PostHog environment.

You may contact info@opinyn.com for more information about applicable transfer safeguards.

Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Unless a longer period is required or justified, the following retention principles apply:

Retention periods may be extended where information is necessary to:

When data is no longer required, it will be deleted or irreversibly anonymised.

Account, content and voting-data deletion

You may delete individual content through available application functions.

You may request deletion of your account:

Deleting the application from your device does not delete your Opinyn account.

Before completing deletion, we may need to verify your identity and account ownership.

Following deletion:

Deleting an individual vote, where this option is available, may change the displayed vote total and percentages.

Where deletion of an individual vote is not available through the interface, you may contact info@opinyn.com. Your right to erasure may be subject to applicable legal exceptions.

Additional information is provided in the Account and Data Deletion Policy.

Your data-protection rights

Where the GDPR applies, you may have the right to:

These rights may be subject to legal conditions and exceptions.

To exercise your rights, contact info@opinyn.com.

Your request should provide enough information for us to identify the account and understand the request.

We may request reasonable verification before acting. We will not request more information than necessary.

We will generally respond within one month, subject to any lawful extension for complex or numerous requests.

Right to object

Where processing is based on legitimate interests, you may object based on your particular situation.

We will stop the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or processing remains necessary for legal claims.

You may object to direct marketing at any time. If you object, your personal data will no longer be used for that purpose.

Withdrawing consent and managing preferences

Where processing relies on consent, you may withdraw consent at any time through:

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Refusing or withdrawing optional analytics, marketing or push-notification consent will not prevent you from using the essential features of Opinyn.

Submitting a vote requires Opinyn to process that vote and associate it internally with your account to provide the requested voting service, maintain accurate results and prevent abuse. This essential processing is not dependent on optional analytics consent.

Automated systems, voting identity and personalisation

Opinyn may use automated systems to:

Voting-identity features may derive information from your activity, such as:

These features are intended for platform functionality, engagement and entertainment. They do not represent a professional, medical, psychological, financial or legal assessment.

Automated indicators may support moderation, but significant enforcement decisions may be reviewed by a person where required by law or appropriate in the circumstances.

Unless expressly stated otherwise, Opinyn does not currently make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning users.

You may contact info@opinyn.com if you believe an automated system has incorrectly affected your content, vote or account.

Children and young users

Opinyn is intended for users aged 16 and older.

If a higher minimum age applies in the user’s country, the higher age applies.

Where a user cannot legally consent independently, valid permission from a parent or legal guardian is required.

Opinyn does not knowingly permit accounts that fail to satisfy applicable minimum-age requirements.

If we reasonably believe that an underage account has been created without valid authorisation, we may:

Parents or guardians who believe that a child is using Opinyn unlawfully may contact info@opinyn.com.

Opinyn takes additional measures designed to protect minors, including content-reporting tools, moderation, account controls and restrictions on prohibited sexual or exploitative content.

Personal data of minors will not be used for targeted advertising.

Information about other people

You must not upload or publish another person’s personal data unless:

Particular care must be taken before publishing information, photographs or videos involving minors.

Security

Opinyn uses reasonable technical and organisational measures designed to protect personal data, which may include:

No online service can guarantee absolute security.

You are responsible for protecting your login credentials and promptly reporting suspected unauthorised access.

Personal-data breaches

If a personal-data breach occurs, Opinyn will assess the nature and risk of the incident.

Where required by law, Opinyn will:

Marketing

Opinyn will send promotional emails or similar direct marketing only where legally permitted.

Where consent is required, we will ask for it separately.

You may unsubscribe at any time by:

Service-related, safety, legal and account-security communications are not marketing and may continue where necessary to operate your account.

Push notifications

If you enable push notifications, Opinyn may send notifications concerning:

Push notifications are delivered only where permission is granted through the relevant device or operating-system settings.

You may manage or disable push notifications at any time through:

Disabling push notifications does not:

Cookies and similar technologies

Where Opinyn provides a website, it may use cookies, local storage, software development kits, device identifiers and similar technologies.

These technologies may be used for:

Non-essential technologies will be used only where an appropriate legal basis exists and consent will be requested where required.

Further details are provided in the Cookie and Tracking Technologies Policy.

External links

Opinyn may contain links to third-party websites or services.

We do not control the privacy practices of third parties. You should review their privacy notices before providing personal data.

Supervisory authority

You have the right to lodge a complaint with the competent data-protection supervisory authority.

In Slovenia, the supervisory authority is:

Information Commissioner of the Republic of Slovenia

Dunajska cesta 22

1000 Ljubljana

Slovenia

Website: https://www.ip-rs.si

Email: gp.ip@ip-rs.si

You may also contact the supervisory authority in the EU or EEA country where you live, work or believe an infringement occurred.

Changes to this privacy policy

We may update this Privacy Policy to reflect:

The updated version will be made available through the Service.

Where changes materially affect your rights or how personal data is processed, we will provide additional notice and request consent where legally required.

Contact

For privacy questions, requests or complaints, contact:

Jan Nik Jesenovec – Manumed s.p.

Kokošnje 13

1233 Dob

Slovenia

Email: info@opinyn.com

Service provider and data controller: Jan Nik Jesenovec – Manumed s.p., Kokošnje 13, 1233 Dob, Slovenia · info@opinyn.com

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