Privacy Policy

Last updated: 2019-09-16

Thank you for visiting our website. Data protection is important to us. In this privacy policy, we would like to inform you which data we process, for what purposes and which rights you are entitled to, when you visit our website, use our software applications, cloud service and other products (collectively, the “Services”)


The Services are operated by Pupil Labs GmbH, Sanderstraße 28, 12047 Berlin (hereinafter also referred to as “we”, “our” or “us”).

What are personal data?

Personal data are any information relating to an identified or identifiable natural person. Personal data include e.g. name, email address or telephone number. Personal data also includes information about websites viewed. Our policy is to only collect, use and/or pass on personal data if this is permitted by law or if you consent to the data processing.

How are your data collected and used?

Visit of our website

When you visit our website, we collect information automatically in so-called “server-log-files” that your browser transfers to us. For that purpose, our website uses cookies. Cookies are small text files that are stored on your hard drive assigned to the browser you use. Our website uses the following types of cookies:

  • Transient cookies: These are automatically deleted when you close the browser. Transient cookies store your session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close the browser.
  • Persistent cookies: These are only deleted after a specified period of time, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time. Please be aware that you may not be able to use all features of this site, when deleting the cookies from your browser history. The setting of cookies can be prevented by appropriate settings in the user's Internet browser at any time.

We collect the following data:

  • type/version of the browser
  • system software used
  • referrer URL
  • hostname of the device
  • time of the server request

If you are using a mobile device the following data are collected additionally through the website

  • country code
  • language
  • hostname of the device
  • name and version of the operational system

We use these data only for statistical analysis for the purpose of operation, security and optimization of our website. However, we reserve the right to check these data retrospectively if there is a justified suspicion of illegal use based on concrete indications. These data are then stored because this is the only way to prevent the misuse of our website and, if necessary, allow us to investigate any crimes committed. The storage of these data is necessary in order to protect us as the entity responsible for processing the data. As a matter of principle, these data will not be passed on to third parties unless there is a legal obligation to pass it on or the transfer of data serves criminal prosecution purposes.

This data processing is based on Art. 6 (1) f. GDPR (European Union General Data Protection Regulation, Regulation (EU) 2016/679) as we wish to stabilize and improve our website and to establish quality insurance and fraud prevention.

You can deactivate the use of cookies in the settings of your browser at any time. To find out how to change the settings, please consult the help function of your browser. However, we want to point out that without cookies, the use and comfort of use of the Services may be restricted.

Contacting us

If you contact us (e.g. by email), your details will be stored for the purpose of processing the enquiry and in the event that follow-up questions arise. This is done on the basis of your consent (Art. 6 (1) a. GDPR) or for the purpose of processing your enquiry (Art. 6 (1) b. GDPR).


On our website you may subscribe to our newsletter, which allows us to inform you about us and the Services.

When registering for the newsletter, you have to provide an email address. After registration, you will receive an email to confirm the registration (“double opt-in”). By clicking the registration link, you have given your consent to the processing of your personal data for receiving our newsletter according to Art. 6 (1) a. GDPR and we may process such data accordingly.

In case of registration for the newsletter, we also store the date of registration.


Mailchimp is a service by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA with which the dispatch of newsletters can be organized and analysed. With the help of Mailchimp we can analyze our newsletter campaigns. When you open an e-mail sent with Mailchimp, a file contained in the e-mail (so-called web beacon) connects to the Mailchimp servers in the USA. This allows you to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of registration, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

The mail provider “Mailchimp” receives and processes on our behalf the data necessary for the order, in particular email address, IP address, device name. These data are processed on servers in the USA. Mailchimp is certified according to the “Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.

If you do not want Mailchimp to analyse your data, you must unsubscribe from the newsletter. For this purpose, we provide a respective link in every newsletter.

Details on Mailchimp and its privacy policy can be found at the following link:

The data that are stored for the purpose of newsletter subscription will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of Mailchimp after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. email address for the use of the Services) remain unaffected.

Registration and use of the cloud service

In order to use our cloud service, you have to register with us, or log in using your previously-provided registration details. During the registration process, we ask you to provide us with certain data. Such data will only be sent and provided to us after you clicked the respective “Sign Up” button.

We will use your submitted data to carry out your registration with us, provide you with necessary functionalities of the Services based on Art. 6 (1) b. GDPR.

We may contact you via email if you send us a request as well as for purposes related to the use of the Services, based on Art. 6 (1) b.

Video Recordings

Whenever the Pupil Invisible device is mounted on the head of an individual (the “wearer”) and switched to the record mode, each eye of the wearer is filmed by one eye camera integrated into the spectacle frame. The two videos recorded by the two eye cameras are fed into a machine learning algorithm (neural network) which calculates the 2D gaze coordinates, and if the world camera is connected, an egocentric third video is recorded which can serve to visualize the gaze point of the wearer. Therefore, two (or three) videos are recorded and stored per recording – one from the world camera (if connected) and one from each of the two eye cameras. The data is saved into a recording folder on the cell phone (companion) device.

During each recording, metadata are also collected and these include recording timestamps, world camera and spectacles serial numbers, world camera image coordinates (2D gaze coordinates), cell phone (android) device ID/model/name, IMU (gyroscope) raw data, wearer ID (uuid), and audio data from the world camera microphone if switched on.

The processing of this data is based on Art. 6 (1) b. GDPR.

Training Videos

In order to improve individual gaze estimation accuracy, users will be able to perform a special routine for a wearer, which consists of recording a short video while looking at a reference gaze target on the cell phone screen. We then use the eye-tracking data and metadata to fine-tune the “universal” neural network into a personalized neural network, which can then be uploaded to the corresponding spectacle device. For this process, we collect the spectacle serial number, cell phone ID and wearer ID (uuid).

The processing of this data is based on Art. 6 (1) b. and f. GDPR as the training data is used to improve the accuracy of the Services in order to best fulfil the contractual obligations and to improve the quality of the Services in general.

If you choose to delete a wearer profile, we will ask you to further use the associated training data to improve the quality of the Services. You can request deletion of this data via email. Otherwise, you consent to the processing of this data based on Art. 6 (1) a. GDPR.

How are your data stored?

Each Pupil Invisible device is connected to a companion cell phone which serves as a data processing and storage unit and serves as power supply. The videos recorded from each exercise can be securely uploaded from the companion cell phone to Pupil Labs cloud storage, currently hosted by cloud service providers, Digital Ocean, LLC ( and Hetzner Online GmbH (, on servers located in Germany. Such upload is optional and provided via an explicit opt-in procedure. However, we have valid data processing agreements with the aforementioned host providers in order to ensure a high level of security for your personal data.

Once uploaded, you can review recordings on the web and collaborate with your team and colleagues. Your team can collaborate at any stage of the research workflow - from study prep, synchronization of devices in the field, to post-hoc analysis. Recordings are organised and searchable by meta-data so you can easily find and filter recordings to download for further analysis.

We, on the other hand, have no access to the recordings or any of your data which are uploaded to the cloud, except in the case of the training videos where we seek to improve individual gaze estimation accuracy.

Duration of the storage of personal data; deletion periods

As a rule, we only store your personal data for as long as it is necessary for the execution of the contract or the respective purpose and limit the storage period to an absolutely necessary minimum. Therefore, we delete your personal data, if your use of the Services ends and you have not agreed to a further use. An extended storage will only occur, if there is a legal obligation or if you have consented to do so.

Automated Decision Making (“Profiling”)

We do not process any data via “profiling” or in form of automated decision making via the Services. Profiling means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person. Examples of such profiling include the analysis of data (e.g. based on statistical methods) with the aim of displaying personalized advertising to the user or giving shopping tips.

Are your data transferred to third parties?

We will transfer your personal data to a third party only within the scope of legal provisions, i.e. in the course of a data processing agreement or if we are obliged to transfer the data due to a government or court order, or, if applicable, legal provisions authorize the transfer or if you give your explicit consent.

We already mentioned above the circumstances under which we transfer your data to Mailchimp and how the said data are used by Mailchimp. In addition to Mailchimp, your data may also be transferred to Stripe, Inc. of 185 Berry Street, Suite 550, San Francisco, CA 94107, USA (hereinafter “Stripe”), and Google, LLC of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).


For any processes regarding payments, we use the services of Stripe. Regarding any processes of payments, we do not receive, collect and/or store any payment data. Stripe will use such data for the purpose of managing the payments relating to our services.

Stripe Inc. is certified according to the Privacy Shield, and its privacy policy can be found at the following link:

The processing of this data is based on Art. 6 (1) f. GDPR as we have a legitimate interest to use professional payment providers for our Services.

Google Analytics

We use Google Analytics a web analytics tool offered by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland. This analysis service uses cookies. The cookies are generally transmitted and stored in Google server in the USA. As IP anonymisation is active on this website, your IP address will be shortened by Google within the member states of the European Union (EU). This information will be used to evaluate your use of the Services offered here and enable us to analyse your website activity and provide other services associated with the Service. The IP address transmitted from your browser, as part of Google Analytics will not be merged with other data from Google.

Adjusting the settings of your browser software can prevent the use of cookies. In this case, it may be possible that the functions of the Services offered here cannot be used in their entirety. Furthermore, it is possible to prevent the acquisition and processing of data generated by the cookies in relation to the use of this website, by downloading and installing the browser plugin available at the following link:

We also use Google Analytics to analyse data of Google Adwords for statistical purposes. OPT-OUT:

We point out that an automated decision making or profiling can take place when integrating Google and an existing Google account. OPT-OUT:

You can also find more information in Google's privacy policy:

The use of Google Analytics is based on Art. 6 (1) f. GDPR as we have a legitimate interest to analyse the use of our Website to optimize and improve our Services.

Are your data transferred outside the EU?

We do not transfer your personal data to any third party provider or location outside the European Economic Area except in accordance with the safeguards required under the GDPR.

We already mentioned above that your data may be transferred to Mailchimp, Stripe and Google (all located in USA) and we informed you of the safety measures applicable in each case.

What are your rights?

As a data subject you have the right:

  • to withdraw your consent to us at any time. As a result, we are no longer allowed to continue the processing of data based on this consent in the future;

  • to object to the processing of your personal data, if your personal data are processed on the basis of legitimate interests pursuant to Art. 6 (1) f. GDPR insofar as there are reasons for this arising from your particular situation;

  • to obtain from us access to your personal data. In particular, you may request access to the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored;

  • to demand a correction of any incorrect personal data;

  • to obtain from us without undue delay the rectification of inaccurate personal data concerning you;

  • to obtain the erasure of your personal data stored with us, unless the processing is necessary to exercise the right to free expression of opinion and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;

  • to demand the restriction of the processing of your personal data, if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have filed an objection against the processing; and

  • to receive your personal data, which you have provided to us, in a structured, current and machine-readable format or to request the transmission to another controller.

If you have given your consent to the processing of your data, you can revoke it at any time by sending us an email at Such revocation will affect the admissibility of processing your personal data by us. Insofar as we base the processing of your personal data on the weighting of interests, you may object to the processing. This is the case if processing your data is not required to fulfil a contract with you.

In the case of your justified objection, we will examine the situation and will either stop processing your data, adapt the data processing or point out to you our compelling legitimate reasons on which we continue the processing.

In general, we process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, deletion of the data is carried out.

If you wish to make use of your rights mentioned above please send us an email at

What safety measures are in place for protection of your data?

We have installed technical and organizational measures in order to safeguard our website and/or products against loss, destruction, access, changes or the distribution of your data by unauthorized persons.

Obligations for our customers who control the data of other persons

Pupil Labs is committed to complying with all data privacy requirements in any location where the Services are used. You should use care when handling personal data of individual wearers and other data subjects, and ensure that you have complied with the best privacy practices.

You shall first obtain the lawful permission of an individual before collecting, using, storing, transmitting, or transferring their data. You must provide access to information about how the data will be used as well as an easily accessible and understandable way to withdraw consent and/or delete their data. Data collected for one purpose may not be repurposed without further consent unless otherwise explicitly permitted by law.

If you consent to the processing of a data subject’s personal data, you warrant that you have the data subject’s permission to do so.

Enforcement of Privacy Policy

We make every effort to ensure that your personal information is used in accordance with this privacy policy. If you have any concerns regarding our adherence to this policy or the manner in which your personal information is used, kindly send us an email at

Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority in the member state of your residence, place of work or place of alleged infringement, if you believe that the processing of your personal data infringes on the GDPR.

Changes to this Policy

This privacy policy is accessible via our website under and may be downloaded and printed anytime. We reserve the right to amend and modify this Policy from time to time, taking into account currently applicable data protection provisions. So, please review it frequently.

Contact Details

For any inquiries and additional questions about processing personal data please contact us at