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.
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).
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 [ firstname.lastname@example.org ] 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 [ email@example.com ].
If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us at firstname.lastname@example.org 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: email@example.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.
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.
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.
If you have any questions or comments about this Privacy Notice or the Service provided by MDforLives, please contact us at: firstname.lastname@example.org