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PRIVACY POLICY


PRIVACY NOTICE

Borderless Access Private Limited (“Borderless Access”) services, including
(without limitation) our website (www.borderlessaccess.com) and other
interactive properties or application through which the services are delivered,
including, but not limited to, The Panel Station (www.thepanelstation.com),
MDforLives (www.mdforlives.com), and associated applications (The Panel Station,
MDForLives) (collectively, the “Service”) are owned, operated and distributed by
Borderless Access (referred to in this Privacy Notice as “Borderless Access” or
“we” and through similar words such as “us,” “our,” etc.). This Privacy Notice
outlines the personal information that MDforLives may collect, how MDforLives
uses and safeguards that information, and with whom we may share it.

MDforLives encourages our customers, visitors, business associates, and other
interested parties to read this Privacy Notice, which applies to all users. By
using our Service or submitting personal information to MDforLives by any other
means, you acknowledge that you understand and agree to be bound by this Privacy
Notice, and agree that MDforLives may collect, process, transfer, use, and
disclose your personal information as described in this Notice. Further, by
accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS
OF OUR TERMS OF SERVICE (the “Terms of Service”). IF YOU DO NOT AGREE WITH ANY
PART OF THIS PRIVACY NOTICE OR OUR TERMS OF SERVICE, PLEASE DO NOT USE ANY OF
THE SERVICES.


WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

Personal information (also commonly known as personally identifiable information
(PII) or personal data) is information that can be used to identify you, or any
other individual to whom the information may relate.

·      The personal information that we collect directly from those registering
for the Service, includes the following categories:

·       Personally, identifiable information (e.g. First Name, Last Name,
Gender, DOB, Phone number; Email, zip/postal code);

·    Personal profiles (Socio economic status, financial, insurance, sports,
automotive, employment, education, health, home &family, lifestyles, ecommerce,
media, technology & travel)

·        Results of surveys taken;

·         Survey history;

·         Medical License Number;

·          National Provider Identifiers (US);

·         Linked Profile links;

·          An assigned unique identification number (“UID”);

·          Non-personally identifiable information on your household members;

·          Photo and video images of you as described in the next section;

·          Company/employer and other relevant employment related information;

·          Geographic or location information;

·           Information contained in posts you may on the public forums and
interactive features of the Service;

·           Information automatically collected about you, your use of the
Service, and your behavior on the Service as described below;

·         Telephone calls and e-mails to us may be recorded and monitored for
quality control purposes only, and we may also intercept communications made to
individual members of staff at MDforLives when this is required for business
purposes and permitted by law;

·         Where permitted by law, aggregated behavioral activity from your
mobile device app, collected using a third-party meter.

·        Other information that may be exchanged in the course of engaging with
the Service, including. You will be aware of any subsequently collected
information because it will come directly from you.


WILL MDFORLIVES COLLECT PHOTOS OR VIDEOS OF ME?

Certain surveys will ask you to record photos or video of yourself as a part of
the responses. You will be alerted to such collection before taking a survey. By
choosing to take those surveys, and granting the appropriate rights at the time
of taking the survey you will grant MDforLives permission to use your likeness
in a photograph, video, or other digital media (“photo”) in any and all of its
publications, including web-based publications, without payment or other
consideration.

You understand and agree that all photos will become the property of MDforLives
and will not be returned. By taking such surveys you authorize MDforLives to
edit, alter, copy, exhibit, publish, or distribute these photos for any lawful
purpose, including, but not limited to marketing/marketing researches purposes.
In addition, you waive any right to inspect or approve the finished product
where your likeness appears. Additionally, you waive any right to royalties or
other compensation arising or related to the use of the photo.

Depending on the jurisdiction in which you are located, you may have the option
of expressing privacy rights as described in this Notice.


WHAT ARE THE SOURCES OF PERSONAL INFORMATION COLLECTED BY MDFORLIVES?

When providing personal information to MDforLives as described in this Notice,
that personal information is typically collected directly from you, and, when
collected directly from you, you will know the precise personal information
being collected by us. MDforLives does not collect personal information from any
other sources, except where it may automatically be collected as described above
regarding the third-party meter and in the section titled “Cookies, Device Data,
and How it is Used,” if the information in that section is considered personal
information.


HOW DOES MDFORLIVES USE PERSONAL INFORMATION?

Subject to the terms of this Privacy Notice, MDforLives uses the above described
categories of personal information in several ways. Unless otherwise stated
specifically, the above information may be used for any of the following
purposes:

·       to administer the Service to you and its customers, including creating a
database of individuals willing to take part in research and surveys and
providing you information about rewards or gifts earned;

·         to invite you to take part in surveys or research;

·          incentivizing your participation in surveys;

·         processing survey results;

·          evaluating which individuals may be best suited for specific surveys
based on past survey history;

·          to respond to your requests;

·          to distribute communications relevant to your use of the Service or
surveys, such as system updates or information about your use of the Service or
surveys;

·          as may be necessary to support the operation of the Service, such as
for billing, account maintenance, and record-keeping purposes;

·          to maintain statutory and regulatory compliance;

·           to send to you MDforLives solicitations, product announcements, and
the like that we feel may be of interest to you (you may “opt out” of receiving
these marketing materials)

·           in other manners after subsequent notice is provided to you and/or
your consent is obtained, if necessary.

 

MDforLives will not sell or rent your personal information to third parties
without your consent and such consent would be explicitly taken from you only
after providing the clear reasoning behind sharing such information in an
understandable manner.


HOW DO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

We may provide any of the described categories of personal information to
Borderless Access’ (for MDforLives) employees, consultants, affiliates or other
businesses or persons for the purpose of processing such information on our
behalf in order to provide the Service to you. In such circumstances, we require
that these parties agree to protect the confidentiality of such information
consistent with the terms of this Privacy Notice.

MDforLives may also share your personal information with third party
sample/market research companies (individually each a “Third-Party MR Company”
and collectively the “Third-Party MR Companies”) for the purpose of identifying
survey opportunities that you may be eligible for through those Third-Party MR
Companies. If you are eligible for a survey opportunity, the Third-Party MR
Company will provide your unique identification number and a survey link to us
and we will invite you to participate in the survey. We will not share your
name, email address, or phone number with the Third-Party MR Companies. If you
have any questions about this data sharing or want to opt-out of the data
sharing, please contact us as described herein.

We will not share your personal information with other, third-party companies
for their commercial or marketing use without your consent or except as part of
a specific program or feature for which you have the ability to opt-in or
opt-out.

In addition, we may release personal information: (i) to the extent we have a
good-faith belief that such action is necessary to comply with any applicable
law; (ii) to enforce any provision of the Terms of Service , protect ourselves
against any liability, defend ourselves against any claims, protect the rights,
property and personal safety of any user, or protect the public
welfare;               (iii) when disclosure is required to maintain the
security and integrity of the Service, or to protect any user’s security or the
security of other persons, consistent with applicable laws (iv) to respond to a
court order, subpoena, search warrant, or other legal process, to the extent
permitted and as restricted by law; or (v) in the event that we go through a
business transition, such as a merger, divestiture, acquisition, liquidation or
sale of all or a portion of our assets.


DIRECT MARKETING COMMUNICATIONS

We may communicate with you using email, SMS, and other channels (sometimes
through automated means) as part of our effort to market our products or
services, administer or improve our products or services, or for other reasons
stated in this Privacy Notice. You have an opportunity to withdraw consent to
receive such direct marketing communications, as permitted by law.

If you no longer wish to receive correspondence, emails, or other communications
from us, you may opt-out by submitting a request through by following Steps on
the website:

1.         Go to the Account Settings;

2.         Press on the Unsubscribe Button on the bottom right of the screen;

3.          Upon clicking on “Unsubscribe”, a Dialogue Box will appear;

4.          Choose the required option from the Dialogue Box;

5.            After choosing the option, press on “Unsubscribe” button.

 

OR

You may opt-out by submitting a request by using the UNSUBSCRIBE link in any
email communication you may have received. Further, you may express your
communication preferences by:

·          Noting your preferences at the time you register your account with
the Site [or our mobile application];

·          Logging into your account settings and updating your preferences;
Contacting us using the contact information provided below

 

Please note that you may continue to receive non-marketing communications as may
be required to maintain your relationship with MDforLives.

In addition to the communication described here, you may receive third-party
marketing communications from providers we have engaged to market or promote our
products and services. These third-party providers may be using communications
lists they have acquired on their own, and you may have opted-in to those lists
through other channels. If you no longer wish to receive emails, SMSs, or other
communications from such third parties, you may need to contact that third party
directly.


RETENTION OF DATA

MDforLives will retain your personal information only for as long as is
necessary for the purposes set out in this Notice, typically until your account
is deleted. We will retain and use personal information to the extent necessary
to comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes and enforce our
legal agreements and policies.

MDforLives will also retain usage data for internal analysis purposes. Usage
data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of our Sites
and/or Portals, or we are legally obligated to retain this data for longer
periods.


COOKIES, DEVICE DATA, AND HOW IT IS USED

When you use our Service, we may record unique identifiers associated with your
device (such as the device ID and IP address), your activity within the Service,
and your network location. MDforLives uses aggregated information (such as
anonymous user usage information, cookies, IP addresses, browser type,
clickstream information, etc.) to improve the quality and design of the Service
and to create new features, promotions, functionality, and services by storing,
tracking, and analysing user preferences and trends. Specifically, we may
automatically collect the following information about your use of Service
through cookies, web beacons, and other technologies:

·        domain name

·        browser type and operating system

·        web pages you view

·        links you click

·        IP address

·        the length of time you visit the Sites, Portals, and/or Services

·        the referring URL or the webpage that led you to the Sites

 

We may also collect information regarding application-level events, such as
crashes, and associate that temporarily with your account to provide customer
service. In some circumstances, we may combine this information with personal
information collected from you (and third-party service providers may do so on
behalf of us).

In addition, we may use "cookies," clear gifs, and log file information that
help us determine the type of content and pages to which you link, the length of
time you spend at any particular area of the Service, and the portion of the
Service you choose to use. A cookie is a small text file that is sent by a
website to your computer or mobile device where it is stored by your web
browser. A cookie contains limited information, usually a unique identifier and
the name of the site. Your browser has options to accept, reject or provide you
with notice when a cookie is sent. Our cookies can only be read by MDforLives;
they do not execute any code or virus; and they do not contain any personal
information. Cookies allow MDforLives to serve you better and more efficiently,
and to personalize your experience with the Service. We may use cookies for many
purposes, including (without limitation) to save your password so you don’t have
to re-enter it each time you visit the Service, and to deliver content (which
may include third party advertisements) specific to your interests.

We may use third party service providers to help us analyse certain online
activities. For example, these service providers may help us measure the
performance of our online campaigns or analyse visitor activity on the Service.
We may permit these service providers to use cookies and other technologies to
perform these services for MDforLives. We do not share any personal information
about our customers with these third-party service providers, and these service
providers do not collect such information on our behalf. Our third-party service
providers are required to comply fully with this Privacy Notice.


DELETING/UNSUBSCRIBING YOUR ACCOUNT

If you choose to end your membership with MDforLives Service or to require us to
cease processing your personal information, you may automatically discontinue
your membership by clicking on Unsubscribe after logging-in to your account on
the particular MDforLives Service. By following the appropriate directions, your
record will be marked as “do not contact”, and you will no longer receive
communications from the particular MDforLives Service. In addition, you will
forfeit any incentive balance that has not been requested as of the time you opt
out. Please allow two to three business days for processing of this change. As
an alternative, you may send an email directly to
[ dataprotectionofficermdfl@borderlessaccess.com ] requesting to be removed. We
will retain your information for as long as your account is active or as needed
to provide you services. We will retain and use your information as necessary to
comply with our legal obligations, resolve disputes, and enforce our agreements.


INTERNATIONAL DATA TRANSFER

If you are located outside the United States, in particular if you are located
in Argentina, Brazil, South Africa, Switzerland, the United Kingdom, or the
European Economic Area (“EEA”), please note that we and our servers are located
outside of the EEA. Any information that you provide to us may be transferred to
and processed in Indian and other countries around the world where we do
business. Although this may include recipients of information located in
countries where there may be a lower level of legal protection for your personal
information than in your country, we will protect your information in accordance
with requirements applicable to the law in your particular jurisdiction and take
steps to only share with third parties that offer similar protection. By using
our Service, you unambiguously consent to your information being collected,
processed, used, and transferred as disclosed herein.


DATA PRIVACY RIGHTS (EU, BRAZIL, SOUTH AFRICA, AND SIMILAR JURISDICTIONS)

If you are located in the EEA, Brazil, South Africa and similarly regulated
countries, data protection laws (e.g. General Data Protection Regulation
(“GDPR”)) grant you certain rights. In particular, the right to access, correct,
and delete the personal information we hold about you. MDforLives will retain
your personal information for the length of time you engage with our services as
described in the retention section of this Notice, until you request deletion of
such personal information.

·        In certain circumstances, you have the following data protection
rights:

·        The right to access, update, or delete the personal information we have
on you.

·        The right of rectification. You have the right to have your personal
information rectified if that information is inaccurate or incomplete.

·        The right to object. You have the right to object to our processing of
your personal information.

·        The right of restriction. You have the right to request that we
restrict the processing of your personal information.

·        The right to data portability. You have the right to be provided with a
copy of the personal information we have on you in a structured,
machine-readable and commonly used format.

·        The right to withdraw consent. You also have the right to withdraw your
consent at any time where we relied on your consent to process your personal
information.

 

 

In order make a request regarding your personal information, please contact
[ dataprotectionofficermdfl@borderlessaccess.com ].

If you have a comment, question, or complaint about how we are handling your
personal information, we hope that you contact us
at dataprotectionofficermdfl@borderlessaccess.com in order to allow us to
resolve the matter. In addition, depending on where you are located, you may
submit a complaint regarding the processing of your personal information to a
regulator (e.g. the EU data protection authorities).


LEGAL BASIS FOR PROCESSING UNDER GDPR AND SIMILAR LAWS

If you are located in the EEA, our legal basis for collecting and using the
personal information described in this Notice depends on the personal
information we collect and the specific context in which we collect it.

·         We may process personal information because:

·         We need to perform a contract with you;

·         You have given us consent to do so;

·         The processing is in our legitimate interest to offer the Service,
when that legitimate interest is not overridden by your rights;

·         To comply with the law.

 

Where personal information is processed based on consent, EU residents have the
right to withdraw such consent at any time. To do so, please contact us as
described in this Notice. If there is a different legal basis that would permit
us to continue processing your personal information after withdrawing consent,
we will notify you of that legal basis at the time of your request.


CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with certain
rights with regard to your personal information under the California Consumer
Privacy Act (“CCPA”). Throughout this Privacy Notice you will find information
required by CCPA regarding the categories of personal information collected from
you; the purposes for which we use personal information, and the categories of
third parties your data may be shared with. This information is current as of
the date of the Notice and is applicable in the 12 months preceding the
effective date of the Notice.

As a California resident, the CCPA provides you the ability to make inquiries
regarding to your personal information. Specifically, the degree to which the
information is not already provided in this Privacy Notice, you have the right
to request disclosure about the collection and use of your personal information
over the past 12 months, including:

·         The categories of personal information collected about you.

·         The categories of sources for the personal information collected about
you.

·         The business or commercial purpose for collecting your personal
information.

·         The categories of third parties with whom your personal information
was shared.

·         The specific pieces of personal information collected about you.

·         If your personal information was disclosed for a business purpose, the
personal information categories disclosed and the categories of third parties to
which the information was disclosed.

·         If your personal information was sold in the past 12 months, the
personal information categories sold and the categories of third parties to
which the information was sold. (NOTE: MDFORLIVES DOES NOT SELL PERSONAL
INFORMATION)

 

Please note that you may only make the above requests twice in a 12-month
period. You also have the right to request that any of your personal information
collected and retained be deleted, subject to certain exceptions. Finally, you
have the right to not receive discriminatory treatment by MDforLives or any
business for exercising any of the rights provided under CCPA.

You may submit a request to delete your personal data under CCPA by logging into
your MDforLives account, then clicking on “Unsubscribe” in the Account Settings
and choosing “Unsubscribe & Delete" option OR by contacting us at:
dataprotectionofficermdfl@borderlessaccess.com].

 

If we receive a CCPA request from you, we will first make determination
regarding the applicability of the law, and we will then take steps to verify
your identity prior to responding. The steps to verify your identity may vary
based on our relationship with you, but, at a minimum, it will take the form of
confirming and matching the information submitted in the request with
information already held by MDforLives and/or contacting you through previously
used channels to confirm that you submitted the request (i.e. confirming
identity through contact information that we have on file, not the contact
information submitted to make the request).

Your rights as stated here can also be exercised by an authorized agent on your
behalf. MDforLives will follow the standards set by the Attorney General of
California regarding designation of an authorized agent to exercise rights under
CCPA. You may review information available through from the Attorney General
regarding how an individual can be designated as an authorized agent under CCPA.

In addition to CCPA, California Civil Code Section 1798.83 permits users of the
Website who are California residents to request certain information regarding
its disclosure of personal information to third parties for their direct
marketing purposes. To make such a request, please contact us as described here.


INFORMATION STORAGE AND SECURITY

Borderless Access is an ISO 27001 certified company and we take adequate steps
to help protect your personal information. We employ industry-standard security
measures designed to protect the security of all information submitted through
the Service. However, the security of information transmitted through the
internet or via a mobile device can never be guaranteed. We are not responsible
for any interception or interruption of any communications through the internet
or for changes to or losses of data.

Users of the Service are responsible for maintaining the security of any
password, user ID or other form of authentication involved in obtaining access
to password protected or secure areas of the Service. In order to protect you
and your information, we may suspend your use of any of the Service, without
notice, pending an investigation, if any breach of security is suspected.


EXTERNAL LINKS

The Service may contain links to other websites maintained by third parties.
Please be aware that we exercise no control over linked sites and MDforLives is
not responsible for the privacy practices or the content of such sites. Each
linked site maintains its own independent privacy and data collection policies
and procedures, and you are encouraged to view the privacy policies of these
other sites before providing any personal information.

You hereby acknowledge and agree that MDforLives is not responsible for the
privacy practices, data collection policies and procedures, or the content of
such third-party sites, and you hereby release MDforLives from any and all
claims arising out of or related to the privacy practices, data collection
policies and procedures, and/or the content of such third-party sites.


CHILDREN’S PRIVACY

The Service is not intended for children under the age of 13 years, and
MDforLives does not knowingly collect the personal information of children under
the age of 13 years.


CHANGES TO THIS PRIVACY NOTICE

MDforLives reserves the right to modify this Privacy Notice from time to time in
order that it accurately reflects the regulatory environment and our data
collection principles. When material changes are made to this Privacy Notice,
MDforLives will post the revised Notice on our website. This Privacy Notice was
last modified as of 1st February 2021.


CONTACT US

If you have any questions or comments about this Privacy Notice or the Service
provided by MDforLives, please contact us
at: dataprotectionofficermdfl@borderlessaccess.com

 

MDforLives is a distinctive community of doctors from all around the world. We
conduct market research, group discussions, and other studies about healthcare
to empower pharmaceutical, life sciences, and medical devices companies with
elusive data from across the globe.

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