Cookie Policy

1. Introduction

Purpose of this Cookie Policy

This Cookie Policy explains how Debmedia Technologies LLP ("Company", "we", "us", or "our") uses cookies and similar tracking technologies when you visit our website, use our services, access our dashboards, or interact with our digital platforms.

We believe in transparency about how we collect and use data. This policy provides detailed information about the types of cookies we use, why we use them, and how you can control them.

Relationship with Privacy Policy

This Cookie Policy should be read in conjunction with our Privacy Policy, which provides comprehensive information about how we collect, use, store, and protect your personal information.

While this Cookie Policy focuses specifically on cookies and tracking technologies, our Privacy Policy covers broader data protection practices. Together, these documents explain our data handling practices comprehensively.

Scope of Application

This Cookie Policy applies to:

• Our main website (www.debmedia.in)
• All subdomains and microsites operated by us
• SaaS tools, dashboards, and online platforms we provide
• Landing pages and marketing websites
• Client portals and project management interfaces
• Any other digital properties owned or operated by Debmedia Technologies LLP

By using our website or services, you consent to the use of cookies as described in this policy, subject to your browser settings and preferences.

2. What Are Cookies?

Definition of Cookies

Cookies are small text files that are stored on your device (computer, smartphone, tablet) when you visit a website. These files contain information that can be read by the website on subsequent visits, allowing the website to remember information about your visit and preferences.

Cookies are a standard technology used by most websites to enhance user experience, improve functionality, and gather analytics about website usage.

How Cookies Work

When you visit our website, we may place one or more cookies on your device. These cookies allow us to:

• Recognize you when you return to our website
• Remember your preferences and settings
• Understand how you use our website and services
• Provide personalized content and features
• Improve our website performance and functionality
• Keep your account secure and authenticated

Cookies can be set by the website you are visiting (first-party cookies) or by third-party services that we use for analytics, advertising, or other purposes (third-party cookies).

Difference Between Cookies and Similar Technologies

While cookies are the most common tracking technology, we also use similar technologies that serve comparable purposes:

Examples of Similar Technologies:

• Local Storage: Browser-based storage that allows websites to store larger amounts of data locally on your device. Unlike cookies, local storage data is not sent to the server with every request.
• Pixels (Web Beacons): Small transparent images embedded in web pages or emails that allow us to track page views, email opens, and user behavior.
• SDKs (Software Development Kits): Code libraries integrated into mobile applications that collect usage data and enable specific functionality.
• Tags: Small pieces of code on web pages that trigger actions such as tracking page views or collecting analytics data.
• Beacons: Tracking technologies that send information about your interaction with content back to servers for analysis.

Throughout this policy, when we refer to "cookies," we also include these similar technologies unless otherwise specified.

3. Why We Use Cookies

We use cookies and similar technologies for several important purposes that enhance your experience and help us provide better services:

To Ensure Website Functionality

Some cookies are essential for our website to function properly. Without these cookies, certain features would not work, such as keeping you logged into your account, remembering items in your shopping cart, or maintaining your security settings.

To Improve Performance and Speed

We use cookies to optimize website performance by:

• Caching resources to reduce loading times
• Balancing server load across multiple systems
• Storing preferences to reduce repeated data requests
• Reducing bandwidth usage through efficient data storage

To Understand User Behavior

Analytics cookies help us understand how visitors interact with our website, including:

• Which pages are most popular
• How long visitors spend on different pages
• Where visitors come from (search engines, social media, direct links)
• Which features are used most frequently
• Where users encounter problems or errors

To Personalize Experience

Cookies allow us to remember your preferences and provide a customized experience:

• Language and region preferences
• Display settings and layout preferences
• Content recommendations based on your interests
• Previously viewed items or services

To Enable Security Features

Security cookies protect your account and our systems by:

• Detecting and preventing fraudulent activity
• Protecting against cross-site request forgery (CSRF) attacks
• Verifying user identity during authentication
• Monitoring for suspicious behavior patterns

To Support Marketing and Advertising

We use cookies to deliver relevant marketing content and measure campaign effectiveness:

• Showing relevant advertisements based on your interests
• Preventing the same ad from appearing too frequently
• Measuring the effectiveness of advertising campaigns
• Understanding which marketing channels drive the most value

To Provide SaaS Tool Functionality

For our software-as-a-service (SaaS) tools and dashboards, cookies enable critical functionality such as:

• Maintaining user sessions across multiple pages
• Saving work in progress to prevent data loss
• Synchronizing data across different parts of the application
• Enabling real-time collaboration features

5. Cookies Used in SaaS Tools and Dashboards

Our Software-as-a-Service (SaaS) platforms, tools, and dashboards use specific cookies that are essential for providing cloud-based application functionality:

Session Authentication Cookies

These cookies maintain your logged-in state across our SaaS platform, ensuring:

• Continuous authentication without repeated login prompts
• Secure session management with encrypted tokens
• Automatic logout after periods of inactivity
• Protection against session hijacking and unauthorized access

Account Management Cookies

Cookies that help manage your account settings and preferences:

• User role and permission levels
• Account configuration and customization settings
• Subscription plan and billing information access
• Team collaboration settings and member permissions

Feature Usage Tracking

Analytics cookies specific to our SaaS tools that help us understand:

• Which features are used most frequently
• User workflows and navigation patterns within the application
• Performance bottlenecks or areas of confusion
• Feature adoption rates and engagement metrics

Error Logging Cookies

Cookies that help us identify and resolve technical issues:

• Capturing error messages and stack traces
• Recording the sequence of actions leading to errors
• Monitoring application stability and reliability
• Enabling faster bug fixes and improvements

Security Monitoring Cookies

Cookies that enhance security for SaaS applications:

• Detecting unusual access patterns or suspicious activity
• Implementing rate limiting to prevent abuse
• Verifying API request authenticity
• Protecting against brute force attacks and unauthorized access attempts

6. List of Cookies We May Use

Below is an illustrative list of common cookies we use on our website and services. This is not an exhaustive list, as cookies may change based on features, services, and third-party integrations.

Note: This table provides examples of cookies we may use. The actual cookies on your device may vary depending on which services you use, how you interact with our website, and your consent preferences. Third-party cookies are subject to the respective third party's privacy policy.

7. How Long Cookies Remain on Your Device

Cookies have different lifespans depending on their purpose and how they are configured. We use two main types based on duration:

Session Cookies vs Persistent Cookies

Session Cookies: These are temporary cookies that are deleted when you close your browser. They are typically used for:

• Maintaining your login state during a browsing session
• Keeping items in your shopping cart as you browse
• Storing form data as you fill out multi-page forms
• Temporary security tokens

Persistent Cookies: These remain on your device for a specified period or until you manually delete them. They are used for:

• Remembering your preferences across multiple visits
• Keeping you logged in between sessions (if you select "Remember Me")
• Analytics and tracking over time
• Advertising and retargeting campaigns

Typical Retention Durations

• Session cookies: Deleted when browser is closed
• Short-term cookies: 24 hours to 7 days
• Medium-term cookies: 30 days to 6 months
• Long-term cookies: 1 to 2 years

Automatic Deletion Rules

Cookies may be automatically deleted in the following situations:

• When they reach their expiration date
• When you manually clear your browser's cookies and cache
• When you use browser privacy modes (incognito/private browsing)
• When browser storage limits are exceeded (older cookies may be deleted)
• When you log out of your account (for some session-related cookies)

8. How We Obtain Consent for Cookies

Cookie Consent Banner Usage

When you first visit our website, you will see a cookie consent banner that informs you about our use of cookies and provides options to accept or customize your cookie preferences.

The banner typically includes:

• Brief explanation of why we use cookies
• Link to this full Cookie Policy
• Options to accept all cookies, reject non-essential cookies, or customize preferences
• Information about strictly necessary cookies that cannot be disabled

First-Visit Consent

On your first visit, only strictly necessary cookies are activated by default. Non-essential cookies (analytics, advertising, functional) are only activated after you provide explicit consent through the cookie banner.

Consent for Non-Essential Cookies

We obtain your explicit consent before setting non-essential cookies. You can:

• Accept all cookies with a single click
• Reject all non-essential cookies
• Customize your preferences by cookie category
• Change your preferences at any time through cookie settings

Implied Consent Scenarios

In some jurisdictions, continued use of the website after being informed about cookies may constitute implied consent. However, we strive to obtain explicit consent through our cookie banner for all non-essential cookies.

Strictly necessary cookies do not require consent as they are essential for the website to function.

Granular Consent Options

Our cookie consent mechanism provides granular control over different cookie categories:

• Strictly Necessary Cookies: Always active (no consent required)
• Performance & Analytics Cookies: Can be enabled or disabled independently
• Functional Cookies: Optional, can be controlled separately
• Advertising & Targeting Cookies: Optional, can be controlled separately
• Third-Party Cookies: Can be managed by category or individually where applicable

Consent Recording and Documentation

When you provide consent, we record the following information to demonstrate compliance:

• Date and time of consent
• Version of the Cookie Policy you consented to
• Specific cookie categories you accepted or rejected
• Method of consent (banner, preference center)
• IP address (for verification purposes)
• User agent and device information

This consent record is stored securely and can be provided to you upon request or to regulatory authorities if required.

Consent for Different User Types

New Visitors (First-Time Users)

When you visit our website for the first time:

• You will see a cookie consent banner prominently displayed
• No non-essential cookies will be set until you make a choice
• The banner will remain visible until you provide consent or dismiss it
• Only strictly necessary cookies will function during this time

Returning Visitors

If you have previously provided consent:

• Your cookie preferences are remembered
• Cookies will be set according to your previous choices
• You can change your preferences at any time through the Cookie Settings link
• If the Cookie Policy has been materially updated, you may be asked to review and re-consent

Registered Users and Account Holders

For users with accounts on our platform:

• Cookie preferences are linked to your account
• Preferences sync across devices when logged in
• You can manage preferences through both the cookie banner and account settings
• Consent history is available in your account dashboard

Pre-Ticked Boxes and Default Settings

In compliance with GDPR and other privacy regulations:

• Non-essential cookie categories are not pre-selected by default
• You must actively opt-in to analytics, advertising, and non-essential functional cookies
• "Accept All" is offered as a convenience but is never the default action
• Silence or inactivity does not constitute consent for non-essential cookies
• Only strictly necessary cookies are pre-enabled (as they don't require consent)

Consent Renewal and Refresh

We may ask you to renew your consent in the following situations:

• Material Policy Changes: When we make significant changes to how we use cookies
• New Cookie Categories: When we introduce new types of cookies requiring consent
• Consent Expiry: After 12 months, to ensure your preferences are still current
• Regulatory Requirements: When required by changes in privacy laws
• Cookie Technology Changes: When we implement new tracking technologies

Consent Validity Requirements

For consent to be valid under GDPR and other regulations, it must be:

• Freely given: Not bundled with acceptance of terms and conditions
• Specific: Separate consent for different purposes and cookie types
• Informed: Clear information about what you're consenting to
• Unambiguous: Clear affirmative action (clicking "Accept")
• Revocable: Easy to withdraw at any time

Special Consent Considerations

SaaS Tools and Dashboards

For users of our SaaS platforms:

• Consent is obtained during account registration or first login
• Certain functional cookies are necessary to provide the service (contractual necessity)
• Analytics and improvement cookies require separate consent
• You can manage cookies without affecting essential platform functionality

Embedded Content and Third-Party Services

When we embed third-party content (videos, maps, social media):

• These embeds may set their own cookies
• We obtain your consent before loading such content where possible
• You may see placeholder content until you consent to third-party cookies
• Alternatively, you can click to load specific embedded content on demand

Cross-Device Consent

Your cookie consent is device-specific by default:

• Consent on your desktop doesn't automatically apply to your mobile device
• For registered users, we can sync preferences across devices (with your permission)
• You can enable cross-device synchronization in account settings

No Cookie Walls

We do not use "cookie walls" that completely block access to our website if you reject non-essential cookies. You can:

• Access public content without accepting non-essential cookies
• Browse product and service information
• Read blog posts and resources
• Contact us and access support information

However, certain advanced features and personalized experiences may require acceptance of functional cookies.

Consent Management Platform (CMP)

We use a Consent Management Platform to:

• Present cookie information in a user-friendly manner
• Manage and store your consent preferences securely
• Ensure compliance with multiple privacy regulations simultaneously
• Provide detailed cookie information and control options
• Generate compliance reports and audit trails

Language and Accessibility

Our cookie consent mechanisms are designed to be accessible:

• Available in multiple languages based on your browser settings
• Keyboard navigable for users who don't use a mouse
• Screen reader compatible with proper ARIA labels
• High contrast mode support for visually impaired users
• Clear, simple language avoiding legal jargon where possible

Consent for Cookies in Mobile Apps

If you use our mobile applications:

• Cookie consent is requested upon first launch or registration
• Mobile-specific identifiers (IDFA, GAID) are treated similarly to cookies
• You can manage preferences in the app settings menu
• App-level permissions (location, notifications) are requested separately
• We respect device-level privacy settings (Limit Ad Tracking, etc.)

Verification of Consent

You can verify your current cookie consent status by:

• Clicking "Cookie Settings" in the website footer
• Viewing your preferences in the Cookie Preference Center
• Checking your browser's cookie storage for our domain
• Reviewing your account settings (for registered users)
• Contacting us to request your consent record

10. Impact of Disabling Cookies

What Happens When You Disable Cookies

While you have the right to refuse or disable cookies, doing so may impact your experience on our website and limit functionality. Here's what may be affected:

Impact on Essential Features

If you disable strictly necessary cookies, you may experience:

• Login issues: You may be unable to log in or stay logged in to your account
• Security problems: Security features may not work properly, increasing vulnerability
• Form submission failures: Multi-step forms may not retain information between pages
• Shopping cart issues: Items may not stay in your cart as you browse
• Session interruptions: Frequent disconnections requiring re-authentication

Impact on Personalization

Disabling functional cookies may result in:

• Loss of saved preferences (language, region, display settings)
• Repetitive prompts for settings you've already configured
• Generic content instead of personalized recommendations
• Reset customization every time you visit
• Inability to remember your previous choices or selections

Impact on Performance

Without performance cookies:

• Slower page load times due to lack of caching
• Inability to optimize your experience based on your device
• Reduced efficiency in content delivery
• Less responsive website behavior

Impact on Analytics

Disabling analytics cookies means:

• We can't understand which features are most valuable to you
• Harder for us to identify and fix problems
• Reduced ability to improve user experience
• Less data to inform product development decisions

Impact on Advertising

Without advertising cookies:

• You'll still see ads, but they may be less relevant to your interests
• You may see the same ad repeatedly
• Ads may not reflect your preferences or browsing history
• We can't measure advertising effectiveness as accurately

Alternative Access Methods

If you choose to disable cookies, you may still be able to:

• Browse public areas of our website
• View general information and content
• Contact us through email or phone
• Access services that don't require authentication

However, access to personalized dashboards, SaaS tools, and account-specific features will be significantly limited or impossible without accepting necessary cookies.

11. Cookies and Similar Technologies

Beyond Traditional Cookies

While this policy primarily discusses HTTP cookies, we also use other tracking technologies that serve similar purposes. Understanding these technologies helps you make informed decisions about your privacy.

Local Storage and Session Storage

What they are: Web storage technologies that allow websites to store larger amounts of data in your browser compared to traditional cookies.

How we use them:

• Storing user preferences and application settings
• Caching data for offline functionality
• Improving performance by reducing server requests
• Saving work in progress in SaaS applications

Key differences from cookies: Data is not sent to the server with every HTTP request, can store more data (typically 5-10MB), and persists differently (session storage is cleared when tab closes, local storage persists until manually cleared).

Web Beacons and Pixels

What they are: Small, invisible graphics embedded in web pages or emails, also known as "tracking pixels" or "pixel tags."

How we use them:

• Tracking email open rates and engagement
• Measuring page views and user interactions
• Monitoring advertising campaign performance
• Understanding user navigation patterns
• Verifying system functionality

JavaScript and Tags

What they are: Small pieces of code that execute in your browser to collect information or enable functionality.

How we use them:

• Loading analytics and tracking services (e.g., Google Analytics)
• Implementing marketing and conversion tracking
• Enabling dynamic content and interactive features
• Managing tag deployment through tag management systems

Device Fingerprinting

What it is: A technique that collects information about your device configuration to create a unique identifier.

Information collected may include:

• Browser type and version
• Operating system
• Screen resolution and color depth
• Installed fonts and plugins
• Timezone and language settings
• Hardware specifications

How we use it: Primarily for fraud prevention, security purposes, and to identify suspicious activities. We do not use fingerprinting as a primary tracking method for analytics or advertising.

SDKs (Software Development Kits)

What they are: Code libraries integrated into mobile applications that provide functionality and collect usage data.

How we use them in our mobile apps:

• Analytics and crash reporting
• Push notification delivery
• In-app messaging and communication
• Payment processing integration
• Social media integration

ETags (Entity Tags)

What they are: HTTP headers used for web cache validation that can also be used for tracking.

How we use them: Primarily for legitimate caching purposes to improve performance. We do not intentionally use ETags for cross-site tracking.

Canvas Fingerprinting

What it is: A tracking technique that uses HTML5 canvas element to generate a unique identifier based on how your device renders graphics.

Our stance: We do not use canvas fingerprinting for tracking purposes. If third-party services we integrate employ this technique, it is governed by their respective privacy policies.

12. Cookies and Personal Data

When Cookies Constitute Personal Data

Under privacy laws such as GDPR and the Digital Personal Data Protection Act (DPDP) in India, cookies can constitute personal data when they can be used to identify an individual, either directly or in combination with other information.

Types of Data Collected Through Cookies

Cookies may collect the following types of information:

Directly Identifiable Information

• User account IDs or usernames (when logged in)
• Email addresses (in some authentication cookies)
• Customer identification numbers

Indirectly Identifiable Information

• IP addresses
• Device identifiers and unique IDs
• Browser fingerprints
• Session identifiers
• Advertising IDs

Behavioral and Usage Data

• Pages visited and time spent on each page
• Click patterns and navigation paths
• Search queries and interactions
• Content preferences and interests
• Form inputs and selections
• Purchase history and shopping behavior

Technical Information

• Browser type and version
• Operating system
• Device type (desktop, mobile, tablet)
• Screen resolution
• Language preferences
• Timezone and location data

How Cookie Data Relates to Our Privacy Policy

Data collected through cookies is subject to the same privacy protections outlined in our Privacy Policy. This includes:

• Lawful basis for processing (consent, legitimate interest, contractual necessity)
• Purpose limitation (using data only for specified purposes)
• Data minimization (collecting only necessary information)
• Storage limitation (retaining data no longer than necessary)
• Security measures to protect cookie data
• Your rights regarding cookie data (access, deletion, portability)

Cookie Data Retention

We retain data collected through cookies according to the following principles:

• Session cookies: Deleted immediately when you close your browser
• Authentication cookies: Retained for the duration of your session or as long as you remain logged in
• Preference cookies: Retained for up to 12 months or until you change your preferences
• Analytics cookies: Aggregated data may be retained for up to 26 months for trend analysis
• Advertising cookies: Typically retained for 3-12 months depending on the purpose

Cookie Data and Third Parties

Some cookie data may be shared with third-party service providers, including:

• Analytics providers: Google Analytics, similar services
• Advertising networks: Google Ads, Meta Ads, LinkedIn Ads
• Customer support tools: Live chat, help desk systems
• Payment processors: For transaction security and fraud prevention
• Cloud service providers: For data storage and processing

We ensure that third parties handling cookie data do so in compliance with applicable privacy laws and our contractual requirements.

13. International Cookie Laws and Compliance

GDPR (European Union) Compliance

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we comply with the General Data Protection Regulation (GDPR) requirements for cookies:

• Clear and comprehensive information: We provide detailed information about cookies before they are set
• Explicit consent: We obtain your explicit consent before setting non-essential cookies
• Granular control: You can choose which types of cookies to accept
• Easy withdrawal: You can withdraw consent at any time through our Cookie Preference Center
• Cookie-free browsing: You can browse without accepting non-essential cookies

ePrivacy Directive (Cookie Law)

The ePrivacy Directive, commonly known as the "Cookie Law," requires that we:

• Inform users about cookies before they are stored on their device
• Obtain consent before storing or accessing cookies (except strictly necessary cookies)
• Provide clear information about the purpose of each cookie
• Offer users the ability to refuse cookies without negative consequences

CCPA/CPRA (California, USA)

For California residents, our cookie practices comply with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know: You have the right to know what personal information is collected through cookies
• Right to delete: You can request deletion of cookie data we have collected
• Right to opt-out: You can opt-out of the "sale" or "sharing" of personal information collected through cookies
• Do Not Sell My Personal Information: We provide mechanisms to opt-out of data sharing for advertising purposes

Digital Personal Data Protection Act (India)

As an Indian company, we comply with the Digital Personal Data Protection Act, 2023 (DPDP Act):

• Consent requirements: We obtain valid consent for processing personal data through cookies
• Purpose limitation: Cookies are used only for specified, legitimate purposes
• Data localization: We comply with data localization requirements where applicable
• User rights: We facilitate exercise of rights under the DPDP Act

Other Jurisdictions

We also respect cookie regulations in other jurisdictions where our users are located, including but not limited to:

• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA)
• Australia: Privacy Act 1988 and Australian Privacy Principles
• Brazil: Lei Geral de Proteção de Dados (LGPD)
• South Africa: Protection of Personal Information Act (POPIA)

14. Legal Basis for Using Cookies

Different Legal Bases for Different Cookie Types

We rely on different legal bases depending on the type of cookie and its purpose:

Consent

Applies to: Analytics cookies, advertising cookies, non-essential functional cookies

How we obtain it: Through our cookie consent banner when you first visit our website

Your rights: You can withdraw consent at any time through the Cookie Preference Center

Characteristics:

• Freely given, specific, informed, and unambiguous
• Can be withdrawn as easily as it was given
• Must be obtained before cookies are set (except strictly necessary cookies)
• Documented and stored to demonstrate compliance

Legitimate Interest

Applies to: Some analytics cookies, fraud prevention cookies, security monitoring cookies

Our legitimate interests:

• Improving our website and services based on usage data
• Protecting our systems and users from security threats
• Detecting and preventing fraud and abuse
• Optimizing website performance and user experience

Balancing test: We have conducted a balancing test to ensure that our legitimate interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interest.

Contractual Necessity

Applies to: Session cookies, authentication cookies, SaaS application cookies

Why it's necessary: These cookies are essential to provide the services you have requested, such as:

• Maintaining your login session
• Processing your transactions
• Delivering SaaS tools and functionality
• Remembering items in your shopping cart

Without these cookies, we cannot fulfill our contractual obligations to you.

Legal Obligation

Applies to: Cookies used for compliance, record-keeping, security monitoring required by law

Examples:

• Tax and accounting record requirements
• Compliance with data protection laws
• Prevention of money laundering and fraud
• Responding to law enforcement requests

15. Cookie Security and Data Protection

Security Measures for Cookie Data

We implement robust security measures to protect data collected through cookies:

Technical Security Measures

• Encryption: Sensitive cookie data is encrypted both in transit (HTTPS/TLS) and at rest
• Secure flag: Cookies containing sensitive information are marked with the "Secure" flag, ensuring they are only transmitted over HTTPS
• HttpOnly flag: Session cookies use the HttpOnly flag to prevent access via JavaScript, protecting against XSS attacks
• SameSite attribute: We use SameSite cookie attributes to prevent CSRF attacks
• Token rotation: Authentication tokens are rotated regularly to minimize exposure risk

Access Controls

• Cookie data is accessible only to authorized personnel with legitimate business needs
• Role-based access controls limit who can view or modify cookie configurations
• Regular access reviews ensure appropriate permissions
• Multi-factor authentication required for accessing sensitive cookie management systems

Monitoring and Detection

• Continuous monitoring for unusual cookie access patterns
• Automated alerts for suspicious activities
• Regular security audits and penetration testing
• Logging and tracking of cookie-related events

Third-Party Cookie Security

For third-party cookies, we:

• Vet third-party providers for security standards
• Require contractual data protection obligations
• Regularly review third-party security practices
• Limit data sharing to necessary minimum
• Ensure third parties comply with applicable privacy laws

Data Breach Response

In the unlikely event of a security breach involving cookie data:

• We will investigate the incident promptly and thoroughly
• Affected users will be notified as required by law
• We will report to relevant data protection authorities when required
• Remediation measures will be implemented to prevent recurrence
• We will cooperate with law enforcement if criminal activity is suspected

Cookie Data Anonymization

Where possible, we anonymize or pseudonymize cookie data to enhance privacy:

• IP address masking in analytics tools
• Aggregation of usage data to prevent individual identification
• Hashing of identifiers where full identifiers are not necessary
• Automatic deletion of granular data after specified periods

16. Cross-Border Cookie Data Transfers

When Cookie Data Is Transferred Internationally

Some of the data collected through cookies may be transferred to, stored, or processed in countries outside your jurisdiction, particularly when we use third-party services based in other countries.

Countries Where Cookie Data May Be Processed

Cookie data may be transferred to and processed in:

• India: Our primary servers and operations are based in India
• United States: For services like Google Analytics, AWS, Cloudflare
• European Union: For some European-based service providers
• Singapore: For Asia-Pacific data center operations
• Other countries: Where our third-party service providers operate

Safeguards for International Transfers

When transferring cookie data internationally, we implement appropriate safeguards:

For EU/EEA Users

• Standard Contractual Clauses (SCCs): We use EU-approved SCCs with data processors outside the EEA
• Adequacy decisions: Where available, we rely on European Commission adequacy decisions
• Data Protection Addenda: Contractual clauses ensuring GDPR-level protection
• Supplementary measures: Additional technical and organizational measures as required

For Indian Users

• Compliance with DPDP Act requirements for cross-border transfers
• Transfers only to countries notified by the Indian government or with user consent
• Contractual obligations ensuring adequate data protection

For California Users

• Disclosures about third-party data sharing practices
• Contractual prohibitions on unauthorized data sales
• Service provider agreements limiting data usage

Your Rights Regarding International Transfers

You have the right to:

• Request information about the safeguards in place for international transfers
• Obtain a copy of the Standard Contractual Clauses we use
• Object to transfers to specific countries or regions
• Request that your data be processed only within specific jurisdictions (where feasible)
• Lodge complaints with your local data protection authority about international transfers

Specific Third-Party Transfer Information

Google Services (Analytics, Ads, Fonts, Maps)

Transfer destination: United States, European Union, and other Google data centers globally

Safeguards:

• EU-US Data Privacy Framework certification (for US transfers)
• Standard Contractual Clauses
• Google's global data protection terms
• IP anonymization where enabled

More information: Google Privacy Policy

Meta/Facebook Services (Pixel, Social Plugins)

Transfer destination: United States, Ireland (for EU users), and other Meta data centers

Safeguards:

• Standard Contractual Clauses for EU data transfers
• Meta's Data Transfer Addendum
• Regional data processing commitments

More information: Meta Privacy Policy

Cloud Service Providers (AWS, Google Cloud, Cloudflare)

Transfer destination: Multiple global regions including US, EU, Asia-Pacific

Safeguards:

• Data Processing Addenda with SCCs
• Regional data residency options where available
• ISO 27001, SOC 2 compliance certifications
• Encryption in transit and at rest

Data Localization and Regional Processing

Where legally required or technically feasible, we implement data localization measures:

• Indian users: We prioritize processing data within India where possible, in compliance with DPDP Act requirements
• EU/EEA users: Where available, we use EU-based data centers and servers
• Regional preferences: Registered users may request regional data processing preferences in account settings

Legal Basis for Cross-Border Transfers

We transfer cookie data internationally based on the following legal grounds:

• Consent: You have explicitly consented to the transfer of your data to specific countries
• Contractual necessity: The transfer is necessary to fulfill our contract with you (e.g., providing SaaS services)
• Legitimate interests: The transfer is necessary for our legitimate business operations, balanced against your rights
• Legal obligation: Required by law or regulatory authorities

Third-Party Transfer Controls

We maintain strict controls over third-party data transfers:

• Vendor assessment: All third-party vendors are assessed for data protection compliance before engagement
• Data Processing Agreements: Written agreements govern all data transfers to third parties
• Purpose limitation: Third parties may only use cookie data for specified purposes
• Onward transfer restrictions: Third parties are prohibited from further transferring data without authorization
• Regular audits: We conduct periodic reviews of third-party compliance

Adequacy Decisions and Approved Transfer Mechanisms

We rely on approved transfer mechanisms recognized by relevant authorities:

European Commission Adequacy Decisions

For EU/EEA users, we transfer data to countries recognized by the European Commission as providing adequate protection, including:

• United Kingdom (post-Brexit adequacy decision)
• Switzerland
• Japan
• Canada (commercial organizations)
• Other countries with adequacy decisions

Certification Frameworks

• EU-US Data Privacy Framework: For transfers to certified US organizations
• APEC Cross-Border Privacy Rules: For transfers within APEC member countries
• Binding Corporate Rules: Where applicable for intra-group transfers

Transparency About Data Transfer Risks

We acknowledge that international data transfers may involve certain risks:

• Different legal protections: Some countries may not have equivalent data protection laws
• Government access: Foreign governments may have legal authority to access data
• Enforcement challenges: Exercising your rights may be more difficult across borders

We implement contractual, technical, and organizational safeguards to mitigate these risks and ensure your data remains protected.

Notification of Transfer Destination Changes

If we significantly change where cookie data is transferred or processed:

• We will update this Cookie Policy with the new information
• Material changes will be communicated through our standard notification process
• Where required by law, we will obtain renewed consent
• You will have the opportunity to object or withdraw consent

Restricting International Transfers

If you wish to restrict international transfers of your cookie data:

• Disable third-party cookies: Many international transfers occur through third-party services
• Contact us: Request that your data be processed only in specific regions (subject to technical feasibility)
• Use VPN services: May affect how your location is determined
• Browser extensions: Use privacy-focused browser extensions to block certain cookies

Please note that restricting international transfers may limit functionality of certain features or services.

Compliance Monitoring

We actively monitor compliance with international transfer requirements:

• Regular legal reviews of transfer mechanisms and safeguards
• Tracking changes in international data protection regulations
• Updating Data Processing Agreements as laws evolve
• Conducting Transfer Impact Assessments (TIAs) for high-risk transfers
• Maintaining documentation of all international transfers for regulatory review

Contact for Transfer-Related Inquiries

For specific questions about international data transfers of cookie data:

• Email: privacy@debmedia.in
• Subject line: "International Cookie Data Transfer Inquiry"
• Include: Your location, specific concerns, and the type of information you're seeking

We will respond with detailed information about the safeguards applicable to your situation and any available options to address your concerns.

18. Updates to This Cookie Policy

Why We May Update This Policy

We may update this Cookie Policy from time to time for various reasons, including:

• Changes in the types of cookies we use
• Implementation of new features or services
• Changes in applicable laws or regulations
• Adoption of new technologies or tracking methods
• Changes in our business practices or third-party services
• Feedback from users or regulatory authorities
• Updates to improve clarity and transparency

How We Notify You of Changes

When we make material changes to this Cookie Policy, we will:

• Update the "Last Updated" date at the top of this policy
• Display a prominent notice on our website for at least 30 days
• Show an updated cookie banner requiring renewed consent for material changes
• Send email notifications to registered users for significant changes
• Provide a summary of changes in the notification or at the top of the policy

Material vs. Non-Material Changes

Material changes include:

• Adding new categories of cookies that require consent
• Changing the purposes for which we use cookies
• Sharing cookie data with new categories of third parties
• Significantly extending retention periods
• Changes affecting your privacy rights

Non-material changes include:

• Clarifications or additional explanations
• Corrections of typos or formatting
• Updates to contact information
• Changes that enhance user privacy
• Administrative updates

Your Options After an Update

After we update this Cookie Policy, you can:

• Accept the changes: Continue using our website with the new cookie practices
• Review and adjust settings: Update your cookie preferences through the Cookie Preference Center
• Withdraw consent: Disable non-essential cookies if you disagree with the changes
• Contact us: Ask questions or raise concerns about the changes
• Stop using our services: If you fundamentally disagree with the updated policy

Version History

We maintain a version history of this Cookie Policy. Previous versions can be requested by contacting us at privacy@debmedia.in.

Effective Date of Changes

Unless otherwise stated, changes to this Cookie Policy become effective:

• Immediately upon posting for non-material changes
• 30 days after notification for material changes
• Upon obtaining renewed consent for changes requiring new consent

19. Children's Privacy and Cookies

Age Restrictions

Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information, including through cookies, from individuals under 18 years of age.

Parental Consent Requirements

If we discover that we have inadvertently collected cookie data from a child under 18 without proper parental consent:

• We will delete such information as quickly as possible
• We will take steps to prevent future collection
• We will notify the parents or guardians if their contact information is available
• We will review our processes to prevent recurrence

Special Protections for Children

We implement additional protections when minors may access our services:

• Age verification mechanisms where appropriate
• Restricted data collection for users who identify as under 18
• No behavioral advertising targeting minors
• Enhanced privacy defaults for younger users

Parental Controls and Rights

Parents or legal guardians can:

• Request deletion of any cookie data collected from their child
• Refuse to permit further collection of data through cookies
• Review any information collected from their child
• Contact us with concerns about children's privacy

Educational Use

If schools or educational institutions use our services:

• We require appropriate consent from the institution
• We limit data collection to educational purposes only
• We do not use student data for advertising or marketing
• We comply with applicable educational privacy laws (e.g., FERPA, COPPA)

How to Report Concerns

If you believe a child under 18 has provided us with personal information through cookies, please contact us immediately at:

• Email: privacy@debmedia.in
• Subject: "Child Privacy Concern"

We will investigate and take appropriate action promptly.

20. Contact Information and Data Protection Officer

How to Contact Us

If you have any questions, concerns, or requests regarding this Cookie Policy or our cookie practices, please contact us through the following channels:

Data Protection Officer (DPO)

For privacy and data protection matters, you can contact our Data Protection Officer:

Response Timeframes

We are committed to responding to your inquiries promptly:

• General inquiries: Within 48 hours (2 business days)
• Cookie consent withdrawal: Within 48 hours
• Data access requests: Within 30 days
• Complaints: Initial response within 5 business days
• Urgent security matters: Within 24 hours

Information to Include in Your Request

To help us respond efficiently, please include:

• Your full name and contact information
• Description of your inquiry or request
• Relevant account details (if applicable)
• Specific cookies or data you're inquiring about
• Any supporting documentation

Supervisory Authority Contact (For EU/EEA Users)

If you are located in the European Economic Area and have concerns about our cookie practices that we have not adequately addressed, you have the right to lodge a complaint with your local supervisory authority.

Grievance Officer (For Indian Users)

Under the Digital Personal Data Protection Act, 2023, we have designated a Grievance Officer to address complaints: