privacy policy app

 

Last updated: October 13, 2025

1. GENERAL

Welcome to BorderPlus (“We”, “Us”, “Our”).

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use the BorderPlus Nurse Companion App (“App”). This policy applies to all users of the App within the European Union (EU) and other regions where the General Data Protection Regulation (“GDPR”) or equivalent data protection laws apply. If you have questions, please contact: appsupport@borderplus.co

 

2. WHO WE ARE

Data Controller: BORDERPLUS CAREERS TECHNOLOGIES PRIVATE LIMITED

Address: 1st Floor, Iconic Building, 95, Ganpatrao Kadam Marg, Mumbai, Maharashtra – 400013, India

Email: appsupport@borderplus.co

We develop and operate the App to help nurses improve communication, clinical readiness, and language proficiency through AI-powered learning modules, including roleplays and pronunciation feedback.

 

3. CONSENT

By creating an account, interacting with Our App, or submitting information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, storage, use, and disclosure of your personal data in accordance with it. you may withdraw your consent at any time by contacting appsupport@borderplus.co. Withdrawal of consent will not affect prior lawful processing but may limit access to certain features of the App.

 

4. WHAT DATA WE COLLECT

We collect only the data necessary to deliver personalized learning experiences and App functionality.

• Information you provide: Name, email address, and account credentials, professional details (e.g., hospital name, training program, or country of practice), language preferences and learning goals.
• Learning and Performance Data: Scenario responses, progress, and completion records, feedback scores and learning analytics, notes or reflections entered by the user.
• Audio Recordings (Voice Data): Recordings you make during read-aloud or roleplay exercises. These are processed to generate feedback on pronunciation, fluency, and empathy. Audio data is stored only with your explicit consent (see Clause 6).
• Device and Usage Data: Device type, operating system, and App version. General App usage statistics and diagnostic logs (non-identifiable).
  What happens if you refuse to provide Personal Data?
  Where We need to collect personal data by law or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you. In this case, We may not be able to provide you access to Our App.

 

5. HOW WE COLLECT YOUR DATA 

We use different methods to collect your data, including through:

1. Direct Interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you create an account on our App, subscribe to our subscription plans (if any) or when you give us feedback or contact us.
2. Automated technologies or interactions. When you use the App, certain technical information is automatically collected about your device and usage patterns. This may include your device type, operating system, unique device identifiers, and App usage analytics. Such data helps us improve App functionality, performance, and user experience.
3. Third parties or publicly available sources. We may receive limited personal data about you from trusted third parties, such as payment processors, authentication providers, or analytics services integrated into the App. These sources help facilitate transactions, verify your identity, or enhance your App experience.

 

6. HOW WE USE YOUR DATA

Your data is used only for legitimate learning and App improvement purposes: 

1. Delivering personalized feedback;
2. Analysing your audio to assess pronunciation accuracy;
3. Tracking learning progress displaying completion charts or scenario streaks;
4. Improving AI feedback quality aggregate usage patterns (non-identifiable);
5. Technical support bug fixes, performance optimization;
6. Communication sending important App updates or privacy notifications; and
7. Complying with legal obligations imposed on Us by the law and for the law.

We do not use your data for marketing or advertising purposes. However, we may share your data with trusted third-party service providers to facilitate processing and ensure optimal performance of our services.

 

7. HOW AND WHERE WE STORE YOUR DATA

Your personal data may be transferred and stored outside your country of residence where data protection laws may differ. We ensure that such transfers comply with applicable data protection laws, including by implementing appropriate approved under GDPR.

1. All data (including audio) is stored on secure servers in Germany (EU).
2. Audio data is stored separately from profile information and encrypted during transmission and storage.
3. Recordings are automatically deleted or anonymized after 12 months, unless deleted earlier by you.
4. You can delete your recordings or withdraw consent at any time (see Clause 8).

 

8. LEGAL BASIS FOR PROCESSING

We process personal data under the following GDPR bases:

1. Consent: We ask for your explicit consent before recording, storing, or processing your data.
2. Contractual necessity: We process account and learning data to provide App functionality and fulfill Our service agreement.
3. Legitimate interest: We use aggregated, anonymized data to improve the App and ensure its security and reliability.

If you do not consent to audio storage, you may still use non-voice features of the App.

 

9. DATA SHARING AND DISCLOSURE

Our App may contain links to or integrate third-party services (such as analytics or payment gateways). These third parties operate independently and are responsible for their own privacy practices. We encourage you to review their respective privacy policies. BorderPlus is not responsible for the privacy or data protection practices of such external entities. We limit data sharing strictly to what is necessary:

1. Recipient purpose shared data.
2. Service providers (processors) hosting, analytics, and AI feedback (under GDPR-compliant contracts) pseudonymized or encrypted data.
3. Institutional partners (optional) aggregate progress reporting anonymized performance summaries (no raw audio).
4. Legal authorities (if required) compliance with applicable laws as legally mandated.

We do not share or sell identifiable audio to any external party.

 

10. YOUR RIGHTS UNDER GDPR

You have full control over your data. You may:

1. Access your personal data: You have the right to obtain information about your personal data stored by Us at any time. You have the right to know for what purposes your personal data is processed, how long it is processed (see storage duration) and to whom it is disclosed, if applicable (see data categories). Please understand that We must first verify the identity of the requesting person before We can provide information.
2. Request correction of inaccurate data: You have the right to have your data rectified and/or supplemented by means of an additional declaration, you also have the right to have your data deleted for the purposes for which they were collected or to limit the processing of your data thereof.
3. Withdraw consent for data processing at any time: If you have given Us consent for a certain processing of your data, you have the right to revoke this consent at any time with effect to the future.
4. Request deletion of your recordings or entire account: You have the right to request the erasure of your recordings or complete account data from Our systems, provided there is no legal obligation or overriding legitimate interest that requires Us to retain certain information.
5. Request data portability: You have the right to request a transfer of your personal data from Us to another entity.
6. Object to certain processing activities: You have the right to complain to a supervisory authority or Our Consent Manager (see Clause 14 below), insofar as you should have a reason to complain.

To exercise these rights, contact appsupport@borderplus.co. We will respond within 30 days as required by GDPR.

 

11. DATA SECURITY

We use advanced technical and organizational safeguards to protect your data:

1. End-to-end encryption for audio transmission;
2. Role-based access controls for authorized personnel only;
3. Regular security audits and monitoring; and
4. Secure data backups within EU jurisdictions.

 

12. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements.

1. Account data: Until user account is deleted
2. Audio recordings: 12 months or until user deletes them
3. Usage analytics: Anonymized after 6 months
4. Logs and diagnostics: Up to 90 days

After retention periods expire, data is deleted or anonymized. However, We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a legal obligation to retain such  data in respect of Our relationship with you.

 

13. ACCOUNT DELETION

1. You may request deletion of your BorderPlus account at any time by emailing appsupport@borderplus.co with the subject “Delete My Account.”
2. Upon verification, your data, including profile, progress, and app usage history, will be permanently deleted within 7 days.
3. Certain anonymized diagnostic or legal records may be retained for up to 30 days.

 

14. CHILDREN’S PRIVACY

This App is intended for professional nursing staff and adult learners (18+). We do not knowingly collect or process data from minors.

 

15. UPDATES TO THIS POLICY

• We may update this Privacy Policy periodically to reflect new features or legal requirements. When We make material changes, We will notify you via email or in-App alert before they take effect. We encourage you to periodically review this Policy for the latest information on Our privacy practices.
• Business Transitions: In the event of a merger, acquisition, restructuring, or sale of all or part of Our business, your personal data may be transferred to the new entity as part of that transaction. We will notify you in advance of any such change and ensure your rights remain protected under applicable privacy laws.

 

16. CONTACT INFORMATION

• If you have any questions, requests, or concerns regarding your data or this policy, please contact:BorderPlus Privacy Office [Data Protection officer/ Consent Manager/ Grievance Officer as per the applicable data privacy laws depending upon the user’s jurisdiction]📧 appsupport@borderplus.co📍 1st Floor, Iconic Building, 95, Ganpatrao Kadam Marg, Mumbai, Maharashtra 400013 India🌐 www.borderplus.co

• In accordance with the Information Technology Act, 2000, Information Technology (Intermediaries guidelines) Rules, 2011 and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, We have appointed a grievance officer (see Clause 14.1). The Digital Personal Data Protection Act, 2023 provides for a Consent Manager, registered with the Data Protection Board of India, to respond to grievances raised by Data Principals (i.e users of the App whose personal data is being processed). Although the Digital Personal Data Protection Act, 2023 came into force on 11/08/2023, Data Protection Board of India has not yet been set up. If you are based in India, you may also raise grievances once the Data Protection Board of India becomes operational, and BorderPlus will designate a Consent Manager in accordance with that law.