5. HOW DO WE COLLECT INFORMATION?

We collect personal information from you in the following ways:

1. a. At registration on our Website, App, or Platform;
2. b. In email, text, and other electronic messages between you and our Website, App, or Platform;
3. c. Through mobile and desktop applications based on your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website, App, or Platform;
4. d. When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
5. e. From forms filled out by you;
6. f. From records or copies of correspondences (including email addresses) if you contact us;
7. g. From search queries on our Website, App, or Platform;
8. h. When you post information to be published or displayed on our Website, App, or Platform; and
9. i. When you click on ads we display, perform a search, or participate in polls.

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

1. a. Usage details;
2. b. IP addresses;
3. c. Information obtained through browser cookies;
4. d. Information obtained through flash cookies;
5. e. Web beacons on our Website;
6. f. Web beacons on emails sent by us; and
7. g. Other tracking technologies.

6. HOW DO WE USE YOUR INFORMATION?

We collect, store and use your personal data to pursue our legitimate business interests which, in general, consist of responding to requests you make to us (such as participation in studies or panels), or aiding us in serving you better. We collect only the information necessary to fulfil our legitimate business interests and stored it on our servers in an aggregated/anonymized form for only as long as is needed to fulfil those interests. We use your data in the following ways:

• •  To facilitate creation and authentication of your personal profile, and identify you as a user on our Platform, and allocate to you a unique identification code;
• •  To verify that you are medical professionals and to protect the integrity of GLocal Panel by preventing fraud.
• •  To help us improve our Website and the studies and panels;
• •  To improve the quality and relevance of your experience in interacting with our Website and with the studies and panels;
• •  To improve our customer service;
• •  To respond to your customer service inquiries;
• •  To match you with appropriate, relevant studies and panels;
• •  To provide you with information, or services requested from us;
• •  To provide you with notices about account and/or subscription, including expiration and renewal notices;
• •  To administer contests, promotions, and surveys or other Website, App, and Platform features;
• •  To notify you about changes to our Website, App, and Platform and any products or services
• •  To anonymize data and aggregate data for statistics;
• •  To respond to legal or regulatory inquiries as we believe to be required by applicable laws, regulations, or administrative authorities;
• •  To process transactions;
• •  To gather references of other HCPs, with your prior consent;
• •  To carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection; and
• •  To process your Honoraria payments as per the [Terms of Service] .

7. HOW DO WE SHARE YOUR INFORMATION?

We collect personal information from you in the following ways:

1. a. Vendors and other authorized third parties

We may share your information in an aggregated/anonymized form with vendors and other authorized third parties that provide us with services to assist us in serving you, including:

• •  Website hosting provider, located in United States of America, Germany, India
• •  Vendors that assist in facilitating the studies and panels, located in North and South America, Europe, Middle East and APAC countries.

To the extent required by law, we will collect your explicit consent prior to providing any personally identifiable information.

2. b. Clients and Partners

We may share your information with our clients, and with partners who supplement our capabilities, in aggregated/anonymized form, unless you give us your consent to share personal information specific to you with our clients or partners, with each such consent only applicable to the specific study for which you gave consent to such sharing.

3. c. Legal or regulatory requirements

We may share your information if we believe in good faith that such disclosure is necessary to:

• •  Investigate, prevent, or otherwise respond to illegal activities, suspected fraud, violations of our Terms, or as otherwise required to comply with relevant laws, regulations, legal process, or governmental request (including to meet national security or law enforcement requirements) or to respond to subpoenas or warrants served on us
• •  Respond to an emergency which we believe in good faith requires to disclose information to assist in preventing death or serious injury
• •  Protect or defend the rights, security, integrity, or property of GLocal Panel or its users, or to enforce our agreements and policies
4. d. Merger or Sale

We may share your information in the event of a potential or completed merger, acquisition, or sale of all or a portion of our assets.

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

1. a. Usage details;
2. b. IP addresses;
3. c. Information obtained through browser cookies;
4. d. Information obtained through flash cookies;
5. e. Web beacons on our Website;
6. f. Web beacons on emails sent by us; and
7. g. Other tracking technologies.

8. CROSS-DEVICE IDENTIFICATION

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

9. OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as "Cookies".

We use Cookies on our Website and App to (a) understand and save your preferences for future visits, (b) keep track of advertisements, (c) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (d) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honour Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.

We allow third party behavioural tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at privacy@glocalmind.com .

10. PERSONAL PROFILE

Once a registered GLocal Panel member, you are invited to provide additional information in your personal and professional profile describing your credentials, professional experiences, academic background, biography, etc.

Your GLocal Panel profile is only available for viewing by you. You may edit your profile at any time by using your e-mail and password to log in to your personal member pages.

Providing additional information in your personal profile beyond what is required at registration is entirely optional and can be altered or removed by you at any time. Providing further information will enable GLocal Panel to better match panellists to available studies and panels and therefore it is advised to keep your profile up to date at all times, to maximize your opportunity to be matched with appropriate available studies and panels.

11. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We will implement reasonable security measures every time you (a) enter, submit, or access your information, (b) register, or (c) access our Platform, on our Website and App.

12. DATA SECURITY MEASURES.

1. a. Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.

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

13. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us with others to enable us to provide you over Services, including contractors, service providers, and third parties ("Partners"). This section discusses only how GLocal Panel may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:

1. a. We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
2. b. We may disclose personal information to our subsidiaries and affiliates.
3. c. We may disclose aggregated, de-personalized personal information to Partners. We require all Partners to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose to them.
4. d. We may disclose personal information in the event of a merger, sale of business, etc.
5. e. We may disclose aggregated, de-personalized personal information to third parties to market their products and services to you if you have either consented to or not opted out of these disclosures. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
6. f. We may disclose aggregated, de-personalized personal information for any other purpose for which you have provided it.
7. g. We only disclose personal information as described in this Privacy Policy or as per your consent.

Other Disclosure of Personal Information.

1. a. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of GLocal Panel, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of GLocal Panel, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection.

Third Party Disclosure.

1. a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
2. b. We do not provide personally identifiable visitor information for marketing purposes.

Choices Users Have About How GLocal Panel Uses and Discloses Information.

1. a. Tracking Technologies and Advertising. You can set your browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly.
2. b. Disclosure of Users Information for Third-Party Advertising. Users can opt-out by (i) checking the relevant form when we collect the data; (ii) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, (iv) emailing us their opt-out request at privacy@glocalmind.com. Users receiving promotional email can unsubscribe using the link in the email or specify the frequency at which they will receive such promotional email distributions.

14. FOR OUR EUROPEAN CUSTOMERS AND VISITORS

1. a. If you are located in the European Union, please take note that information we collect from you will not be transferred to and processed outside the European Union.
2. b. If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, (referred here as Personal Information), as defined in the General Data Protection Regulation, Regulation (EU) 2016/679 ('GDPR').
3. c. Please note that in some circumstances, we may not be able to fully comply with your request, or we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request.
4. d. In such situations, however, we will still respond to let you know of our decision. As used herein, 'Personal Information” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.
5. e. To make any of the following requests, please contact us (i) via email at privacy@glocalmind.com, or (ii) by writing to us at GLocal Mind Inc. #4512 Legacy Dr, Ste 100,Plano,TX, 75024.
1. i. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
2. ii. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
3. iii. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
4. iv. Erasure: You can request that we erase some or all of your Personal Information from our systems.
5. v. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
6. vi. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
7. vii. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
8. viii. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority.
9. ix. Response. We will respond to your inquiry within thirty (30) days of the receipt.
6. f. If you have any questions or concerns about privacy-related issues, you may contact our Privacy Officer: Name: Meghamala Hegde Email: privacy@glocalmind.com Address: #5, 10th Cross, Siddaiah Road, Wilson Garden, Bangalore 560027, India

15. FOR OUR CANADIAN USERS

This Section supplements the information contained in our Privacy Policy above and applies solely to all Panellists and other visitors to our Website, App, or Platform, who reside in Canada ('consumers' or 'you'). We ensure with the Personal Information Protection and Electronics Document Act of 2000 ('PIPEDA') and any terms defined in the PIPEDA have the same meaning when used in this Section.

1. a. Definition of Personal Information. Any information about an identifiable individual. Whatever may be the physical form or characteristics of a particular regime for "business contact information" (name, position, title, address, professional phone number, etc.)
2. b. Right to Access Personal Information. You can request to access your personal information we hold about you. We will first confirm whether you have requested such information, explain how we have used your information, provide a list of names with whom your information has been shared and provide a copy of your information in an accessible format and make alternative formats available if requested.
3. c. Right to Correction/Limited Right to Deletion. You can request us to correct or delete your information IF you demonstrate that the personal information we hold on you is inaccurate. We will delete or correct your information within thirty (30) calendar days. When we delete/correct your personal information we will inform the third parties with whom we have shared your information.
4. d. Right to be Forgotten. Your information will be kept with us for as long as it is required for the fulfilment of the purposes of GLocal Panel platform. Unless we otherwise give you notice, we will retain your Information on the GLocal Panel Platform on your behalf until such times as you or we terminate your User Account.
5. e. Data Breach Notification. We will send a notification to you as soon as feasible regarding the information of any breach that creates a "real risk of significant harm" to you. We keep a record of every data breach and, on request, provide the Office of the Privacy Commissioner with access to the record.
6. f. Canadian Privacy Officer. We have appointed a Canadian Privacy and Data Protection Officer, Meghamala Hegde who may be reached at privacy@glocalmind.com to make sure the privacy rights of our Canadian users are protected in compliance with PIPEDA.
7. g. Contact Information. You may contact us (i) at privacy@glocalmind.com. or (ii) by writing to us at Privacy Officer, at GLocal Mind Inc. #4512 Legacy Dr, Ste 100,Plano,TX, 75024. to (i) make a Personal Information Request, (ii) correct or delete your personal information, (iii) discuss our Privacy Policy and/or anything that has to do with it. We will respond within thirty (30) calendar days of receiving such a request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

16. CALIFORNIA RESIDENTS

GLocal Panel does not sell, trade, or otherwise transfer to outside third parties your "Personal Information" as the term is defined under the California Civil Code Section § 1798.82(h). If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties direct marketing purpose. To request a notice, please submit your request to GLocal Mind Inc. #4512 Legacy Dr, Ste 100,Plano,TX, 75024 or email us at privacy@glocalmind.comb>.

If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email: privacy@glocalmind.com.

17. CALIFORNIA DO NOT TRACK DISCLOSURE

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

18. SPAM

GLocal Panel maintains a strict "No-Spam" policy, which means that GLocal Panel does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent, unless otherwise stated in this Policy. Before any professional is added to GLocal Panel, each professional is sent an invite (e-mail) to join the GLocal Panel. To ensure the privacy of professionals, each invite provides for an unsubscribe option. Once this unsubscribe option is selected by the professionals, Glocal Panel does not contact such professionals in future.

19. CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

1. • not use false or misleading subjects or email addresses;
2. • identify the email message as an advertisement in some reasonable way;
3. • include the physical address of GLocalMind, Inc., which is #4512 Legacy Dr, Ste 100, Plano, TX, 75024;
4. • monitor third-party email marketing services for compliance, if one is used;
5. • honour opt-out/unsubscribe requests quickly; and
6. • give an 'opt-out' or 'unsubscribe' option.

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@glocalmind.com and we will promptly remove you from all future marketing correspondences.

20. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

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

21. CHILDREN'S PERSONAL DATA

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

22. LIST OF THIRD-PARTY SERVICE PROVIDERS

GLocal Panel uses the following third-party service providers for the provision of services as mentioned under here:

Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@glocalmind.com.

23. COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 ('DMCA Takedown Notice')) must be provided to our designated Copyright Agent.

1. •  Your physical or electronic signature;
2. • Identification of the copyrighted work(s) that you claim to have been infringed;
3. • Identification of the material on our Website that you claim is infringing and that you request us to remove;
4. • Sufficient information to permit us to locate such material;
5. • Your address, telephone number, and email address;
6. • A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
7. • A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

GLocal Panel's Copyright Agent to receive DMCA Takedown Notices is Meghamala Hegde and can be reached either via email at privacy@glocalmind.com, or at GLocalMind, Inc., Attn: DMCA Notice, 4512 Legacy Dr, Ste 100, Plano, TX, 75024. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by GLocalMind, Inc. in connection with the written notification and allegation of copyright infringement.

24. CHANGES TO THE PRIVACY POLICY

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

25. CONTACT US

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
- Privacy Officer
- Email: privacy@glocalmind.com
- Address: 4512 Legacy Dr, Ste 100, Plano, TX, 75024

PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR Terms of Service , AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR Terms of Service, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.

[Link] to previous versions of Privacy Policies.