1. Why these terms exist
Normally you list a Study on Voxa and run it somewhere else, so we never see your questions or your Participants' answers. Our AI task builder and survey builder change that: they let you build and run a Study inside Voxa, which means we hold your Study content, your Participants' Submissions and any files they upload.
That is a materially different data protection position, and the law requires it to be written down. These Supplementary Terms do that. They apply automatically whenever you publish a Study with a data collection type of AI task or survey (a "Hosted Study").
These terms supplement the Researcher Terms, which continue to apply in full. The definitions in the Researcher Terms apply here, and references there to "these Terms" include these Supplementary Terms. Where these Supplementary Terms conflict with the Researcher Terms, these take priority.
2. Where the tools are available
Hosted Studies are available only where your organisation is established in the United Kingdom, the European Economic Area, Argentina, Canada, Israel, Japan, New Zealand, South Korea and the United States. We restrict availability because holding Submissions makes us your processor, and a processor-to-controller transfer needs a lawful route that we can stand behind.
We may change the approved territories, and may withdraw access to the tools, where a change in law, an adequacy decision or our own transfer assessment requires it. If we do, we will give you reasonable notice and you will be able to export your data before access ends.
If a Hosted Study will not meet your requirements, use an external study platform instead and list the Study on Voxa in the ordinary way.
3. What changes when a Study runs on Voxa
- We hold your Study content. Your questions, prompts, instructions, any dataset rows you upload and your survey pages are stored on our infrastructure.
- We hold Submissions. Participants' answers and any files they upload (up to 25 MB per file) are stored on our infrastructure and made available to you to review and export.
- Your Study content and Submissions are confidential. We will not disclose them to anyone other than our staff for the purposes described below, all of whom are bound by confidentiality obligations. We may disclose where the law requires it, or to our lawyers or insurers where necessary to take confidential advice or to establish or defend a claim.
- We may review Study content and Submissions, but only to confirm you are complying with the Researcher Terms and these terms; where a safeguarding concern or a Participant complaint arises; to resolve a dispute or appeal; and for troubleshooting, bug fixing and improving the platform.
- We will not use your Study content or Submissions for our own research or commercial purposes, and we will not use them to train general-purpose machine learning models.
4. What you must not collect
Two restrictions are absolute in a Hosted Study, because we hold the data and cannot accept the risk of holding it:
- Do not request direct identifiers. That includes name, email address, telephone number, full postcode, date of birth, and social media or gaming usernames.
- Do not collect special category data: information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation, even on a pseudonymous basis linked only to the participant identifier.
4a. Authenticity checks
A Hosted Study can measure how answers were produced and report a rating of high, mixed, low, or not checked against each submission. The measurement covers typing rhythm, pasted text, and time away from the page. It never analyses what a participant wrote, and we do not run responses through a text detector.
The rating tells you where to look. It does not tell you what happened, and you must not treat it as a finding of misconduct.
- Do not reject a submission on the rating alone. Read the answers and give a specific, verifiable reason, exactly as you would for any other rejection.
- Expect honest submissions to be rated low sometimes. Drafting elsewhere and pasting, dictation and other assistive input, and switching tabs to reread instructions all produce the same signals.
- Do not use the rating, or the fact that a participant was flagged, for any purpose beyond reviewing that submission.
5. Content standards
Because we host your Study content, unlawful content in it creates risk for us. You must not include in a Hosted Study any content that infringes a third party's copyright, rights in confidential information, image rights, privacy or other rights; that is defamatory, obscene, threatening or harassing; that encourages a crime; or that is otherwise unlawful.
Where unlawful content is included we may suspend your account immediately, remove the content, and you will be liable to us for the costs, expenses, losses, damages and liabilities we incur as a result, including under the indemnity in the Researcher Terms.
6. Who is controller and who is processor
You remain the controller of everything you collect. You decide the research question, the questions asked and what happens to the answers. You must still provide Participants with, or direct them to, a privacy notice that complies with the law applicable to you, and you must still have a lawful basis for what you collect.
| Data | Your role | Our role |
|---|---|---|
| Participants' Submissions to your Hosted Study, including uploaded files | Controller | Processor, acting on your documented instructions |
| Your Study content and configuration | Controller and owner | Processor, plus a limited own-purpose review right under section 3 |
| Participant demographic, screening and performance data we make available to you | Controller | Controller (controller-to-controller sharing) |
| Fraud, duplicate-account and authenticity signals we generate about a Submission | Recipient of high-level indicators only | Controller, for our own integrity purposes |
| Your Researcher account and billing data | Data subject | Controller |
7. Data processing agreement: details of processing
This section and the two that follow form the data processing agreement required by Article 28(3) of the UK GDPR and the EU GDPR (together "GDPR") in respect of the personal data we process on your behalf.
| Required detail | Position for Hosted Studies |
|---|---|
| Subject matter | Administration of your Hosted Study on the Voxa platform. |
| Nature and purpose of processing | Receiving, storing, transmitting, making available to you, exporting and deleting personal data in order to run your Hosted Study and support you. |
| Type of personal data | The personal data forming part of Participants' Submissions, including free-text answers, selections, ratings and uploaded files. The precise types depend on the questions you ask. Direct identifiers and special category data are prohibited under section 4. |
| Categories of data subject | Participants who take part in your Hosted Study. |
| Duration of processing | From the point you publish the Hosted Study until six months after a Submission is made, when we delete it automatically. You may export or delete sooner at any time, and we delete on account closure. |
| Your instructions | These Supplementary Terms, the Researcher Terms, and the configuration you set in the product, are your documented instructions to us. |
8. Our obligations as your processor
Where you ask us for assistance under this section that goes beyond what the product already provides, we may charge our reasonable costs, and we will tell you before we do.
- We will process the personal data only on your documented instructions, including as to international transfers, unless UK or EU law requires otherwise. In that case we will tell you before processing, unless the law prohibits us from doing so on important grounds of public interest.
- We will ensure that everyone authorised to process the personal data is bound by an appropriate duty of confidentiality.
- We will implement appropriate technical and organisational measures to secure the personal data, as required by Article 32 GDPR.
- We will assist you, by appropriate technical and organisational means and taking account of the nature of the processing, in responding to data subject rights requests.
- We will assist you in meeting your obligations under Articles 32 to 36 GDPR, taking account of the nature of the processing and the information available to us.
- We will delete Submissions six months after they are made, and on request or on closure of your account will delete or return the personal data we process for you. In practice you can export or delete it yourself at any time from the product.
- We will make available the information reasonably necessary to demonstrate compliance with these obligations, and will allow for and contribute to audits by you or an auditor you appoint, no more than once a year unless a regulator requires otherwise or we have had a material security incident.
- We will notify you without undue delay after becoming aware of a personal data breach affecting the personal data we process for you, and will give you the information you reasonably need to meet your own notification obligations.
9. Sub-processors
You give us general authorisation to appoint sub-processors, provided we impose on them data protection obligations equivalent to those in this agreement and meeting the requirements of Article 28 GDPR, and provided we remain liable to you for their performance.
Our current sub-processors for Hosted Study data are:
| Sub-processor | Function |
|---|---|
| Supabase | Managed PostgreSQL database holding all platform records, including Voxa-hosted study content and submissions. |
| Vercel | Application hosting, content delivery, serverless execution and scheduled maintenance jobs. |
| Malware scanning endpoint | Optional scanning of identity documents and verification video before storage. Only active when configured. |
10. Transfers of Submissions to you
This section applies only where your organisation is established outside the United Kingdom and the European Economic Area, and outside a territory covered by a relevant adequacy decision.
The Researcher Terms already cover controller-to-controller transfers of demographic, screening and performance data. Making Submissions available to you is a further transfer, on a processor-to-controller basis, where we are the processor and you are the controller.
That transfer is made subject to Module Four of the Standard Contractual Clauses approved by the European Commission on 4 June 2021 (the "EU SCCs"), as supplemented for UK transfers by the ICO's International Data Transfer Addendum (the "UK Addendum"). The optional docking clause does not apply. The EU SCCs and the UK Addendum are incorporated into these Supplementary Terms in full and both of us agree to comply with them.
For the purposes of Annex I of the EU SCCs and Part 1 of the UK Addendum: we are the data exporter and processor, and you are the data importer and controller; the data subjects are Participants in your Hosted Study; the categories of data are the personal data forming part of Submissions; the permitted recipients are your institution or organisation and any other recipient disclosed in your Study Terms; the frequency of transfer depends on how often you run Hosted Studies; the nature of the processing is receiving, storing, transmitting and deleting personal data; the purpose is administration of your Hosted Study; the duration is determined by you using the export and deletion features, and otherwise ends on closure of your account; and the competent supervisory authority is the UK Information Commissioner's Office.
For the purposes of Annex II, the technical and organisational measures you apply are those you disclosed to us when opening your account or subsequently and, until you have disclosed specific measures, the measures required by Article 32 GDPR.
11. Retention and export
We delete Submissions to a Hosted Study, including any uploaded files, six months after the Submission is made. This runs automatically as part of our scheduled maintenance. Export what you need before then: you will not be able to recover it afterwards.
You can export responses and delete them yourself at any time from the product. If your Voxa account is terminated or closed for any reason, we will delete Submissions held in the platform and may delete associated Hosted Study data.
Deleting a Submission does not delete the records that prove a Participant took part and was paid. Reservation, submission status, reward, ledger and audit records are retained under the ordinary schedule in our privacy notices, and contain no Study content.
12. Liability and other terms
The limitation of liability, indemnity, confidentiality, intellectual property, suspension, termination and general provisions of the Researcher Terms apply to Hosted Studies without change.
Where you use more than one Voxa tool for the same Study, and more than one set of Supplementary Terms applies, the terms specific to the tool that hosts the data take priority on questions about that data.
13. Changes
We may revise these Supplementary Terms and will notify you of material changes, normally by service message, at least 30 days before they take effect. Changes will not affect Hosted Studies already listed before they take effect. By continuing to use the tools after the effective date you accept the revised terms.