Privacy Notice

At Sapien, we are committed to protecting your personal data and privacy. Please read this privacy notice carefully to understand what personal data we collect about you, how we use it, who we share it with, and what privacy choices you have.

Sapien, established in 2023, is building the world’s largest and most diverse network of human data labelers that the AI industry relies on to power its high-performance models. Sapien’s novel approach to human data labeling through gamification creates positive reinforcement loops that ensure high engagement from labelers and optimal data quality for customers.

Sapien serves AI customers across multiple industries, including healthcare, web3, education, and leading LLMs. Sapien’s commitment to empowering anyone to earn a living wage by producing quality data while having fun is setting a new standard for how humans and AI work together.

This Privacy Notice applies to the personal data we collect from you when you participate in any of our data submission and data labeling activities.

When we refer to “Personal Data” in this Notice, we mean any information relating to an identified or identifiable individual. This includes, for example, names or personal identifiers such as your name and your IP address.

1. Personal Data We Collect

When you sign up to participate in our data submission, data labeling activities, and tasks you will provide certain information about yourself. This includes your name, contact information, and financial information to receive your rewards.

Depending on the specific data submission, data labeling project, or activity you are participating in, we will collect the following categories and types of personal data about you:

Categories of Personal Data we Collect	Examples of Personal Data Collected	Categories of Sources of Personal Data
Personal Identifiers	Name, Date of Birth, National Identification Number, IP Address	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks, Cookies, and other tracking technologies
Contact Information	Email Address, Home Address, Billing Address, Phone Number	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks
Account Information	User Name, Password, Activities, Completed Tasks	Directly from you when you sign up and derived from your participation in tasks
Sensitive Personal Data	Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, data concerning health, or data concerning your sex life or sexual orientation	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks, only when strictly required for the specific project you are signing up for and only subject to your explicit consent
Professional Information	Previous place(s) of employment, position(s), work history, earnings, resume	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks
Information about work completed for Sapien	Information about your data submissions and labeling work you have carried out for Sapien, including when you complete challenges	Directly from you or derived from your participation in our data submission or data labeling activities and tasks
Financial & Payment Information	Bank Account, PayPal Account, or other financial account information	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks
Internet or Other Network or Device Activities, Including Information from Cookies	Unique device and app identifiers (such as IP address), browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to Sapien, the search terms you entered into a search engine that led you to Sapien, which Sapien pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites	Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers, and other users)
Our interactions with you	Our interactions, such as email exchanges with our operations team, interactions you have with our employees or representatives, or any interactions with our social media posts	Directly from you, when you interact with Sapien
Any other information you choose to share with us	User-generated content (e.g., community posts, feedback), photographs, examples of your work, information on work previously performed, skills, tests taken, test scores, pay rates, and earnings information	Directly from you or derived from your participation in our data submission or data labeling activities and tasks

2. Cookies

Subject to your consent, we will use so-called “cookies” to offer you a comprehensive range of functions and to make using our website more convenient.Cookies are small files that are stored on your device with the help of your internet browser. You can consent to the use of cookies, learn more about the cookies we use and their purposes, and manage your preferences through the cookie declaration on our website.

3. How We Use Your Information

Purpose of processing	Lawful basis for processing
To administer your participation in our data submission and labeling projects and activities We will use your name, contact details, account information, professional qualifications, experience, and any other relevant professional information you provide to assign you appropriate projects and tasks based on your skills, experience, and past performance. Additionally, we will process information about the work you complete for Sapien, such as details of completed data submission and data labeling task projects and tasks, the quality and accuracy of your submissions, the time spent on tasks, to monitor your progress in these tasks and to ensure compliance with our standards.	Contract performance Our legitimate business interest in maintaining and facilitating your participation in our data submission and labeling projects and activities.
To manage your account We will use your username, account credentials, and account activities to create, manage, and maintain your account, ensuring that your participation in the data submission and labeling projects and activities and other projects is properly tracked and recorded.	Contract performance
To evaluate your submissions and ensure their quality We will use the information we hold about your data submissions and labeling work, to evaluate your work for quality, accuracy, and adherence to project requirements. This may include automated and manual review processes to maintain the high standards expected by Sapien and its clients.	Contract performance Our legitimate interest in ensuring that your submissions are of the quality required by us and our clients.
To distribute rewards We will use your name, contact information, information about your work completed for Sapien, and your financial and payment details to determine your eligibility for rewards Contract performance based on the quality and quantity of your work, and to facilitate the payment of these rewards.	Contract performance
To communicate with you We will use your name and email address to communicate with you about your ongoing participation in our data submission and data labeling projects and activities, as well as to send you notifications about new projects and challenges, updates, and any changes to our policies or processes.	Contract performance Our legitimate interest in recruiting participants for data submission, data labeling projects, and activities
To carry out performance analytics and improve our service We will use your personal identifiers, such as your name, account information, and other relevant details, along with information about the work you have completed for Sapien, to conduct comprehensive performance analytics. We will use the insights gained to refine our processes, tools, and guidelines and improve the experience for all participants by identifying common challenges or areas where additional support may be beneficial. We will also use aggregated data to provide better insights and services to our clients, ensuring that the data we deliver meets their specific quality and performance standards.	Our legitimate interest in managing our global network of individuals engaging in data submission and data labeling projects, activities, and tasks, and improving our services
To optimize our website experience and present you with personalized ads and content We will collect, use, and store your data, including the time of visit, originating IP address, domain name, type of browser and operating system, and geographic location, to compile statistics, understand how our website is used, and improve its operation. We will also present you with personalized ads and content based on your activities.	Your consent for the use of cookies Our legitimate interest in operational improvement and analytics
To promote the security of our website and services We will use your IP address, domain name, type of browser and operating system, and activity information to monitor the use of our website and services, verifying user activity and enforcing our information security policies.	Our legitimate interest in promoting the security of our websites and services and in protecting our rights and the rights of others.
For legal and administrative purposes We will collect and process the categories of personal data described in Section 2 above to comply with our legal and regulatory obligations and for legal and administrative purposes such as screening against fraud and money laundering and other criminal or unlawful activities, accounting, billing, and audit purposes, developing, maintaining and testing our systems, and for understanding, exercising, enforcing or protecting our legal rights and those of others.	Compliance with legal obligation Our legitimate interest in carrying out our business operations

4. Marketing

We may use your name, email address, IP address, and browsing history to send or show you updates on the latest news, offers, and promotions related to our products and services or to tailor and track your interactions with our ads on third-party websites. We will provide you with an option to unsubscribe or opt out of future direct marketing communications. You may also opt out by contacting us as set out in Section 9 below.

5. Information Sharing and Disclosure

We never sell your personal information; we will only share and disclose it as specified in this Privacy Notice:

Category of personal data	Who do we share it with?	For what purpose?
All personal data categories specified in Section 2 of this notice	Our service providers who process personal data on our behalf	We employ service providers to carry out certain functions on our behalf for the purposes set out in Sections 3 and 4. Examples of such service providers include Google Workspace, web hosting, payment processing providers, marketing agencies, IT systems, and applications.
All personal data categories specified in Section 2 of this notice	Our clients for which we are carrying out the data submission or data labeling project or activity	In specific projects, activities and challenges, it may be explicitly required by our clients that your personal data be shared with them as part of the project deliverables or to assess your eligibility to participate in the project. If such a requirement exists, we will inform you of this in the specific challenge terms before you participate. This data sharing will be limited to the information necessary for the client’s purposes and will be conducted in accordance with applicable data protection laws.
Your cookies data	Third-party networks and websites	Subject to our having obtained the appropriate consent from you, we share the data we collected through the use of cookies with third-party social media networks, advertising networks, and websites to advertise our services.
All personal data categories specified in Section 2 of this notice may be relevant	Prospective Buyer	Your personal information may be transferred as part of a merger, acquisition, or sale of all or a portion of our assets.
All personal data categories specified in Section 2 of this notice may be relevant	Government and regulatory bodies and other individuals, bodies, and organizations	Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities based on our legitimate interests or legal obligations. We may also disclose your personal data to individuals, bodies, and organizations such as law firms, accounting companies, consultants, banks, insurers, etc.

We enter into written agreements with the above companies specifying the purpose, duration, method of processing, types of personal data, protection measures, rights, and obligations of both parties. We will also reasonably supervise their personal data processing activities.

6. International Transfers of Personal Data

As an organization with a global workforce, we collect, transfer, store, and process your personal data in different jurisdictions, including Canada, the European Economic Area, and the United States.

Therefore, your personal data, as specified in Section 2 of this privacy notice, may be processed outside of your jurisdiction in countries and jurisdictions that are not deemed as providing an adequate or equivalent level of personal data protection by your local legislator or data protection supervisory authority. Nonetheless, we are committed to applying and maintaining the appropriate safeguards as required by your applicable data protection law to ensure the legality of such cross-border processing of personal data.

Certain data submission and data labeling activities may include sharing of your personal data and submissions to our clients that are based outside of your jurisdiction, in countries and jurisdictions that are not deemed as providing an adequate or equivalent level of personal data protection by your local
legislator or data protection supervisory authority. Where permitted to do so under the applicable data protection laws and regulations, such transfer shall take place as necessary for the performance of a contract between you and Sapien. You will always be notified in advice when you sign up for data submission and data labeling activities involving such transfer.

If you would like to get more information on the countries where we process personal data or obtain a copy of the appropriate
safeguard in place, please reach out to us at privacy@sapien.io.

7. Data Handling Practices

7.1 Security of processing

We implement reasonable security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure.

7.2 Retention period

We will retain your personal data for as long as necessary to achieve the purposes for which it was collected. We will also retain someof the personal data you share with us for other permitted purposes, such as to meet certain statutory requirements or for theestablishment, exercise, or defense of legal claims.

Our retention periods are based on business needs, and when your personal data is no longer needed, it is either irreversiblyanonymized or securely destroyed.If you would like to obtain more information on the retention periods applicable to your personal data, please reach out to us at privacy@sapien.com

8. Your Privacy Rights

8.1 Right of Access

You can ask Sapien to confirm whether or not we process your personal data and request a copy of that personal data.

Pursuant to the California Shine the Light Law, if you are a California resident, you can ask us for information about the third parties with whom we have shared your personal data for their marketing use.

8.2 Right to Rectification

You can ask us to amend or correct any outdated or inaccurate personal data we hold about you.

8.3 Other privacy rights

The data protection laws applicable to your personal data may provide for additional privacy rights, as listed below. Please be aware that certain exceptions apply to the exercise of these rights, and you will not be able to exercise them in all situations.

8.3.1 Right to erasure

In certain circumstances, you can ask us to delete or anonymize the personal data we hold about you. We will take reasonable steps to inform other controllers who are processing the data that you have requested to erase any links to, copies of, or replications of it.

8.3.2 Right to withdraw consent

You can withdraw any consent to processing that you have given us and prevent further processing of your personal data if there is no other ground under which Sapien can use to justify the processing of your personal data.

8.3.3 Right to restrict the processing

In certain circumstances, for example, when you ask us to correct your personal data, you can ask us to cease processing it with the exception of storage.

8.3.4 Right to object or opt-out of processing

In certain circumstances, for example, when we process your personal data in our legitimate interests, you can object or opt-out of such processing. Following your objection, we shall no longer process your personal data unless we can demonstrate compelling reasons to continue the processing.

You can always opt-out of the processing of your personal data for marketing purposes, including profiling, and we will stop such processing.

The right to object or opt-out of processing extends to your right to opt-out of the sale or sharing of personal information as set out in the US privacy laws applicable to your personal data.

We do not make any decisions about you based only on automated processing (with no human interaction), which produce legal effects or significantly affect you.

8.3.5 Right to data portability

You can ask us to transmit the personal data, that we have collected from you based on your consent or to execute our contract with you, to another organization electronically in a machine-readable format.

9 Contacting us

If you have any questions about Sapien’s personal data handling practices or would like to exercise your privacy rights, please do not hesitate to contact our Data Protection Officer at privacy@sapien.io.

If we are unable to resolve your inquiry or complaint, you have the right to contact the data protection authority in the country where you are based.

If you reside in the European Union, you can find the details of your relevant data protection authority here. We have also appointed anEU representative based in the Netherlands, who you can contact at privacy@sapien.io.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of such websites. We encourage you to review the privacy policies of those websites before providing any personal information.

11. Children's Privacy

Our website is not intended for children under the age of 13. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page and updating the "Last Updated" date at the top of the notice.

13 Provisions Applicable to California Residents

This Section applies in all cases where we process personal information of residents of the State of California. We have drafted this section in line with the California Consumer Privacy Act (CCPA) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Personal Information We Collect

We collect information that identifies, relates to, describes, references, can be associated with, or is directly or indirectly related to a particular consumer (“personal information”). In particular, we have collected the following categories of personal information from consumers in the last 12 months:

Category	Examples	Source
A. Identifiers	Name, phone number, email, IP address	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks.
B. Customer Records Information	Name, phone number, email	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks.
D. Commercial Information	Records of your participation in Sapien’s data submission and data labeling project, activities	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks.
F. Internet or other electronic network activity information	Browsing history, search history, information regarding your interaction with our website, and advertisement	Information collected via cookies and similar technologies
G. Geolocation data	Your geographic location	Information collected via cookies and similar technologies
K. Inferences drawn from your personal information	Profile of your preferences	Directly from you when you sign up to participate in our data submission or data labeling activities and tasks Information collected via cookies and similar technologies

We use your personal information as described in Section 3 of the Privacy Notice.

We may disclose your personal information to a third party for business purposes as described in Section 5 of this privacy notice.

In the last 12 months, we have disclosed the following categories of personal information for business purposes to the parties listed in Section 5 of this privacy notice:

Category A: Identifiers

Category B: Customer Records Information

Category D: Commercial Information

Category F: Internet or other electronic network activity information

Category G: Geolocation data

Category K: Inferences drawn from your personal informationIn the preceding 12 months we have not sold any personal information.

Your Rights

You can request to exercise all of the data subject rights stipulated in Sections 8.1, 8.2, and 8.3 free of charge by contacting us at privacy@sapien.io.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

Deny you any goods or services;
Charge your different prices for our services;
Provide a different quality of our services
Suggest that we will take any of the actions listed above.

14. Provisions Applicable to China Residents

This section applies in all cases where we process personal data of data subjects residing in China.

We do not collect any personal data that might be classified as sensitive under the China Personal Information Protection Law (PIPL).

Please refer to Section 5 above to understand how we share personal information with third parties.

Your Data Subject Rights

You can request to exercise all of the data subject rights stipulated in Sections 8.1, 8.2, and 8.3 free of charge by contacting us at privacy@sapien.io.

Cross-border Processing of Personal Data

We will follow the required procedures according to the law and take necessary steps to ensure that any personal data recipients comply with the protection standards specified by the relevant laws and regulations. If mandated by the applicable laws, we will conduct a security assessment or certification or use a standard contract for the cross-border transfer of personal data.

Contact

If you have any questions about how we process your personal data, please contact the person in charge of personal data protection at Sapien: privacy@sapien.io.

Last updated: Jan 21, 2025