Privacy Policy

Protecting the individual's privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual`s right to data protection and privacy.

This Privacy Statement outlines how we handle information that we collect that can be used to directly or indirectly identify an individual ("Personal Data"). This Privacy Statement also provides information regarding how you can access and update your Personal Data and make certain choices about how your Personal Data is used by us. This Privacy Statement will come into effect from May 25, 2018.


WHO WE ARE



m360 Research Panels (www.m-panels.com) is owned and operated by M-Panels Research Services Pvt. Ltd., a leading international marketing research and marketing consulting company in Bangalore, India. We subscribe to the privacy, confidentiality, and ethics policies of these professional marketing and marketing research organizations:


  • European Pharmaceutical Market Research Association (EphMRA)
  • World Association of Research Professionals (ESOMAR)
General Information



When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to m360 Research and/or its affiliates or its group entities ("m360 Research") through m-panels.com (the "Website") or through subscription of our products and/or services, or by joining the m360 Research community on social media websites, or which is provided to one of our marketing partners, or which is provided through other engagements with m-panels or which is derived from the Personal Data as outlined below.


The use of and any information that is gathered by cookies or other web tracking technologies on the Website is subject to the disclosures and options provided by the Cookie Policy.


Data Controller. The data controller of the Website is m360 Research, 40/4, Lavelle Road, Bangalore - 560 001, Karnataka, India. Where a registration form is presented on this Website, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form's privacy statement. m360 Research's data protection officer is Rakesh Singh (dpo@m360research.com) and any queries that you may have regarding this Privacy Statement may be addressed to the above email address.


What Personal Data does m360 Research collect? m360 Research may collect the following information from you, through your use of the Website during the Website registration process, during the survey participation process, or by joining the m360 Research community on social media websites, or which is provided to one of our marketing partners or through engagement with m360 Research:

  • We collect (i) name; (ii) title; (iii) email address; (iv) company name and (v) phone number.
  • We also collect the IP address of the computer you used at the time you registered and confirmed your registration.
  • We also gather information on your practice such as education, specialty, number of patients, surgeries performed, type of practice, and your Internet speed, and computer capabilities to help us pre-screen members for certain surveys.
  • Additional information may also be requested when you participate in surveys.

None of the information collected in surveys is reported by the names or addresses of members. Your individual information is always placed into anonymous, statistical summaries that are used in Market Research. No one outside of m360 Research will ever know how you personally answered any of the questions in our surveys.


Cookies. Additionally, m360 Research may also collect cookies through your use of the Website. Cookies are text files that m360 Research may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. However, no personal information identifying the user is collected nor any data capture mechanisms is employed. You may change your cookie settings at any time, on your browser.


What do we do with your Personal Data? We will process the Personal Data provided hereunder only as set out in this Privacy Statement. Further information can be found in Sections B. and C. below. (1) Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data We are processing or using for which purposes in Section B below. (2) Where consent for the processing of your Personal Data is required you can find further information in Section C. below.


Duration of processing of Personal Data. Where m360 Research is processing and using your Personal Data as permitted by law (see B. below) or under your consent (see C. below), m360 Research will store your Personal Data (i) only for as long as is required to fulfil the purposes for which the Personal Data was collected. If, at any time, you object to use of your Personal Data (where m360 Research has a legitimate interest in using your Personal Data), or you withdraw your consent (as provided under Section C), m360 Research will stop processing of such Personal Data. However, where m360 Research is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for m360 Research to assert or defend against legal claims, m360 Research will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.


Why am I required to provide Personal Data? As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which m-panels cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to a web offering, newsletter or participate in a particular survey. In these cases, it will unfortunately not be possible for MANTHA Panels to provide you with what you request without the relevant Personal Data. At every instance when we are collecting Personal Data from you, you will be informed of the purposes for which such Personal Data will be used, and the option to opt-out of providing the information or any of the purposes for which your Personal Data might be used.


Where will your Personal Data be processed? As part of a global group of companies, m360 Research has affiliates and third-party service providers within as well as outside of the European Economic Area (the "EEA"). As a consequence, whenever m360 Research is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, m360 Research may transfer your Personal Data to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request to dpo@m-panels.com.


Data subject's rights.


Right to request for correction or deletion of Personal Data. You can request from m360 Research at any time information about which Personal Data m360 Research processes about you and the correction or deletion of such Personal Data. Please note, however, that m360 Research can delete your Personal Data only if there is no statutory obligation or prevailing right of m360 Research to retain it. Kindly note that if you request that m360 Research delete your Personal Data, you will not be able to continue to use any m360 Research service that requires m360 Research's use of your Personal Data.


Right to request for a copy of the Personal Data. If m360 Research uses your Personal Data based on your consent or to perform a contract with you, you may further request from m360 Research a copy of the Personal Data that you have provided to m360 Research.


Please click Subject Access Request Form to download the form and return the completed form to the contact details listed in the page.


Right to request for m360 Research to stop processing. Furthermore, you can request from m360 Research that m360 Research restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data m360 Research has about you is incorrect, (but only for as long as m360 Research requires to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for m360 Research processing your Personal Data and you demand that m360 Research restricts your Personal Data from further processing, (iii) m360 Research no longer requires your Personal Data but you claim that you require m360 Research to retain such data in order to claim or exercise legal rights or to defend against third party claims or (iv) in case you object to the processing of your Personal Data by m360 Research (based on m360 Research's legitimate interest as further set out in B. below) for as long as it is required to review as to whether m360 Research has a prevailing interest or legal obligation in processing your Personal Data.


Please direct any such request to dpo@m360research.com.


Right to lodge a complaint. If you believe that m360 Research is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which m360 Research has its registered seat.


Right to have the Personal Data transferred If at any time you wish to have your Personal Data transferred to another controller, you may contact us to request for such transfer.


Use of this website by children. This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website. If at any time, m360 Research is intimated that it has collected the data of users below 16 years or has provided services to such person, we will at once delete the data from our records and stop the provision of services.


Links to other websites. This website may contain links to foreign (meaning non-m360 Research Group companies) websites. m360 Research is not responsible for the privacy practices or the content of websites outside the m360 Research Group of companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.


Where m360 Research uses your Personal Data based on applicable Law




In the following cases, m360 Research Panel is permitted to process your Personal Data under the applicable data protection law.


We use information about you, your educational and professional data to determine whether you qualify to participate in a survey.


We use your email address to invite you to complete surveys and to notify you of news regarding the m360 Research Panel Operations.


We use your name and address to send you incentives to which you are entitled.


We use personal information gathered during surveys to analyse the survey results.


We use your personal information to verify you are who you say you are, and live where you say you live. Any evidence of false or dishonest information will result in the permanent loss of your membership.


We may use your contact information, such as email address, registration data and IP address to verify the opt-in nature of our email list when asked to do so by an Internet Service provider.


Usage of Personal Data. Furthermore, we communicate on a regular basis by email with users who subscribe to our services for the purposes as provided below, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions.


We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), m360 Research will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time at https://www.m-panels.com/Unsubscribe_User.php?id={link2}&src=N


Ensuring compliance. m360 Research and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, m360 Research is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through m360 Research's websites or other delivery channels controlled by m360 Research. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to m360 Research's services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.


Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the relevant m360 Research Group company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the m360 Research Group as required to ensure compliance.


m360 Research's legitimate interest. Each of the use cases below constitutes a legitimate interest of m360 Research to process or use your Personal Data. If you do not agree with this approach, you may object against m360 Research's processing or use of your Personal Data as set out below.


Purpose and legal basis for processing your personal data: We collect this personal data to provide the services to you that you are registering for, to tailor them to your needs and to provide services to our clients. Mandatory fields are marked on the registration form and without them you will not be able to register. Without this minimum amount of data, we cannot provide these services to you or conduct our business.


We process your personal data on the basis of our legitimate interest (i.e. we have a valid business reason to do this) and we have carefully balanced your individual rights against this need.


Questionnaires and surveys. m360 Research may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, m360 Research may use such Personal Data to improve its products and services.


Creation of anonymized data sets and profiling. m360 Research may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve our products and services.


Personal Data We May Collate About You: We use a variety of public sources to collate information about healthcare professionals we believe may be suitable to complete specific Activities or may wish to become members of m360 Research Panels. We may also receive a referral from one of your colleagues and process that information in a similar way. In addition, we will use our systems and public sources of information to keep the personal information we collect accurate and up-to-date. The information would include your name, contact information (address, phone number(s) and possibly email address) and your healthcare specialty.


Purpose and legal basis for processing your personal data: This data is used to manage our contact with you, so that for example multiple people do not try and contact you regarding the same project or you are not contacted again after you have already told us you are not interested in a specific project. We also use it as we generate lists of potential people to contact.


We process your personal data on the basis of our legitimate interest (i.e. we have a valid business reason to do this) and we have carefully balanced your individual rights against this need. For more information on legitimate interests please click here.


If you wish to be excluded from our programs entirely then please let us know either when an agent next contacts you or by emailing dpo@m360research.com with your request. You will then be added to our do not contact list.


Sharing your personal data with others: This personal data is not shared with third parties.


Your rights: You have the right to object to us processing your data in this way.


Data Retention: We retain this personal data for 1 year after the specific project has been completed, or for no more than 1 year if it does not relate to a specific project, and then the data is deleted.


Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, m360 Research may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of m360 Research's services.


In order to keep you up-to-date/request feedback. Within an existing business relationship between you and m360 Research, m360 Research may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from m360 Research. Furthermore, where you have attended a webinar, seminar or event of m360 Research or purchased products or services from m360 Research, m360 Research may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.


Right to object. You may object to m360 Research using Personal Data for the above purposes at any time by unsubscribing https://www.m-panels.com/Unsubscribe_User.php?id={link2}&src=N.


If you do so, m360 Research will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless m360 Research is permitted to use such Personal Data for another purpose set out in this Privacy Statement or m360 Research determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.


Data Retention: We retain your personal data for 10 years after you end your membership so that we can comply with our data obligations to clients to maintain records for a minimum period. The data is then deleted.


Personal Data We Retain For An Extended Period:


In order to manage its business, m360 Research needs to retain limited personal data about previous members for longer periods of time. We have carefully limited the personal data retained and the circumstances in which it is needed to the following:

  • Requests by individuals to not email them
  • Requests by individuals not to be contacted by m360 Research
  • Individuals who have objected to m360 Research processing their personal data (where there is not an overwhelming interest in us continuing to do so)
  • Individuals who have breached the Sites Terms of Use , including those suspected of fraudulent behaviour

This personal data is not shared with anyone and is only used to honour your requests or to prevent subsequent Activity participation.


Purpose and legal basis for processing your personal data: m360 Research has an obligation to protect its business from suspicious and unlawful activity as well as to respond to requests from individuals to cease contact or processing of their personal data. To do this we need to keep records and process personal data.


If you ask us not to email you, we keep a copy of your email address in our systems to prevent any emails to that email address being sent - this is referred to as our Do Not Contact List and it is the only way we can comply with your request.


If you ask us not to contact you, or have objected to us processing your personal data, we keep a record of your name, address, medical specialty (if you are a healthcare professional) and email address. Your email address is added to our Do Not Contact List. The other details listed are maintained in our systems so we can make our best efforts to remove you from any lists we use - it is the only way we can comply with such requests.


Personal data about individuals suspected of fraudulent behaviour or breaching our terms of use is maintained to prevent these individuals from registering with m360 Research Panels and from participating in our Activities as a non-member. We keep a record of name, address, medical specialty (if you are a healthcare professional) and email address for this purpose.


We process your personal data on the basis of our legitimate interest (i.e. we have a valid business reason to do this) and we have carefully balanced your individual rights against this need. For more information on legitimate interests please click here.


Sharing your personal data with others: This information is not shared with third parties.


Your rights: You have the right to object to your personal data being used in this way as well as certain other rights.


Data Retention: This data is held for 50 years to ensure we meet our obligations as described above and then it is deleted.

Where m360 Research uses your Personal Data based on your Consent




In the following cases m360 Research will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations.


News about m360 Research's Products and Services. Subject to a respective provision and your consent, m360 Research may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with m360 Research (prior purchases, participation in webinars, seminars, or events or the use of (web) services) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about m360 Research's software and services (including marketing-related newsletters) as well as events of m360 Research and in order to display relevant content on m360 Research's websites. In connection with these marketing-related activities, m360 Research may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks' data or the web offerings' own data bases in order to display to you more relevant information.


Creating user profiles. m360 Research offers you the option to use its web offerings including forums, blogs, and networks (such as the m360 Research Community) linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.


These profiles may relate to a single web offering of m360 Research or, if created in the m360 Research Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of m360 Research or of other entities of the m360 Research Group, or both (irrespective of any consent granted under the section "Forwarding your Personal Data to other m360 Research companies." below). It is, however, always your choice which of these additional web offerings you use, and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for m360 Research to create such user profiles m360 Research will not be in a position to offer such services to you where your consent is a statutory requirement that m360 Research can provide these services to you.


Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by m360 Research to foster the quality of communication and collaboration through such offerings and for m360 Research to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.


Forwarding your Personal Data to other m360 Research companies. m360 Research may transfer your Personal Data to other entities in the m360 Research Group. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above


Forwarding your Personal Data to our marketing partners. m360 Research may, with your prior consent, share your Personal Data with our marketing partners to enable them to reach out to you for relevant marketing products and/or services that you may be interested in. For example, our marketing partners may reach out to you for programmes to improve customer satisfaction, performing market research, providing value added services, for regional support of services, or to organize m360 Research events. m360 Research will not, at any time, sell your Personal Data to any third party.


Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://www.m-panels.com/Unsubscribe_User.php?id={link2}&src=N. In case of withdrawal, m360 Research will not process Personal Data subject to this consent any longer unless legally required to do so. In case m360 Research is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by m360 Research up to the point in time of your withdrawal. Furthermore, if your use of an m360 Research offering requires your prior consent, m360 Research will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for m360 Research to use your profile under the m360 Research Cloud Platform Identity Authentication Service for multiple m360 Research offerings), offer or event to you after your revocation.

D. Miscellaneous




How does m360 Research protect your Personal Data?


m360 Research implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of your Personal Data such as (i) only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store your information; and (iii) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.


Our databases have a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users. Personal Data we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication and any information you transmit to m360 Research you do at your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Data, subject to applicable law, m360 Research, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such unforeseen breach.

Changes to the Privacy Statement




From time to time, we may update this Privacy Statement to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Statement. If we make any material changes, we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Grievance Redressal



If you have any questions or concerns about this Privacy Policy, please feel free to contact us by writing to us at dpo@m360research.com or using the details provided on our 'Contact Us' page. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of personal information about you. Except where required by law, m360 Research cannot ensure a response to questions or comments regarding topics unrelated to this policy or m360 Research's privacy practices.

E. E.U. Specific Provisions




This Privacy Statement is in compliance with the provisions of the European Union General Data Protection Regulation.

F. U.S.-Specific Provisions




Where m360 Research is subject to U.S. privacy requirements, the following also applies:


Do Not Track. Your browser may allow you to set a "Do not track" preference. Unless otherwise stated, our sites do not honor "Do not track" requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by way of the TrustArc Consent Manager if the relevant website contains a link to it. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.


Requirements to Protect Children's Privacy. We do not intend for our websites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact at dpo@m360research.com.

G. m360 Research Supplementary Privacy Notice for California Residents Only



Effective Date: April 27, 2021
Last Revised: April 27, 2021



This notice supplements the information contained in the main m360 Research Privacy Policy and applies solely to residents of the State of California ("California Privacy Policy"). We have adopted our California Privacy Policy in order to comply with the California Consumer Privacy Act of 2018 ("CCPA")1.


Our California Privacy Policy is intended to fulfill CCPA's objectives of providing California consumers with a comprehensive disclosure of the collection, sharing, disclosure, and sale of their personal information by particular businesses (as CCPA defines those terms), and of the rights that California consumers have regarding their personal information ("California Privacy Rights").


I. California Privacy Rights Under CCPA


  1. Right to Know About Personal Information Collected, Disclosed or Sold ("Right to Know")


    1. Scope of Applicable Personal Information


      CCPA provides you the right to request that we disclose to you any or all of the following about your personal information for the 12-month period preceding your request:


      • the specific pieces of personal information that we have collected about you;
      • the categories of personal information we have collected about you;
      • the categories of sources from which we have collected your personal information;
      • the categories of personal information that we have sold or disclosed for a business purpose about you;
      • the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
      • the business purpose for collecting or selling your personal information.

      CCPA also provides you the right to receive information about any financial incentives (i.e., compensation payments) that we may offer in connection with use of your personal information for participating in certain of our Activities (as that term is defined in "About M360 Research" in our Main Privacy Policy ).


      For detailed information about the personal information that we collect and the purposes for which we collect it, please see Part II ("Information We Collect and What We May Do With It") below.


      If you exercise your Right To Know, after we confirm your identity, as explained more fully in Part III ("Exercising Your California Privacy Rights"), we will: (a) disclose to you the information we have collected about you during the preceding 12 months that corresponds to your request; and (b) deliver, free of charge to you, by mail, or electronically, the personal information that you have requested, in the manner required by CCPA and as further described below in Part III ("Exercising Your California Privacy Rights").



    2. Exclusions from Scope of Personal Information


      CCPA excludes the following from its definition of "personal information":


      • Publicly available information from government records
      • De-identified or aggregated consumer information
      • Information excluded from CCPA's scope, such as
        • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
        • Personal information regulated by other sector-specific laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

  2. Right to Have Personal Information Deleted ("Right to Delete")


    You have the right to request the deletion of your personal information that we collect or maintain.


    If you exercise your Right to Delete, after we confirm your identity, as explained more fully below in Part III ("Exercising Your California Privacy Rights"), we will, in the manner specified by CCPA, permanently delete your personal information from our records, unless one of the CCPA exceptions applies to your deletion request applies.


    Also, to the extent required by CCPA, we will direct deletion of your personal information by third parties with whom we have shared the personal information that you have requested that we delete.


    Exceptions to your Right To Delete include, but are not limited to, instances when the personal information is necessary to complete a transaction or provide the service requested by you for which the subject personal information was collected or provided (such as to participate in our market research Activities), detect security incidents or protect against deceptive, fraudulent, or illegal activity, or to comply with a legal obligation under CCPA, the California Electronic Communications Privacy Act, or other California or US federal law.


  3. Right to Opt-Out of the Sale of Personal Information ("Right to Opt-Out")


    Under CCPA, you have the right to opt-out of the "sale" (as defined by CCPA) by a CCPA-subject business of your personal information to third parties. CCPA defines a "sale" of personal information as occurring when a business exchanges personal information of California residents to a third party for monetary or other valuable consideration.


    M360 Research does not "sell" your personal information, in either the CCPA sense, nor any other sense.


    When you consent to participate in one of our market research Activities, we may share your personal information with our clients and carefully selected service providers solely for business purposes and as otherwise required by law.


    Except as set forth herein, all data that we share will be deidentified information (meaning, data that has been carefully encrypted so it no longer identifies you or is linkable to you) or aggregate information (which means data from a group of individuals from which all individual identities have been carefully removed so no particular person may be identified). Neither deidentified information nor aggregate consumer information are considered personal information as defined in CCPA.


    To the extent we collect personal information of minor children under the age of 18, we similarly limit the disclosure of their personal information to business purposes, or use deidentified or aggregate information about them. We do not sell the personal information of minor children.


    Personal information will never be shared in any way, or for any purpose, other than for what has been specifically consented for us to do with it.


  4. Right to Not Be Discriminated Against for Exercising Your California Privacy Rights ("Right to Non-Discrimination")


    You have the right to not receive discriminatory treatment if and when you exercise any of your California Privacy Rights under CCPA. This would include, as examples, imposing a penalty fee or denying services to you because you exercised a CCPA right.


    We will never penalize or otherwise subject you to discriminatory treatment for exercising any of your California Privacy Rights.


    Please note that exercising your right to delete some or all of your personal information may mean that you are not able to participate in certain market research opportunities that we offer.


    For example, if we do not have enough information to determine whether you meet the criteria for a study, you will not receive invitations to participate. In addition, certain studies may require that certain aspects of your personal information be shared with the client (such as a focus group opportunity, where your name, contact information, medical background, and practice location are needed in order to convene a desired focus group).


    Financial incentives, such as per-survey compensation payments, are made for certain of our market research Activities. Market research compensation payment amounts are set at levels determined by taking into account many variables such as (by way of examples only) the complexity of the subject matter of the research inquiry, the professional education, training, and experience level desired for the respondents, the number of respondents needed, and the number of qualified respondents available.


    If you have questions about your Right to Non-Discrimination, please contact us as described in Part III ("Exercising Your California Privacy Rights") below.


II. Information We Collect and What We May Do With It


M360 Research, our subsidiaries, and our affiliates, as well as our third-party business partners with whom we conduct our regular business operations, may collect, share, or disclose personal information solely for business purposes as described in the following sections:


  1. Categories of Third Parties refers to the following persons or entities with whom we may share personal information for business purposes:

    1. Business Support Consultants (examples include our consultants, advisors, and/or vendors who help us by (as examples only): (a) preventing fraud or violations of our Terms of Service; (b) analyzing site user data and behavior, and tracking page performance; (c) identifying site issues and repair errors that impair intended functionality; (d) providing marketing and survey panel recruitment assistance, such as moderators and translators; (e) providing customer service to our Site users; (f) providing CCPA-required and other verifications of consumers or consumer consent; and/or (g) providing data storage and/or data processing services.


      All of our Business Support Consultants have written agreements with us which:


      • require them to comply with all legal privacy requirements to which we are subject, including those provided in CCPA;

      • limit their access to personal information to the minimum necessary in order to perform their services for us; and

      • restrict them from making any use of personal information beyond fulfilling the specific services to us for which they are engaged;

    2. Business Partners (examples include clients, prospective clients and their representatives who may engage us to conduct market research or provide other services for CCPA-permitted business purposes); and

    3. Public Authorities (examples include law enforcement and other government authorities if required by law or reasonably necessary to protect the rights, property, and safety of others or ourselves)

  2. Personal Information We Have Collected Over the Past Twelve Months:


    CATEGORY OF PERSONAL INFORMATION EXAMPLES COLLECTED IN PAST 12 MONTHS
    A. Identifiers Real name, postal address, e-mail address, unique personal or online identifiers, account names, telephone numbers, social security or tax ID numbers, internet protocol address, driver's license number, passport numbers, or similar YES
    B. Categories of Personal Information from California's Customer Records statute Information that identifies, is associated with, or capable of being associated with a particular individual, such as signature, physical description, education, employment, employment history, but excluding that from available from public federal, state, or local government records YES
    C. Protected Classifications Under US or California Law National origin, age (consumers over 40), race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender or sex (and related identifiers/characteristics), sexual orientation, veteran or military status, or genetic information YES
    D. Commercial Information Personal property records, products or services purchased, obtained or considered, purchasing or consuming histories or tendencies YES
    E. Biometric Information Genetic physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data NO
    F. Internet or Other Electronic Network Activity Information Browsing history, search history, and information about interaction with a websites, applications, or advertisements YES
    G. Geolocation Data General physical location, precise GPS location or movements YES
    H. Sensory Information Audio, electronic, visual, thermal, olfactory or similar information YES
    I. Professional or Employment-Related Information Employers, job history, and performance evaluations YES
    J. Non-Public Information from US Family Educational Rights and Privacy Act (20 U.S.C. ยง 1232) Grades, transcripts, class lists, student schedules, student ID numbers, student financial information, or student disciplinary records and other education records directly related to a student NO
    K. Inferences Drawn From Other Personal Information Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes YES

  3. Categories of Sources From Which Personal Information Has Been Collected During Past 12 Months


    1. Directly from you (such as from forms or profiles that you create on our website or from our Activities) or indirectly from you (as collected automatically through our website)

      Personal Information Categories Collected: A, B, C, D,F,G, H, I


    2. Business Support Consultants

      Personal Information Categories Collected: A, B, C, D, F, G, H, I, K


    3. Business Partners

      Personal Information Categories Collected: A, B, C, D, F, H, I


    4. Public Authorities or Public Records

      Personal Information Categories Collected: A, C, D, I


  4. Personal Information Disclosed for a Business Purpose During Past 12 Months


    We have disclosed personal information for one or more of these business purposes:


    1. Providing you with the services and support that you may request, and processing and validating your transactions;

    2. Communicating with you about your account or transactions, changes to our policies and other administrative matters, or responding to your questions and comments;

    3. Understanding better your interests in order to provide you with customized market research opportunities, relevant articles, advertising and other content;

    4. Administering our research surveys, studies, and quizzes, and improving all of our products, services and operations;

    5. Ensuring compliance with our policies and Website Terms and Condition, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others;

    6. Complying with our legal and regulatory requirements; and

    7. Helping us better search for, communicate with, and validate prospective panel members in our systems in order to match them with particular market research needs.


  5. Sales of Personal Information During Past 12 Months


    M360 Research does not ever "sell" personal information, as described in more detail above in Part I.C ("Right to Opt-Out of the Sale of Personal Information").



III. Exercising Your California Privacy Rights


Exercising Rights to Opt-Out of Sale of Personal Information: As M360 Research does not "sell" any personal information, as that term is defined in CCPA, we have not provided consumers with a means to "opt-out" of such sales. However, we will be glad to answer any questions you may have about this or any of your California Privacy Rights. Please use one of the contact methods described below to reach us for any questions.


In order to exercise your Right to Know, Right to Delete, or Right To Non-Discrimination, please submit your request to us in any one of the ways listed below.


By E-mail: info@m-panels.com (please put "California Privacy Request" in the subject line)


By Mail or Courier:

m360 Research Data Protection Officer
c/o m360 Research Systems,
41/1, Lavelle Road,
Bangalore - 560 001, Karnataka, India


Only you, or a person (or a business entity registered with the California Secretary of State) whom you have authorized to act on your behalf may make a consumer request about your personal information. Consistent with CCPA's provisions, we may require either (or both) that you provide your authorized agent with written permission to act for you and verify your own identity to us (or provide a power of attorney signed by you stating your authorized agent's power to act for you) 2 .


If you have questions or concerns about your rights under our California Privacy Policy, or any of the provisions or practices described in either our California Privacy Policy or our Main Privacy Policy, please contact us via the telephone number, e-mail address, or mail/courier address provided above.


IV. Responding to Right to Know and Right to Delete Requests


Within ten (10) business days of receipt of your Right to Know or Right to Delete request, we will confirm our receipt, provide you details about the process we will follow to respond to your request, and/or ask questions, or for additional information, that may be required.


We plan to fulfill these requests within 45 calendar days of receiving the request. If we need more time to respond to your request, we will let you know the reason and, within the first 45 calendar days following receipt of your request, estimate how much additional time we will need (in any event, we will complete your request within 90 calendar days in total from receipt of the request).


If we deny your Right to Know or Right to Delete request, in whole or in part, we will provide you with the reason for this, and if our denial is partial, we will disclose to you, or delete (as applicable), the other information you have requested.


  1. Verification Process: To assert your Right to Know or your Right to Delete, you will be asked to verify your identity before fulfilling your request. This verification process may require you to provide pieces of personal information that we already hold on you, or, in certain circumstances, a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

  2. Procedure; Frequency of Submitting Right to Know Requests: You may make requests regarding your Right to Know only twice within any 12-month period.

    We do not charge a fee to process or respond to your Right to Know requests, unless a particular request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


  3. Procedure; Frequency of Submitting Right to Delete Requests: You may make a Right to Delete request to us at any time. Following verification of your request, we will immediately and permanently delete the personal information requested by you, unless one of CCPA's exception to this right applies to your request.


    If we cannot verify the identity of the consumer requesting deletion of personal information, we may deny the Right to Delete request, and will inform the requestor of this.


    Once we verify the identity of the consumer making the Right to Delete request, we will respond to their request by either:

    1. permanently and completing erasing the personal information from our systems and records, in the manner specific by CCPA;

    2. de-identifying the personal information (meaning, carefully encrypting the personal information so it no longer identifiable or linkable to a particular consumer); or

    3. aggregating the personal information individual (meaning, we will carefully remove any consumer-identifiers from it, and group it together with other similarly-stripped data from which the resulting data group contains no particular consumer's personal information in an identifiable fashion).


    We will inform you of the manner in which we have deleted your personal information following a Right to Delete request.


V. Updates to this Supplementary Privacy Notice


We may reserve the right to periodically update our California Privacy Policy. Please reference the "LAST UPDATED" legend above for the effective date of the most recent updates. Your continued use of our Site following these changes means that you accept the revised California Privacy Policy.


1 California's full CCPA statute, 1798 Cal. Civ. Code #chr(0167)##chr(0167)# 1978.100 - 1798.199, may be found here: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=CIV&division=3.&title=1.81.5.&part=4.


2 For information on preparing a Power of Attorney, see Cal. Probate Code #chr(0167)##chr(0167)# 4000-4465 ("Powers of Attorney"), here: http://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=PROB&division=4.5.

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