Borderless Access Private Limited (referred to in this Privacy Policy as “Borderless Access”, “we”, “us”, or “our”) provides and operates various services, including, without limitation, our Website (www.borderlessaccess.com) and other interactive websites, platforms, or applications through which such Services are made available, including but not limited to The Panel Station (www.thepanelstation.com) and its associated applications (The Panel Station).
This Privacy Policy describes the categories of personal information we collect, the purposes for which it is used, the safeguards we apply in order to protect your personal information, the parties with whom such information may be shared, your rights in relation to your personal information, and details of our Data Protection Officer. This Privacy Policy applies to all users, and we encourage our panellists, customers, visitors, business associates, and other interested parties to review it carefully before accessing our Services and sharing their personal information.
By using our Services or submitting personal information to us, you acknowledge that you understand and agree to be bound by this Privacy Policy, and agree that we may collect, process, transfer, use, and disclose your personal information as described in this Policy.
Further, by accessing any part of the Service, you are agreeing to this Privacy Policy.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, PLEASE DO REFRAIN FROM USING ANY OF THE SERVICES.
“Website” means https://www.thepanelstation.com/ and www.borderlessaccess.com, including all pages, content, features, and Services accessible through it, as well as any related subdomains or online Platforms that we manage. For the purposes of this Privacy Policy, Services refers to the online Platform available and operated at https://www.thepanelstation.com/ and its associated applications on the Apple App Store and the Google Play Store (collectively, the “Platform”), through which you may:
• Register for membership in a global community of survey participants;
• Complete online surveys, polls, and other feedback activities relating to products, Services, brands, trends, and consumer experiences;
• Earn points, rewards, vouchers, gift cards, or other incentives in exchange for providing opinions and responses; and
• Access features that facilitate communication, reward redemption, and participation in research activities.
(collectively, the “Services”).
The Services include all functionalities, features, content, and tools made available through the Website and related applications that help facilitate these research and reward activities.
Commitment to Professional Market Research Standards
Borderless Access Private Limited conducts market, opinion and social research in accordance with the principles set out in the ICC/ESOMAR International Code on Market, Opinion and Social Research and Data Analytics and other applicable professional standards governing market research in the jurisdictions where we operate. Personal Information collected for research purposes is processed solely to generate statistical, analytical and research insights and shall not be used for direct marketing, sales solicitation or advertising unless you have separately provided your explicit consent or such processing is otherwise permitted under applicable law.
Controller vs Processor
Depending upon the nature of the research project, Borderless Access may act as:
i. an independent Data Controller;
ii. a joint controller; or
iii. a Data Processor or Service Provider acting on behalf of our clients.
1. What personal information do we collect about you?
1.1. What is personal information?
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.
1.2. The personal information that we collect directly from those registering for the Service, includes the following categories:
i. personally identifiable information (e.g. first name, last name, gender, date of birth, phone number; marital status, e-mail, zip/postal code);
ii. personal profiles (Socio economic status, financial, insurance, sports, automotive, employment, education, employment status, health, home & family, household size, lifestyles, ecommerce, media, technology & travel);
iii. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning health, genetic data, data concerning a person’s sex life;
iv. results of surveys taken, interests, preferences and feedback;
v. survey history;
vi. an assigned unique identification number (“UID”);
vii. non-personally identifiable information on your household members;
viii. photo and video images of you as described in the next section;
ix. company/employer and other relevant employment related information;
x. geographic or location information;
xi. information contained in posts you may on the public forums and interactive features of the Service;
xii. information automatically collected about you, your use of the Service, and your behavior on the Service as described below;
xiii. 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 our staff when this is required for business purposes and permitted by law;
xiv. where permitted by law, aggregated behavioural activity from your mobile device app, collected using a third-party meter; or
xv. any other information that may be exchanged while accessing the Services, subject to you providing your consent for such additional information.
You are encouraged to ensure that the personal data provided to us remains accurate and up to date and to inform us promptly of any changes during the course of your relationship with us.
1.3. Sensitive Personal Information:
Certain research studies may require us to collect or process categories of Personal Information that are considered "Sensitive Personal Information", "Special Category Personal Data", or similar categories under applicable data protection laws.
1.4. Depending on the nature of the research study, this may include information relating to:
i. racial or ethnic origin;
ii. political opinions;
iii. religious or philosophical beliefs;
iv. trade union membership;
v. physical or mental health;
vi. genetic or biometric information;
vii. sex life or sexual orientation; or
viii. any other category of Personal Information designated as sensitive under applicable law.
1.5. We collect and process such information only:
i. where it is necessary for legitimate market, opinion or social research purposes;
ii. where such processing is permitted under applicable law;
iii. where appropriate safeguards have been implemented to protect your privacy; and
iv. where required by applicable law, after obtaining your explicit, informed and freely given consent.
We do not use Sensitive Personal Information for direct marketing, behavioural advertising, or to make decisions that produce legal or similarly significant effects on you unless expressly permitted by applicable law and disclosed to you in advance.
1.6. Will my photos or videos be collected?
i. Not all surveys require you to submit photographs or video recordings. Where a particular survey requires the submission of a photograph or video recording, you will be clearly informed before participation, and such content will only be collected with your explicit, informed, and freely given consent.
ii. Photographs or video recordings may be collected solely for legitimate market research purposes, including where necessary to fulfil the requirements of a specific research study, verify survey responses, confirm participant identity, or detect and prevent fraudulent or duplicate participation.
iii. We may engage trusted third-party service providers to collect, analyse, verify, or process such photographs or video recordings on our behalf. Such third parties are contractually required to protect your Personal Information and process it only in accordance with our instructions and applicable law. Where a third party collects or processes your information directly, its privacy policy may also apply, and we encourage you to review it before participating.
iv. You may withdraw your consent at any time; however, where photographs or video recordings are required for a particular survey, withdrawing your consent may prevent you from participating in that survey. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.
v. Nothing in this section limits or waives any rights you may have under applicable data protection laws.
1.7. How do we use your personal information?
Subject to the terms of this Privacy Policy, we use the above-mentioned categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the following purposes:
i. fraud detection, prevention and panel quality checks;
ii. to verify your identity;
iii. to conduct duplicate account checks;
iv. to conduct a quality scoring;
v. to prevent bots or invalid responses;
vi. to administer the Services to you and to our customers/ clients, including creating a database of individuals willing to take part in research and surveys and providing you information about rewards or gifts earned;
vii. to invite you to take part in surveys or research;
viii. to send you newsletters, e-mails or other communications relating to participation in any of our events, our proprietary product-related information, promotional events and content
ix. incentivizing your participation in surveys;
x. converting your points to vouchers/ coupons which shall include sharing your personal with our trusted third-party vendors who will administer these rewards to you on our behalf;
xi. processing survey results;
xii. evaluating which individuals may be best suited for specific surveys based on past survey history;
xiii. to respond to your requests;
xiv. 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;
xv. as may be necessary to support the operation of the Service, such as for billing, account maintenance, and record-keeping purposes;
xvi. to maintain statutory and regulatory compliance;
xvii. to send to you, solicitations, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
xviii. to anonymise or aggregate your data so that it can be used for statistical, research, and analytical purposes;
xix. to engage trusted service providers who support our operations (e.g., hosting, analytics, communication, security), subject to appropriate contractual safeguards;
xx. to comply with legal obligations, respond to lawful requests from authorities, enforce our rights, and resolve disputes;
xxi. to monitor, maintain, and improve the security of our systems and protect against unauthorized access or misuse;
xxii. to improve the functionality, performance, and user experience of the Service, including troubleshooting and analytics; or
xxiii. to profile users based on demographics, survey history, and interests to match them with relevant surveys.
We do not sell your personal information. If any sharing requires your consent, we will first provide a clear explanation of the purpose and obtain your explicit, informed consent before proceeding.
1.8. How your information moves through our research platform?
i. Registration and account creation.
ii. Identity verification and fraud prevention checks.
iii. Survey matching based on demographic and profiling information.
iv. Participation in research studies.
v. Reward fulfilment and account administration.
vi. Retention for legal, operational and quality assurance purposes.
vii. Deletion, anonymisation or de-identification in accordance with our retention policies and applicable law.
1.9. Privacy by Design:
Privacy and data protection principles are embedded into the design, development and operation of our systems, technologies and research methodologies. We implement technical and organisational measures intended to ensure that only Personal Information necessary for each specific purpose is processed.
1.10. Data Minimisation:
We collect only the Personal Information reasonably necessary to administer your panel membership, conduct research, prevent fraud, comply with legal obligations and operate our services. We regularly review our processing activities to ensure Personal Information remains adequate, relevant and limited to what is necessary for these purposes.
2. How do we share your personal information with third parties?
2.1. We may provide any of the described categories of personal information to our employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Services to you and to communicate with you.
2.2. We typically share your survey responses with clients in either anonymised, aggregated form or in pseudonymised form. Anonymised and aggregated data reflects group-level insights and cannot identify you. Pseudonymised data is shared at an individual level using unique identifiers such as your UID - but does not include your identity or contact details.
2.3. Pseudonymised data is information that relates to you but does not directly identify you because details such as your name and contact information are removed, though it could potentially identify you if combined with other data. Examples include your UID, a hashed email address, or other technical identifiers. We may share your UID with our clients, who may use cookies or other technical data for fraud detection and quality checks across different systems. Your identity or contact information will only be shared with clients for specific research purposes, and only after we obtain your explicit consent and confirm that their use complies with applicable laws and market research standards.
2.4. We may share your personal information with selected third-party service providers, vendors, and suppliers (“sub-processors”) who assist us in operating, maintaining, supporting, and improving the Services. These sub-processors may provide services such as hosting and cloud infrastructure, data analytics, communications, security, customer support, incentive fulfilment, and other operational or technical support functions.
2.5. Where required by applicable law, we ensure that appropriate safeguards are in place with respect to such disclosures, including written data processing agreements, confidentiality obligations, and, where applicable, cross-border transfer mechanisms such as standard contractual clauses or other lawful transfer safeguards. We do not permit our sub-processors to use your Personal Information for their own purposes, and we remain responsible for the protection of your Personal Information processed on our behalf.
2.6. We 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.
2.7. 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 our 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.
For this purpose, we enter into written agreements with any entity (including companies, organizations, or individuals) to whom we entrust the processing of personal information. Such agreements impose obligations relating to confidentiality, data security, restricted processing, and compliance with applicable data protection and privacy laws. Where personal information is transferred across borders, we ensure that appropriate legal safeguards are in place, such as standard contractual clauses or other lawful transfer mechanisms, as required by applicable law.
2.8. Separation of Research and Marketing Activities:
i. Research Activities:
Your survey responses are collected solely for legitimate market, opinion and social research purposes. We do not use individual survey responses to send targeted advertising, build consumer marketing profiles or make commercial decisions about you.
ii. Marketing Communications:
Where you choose to receive newsletters, promotional communications or other marketing materials, such communications are managed independently from your participation in research studies and may be withdrawn at any time using the unsubscribe mechanism provided or by contacting us.
2.9. Automated decision Making & Artificial Intelligence:
We may use automated systems to facilitate survey matching, participant eligibility assessment, fraud prevention, duplicate account detection, quality assurance and operational efficiency.
These processes are designed to support the integrity of our research panel and generally do not produce legal or similarly significant effects on individuals. Where applicable law requires additional safeguards or human review, we will implement such measures accordingly.
We may utilise artificial intelligence, machine learning and other automated technologies to improve fraud detection, respondent authentication, survey routing, language translation, operational efficiency and quality assurance.
These technologies are used responsibly and are subject to appropriate governance and human oversight where required by applicable law. AI systems are not used to make solely automated decisions producing legal or similarly significant effects on individuals without appropriate safeguards.
These activities are undertaken solely to protect research quality, maintain panel integrity and prevent fraudulent participation.
3. International / third-country data transfers:
3.1. We operate globally and therefore your Personal Information may be transferred to, stored or processed in countries other than your country of residence.
3.2. If you are located outside the United States, including in Argentina, Brazil, South Africa, Switzerland, the United Kingdom, or the European Economic Area (“EEA”), please note that our servers may be located outside your country of residence, including in India and other jurisdictions where we or our service providers operate. As a result, your personal data may be transferred to, stored in, and processed in countries outside your jurisdiction, including countries that may not provide the same level of data protection as your home country.
3.3. Where your Personal Information is transferred to or accessed from a country outside your jurisdiction of residence, we will ensure that such transfers are carried out in accordance with applicable data protection and privacy laws. This includes implementing appropriate safeguards, such as standard contractual clauses or other approved transfer mechanisms under the General Data Protection Regulation (GDPR), or complying with any conditions, restrictions, or mechanisms prescribed under the Digital Personal Data Protection Act, 2023 (India) or other applicable laws, where the destination country does not provide an adequate level of data protection.
3.4. In connection with such transfers, we enter into written agreements with the relevant recipient or sub-processor that clearly define the purpose, duration, and nature of the processing, the categories of Personal Information involved, the required security and protection measures, and the respective rights and obligations of the parties. We also conduct periodic oversight and monitoring of such recipients or sub-processors to ensure ongoing compliance with these agreed-upon safeguards.
3.5. Notwithstanding the foregoing, we remain committed to protecting your personal data and will continue to employ appropriate security procedures and technologies to keep it safe.
3.6. Where required by applicable law, we implement appropriate safeguards to protect such transfers, including:
i. Standard Contractual Clauses approved by the European Commission;
ii. the UK International Data Transfer Agreement or UK Addendum;
iii. adequacy decisions recognised by competent authorities;
iv. contractual safeguards required under applicable privacy laws; and
v. any other legally recognised transfer mechanisms.
Regardless of where your information is processed, we maintain appropriate technical and organisational safeguards designed to protect your Personal Information.
4. Direct Marketing Communications:
4.1. We may communicate with you using email, SMS, and other channels (sometimes through automated means) as part of our effort to market our Services, administer or improve our Platform or Services, or for other reasons stated in this Privacy Policy. You have an opportunity to withdraw consent to receive such direct marketing communications, as permitted under the applicable laws or by directly contacting us on the details mentioned at the “Contact Us” section below. 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:
i. Go to the Account Settings;
ii. Press on the “Unsubscribe” tab on the bottom right of the screen;
iii. Upon clicking on “Unsubscribe”, a dialogue box will appear;
iv. Choose the required option from the dialogue box; and
v. After choosing the option, press on “Unsubscribe” button.
OR
4.2. 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:
i. Noting your preferences at the time you register your account with the Platform;
ii. Logging into your account settings and updating your preferences; and
iii. Contacting us using the contact information provided below in “Deleting/Unsubscribing Your Account”.
4.3. Please note that you may continue to receive non-marketing communications as may be required to maintain your relationship with us. In addition to the communication described here, you may receive third-party marketing communications from providers we have engaged to market or promote the 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 such third party directly.
The applicable role depends upon the specific research engagement and the contractual arrangements governing the project.
5. Retention of your personal information and other data:
5.1. We will retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including the operation and administration of your account, facilitating your participation in research activities, administering rewards and incentives, maintaining the integrity of our research panel, or until your account is deleted, whichever is earlier. Personal data may be retained and processed for longer periods where required to comply with applicable legal or regulatory obligations, to comply with contractual obligations owed to our clients, to resolve disputes, enforce our agreements, conduct audits, verify survey participation and incentive fulfilment, respond to client reconciliation or validation requests, investigate complaints or suspected fraud, or protect our legal rights and legitimate interests.
5.2. Usage and technical data may be retained for internal analytics, security, fraud prevention, quality assurance, panel management, response verification and service improvement purposes and is generally retained for a limited duration, unless a longer retention period is required by law or is necessary to ensure the security, integrity, or proper functioning of our Sites and/or Portals.
5.3. We may retain limited personal data of individuals who have not completed the registration process or who have been identified as Fraudulent Users, solely for the purposes of providing registration-related support, preventing misuse of surveys, protecting the incentive redemption process, and ensuring Platform integrity, preventing duplicate registrations or repeated fraudulent activity, in accordance with applicable law. For the purposes of this Policy, “Fraudulent users” include individuals who engage in unlawful, deceptive, or abusive practices, such as creating bots, maintaining multiple accounts, submitting duplicate or automated responses, providing materially inaccurate information, or engaging in behaviour inconsistent with genuine survey participation.
5.4. Where you request deletion of your account or withdraw your consent, we may retain limited Personal Information for a period of up to one (1) year from the date of such request or account closure, where reasonably necessary to: (i) comply with applicable legal or regulatory obligations; (ii) satisfy contractual obligations owed to our clients; (iii) conduct audits, reconciliation, response verification, quality assurance or incentive validation; (iv) investigate or resolve complaints, disputes or suspected fraudulent activity; (v) establish, exercise or defend legal claims; or (vi) otherwise protect the integrity of our Services. During this retention period, your Personal Information will not be used to invite you to participate in surveys or for marketing purposes unless you subsequently reactivate your account or otherwise provide fresh consent.
6. Cookies, device data, and how is it used?
6.1. 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 us, they do not execute any code or virus and they do not contain any personal information. Cookies allow us to serve you better and more efficiently, and to personalize your experience while using the Services. 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 Platform, and to deliver content (which may include third party advertisements) specific to your interests. We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on the Platforms. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any of your personal information 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 Policy. You may also refer to our Cookies Policy.
6.2. When you use our Services, we may automatically collect certain technical and usage-related information associated with your device and interaction with the Services. This may include unique identifiers such as device identifiers and IP addresses, information about your activity within the Services, and general network or location information.
6.3. This information constitutes personal information under applicable data protection laws. We may use such information, either on an individual basis or after it has been aggregated and/or anonymised, to operate, maintain, improve, and enhance the quality, functionality, and security of the Services, to analyse usage trends, and to develop new features, promotions, and services.
6.4. Subject to applicable law and, where required, your consent, we may automatically collect the following information through cookies and similar technologies:
i. Domain name;
ii. Browser type and operating system;
iii. Web pages viewed;
iv. Links clicked;
v. IP address;
vi. Duration of visits to the Sites, Portals, and/or Services; and
vii. Referring URL or webpage.
6.5. 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).
6.6. 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.
7. Deleting/unsubscribing your account:
7.1. If you no longer wish to receive survey invitations, newsletters, promotional communications or other non-essential communications from us, you may unsubscribe by clicking on the "Unsubscribe" option available within your account or by following the process specified in Section 4 above. Please note that unsubscribing does not result in the deletion of your account or Personal Information. It only means that you will no longer receive survey invitations, promotional communications, or other marketing-related messages from us. Your account will remain active unless you separately request its deletion in accordance with Section 7.3 below.
7.2. If you choose to unsubscribe, you may continue to access your account in accordance with our applicable terms. However, where you request deletion of your account, any incentive balance that has not been redeemed or requested prior to the deletion request may be forfeited, subject to the applicable Rewards Policy. Please allow two to three (2–3) business days for processing any outstanding redemption requests.
7.3. If you wish to permanently delete your account and Personal Information, you must submit a deletion request by contacting our Data Protection Officer at dataprotectionofficer01@borderlessaccess.com.
7.4. Upon receipt of a valid deletion request, we will begin processing your request promptly. Please allow up to thirty (30) days for the deletion process to be completed.
7.5. During this 30-day period, your account will remain in a pending deletion status. If you log into your account, access the Platform using your existing account credentials, or access your account through any historical survey invitation, account activation link, or other account-specific link during this period, your deletion request will be deemed withdrawn and will automatically be cancelled.
7.6. Accordingly, if you wish your account to be permanently deleted, you should refrain from logging into your account or accessing the Platform using any existing account credentials or historical account-related links until you receive confirmation that your account has been deleted.
8. Your rights:
8.1. You may request access to, correction, erasure, or restriction of processing of your personal data, or withdraw consent where applicable, by contacting us at the email address provided in the below section. Such requests will be handled in accordance with the applicable laws and shall be subject to any lawful exceptions.
8.2. Depending on your country of residence and the applicable data protection laws, you may have one or more of the following rights in relation to your Personal Information:
i. the right to obtain confirmation regarding whether we process your Personal Information;
ii. the right to access your Personal Information;
iii. the right to correct inaccurate or incomplete Personal Information;
iv. the right to request deletion or erasure of your Personal Information;
v. the right to restrict or object to certain processing activities;
vi. the right to withdraw your consent at any time where processing is based on consent;
vii. the right to data portability where required by applicable law;
viii. the right to request human review of certain automated decisions where applicable;
ix. the right to lodge a complaint with the relevant supervisory or regulatory authority; and
x. any additional rights available under applicable law.
8.3. Legal Basis for Processing under GDPR and similar laws:
i . If you are located in the EEA, our legal basis for collecting and using the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect it.
ii. 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; and
• To comply with the law.
iii. 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 Policy. 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.
iv. To make a request relating to your personal information, please contact us at [dataprotectionofficer01@borderlessaccess.com]. If you have any questions, comments, or concerns about how we collect, use, or otherwise process your personal information, we encourage you to reach out to us at this address so that we may address and resolve the matter promptly. You also have the right, depending on your location, to lodge a complaint with the relevant data protection authority or regulatory body (for example, the applicable data protection authority in the European Union).
8.4. If you are a California resident - California Privacy Rights:
i. 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 Policy 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 Policy and is applicable in the 12 months preceding the effective date of the Policy. 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 Policy, 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: THE PANEL STATION DOES NOT SELL PERSONAL INFORMATION).
ii. 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 The Panel Station 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 Panel Station account, then clicking on “Unsubscribe” in the Account Settings and choosing “Unsubscribe & Delete” option OR by contacting us at: [dataprotectionofficer01@borderlessaccess.com]. If we receive a CCPA request from you, we will first make a 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 The Panel Station 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. The Panel Station 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 under section “Contact Us”.
8.5. If you are Indian resident -Data Privacy Rights (India – Digital Personal Data Protection Act, 2023):
i. If you are located in India, the Digital Personal Data Protection Act, 2023 (“DPDP Act”) grants you certain rights as a Data Principal in relation to your Personal Data processed by The Panel Station, acting as a Data Fiduciary. These rights are subject to applicable law and are intended to enable transparency, accountability, and protection of your privacy. The Panel Station shall retain your personal data for only such period as is necessary to fulfil the purposes for which it was collected, or until you request erasure of such personal data, in accordance with the retention practices described in this Notice/Policy and subject to any legal or regulatory retention requirements.
ii. Subject to the DPDP Act and applicable rules, you have the following rights:
• Right to Access Information: You have the right to obtain confirmation of whether your personal data is being processed and to access a summary of such personal data and related processing activities.
• Right to Correction and Erasure: You have the right to request correction of inaccurate or misleading personal data, completion of incomplete personal data, and erasure of personal data that is no longer necessary for the stated purpose or where consent has been withdrawn, subject to lawful exceptions.
• Right to Withdraw Consent: You have the right to withdraw your consent at any time, where processing is based on consent, and such withdrawal shall not affect the lawfulness of processing carried out prior to the withdrawal.
• Right to Grievance Redressal: You have the right to register a grievance in relation to the processing of your personal data, and such grievance shall be addressed by us within the timelines prescribed under applicable law.
• Right to Nominate: You have the right to nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity.
8.6. How can you exercise your rights?
Contact Us: mailto: dataprotectionofficer01@borderlessaccess.com
You may contact our Data Protection Officer or Grievance Officer, as applicable, with any questions, concerns, or complaints regarding the processing of your Personal Data. We will acknowledge and seek to resolve such matters in accordance with applicable data protection laws and within the statutory timelines.
If you are located in the European Economic Area (EEA), you have the right to lodge a complaint with the competent Supervisory Authority in your Member State in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation).
If you are located in the United Kingdom, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) under the UK General Data Protection Regulation and the Data Protection Act 2018.
If you are located in India, you have the right to raise a grievance under the Digital Personal Data Protection Act, 2023, including the right to approach the Data Protection Board of India where your grievance has not been resolved within the prescribed period.
If you are located in the United States, you may exercise your rights and submit complaints in accordance with applicable federal or state privacy laws, including, where applicable, to the relevant state authority such as a State Attorney General or designated privacy regulator (for example, under the California Consumer Privacy Act/California Privacy Rights Act).
If you are located in the United Arab Emirates, you have the right to lodge a complaint with the UAE Data Office or the competent local data protection authority under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data.
If you are located in African jurisdictions, you may lodge a complaint with the relevant national data protection authority in accordance with applicable law, including, where applicable:
• Information Regulator (South Africa) under POPIA,
• Nigeria Data Protection Commission (NDPC) under the Nigeria Data Protection Act,
• Office of the Data Protection Commissioner (Kenya) under the Data Protection Act, 2019, or
• Other competent supervisory authorities in your jurisdiction.
In accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679, the UK GDPR, and the Digital Personal Data Protection Act, 2023, the contact details of our designated Data Protection Officer / Grievance Officer are provided below.
Name: Ramanjeet Singh
Designation: Data Protection Officer / Grievance Officer
Email Address: dataprotectionofficer01@borderlessaccess.com
Postal Address: 7th Floor, Building 2B, Tower-3, Embassy Tech Village, Marathahalli, Outer Ring Road, Devarabeensanahalli, Bengaluru, Karnataka, India-560103
The Data Protection Officer / Grievance Officer may be contacted for any queries, requests, or grievances relating to the processing of personal data, including the exercise of data subject rights under applicable data protection laws. Any grievance, complaint, or request received under this section shall be acknowledged and addressed within such timelines as may be prescribed under applicable law. Where no specific timeline is mandated, we shall use reasonable efforts to respond within a reasonable period, taking into account the nature, complexity, and volume of requests.
9. Information Storage and Security:
9.1. Borderless Access is an ISO/IEC 27001:2022 and ISO/IEC 27701:2019 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.
9.2. 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.
10. External Links:
10.1. The Service may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and The Panel Station 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 The Panel Station is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release The Panel Station 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.
11. Children’s privacy:
11.1. The Service is not intended for individuals under the age of 18 years, or such higher legal age as may be prescribed under applicable law. The Panel Station does not knowingly collect personal information from individuals below this age. Where, at any time, the Services or Platform are made available to children, access shall be subject to the prior verifiable consent of a parent or legal guardian. If we are unable to verify such consent or establish the parent–child or guardian relationship, we reserve the right, at our sole discretion, to restrict or block access to the Platform and/or Services. Where research studies involve minors, additional safeguards may apply in accordance with applicable legal requirements, including the GDPR, COPPA, the UK GDPR and relevant local legislation.
12. Access of our Platform and Services by vulnerable persons:
12.1. Where the Services or Platform are accessed by individuals who may be considered vulnerable data subjects under applicable data protection laws, we shall take reasonable steps to ensure that any consent relied upon for the processing of personal data is freely given, specific, informed, and unambiguous. Where applicable law requires consent to be provided or validated by a legally authorised representative, guardian, or caregiver, we shall seek verifiable confirmation of such authority prior to processing. In the event we are unable to verify the validity of such consent or the authority of the representative, we reserve the right to restrict, suspend, or block access to the Platform and/or Services to ensure compliance with applicable law and to protect the rights and interests of the data subject.
13. Public Forums, Community Areas, and Testimonials:
13.1. Any information or content you choose to post in these spaces will be visible to other users and the public, and may be read, collected, and used by others. We recommend that you do not share sensitive or personal information in public areas. From time to time, we may display testimonials or endorsements on our Platform. Such testimonials will be published only with your consent and may include your username. If you wish to update or remove your testimonial, you may contact us using the details provided in the “Contact Us” section.
13.2. Please note that any personal data you voluntarily make public on the Platform including posts, comments, reactions, or other contributions in community areas—may be accessed, stored, or used by other users and could result in unsolicited communications. We are not responsible for how third parties use information that you choose to make public.
14. Changes to this Privacy Policy:
14.1. We review this Privacy Policy periodically to reflect changes in applicable laws, technology, market research standards, and our business practices. Any material changes will be published on this page together with the revised effective date. Where required by applicable law, we will notify you or obtain your consent before such changes take effect.
15. Personal Data Breach and Incident Response:
15.1. We maintain appropriate technical and organisational safeguards to detect, assess, and respond to personal data breaches. A “Personal Data Breach” means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.
15.2. In the event of a Personal Data Breach, we will investigate the incident, take reasonable steps to mitigate its impact, and document the facts, effects, and remedial actions taken, in accordance with applicable data protection laws.
15.3. Where required under applicable law, we will notify the relevant supervisory or regulatory authority and affected individuals, taking into account the nature of the breach and the potential risk to the rights and interests of individuals. Such notifications will be made in the form and manner prescribed under applicable laws. Any notification to affected individuals will, where required, include information about the nature of the breach, its likely consequences, and the measures taken or proposed to address it.
15.4. Notification may be delayed, limited, or omitted where permitted by law, including where such disclosure would impede a lawful investigation or where appropriate technical safeguards have rendered the affected personal data unintelligible.