Privacy Policy

Commitment to your privacy

Glocal Panel is a professional online research company, which adheres to Intellus guidelines in protecting respondent confidentiality along with ESOMAR (European Society for Opinion and Marketing Research) and BHBIA codes of conduct. The collection and reporting of information you provide will be maintained with high standard of professional conduct. All personal data you submit for market research purposes is pooled together and strictly remains confidential and anonymous unless explicitly stated in the study. Glocal Panel will respect your privacy at all times and the confidentiality of your answers will be maintained as described in this Policy. Your name, address, telephone number, personal data and individual responses will only be used as described in this Policy. Glocal Panel will respect your decision regarding participation in surveys, answering specific questions or termination of your membership in the panel. Details on termination of your membership can be found under our Terms and Conditions.
Before any professional is added to Glocal Panel, each professional is sent an invite (e-mail) to join the Glocal Panel. To ensure the privacy of professionals, each invite provides for an unsubscribe option. Once this option is selected by the professionals, Glocal Panel does not contact such professionals in future.

Who is collecting information and for what purpose?

Glocal Panel collects valuable information, which assists in developing new products and services. When you are on a Glocal Panel site and are asked for personal data, as defined under the GDPR, you are sharing that information with Glocal Panel alone, unless it is specifically stated otherwise.You acknowledge and accept that Glocal Panel may pass your personal data to any third-party company which assists Glocal Panel in managing the Honoraria Program available to its members. For the avoidance of doubt, such information may include your name and address and all other information necessary to enable these honorary providers or any other third party to properly administer our Honoraria Program.

WHAT INFORMATION AND HOW DO WE COLLECT?

We collect, store and use personal data in order to learn more about your use of the Website and to enable you to register for participation in studies or panels, such as when you update your profile data to ensure you receive invitations to studies or panels that are relevant to you, or when you update your address to ensure that your honoraria is sent to you.The kinds of personal data we collect include the following:
Information about your visits to and the use of the Website (see “Information About Website Visits” below)Information that you provide to us for the purpose of registering with us and enabling you to participate in studies or panels: Name Telephone number Email address Password Fax number Gender Birthdate Language Employer and other professional details TitlePrimary / secondary specialty Industry association membership / affiliation Website Employer name / type Qualifications Number of patients seen Participation in clinical trialsConferences attended Physical address Education detailsClient Information: Name Email address Title Company Office/geographic locationPhone Number

HOW DO WE USE YOUR INFORMATION?

We use your personal data to pursue our legitimate business interests which, in general, consist of responding to requests you make to us (such as wanting to participate in a study), or aiding us in serving you better. We collect only the information necessary to fulfill our legitimate business interests and keep it for only as long as is needed to fulfill those interests. We use your data in the following ways:To facilitate and improve our business:To facilitate creation and authentication of your personal profile, and identify you as a user in our systemTo help us improve our Website and the studies and panelsTo improve the quality and relevance of your experience in interacting with our Website and with the studies and panelsTo respond to your customer service inquiriesTo match you with appropriate, relevant studies and panelsTo respond to legal or regulatory inquiries as we believe to be required by applicable laws, regulations, or administrative authoritiesIf you choose not to provide your information to us, then we may not be able to provide you with certain requested information, and we may not be able to match you with appropriate, relevant studies and panel or provide you with honoraria.We may combine information you give us with publicly available information and information we receive from or cross-reference with select partners and others. By combining this information, we are better able to communicate with you about our services, enabling us to more effectively deliver opportunities to better serve you.

HOW DO WE SHARE YOUR INFORMATION?

Vendors and other authorized third partiesWe may share your information with vendors and other authorized third parties that provide us with services to assist us in serving you, including:Website hosting provider, located in United States, IndiaVendors that assist in facilitating the studies and panels, located in [North and South America, Europe, Middle East and APAC countries]Clients and PartnersWe may share your information with our clients, and with partners who supplement our capabilities, in aggregated/anonymized form, unless you give us your consent to share personal information specific to you with our clients or partners, with each such consent only applicable to the specific study for which you gave consent to such sharing.Legal or regulatory requirementsWe may share your information if we believe in good faith that such disclosure is necessary to:Investigate, prevent, or otherwise respond to illegal activities, suspected fraud, violations of our Terms of Use, or as otherwise required to comply with relevant laws, regulations, legal process, or governmental request (including to meet national security or law enforcement requirements) or to respond to subpoenas or warrants served on usRespond to an emergency which we believe in good faith requires to disclose information to assist in preventing death or serious injuryProtect or defend the rights, security, integrity, or property of GLocal Panel or its users, or to enforce our agreements and policiesMerger or SaleWe may share your information in the event of a potential or completed merger, acquisition, or sale of all or a portion of our assets.

CROSS-DEVICE IDENTIFICATION

If you use multiple devices to access the Site, we may acquire and utilize capabilities that link your various devices so that content you access on one device can result in relevant advertising on another device. Information we have collected from your different devices may be combined with other information you have provided us. We may use such information to help provide more tailored experiences and consistent services and experiences across all of your devices as explained in this Privacy Policy. We also may use this information to prevent fraud, such as by identifying when your personal profile is accessed from an unfamiliar device.

AUTOMATED INFORMATION COLLECTION

Information about Website visits

We may collect information about your computer and your visits to this Website such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information in the administration of this Website, to improve the Website’s usability and customize the content and/or layout of our page for each individual visitor.We may collect information about you using automated information collection technologies.  Such information may include browser and device information, demographic information and other information provided by you, and aggregated information where we combine your information with the information obtained from other users and other sources.  We may use and disclose such information for any lawful purpose.

Cookies and Related Technology

We and our service providers use cookies, web beacons, Adobe Flash cookies, and other technologies to receive and store certain types of information whenever you interact with us, or third parties that use our studies and panels, through your computer or mobile device. This information, which includes, but is not limited to: the pages you visit on our site or mobile application, ads you click on, which web address you came from, the type of browser/device/hardware you are using, purchase information and checkout process, search terms, and IP address-based geographic location, helps us recognize you, customize your Website experience and make our marketing messages more relevant. This includes GLocal Panel content presented on another website or mobile application. In addition to other technologies, we use Flash cookies to prevent fraud or other harmful activities.The help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time. If you set your device to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features (i.e. you will be able to browse the site, but you will not be able to make a purchase). You can block or control Adobe Flash based collection using the Website Storage Settings Panel and the Global Storage Settings Panel and following the instructions provided.

Location Information

When you use our Websites, mobile apps, and other services, we may use automated technology to collect information indicating the physical location of your device, such as GPS data, cell phone tower data, Wi-Fi signals, or your device’s IP address. We may use and disclose your location information as described in this Privacy Policy. For example, we may use your device’s physical location to provide you with personalized location-based services and content, such as by sending you information pertaining to products, services or offers that are relevant to your location. You may be permitted to allow or deny such uses, but if you do deny them, we may not be able to provide you with a personalized user experience.

Mobile

If you use a mobile device, your device may share location information (when you enable location services) with our Websites, mobile applications, services, or our service providers. We may also track and collect usage data, such as the date and time you use a mobile application to access our servers and the specific information accessed, based on your device number or other identifier. We use this information to improve our services, and provide you more relevant and personalized advertisements, studies and panels, and promotions.

Analytics

Analytics services such as Adobe Analytics and Google Analytics provide services that analyze information regarding visits to our Websites and mobile applications. They use cookies, web beacons, and other tracking mechanisms to collect this information.

Aggregated Information

We may collect and use aggregated personal information, which does not personally identify you. For example, we may calculate the percentage of our site users who have a particular zip code. In the course of aggregating data, we may combine third party data with yours and that of other users.

COOKIES

We may place a text file called a “cookie” in the browser files of your computer. The cookie itself does not contain personal information although it will enable us to relate your use of the GLocal Panel site to information that you have specifically and knowingly provided.In order to store visitor’s preferences, we may use cookies to record session information, record user-specific information on what pages users access or visit, customize web page content based on visitors’ browser type or other information that the visitor sends, alert visitors to new areas that we think might be of interest to them when they return to our site.A cookie can’t read data off your hard disk or read cookie files created by other sites. You can refuse cookies by turning them off in your browser. If you’ve set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You do not need to have cookies turned on to use this site.

PERSONAL PROFILE

Once a registered GLocal Panel member, you are invited to provide additional information in your personal and professional profile describing your credentials, professional experiences, academic background, biography, etc.Your GLocal Panel profile is only available for viewing by you. You may edit your profile at any time by using your e-mail and password to log in to your personal member pages.Providing additional information in your personal profile beyond what is required at registration is entirely optional and can be altered or removed by you at any time. Providing further information will enable GLocal Panel to better match panellists to available studies and panels and therefore it is advised to keep your profile up to date at all times, to maximize your opportunity to be matched with appropriate available studies and panels.

SECURITY OF YOUR PERSONAL DATA

GLocal Panel operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised individuals have access to the information provided by our customers.We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. Unfortunately, data transmission over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. While no computer system is completely secure, we believe the measures implemented by GLocal Panel reduce the likelihood of security problems to a level appropriate to the type of data involved.

SPAM

GLocal Panel maintains a strict “No-Spam” policy, which means that GLocal Panel does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent

CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations.  Per the CAN-SPAM Act, we will:not use false or misleading subjects or email addresses;identify the email message as an advertisement in some reasonable way;include the physical address of GLocalMind, Inc., which is #4512 Legacy Dr, Ste 100, Plano, TX, 75024;monitor third-party email marketing services for compliance, if one is used;honor opt-out/unsubscribe requests quickly; andgive an “opt-out” or “unsubscribe” option.If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at support@glocalmind.com and we will promptly remove you from all future marketing correspondences.

COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website is not meant for use by children under the age of 13. Our Website do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at support@glocalmind.com.IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE.

CHILDREN’S PERSONAL DATA

Our Website, studies and panels are not directed toward children under the age of 16, and we do not intentionally collect personal data from children under the age of 16. If a child under the age of 16 has provided us with personal data, we may disable the personal profile or seek to have a parent or guardian provide consent for the child’s personal profile.

CALIFORNIA RESIDENTS

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year.To request a notice, please submit your request to GLocalmind Inc. #4512 Legacy Dr, Ste 100,Plano,TX, 75024 or email us at support@glocalmind.com.If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email: support@glocalmind.com.

CALIFORNIA DO NOT TRACK DISCLOSURE

Some browsers have a do not track feature that lets you tell Websites that you do not want to have your online activities tracked. At this time, we do not respond to browser do not track signals, but we do provide you the option to opt out of interest-based advertising. To learn more about IBA or to opt-out of this type of advertising, visit the Network Advertising Initiative Website and the Digital Advertising Alliance Website. Options you select are browser- and device-specific.

PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional communications from us at any time by: (i) logging into your online and updating your preferences; (ii) contacting us by phone, email or postal mail, or (iii) following the removal instructions in the communication that you receive.

LIST OF THIRD-PARTY SERVICE PROVIDERS

GLocal Panel uses the following third-party service providers for the provision of services as mentioned. Additionally, if you have any questions or concerns about our third-party service providers, please email us at support@glocalmind.com.

COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.Your physical or electronic signature;Identification of the copyrighted work(s) that you claim to have been infringed;Identification of the material on our Website that you claim is infringing and that you request us to remove;Sufficient information to permit us to locate such material;Your address, telephone number, and email address;A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; andA statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.GLocal Panel’s Copyright Agent to receive DMCA Takedown Notices is 4512 Legacy Dr, Ste 100, Plano, TX, 75024, support@glocalmind.com, at GLocalMind, Inc., Attn: DMCA Notice, 4512 Legacy Dr, Ste 100, Plano, TX, 75024. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by GLocalMind, Inc. in connection with the written notification and allegation of copyright infringement.

FOR OUR EUROPEAN CUSTOMERS AND VISITORS

If you are located in the European Union, please take note that information we collect from you may be transferred to and processed in the United States, India, or other jurisdictions, where the applicable privacy protections may not be as comprehensive as those of your country of residence or citizenship, in order to fulfill the business purposes set forth in this Privacy Policy. By providing us with any information, you consent to your information being transferred to and processed in the United States, India or other countries whose privacy protections may be less comprehensive.We will comply with the EU Standard Contractual Clauses with respect to the transfer of personal data from the EU to the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of personal data to processors established in the U.S. (Commission Decision 2010/87/EC).

Obligations of the data importer (processors)

The data importer agrees and warrants:

• to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
• that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
• that it has implemented the technical and organizational security measures before processing the personal data transferred;
• that it will promptly notify the data exporter about:
  1. any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,
  2. any accidental or unauthorized access, and
  3. any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
• to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
• at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
• that to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;it has implemented the technical and organizational security measures before processing the personal data transferred;
• that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;
  

Obligations of the data exporter

The data exporter agrees and warrants:

• that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
• that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;
  
• that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
  
• that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
  
• that it will ensure compliance with the security measures;
  
• that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
  
• to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information; and
  
• that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses.
  

Liability

• Any data subject who has suffered damage as a result of any breach of the obligations by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
  
• If a data subject is not able to bring a claim for compensation in accordance with paragraph against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.
  

YOUR RIGHTS

You have the following rights with respect to your personal data:

• The right to be informed about how your personal data is used;
  
• The right to access your personal data;
  
• The right to rectify your personal data if it is inaccurate or incomplete;
  
• The right to erasure of your personal data (“the right to be forgotten”);
  
• The right to restrict processing of your personal data;
  
• The right to data portability—to retain and reuse your personal data for your own purposes;
  
• The right to object, in certain circumstances, to the use of your personal data; and
  
• The right to not be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects.
  
• The right to withdraw your consent
  
• practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority.
  
• Response. We will respond to your inquiry within thirty (30) days of the receipt.
  

To request more information about your rights or to exercise them, you may contact us at the contact information provided below.

CONTACT INFORMATION

If you have any questions or concerns about privacy-related issues, you may contact:
Name: Meghamala Hegde
Email: support@glocalmind.com
‍Address: #5, 10th Cross, Siddaiah Road,
Wilson Garden, Bangalore – 560027, India

FAIR INFORMATION PRACTICE PRINCIPLES

In the event of a personal data breach, we will notify you within seventy-two (72) hours of the breach via (i) email and/or (ii) our notification system on our Website.  We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

YOUR INDIA SPECIFIC PRIVACY RIGHTS

GLocal Panel does not sell, trade, or otherwise transfer to outside third parties your Personal Information as the term is defined under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to support@glocalmind.com or write us at GM Insights Solutions Pvt Ltd at #5, 10th Cross, Siddaiah Road, Wilson Garden, Bangalore – 560027, India.

Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at support@glocalmind.com or write us at GM Insights Solutions Pvt Ltd, at #5, 10th Cross, Siddaiah Road, Wilson Garden, Bangalore – 560027, India.

CHANGES TO THE PRIVACY POLICY

GLocal Panel may at any time, and in its sole discretion, amend its Terms and Conditions, including this Privacy Policy. Past versions of this Privacy Policy can be found below. If there are material changes to the Terms and Conditions or this Privacy Policy, GLocal Panel will make reasonable efforts to notify you. Please review our Terms and Conditions, and this Privacy Policy, periodically. Your continued use of the Website or participation in our research projects after any such amendments signifies your acceptance and agreement thereof.

JURISDICTION

These Terms and Conditions, and our Privacy Policy, constitute the entire agreement between you and GLocal Panel. This agreement shall be governed by and construed in accordance with Indian law.

Effective Date: August 11, 2020