Enforceable with effect from: 25 May 2018
Last updated: 23 July 2026
1. Introduction
AptZion Private Limited (“AptZion,” “we,” “us,” or “our”) is a market research organisation. This Policy explains how we collect, use, share, and protect personal data when you visit our website, take part in a survey, join a research panel, or otherwise interact with our research activities, in accordance with the UK General Data Protection Regulation, the EU General Data Protection Regulation (where applicable), and the UK Data Protection Act 2018.
This Policy applies to:
- Visitors to our website
- Survey respondents and research panel members
- Business contacts of our clients and suppliers
- Job applicants (covered separately in our HR Policy Manual, referenced where relevant)
2. Who We Are
AptZion Private Limited operates from offices in India and the United Kingdom.
Data Controller contact details
- Email: privacy@mar-tech.aptzion.com
- Phone: +44 204 513 3886
- Address: 128 City Road, London EC1V 2NX
- Address : A806 Majestique Euriska, Pune, Maharashtra 411060
Where AptZion conducts research on behalf of a client, the client is typically the data controller and AptZion acts as a data processor under a data processing agreement. This Policy addresses AptZion’s role as a controller for website visitors and panel members, and notes our obligations as a processor where relevant.
3. What Personal Data We Collect
Depending on how you interact with us, we may collect:
Website usage data
- IP address, browser type, device information, pages visited, referral source
- Cookies and similar tracking technologies (see Section 9)
Survey and panel data
- Contact details: name, email address, phone number, postal address
- Demographic information: age, gender, location, occupation, income band, household composition
- Survey responses, opinions, preferences, and behavioural data relevant to the research topic
- Panel account information: username, password (hashed), participation history, points or incentive balances
Special category data
Some research studies ask about health, ethnicity, religion, political opinions, or similar special category data under Article 9 GDPR. We only collect this where the survey specifically asks for it, we obtain your explicit consent beforehand, and the question is clearly flagged as optional wherever possible.
Incentive and payment data
Where you receive a reward or incentive for participation, we may collect bank details, e-wallet information, or postal address to fulfil that reward, typically processed through a third-party incentive fulfilment vendor.
We do not knowingly collect more personal data than is necessary for the specific research purpose.
4. Legal Basis for Processing
We rely on the following legal bases under Article 6 GDPR:
| Basis | When it applies |
| Consent | Joining a research panel, taking part in a survey, receiving marketing communications, non-essential cookies |
| Contract | Managing your panel membership account and fulfilling incentive payments |
| Legitimate interests | Website analytics, fraud and quality-control checks on survey responses, direct communications with existing panel members about similar research opportunities |
| Legal obligation | Responding to lawful requests from regulators or tax authorities |
Where we process special category data, we additionally rely on your explicit consent (Article 9(2)(a)) or, where applicable, the substantial public interest condition for research purposes.
You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal. See Section 8.
5. How We Use Your Data
- Administer research panels and manage participant accounts
- Design, distribute, and analyse surveys and other research instruments
- Verify respondent identity and eligibility, and detect fraudulent or low-quality responses
- Compile aggregated and anonymised or pseudonymised insights and reports for our clients
- Issue incentives, rewards, or prize draw payments
- Communicate with you about your account, ongoing studies, or new research opportunities you have opted into
- Maintain the security and performance of our website
- Comply with legal and regulatory obligations
Client reporting is anonymised or aggregated wherever possible. We only pass identifiable survey data to a client where the study design requires it (for example, a named qualitative interview) and where you have been clearly informed of this before taking part.
6. Sharing Your Data
We share personal data with:
- Clients, generally in aggregated or anonymised form; identifiable data only where the study explicitly requires it and you have been informed
- Subprocessors and service providers, such as survey hosting platforms, panel management software, incentive fulfilment vendors, and cloud hosting providers, each bound by a data processing agreement
- Professional advisers and auditors, where necessary for legal, accounting, or compliance purposes
- Regulators or law enforcement, where required by law
We do not sell personal data. We do not share special category data with clients unless you have given explicit consent for that specific use, disclosed to you at the point of collection.
7. International Data Transfers
As AptZion operates in both India and the United Kingdom, personal data may be transferred between these locations, and in some cases to subprocessors located elsewhere. Where we transfer personal data outside the UK or European Economic Area, we rely on one or more of the following safeguards:
- An adequacy decision by the UK or European Commission
- Standard Contractual Clauses (SCCs) or the UK International Data Transfer Addendum
- Other safeguards recognised under Article 46 GDPR
You may request further details of the safeguards used for a specific transfer by contacting us at privacy@mar-tech.aptzion.com.
8. Your Rights
Under GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erase your data (“right to be forgotten”), subject to legal exceptions
- Restrict processing in certain circumstances
- Data portability, to receive your data in a structured, commonly used format
- Object to processing based on legitimate interests or for direct marketing
- Withdraw consent at any time, without affecting prior lawful processing
- Lodge a complaint with a supervisory authority — in the UK, the Information Commissioner’s Office (ICO), ico.org.uk
To exercise any of these rights, contact us at privacy@mar-tech.aptzion.com. We will respond within one month, as required by law.
9. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to:
- Operate core site functionality (strictly necessary, no consent required)
- Understand site usage through analytics (requires consent)
- Remember preferences such as language or region (requires consent, unless strictly necessary)
You can manage cookie preferences through our cookie banner or your browser settings at any time. Disabling non-essential cookies will not affect your ability to browse the site, but may limit certain functionality.
10. Panel Members and Survey Respondents — Additional Information
- Eligibility screening. We may ask screening questions to confirm you qualify for a study. If you do not qualify, your response to screening questions is retained only as long as necessary for quality-control and fraud-prevention purposes, then deleted or anonymised.
- Quality control. We use automated checks (for example, response-time analysis, straight-lining detection, digital fingerprinting) to identify low-quality or fraudulent responses. This does not constitute solely automated decision-making with legal or similarly significant effect on you; flagged responses are reviewed by our research team before any account action is taken.
- Incentives. Points, rewards, or payments are processed according to the terms you agreed to when joining the panel. Incentive fulfilment data is retained only as long as needed to complete payment and for tax/audit purposes.
- Leaving a panel. You may close your panel account at any time by contacting privacy@mar-tech.aptzion.com. We will delete or anonymise your account data, except where we are required to retain records (for example, incentive payment records for tax purposes).
11. Children’s Data
Our research services are not directed at children. Where a study specifically requires responses from a minor, we obtain verifiable parental or guardian consent beforehand and apply additional safeguards appropriate to that study.
12. Data Retention
| Data type | Typical retention |
| Panel account data | Duration of active membership, plus 7 years after account closure for legal and financial audit purposes. |
| Survey response data | 7 years from the date of the project, then anonymised or deleted per client agreement |
| Incentive/payment records | 7 years following the end of the financial year in which the payment was processed. |
| Website analytics | 14 months from collection (or the maximum allowed by Google Analytics settings). |
| Marketing consent records | Until consent is withdrawn, plus a record of the withdrawal maintained for 7 years to prove compliance. |
13. Data Security
We apply technical and organisational measures appropriate to the risk, including access controls, encryption in transit, and staff training. Our approach to information security aligns with our ISO 27001:2022 alignment programme and Incident Response Plan. In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware, and will notify affected individuals directly where the breach is likely to result in a high risk to them, in line with our Incident Response Plan.
14. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date at the top of this Policy shows when it was last revised. Material changes will be communicated to panel members and, where required, your renewed consent will be sought.
| 15. Contact Us For any questions about this Policy or to exercise your data protection rights: AptZion Private Limited Email: privacy@mar-tech.aptzion.com Phone: +44 204 513 3886 Address: 128 City Road, London EC1V 2NX Address : A806 Majestique Euriska, Pune, Maharashtra 411060 ICO Security Number : CSN3961099 / ICO Registration Reference : ZC222380 If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority, or the ICO in the UK (ico.org.uk) |