Last updated: July 2, 2025 
            This Privacy Policy (“Policy”) explains the information collection, use, and sharing practices of Opinew
            Limited, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, Scotland, EH4 2HS
            (“we,” “us,””Opinew” and “our”), operated by Shop Circle LTD, One Kingdom Street, Paddington Central,
            London, United Kingdom, W2 6BD.
            
            Unless otherwise stated, this Policy describes and governs the information collection, use, and sharing
            practices of Opinew with respect to your use of our website https://www.opinew.com, services (“Services”)
            and apps (“Apps”) we provide and/or host on our servers.
            
            Before you use or submit any information through or in connection with the Services or Apps, please
            carefully review this Privacy Policy. By using any part of the Services, you understand that your
            information will be collected, used, and disclosed as outlined in this Privacy Policy.
            
            If you do not agree to this privacy policy, please do not use our Services or Apps.
             
Our Principles
            Opinew has designed this policy to be consistent with the following principles:
            
            Privacy policies should be human-readable and easy to find.
            
            Data collection, storage, and processing should be simplified as much as possible to enhance security,
            ensure consistency, and make the practices easy for users to understand.
            
            Data practices should meet the reasonable expectations of users.
             
              Information We Collect
            
            We will collect any information you provide to us. We may collect information from you in a variety of
            ways, such as when you: (a) Install the app, (b) contact support, (c)enter a newsletter flow, (d) download
            any of our apps. This information may include but is not limited to your name, email address, phone
            number, mailing address, payment information and your geographic location.
             
              Information You Provide Directly to Us
            
            We will collect any information you provide to us. We may collect information from you in a variety of
            ways, such as when you: (a) Install the app, (b) contact support, (c)enter a newsletter flow, (d) download
            any of our apps. This information may include but is not limited to your name, email address, phone
            number, mailing address, payment information and your geographic location.
             
              Information that Is Automatically Collected
            
 
              Device/Usage Information
             
            We may automatically collect certain information about the computer or devices (including mobile devices
            or tablets) you use to access the Services. As described further below, we may collect and analyze (a)
            device information such as IP addresses, location information (by country and city), unique device
            identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile device
            carrier information, and (b) information related to the ways in which you interact with the Services, such
            as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing
            pages, pages and content viewed and the order of those pages, statistical information about the use of the
            Services, the amount of time spent on particular pages, the date and time you used the Services, the
            frequency of your use of the Services, error logs, and other similar information. As described further
            below, we may use third-party analytics providers and technologies, including cookies and similar tools,
            to assist in collecting this information.
             
 Cookies and Other Tracking Technologies 
            We also collect data about your use of the services through the use of Internet server logs and online
            tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website
            activity is stored. A cookie is a small text file that is placed on your computer when you visit a
            website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c)
            understand the web pages of the Services you have visited and the referral sites that have led you to our
            Services; (d) enhance your user experience by delivering content specific to your inferred interests; (e)
            perform searches and analytics; and (f) assist with security administrative functions. Tracking pixels
            (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier
            embedded in websites, online ads and/or email, and that are designed to provide usage information like ad
            impressions or clicks, measure popularity of the Services and associated advertising, and to access user
            cookies. We may also use tracking technologies in our license buttons and/or icons that you can embed on
            other sites/services to track the website addresses where they are embedded, gauge user interaction with
            them, and determine the number of unique viewers of them. If you receive email from us (such as the
            newsletter, campaign updates, or other ongoing email communications), we may use certain analytics tools,
            such as clear GIFs, to capture data such as whether you open our message, click on any links or banners
            our email contains, or otherwise interact with what we send. This data allows us to gauge the
            effectiveness of our communications and marketing campaigns.
            Please note that you can change your settings to notify you when a cookie is being set or updated, or to
            block cookies altogether. Please consult the “Help” section of your browser for more information. Please
            note that by blocking any or all cookies, you may not have access to certain features or offerings of the
            Services or Apps.
             
Information from Third Parties
            By the extent permitted by law, we may also collect information from third parties, including public
            sources, social media platforms, and marketing and market research firms. Depending on the source, this
            information collected from third parties could include name, contact information, demographic information,
            information about an individual’s employer, information to verify identity or trustworthiness, and
            information for other fraud or safety protection purposes.
             
How We Use Your Information
            We may use the information we collect from and about you to: Fulfill the purposes for which you provided
            it.
            
            Provide and improve the Services, including to develop new features or services, take steps to secure the
            Services, and for technical and customer support
            
            Send you information about your interaction or transactions with us, account alerts, or other
            communications, such as newsletters to which you have subscribed.
            
            Process and respond to your inquiries or to request your feedback.
            
            Conduct analytics, research, and reporting, including to synthesize and derive insights from your use of
            our Services.
            
            Comply with the law and protect the safety, rights, property, or security of Opinew operated by
            ShopCircle, the Services, our users, and the general public; and
            Enforce our Terms of Use, including to investigate potential violations thereof.
            
            Please note that we may combine information that we collect from you and about you (including
            automatically collected information) with information we obtain about you from our affiliates and/or
            non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.
            
            We may aggregate and/or de-identify information collected through the Services. We may use de-identified
            and/or aggregated data for any purpose, including without limitation for research and marketing purposes.
             
 When We Disclose Your Information
            We may disclose and/or share your information under the following circumstances:  
Service Providers 
            We may disclose your information with third parties who perform services on our behalf, including without
            limitation, event management, marketing, customer support, data storage, data analysis and processing, and
            legal services.
             
Legal Compliance and Protection of Creative Commons and Others 
            We may disclose your information if required to do so by law or on a good faith belief that such
            disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the
            following reasons: (a) to comply with legal process; (b) to enforce or apply our Terms of Use and this
            Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c)
            enforce our Charter including the Code of Conduct and policies contained and incorporated therein, (d) to
            respond to your requests for customer service; and/or (e) to protect the rights, property, or personal
            safety of Opinew operated by ShopCircle ltd., our agents and affiliates, our users, and the public. This
            includes exchanging information with other companies and organizations for fraud protection, spam/malware
            prevention, and similar purposes.
             
Business Transfers 
            As we continue to develop our business, we may engage in certain business transactions, such as the
            transfer or sale of our assets. In such transactions, (including in contemplation of such transactions,
            e.g., due diligence) your information may be disclosed. If any of our assets are sold or transferred to a
            third party, customer information (including your email address) would likely be one of the transferred
            business assets.
            
            Affiliated Companies
            
            We may disclose your information with current or future affiliated companies.
            
            Consent
            
            We may disclose your information to any third parties based on your consent to do so.
            
            Aggregate/De-identified Information
            
            We may disclose de-identified and/or aggregated data for any purpose to third parties, including
            advertisers, promotional partners, and/or others.
            
            Confidential Information
            
            Opinew may not, during the term of this Agreement or at any time thereafter, without written permission of
            the Client, directly or indirectly disclose to any person outside of the Client, or to any person within
            the Client other than a person whose province it is to know the same, any information which is of a
            confidential nature or disclosure of which may damage the interests of the Client. Confidential
            information includes, but is not limited to, trade secrets, methods of doing business and customer and
            supplier lists.
            
            Opinew will not, and will use all reasonable endeavours to procure that every person connected or
            associated with Opinew will not, use other than in connection with the Proposal any confidential
            information which may have come to Opinew’s knowledge concerning the affairs of the Client, unless
            required to do so by law or by the regulation of any regulatory authority to which the Client is subject.
            
            On the termination of this Agreement, Opinew will deliver to the Client any and all documents or other
            media relating to the business of the Client.
             
 Intellectual Property Rights
            Opinew acknowledges that all the Client Materials and all associated Intellectual Property Rights will at
            all times remain the property of the Client or the Client’ licensor. Opinew will not use or modify the
            Client Materials or the Foreground IPRs other than for the proper performance of the Services. Opinew will
            keep the the Client Materials and the Foreground IPRs safe and secure and will take all reasonable care of
            any the Client Materials in its possession or control.
             
Legal Basis for Processing Personal Data
            The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or
            disclose information that can be directly linked to or used to identify you. To the extent those laws
            apply, our legal grounds for processing such information are as follows:
             
To Honor Our Contractual Commitments to You 
            Much of our processing of information is to meet our contractual obligations to provide services to our
            users.
             
Legitimate Interests In many cases, we handle information on the ground that it furthers our legitimate interests in
            ways that are not overridden by the interests or fundamental rights and freedoms of the affected
            individuals, these include:
             
- Customer service
- Marketing, advertising, and fundraising
- Protecting our users, personnel, and property
- Managing user accounts
- Organizing and running events and programs
- Analyzing and improving our business
- Managing legal issues
            We may also process information for the same legitimate interests of our users and business partners.
             
Legal Compliance 
            We may need to use and disclose information in certain ways to comply with our legal obligations.
             
Consent 
            Where required by law, and in some other cases where legally permissible, we handle information on the
            basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw
            your consent; in accordance with applicable law.
             
Online Analytics 
            We may use third-party web analytics services (such as Google Analytics) on our Services to collect and
            analyze the information discussed above, and to engage in auditing, research, or reporting. The
            information (including your IP address) collected by various analytics technologies described in the
            “Cookies and Other Tracking Technologies” section above will be disclosed to or collected directly by
            these service providers, who use the information to evaluate your use of the Services, including by noting
            the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud
            prevention, and providing certain features to you. To prevent Google Analytics from using your information
            for analytics, you may install the official Google Analytics Opt-out Browser Add-on.
             
Your Choices and Data Subject Rights
            You have various rights with respect to the collection and use of your information through the Services
            and Apps. Those choices are as follows:
             
EU Data Subject Rights 
            Individuals in the European Economic Area (“EEA”) and other jurisdictions have certain legal rights
            (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold certain
            information about them, to access such information, and to obtain its correction or deletion in
            appropriate circumstances. You may have the right to object to our handling of your information, restrict
            our processing of your information, and to withdraw any consent you have provided. To exercise these
            rights, please email us info@opinew.com with the nature of your request.
            
            International Transfers
            
            As described above in the “When We Disclose Your Information” section, we may share your information with
            trusted service providers or business partners in countries other than your country of residence in
            accordance with applicable law. This means that some of your information may be processed in countries
            that may not offer the same level of protection as the privacy laws of your jurisdiction. By providing us
            with your information, you acknowledge any such transfer, storage or use. If we provide any information
            about you to any third parties information processors located outside of the EEA, we will take appropriate
            measures to ensure such companies protect your information adequately in accordance with this Privacy
            Policy and other data protection laws to govern the transfers of such data.
            
            Security Measures
            
            We have implemented technical, physical, and organizational security measures to protect against the loss,
            misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the
            information that we collect and store. However, we cannot and do not guarantee that these measures will
            prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts,
            no Internet and/or other electronic transmissions can be completely secure.
            
            Data Retention
            
            We retain the information we collect for as long as necessary to fulfill the purposes set forth in this
            Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in
            copies made for backup and business continuity purposes for additional time. The data can also be
            completely erased upon receiving a request.
            
            Third-Party Links and Services
            
            The Services may contain links to third-party websites (e.g., social media sites like Facebook and
            Twitter), third-party plug-ins (e.g., the Facebook “like” button and Twitter “follow” button), and other
            services. If you choose to use these sites or features, you may disclose your information not just to
            those third-parties, but also to their users and the public more generally depending on how their services
            function. Opinew, is not responsible for the content or privacy practices of such third party websites or
            services. The collection, use and disclosure of your information will be subject to the privacy policies
            of the third party websites or services, and not this Privacy Policy. We encourage you to read the privacy
            statements of each and every site you visit.
            
            Changes to this Privacy Policy
            
            We will continue to evaluate this Privacy Policy as we update and expand our Services, and we may make
            changes to the Privacy Policy accordingly. We will post any changes here and revise the date last updated
            above. We encourage you to check this page periodically for updates to stay informed on how we collect,
            use and share your information.
            Questions About this Privacy Policy
            If you have any questions about this Privacy Policy or our privacy practices, you can contact us at:
            support@opinew.com
             
Questions About this Privacy Policy
 
            If you have any questions about this Privacy Policy or our privacy practices, you can contact us at:
            support@opinew.com