IR Digital Media (hereinafter referred to as “Isrg Rajan Digital Media”, “Isrg”, “Isrg KB”, “Isrg Store”, “we”, “us”, “our”, or its affiliates) is committed to protecting the privacy of our users. This Privacy Policy (“Policy”) explains our privacy practices, including what information we collect, how we use it, and what steps we take to protect it.
Our Privacy Statement was first published on February 7, 2014 and updated on April 05, 2024. By using the Service, you agree to be bound by Privacy Policy, Terms of Service, and Cookies Policy. If you do not agree to these Terms and Policies, you must not use the Service.
Information We Collect
IR Digital Media collects information from you when you use our services. This information may include:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
How We Use Information
IR Digital Media uses the information we collect to provide, maintain, and improve our services, as well as to communicate with you. This includes:
- Providing our services: We use the information we collect to provide you with the services you request.
- Improving our services: We use the information we collect to improve our services and make them more relevant to you.
- Communicating with you: We use the information we collect to communicate with you, such as to send you updates or to respond to your inquiries.
Disclosure of Information
IR Digital Media will not sell or rent your personal information to third parties. However, we may disclose your information in the following circumstances:
- With your consent: We may disclose your information if you have given us your consent to do so.
- For legal purposes: We may disclose your information if required to do so by law or in response to a valid request from a law enforcement agency.
The General Data Protection Regulation (GDPR)
IR Digital Media is committed to protecting the privacy rights of individuals in accordance with the General Data Protection Regulation (GDPR). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Definitions
For the purposes of this Policy, the following definitions shall have the following meanings:
- “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
- “Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller.
Information We Collect
IR Digital Media may collect the following types of Personal Data from you:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
Purposes for Processing Personal Data
IR Digital Media processes your Personal Data for the following purposes:
- To provide our services: We use your Personal Data to provide you with the services you request.
- To improve our services: We use your Personal Data to improve our services and make them more relevant to you.
- To communicate with you: We use your Personal Data to communicate with you, such as to send you updates or to respond to your inquiries.
Legal Basis for Processing Personal Data
IR Digital Media processes your Personal Data on the following legal bases:
- Consent: We may process your Personal Data if you have given us your explicit consent to do so.
- Contractual necessity: We may process your Personal Data where it is necessary for the performance of a contract between you and us.
Disclosure of Personal Data
IR Digital Media will not sell or rent your Personal Data to third parties. However, we may disclose your Personal Data in the following circumstances:
- With your consent: We may disclose your Personal Data with your consent.
- To our service providers: We may disclose your Personal Data to our service providers, who process your data on our behalf for the purposes set out in this Policy.
- To comply with legal obligations: We may disclose your Personal Data to comply with legal obligations, such as to respond to a subpoena or to protect the rights of IR Digital Media.
Retention of Personal Data
Under the General Data Protection Regulation (GDPR), IR Digital Media is required to retain personal data only for as long as necessary to fulfill the purposes for which it was collected.
Once the purpose for which the personal data was collected has been fulfilled, IR Digital Media must delete the data in a secure manner or securely store the data for a limited time if required by law or for a legitimate business purpose.
IR Digital Media will regularly review the personal data it holds to ensure that it is still necessary for the purpose for which it was collected and will delete the data if it is no longer required.
Individuals have the right to access, rectify, or request the deletion of their personal data held by IR Digital Media. If an individual requests that their personal data be deleted, IR Digital Media will take reasonable steps to delete the data in a secure manner, except where the law requires it to be retained.
IR Digital Media is committed to retaining personal data for only as long as necessary and to regularly reviewing the data it holds to ensure compliance with the GDPR.
California Consumer Privacy Act (CCPA) Policy
IR Digital Media is committed to protecting the privacy rights of California residents in accordance with the California Consumer Privacy Act (CCPA). This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Definitions
For the purposes of this Policy, the following definitions shall have the following meanings:
- “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- “Consumer” means a natural person who is a California resident.
Information We Collect
IR Digital Media may collect the following types of Personal Information from you:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
Purposes for Processing Personal Information
IR Digital Media processes your Personal Information for the following purposes:
- To provide our services: We use your Personal Information to provide you with the services you request.
- To improve our services: We use your Personal Information to improve our services and make them more relevant to you.
- To communicate with you: We use your Personal Information to communicate with you, such as to send you updates or to respond to your inquiries.
Disclosure of Personal Information
IR Digital Media will not sell or rent your Personal Information to third parties. However, we may disclose your Personal Information in the following circumstances:
- With your consent: We may disclose your Personal Information with your consent.
- To our service providers: We may disclose your Personal Information to our service providers, who process your data on our behalf for the purposes set out in this Policy.
- To comply with legal obligations: We may disclose your Personal Information to comply with legal obligations, such as to respond to a subpoena or to protect the rights of IR Digital Media.
Retention of Personal Information
IR Digital Media will retain your Personal Information for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by law.
Consumer Rights under CCPA
The CCPA gives California residents the following rights:
- The right to know: You have the right to request that IR Digital Media disclose what Personal Information it has collected about you, the sources of that information, and how it has been used and disclosed.
- The right to delete: You have the right to request that IR Digital Media delete your Personal Information.
- The right to opt-out of sale: You have the right to opt-out of the sale of your Personal Information by IR Digital Media.
How to Exercise Your Rights
To exercise your rights under the CCPA, you may contact us at [email protected] or visit our contact page at https://www.isrgrajan.com/contact.
Verification of Your Identity
In order to protect your privacy and ensure the security of your Personal Information
California Privacy Rights Act (CPRA)
IR Digital Media is committed to protecting the privacy rights of California residents in accordance with the California Privacy Rights Act (CPRA) and the “Do Not Sell or Share My Personal Information” request. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Definitions
For the purposes of this Policy, the following definitions shall have the following meanings:
- “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- “Consumer” means a natural person who is a California resident.
Information We Collect
IR Digital Media may collect the following types of Personal Information from you:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
Purposes for Processing Personal Information
IR Digital Media processes your Personal Information for the following purposes:
- To provide our services: We use your Personal Information to provide you with the services you request.
- To improve our services: We use your Personal Information to improve our services and make them more relevant to you.
- To communicate with you: We use your Personal Information to communicate with you, such as to send you updates or to respond to your inquiries.
Disclosure of Personal Information
IR Digital Media will not sell or rent your Personal Information to third parties. However, we may disclose your Personal Information in the following circumstances:
- With your consent: We may disclose your Personal Information with your consent.
- To our service providers: We may disclose your Personal Information to our service providers, who process your data on our behalf for the purposes set out in this Policy.
- To comply with legal obligations: We may disclose your Personal Information to comply with legal obligations, such as to respond to a subpoena or to protect the rights of IR Digital Media.
Retention of Personal Information
IR Digital Media will retain your Personal Information for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by law.
Consumer Rights under CPRA
The CPRA gives California residents the following rights:
- The right to know: You have the right to request that IR Digital Media disclose what Personal Information it has collected about you, the sources of that information, and how it has been used and disclosed.
- The right to delete: You have the right to request that IR Digital Media delete your Personal Information.
- The right to opt-out of sale: You have the right to opt-out of the sale of your Personal Information by IR Digital Media.
Do Not Sell or Share My Personal Information
California residents have the right to opt-out of the sale of their Personal Information by IR Digital Media. You may submit a “Do Not Sell or Share My Personal Information” request.
Virginia Consumer Data Protection Act (VCDPA)
IR Digital Media and its affiliates (hereafter referred to as “the Company”) are committed to protecting the privacy and data of its customers and other individuals with whom it interacts. The Virginia Consumer Data Protection Act (VCDPA) requires the Company to implement certain policies and procedures to ensure that it complies with the Act. This policy outlines the Company’s approach to VCDPA compliance.
- Scope
This policy applies to all Company employees, contractors, and agents who handle personal data, as defined by the VCDPA. This includes all data collected from Virginia consumers or data that relates to Virginia consumers.
- Policy Statement
The Company is committed to complying with the VCDPA and protecting the privacy and data of its customers and other individuals. To achieve this, the Company will:
- Designate a Data Protection Officer (DPO)
The Company will designate a DPO who will be responsible for overseeing the Company’s compliance with the VCDPA. The DPO will also serve as a point of contact for individuals with questions or concerns about the Company’s data handling practices.
- Conduct Data Mapping and Risk Assessment
The Company will conduct a data mapping exercise to identify all personal data collected, processed, or stored by the Company. This will be followed by a risk assessment to identify and mitigate potential privacy risks associated with the data.
- Implement Privacy Policy and Notice
The Company will create a privacy policy that outlines its data handling practices and post it on its website. The policy will provide clear and concise information about the types of personal data the Company collects, how it uses the data, and with whom it shares the data.
- Obtain Consent
The Company will obtain opt-in consent from Virginia consumers before collecting, processing, or sharing their personal data. The Company will also provide consumers with the option to withdraw their consent at any time.
- Implement Security Measures
The Company will implement appropriate technical and organizational security measures to protect personal data from unauthorized access, disclosure, alteration, or destruction. These measures will be regularly reviewed and updated as necessary.
- Establish Data Subject Rights
The Company will establish processes for handling requests from Virginia consumers to exercise their rights under the VCDPA, including the right to access, correct, delete, or restrict the processing of their personal data. The Company will also establish a process for handling data breach notifications.
- Train Employees and Contractors
The Company will provide training to employees and contractors who handle personal data to ensure they understand their responsibilities under the VCDPA and are aware of the Company’s policies and procedures for handling personal data.
Colorado Privacy Act (“CPA”)
IR Digital Media and its affiliates are committed to protecting the privacy of our customers and website visitors. We understand the importance of maintaining the confidentiality of personal information, and we take this responsibility seriously. This Colorado Privacy Act Policy (“Policy”) sets out how we collect, use, and protect personal information.
Scope:
This Policy applies to IR Digital Media and its affiliates, which include any entities owned or controlled by IR Digital Media. It covers all personal information collected, processed, and stored by IR Digital Media in the course of its business activities.
Definitions:
For the purposes of this Policy, the following definitions apply:
- “Personal information” means any information that can be used to identify an individual, including but not limited to name, address, email address, phone number, and any other information that can be used to identify an individual.
- “Processing” means any operation or set of operations performed on personal information, whether by automated means or not, including but not limited to collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.
Collection of personal information:
IR Digital Media collects personal information from its customers and website visitors for the following purposes:
- To provide products and services requested by our customers;
- To process orders and payments;
- To communicate with our customers regarding their orders, products, and services;
- To respond to customer inquiries and support requests;
- To improve our products and services;
- To comply with legal obligations and requirements.
IR Digital Media only collects personal information that is necessary for these purposes, and we do so through fair and lawful means. We may collect personal information directly from our customers and website visitors, or we may obtain it from third-party sources.
Use and disclosure of personal information:
IR Digital Media uses personal information collected for the purposes described above, and we may disclose personal information to third-party service providers who assist us in providing products and services to our customers. We may also disclose personal information if required by law or to comply with a legal obligation.
IR Digital Media does not sell or rent personal information to third parties.
Protection of personal information:
IR Digital Media takes reasonable steps to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing personal information.
Retention of personal information:
IR Digital Media retains personal information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law or regulation.
Rights of individuals:
Under the Colorado Privacy Act, individuals have the following rights regarding their personal information:
- Right to access: Individuals have the right to request access to their personal information held by IR Digital Media.
- Right to correction: Individuals have the right to request that IR Digital Media correct inaccurate or incomplete personal information.
- Right to deletion: Individuals have the right to request that IR Digital Media delete their personal information, subject to certain exceptions.
- Right to opt-out of sale: Individuals have the right to opt-out of the sale of their personal information.
IR Digital Media will respond to such requests in accordance with the Colorado Privacy Act.
Connecticut Data Privacy Act (“CDPA”)
Connecticut Data Privacy Act (“CDPA”) for IR Digital Media and its affiliates:
Section 1: Definitions
For the purposes of this Act, the following definitions shall apply:
- “IR Digital Media” means the company named IR Digital Media and all its affiliates.
- “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- “Business” means any entity, including any sole proprietorship, partnership, corporation, or other organization that collects, processes, sells, or shares personal information of consumers.
- “Consumer” means any natural person who is a resident of Connecticut, acting in an individual or household context.
Section 2: Requirements for Businesses
- Duty to Disclose
IR Digital Media and its affiliates shall disclose, in a clear and conspicuous manner, the categories of personal information collected, the purposes for which the personal information will be used, and any third parties with whom the personal information will be shared.
- Duty to Obtain Consent
IR Digital Media and its affiliates shall obtain opt-in consent from consumers before selling their personal information to third parties.
- Duty to Implement Reasonable Security Measures
IR Digital Media and its affiliates shall implement and maintain reasonable security measures to protect personal information from unauthorized access, destruction, use, modification, or disclosure.
- Duty to Respond to Consumer Requests
IR Digital Media and its affiliates shall respond to consumer requests to access, delete, or correct their personal information within 45 days of receipt of the request.
- Duty to Comply with Data Protection Officer Requirements
IR Digital Media and its affiliates shall appoint a Data Protection Officer who shall be responsible for ensuring compliance with this Act and for responding to consumer requests.
Section 3: Enforcement
- Enforcement Authority
The Connecticut Attorney General shall have the authority to enforce this Act.
- Civil Penalties
A business that violates this Act shall be subject to a civil penalty of up to $7,500 for each violation.
- Private Right of Action
A consumer who is harmed by a violation of this Act shall have a private right of action to recover damages.
Utah Consumer Privacy Act (“UCPA”)
Utah Consumer Privacy Act (“UCPA”) for IR Digital Media and its affiliates:
- Definitions
a. “Company” refers to IR Digital Media and all its affiliates.
b. “Consumer” refers to any natural person who is a resident of Utah and engages in a business transaction with the Company.
c. “Personal Information” refers to any information that identifies, relates to, describes, or is capable of being associated with a particular consumer. - Right to Know
a) Upon request by a consumer, the Company shall disclose to the consumer the categories of personal information collected, the sources of the personal information, the purposes for which the personal information is collected, and the categories of third parties with whom the personal information is shared.
b) The Company shall provide the requested information to the consumer within 45 days of receiving the request. - Right to Opt-Out
a) The Company shall provide consumers with a clear and conspicuous opt-out mechanism for the sale of their personal information.
b) The Company shall not sell the personal information of a consumer who has opted out, unless the consumer subsequently provides express consent to the sale. - Right to Deletion
a. Upon request by a consumer, the Company shall delete the personal information of the consumer.
b. The Company shall delete the personal information within 45 days of receiving the request, unless retention of the personal information is necessary for the Company to:
i. Complete the transaction for which the personal information was collected;
ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
iii. Debug to identify and repair errors that impair existing intended functionality;
iv. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
v. Comply with the California Electronic Communications Privacy Act;
vi. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;
vii. Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; or
viii. Comply with a legal obligation. - Discrimination Prohibited
a)The Company shall not discriminate against any consumer who exercises any of their rights under this act.
b) The Company shall not:
i. Deny goods or services to the consumer;
ii. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
iii. Provide a different level or quality of goods or services to the consumer; or
iv. Suggest that the consumer will receive a different price, rate, level, or quality of goods or services. - Verification
a) The Company shall establish procedures to verify the identity of a consumer who requests to exercise their rights under this act.
b) The Company shall not disclose or delete personal information in response to a request unless it can verify the identity of the consumer making the request to a reasonable degree of certainty. - Enforcement
a) Any consumer who has been harmed by a violation of this act may bring a civil action against the Company.
b) The Attorney General may bring a civil action on behalf of the State of Utah to enforce this act.
c) The remedies for a violation of this act may include injunctive relief, actual damages, statutory damages, or any other relief the court deems proper.
California Online Privacy Protection Act (CalOPPA)
IR Digital Media is committed to protecting the privacy of users of our services and complying with the California Online Privacy Protection Act (CalOPPA). This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Definitions
For the purposes of this Policy, the following definitions shall have the following meanings:
- “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
Information We Collect
IR Digital Media may collect the following types of Personal Information from you:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
Purposes for Processing Personal Information
IR Digital Media processes your Personal Information for the following purposes:
- To provide our services: We use your Personal Information to provide you with the services you request.
- To improve our services: We use your Personal Information to improve our services and make them more relevant to you.
- To communicate with you: We use your Personal Information to communicate with you, such as to send you updates or to respond to your inquiries.
Disclosure of Personal Information
IR Digital Media will not sell or rent your Personal Information to third parties. However, we may disclose your Personal Information in the following circumstances:
- With your consent: We may disclose your Personal Information with your consent.
- To our service providers: We may disclose your Personal Information to our service providers, who process your data on our behalf for the purposes set out in this Policy.
- To comply with legal obligations: We may disclose your Personal Information to comply with legal obligations, such as to respond to a subpoena or to protect the rights of IR Digital Media.
Retention of Personal Information
IR Digital Media will retain your Personal Information for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by law.
California Privacy Policy Requirements
Under CalOPPA, IR Digital Media is required to:
- Include a privacy policy on our website that sets out the information we collect, how we use that information, and the choices you have about your information.
- Provide a clear and conspicuous link to the privacy policy on our website’s home page.
- Provide a means for users to contact us with any questions or concerns about our privacy practices.
Personal Information Protection and Electronic Documents Act (PIPEDA)
IR Digital Media is committed to protecting the privacy of users of our services and complying with the Personal Information Protection and Electronic Documents Act (PIPEDA). This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Definitions
For the purposes of this Policy, the following definitions shall have the following meanings:
- “Personal Information” means information about an identifiable individual.
Information We Collect
IR Digital Media may collect the following types of Personal Information from you:
- Personal Information: This may include your name, email address, phone number, and any other information you choose to provide us.
- Usage Information: This may include information about your usage of our services, such as the pages you visit, the time you spend on our services, and the actions you take within our services.
- Technical Information: This may include information about your device, such as the type of device you use, the IP address, and other device-specific information.
Purposes for Processing Personal Information
IR Digital Media processes your Personal Information for the following purposes:
- To provide our services: We use your Personal Information to provide you with the services you request.
- To improve our services: We use your Personal Information to improve our services and make them more relevant to you.
- To communicate with you: We use your Personal Information to communicate with you, such as to send you updates or to respond to your inquiries.
Consent
IR Digital Media may collect, use, or disclose Personal Information only with your consent, except as permitted or required by law. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
Disclosure of Personal Information
IR Digital Media will not sell or rent your Personal Information to third parties. However, we may disclose your Personal Information in the following circumstances:
- With your consent: We may disclose your Personal Information with your consent.
- To our service providers: We may disclose your Personal Information to our service providers, who process your data on our behalf for the purposes set out in this Policy.
- To comply with legal obligations: We may disclose your Personal Information to comply with legal obligations, such as to respond to a subpoena or to protect the rights of IR Digital Media.
Retention of Personal Information
IR Digital Media will retain your Personal Information for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by law.
Access to Personal Information
You have the right to access your Personal Information held by IR Digital Media, subject to certain exceptions provided by law. You may request access to your Personal Information by sending an email to [email protected].
The Family Educational Rights and Privacy Act (FERPA)
IR Digital Media is committed to complying with the Family Educational Rights and Privacy Act (FERPA), which is a federal law that governs the access and privacy of student education records. The law applies to all educational institutions that receive funding from the U.S. Department of Education, including public schools, colleges, and universities.
FERPA gives students the right to access their education records and to request the correction of any inaccurate or misleading information contained in those records. The law also gives students control over the release of their education records to third parties, including prospective employers, without their prior written consent.
IR Digital Media recognizes the importance of protecting the privacy of student education records and has implemented policies and procedures to ensure that all student records are handled in accordance with FERPA.
The following steps have been taken to ensure FERPA compliance at IR Digital Media:
- Identification of Education Records: IR Digital Media has identified all education records maintained by the institution and has established procedures for maintaining the confidentiality of these records.
- Release of Education Records: IR Digital Media will only release education records to third parties with the written consent of the student or in accordance with the provisions of FERPA.
- Training for Employees: All employees of IR Digital Media who have access to student education records have been trained on FERPA regulations and their responsibilities for maintaining the confidentiality of these records.
- Student Access to Records: IR Digital Media will provide students with access to their education records within a reasonable time frame and will assist students in correcting any inaccuracies or misleading information in their records.
- Record Retention: IR Digital Media will retain student education records in accordance with state and federal regulations.
IR Digital Media is committed to upholding the privacy rights of students and to ensuring that student education records are handled in a confidential and secure manner. If you have any questions or concerns about FERPA, please contact us at [email protected].
The Children’s Online Privacy Protection Act (COPPA) and New York Section 2-D
IR Digital Media is committed to complying with the Children’s Online Privacy Protection Act (COPPA) and New York Section 2-D, which are laws that govern the collection, use, and disclosure of personal information from children under the age of 13.
COPPA requires that website operators obtain verifiable parental consent before collecting personal information from children under the age of 13. New York Section 2-D, also known as the “Stop Hacks and Improve Electronic Data Security” (SHIELD) Act, requires that all businesses that conduct business in New York and own or license computerized data that includes personal information of New York residents implement and maintain reasonable safeguards to protect that information.
IR Digital Media recognizes the importance of protecting the privacy of children and has implemented policies and procedures to ensure that we comply with COPPA and New York Section 2-D.
The following steps have been taken to ensure compliance:
- Age Verification: IR Digital Media has implemented procedures to verify the age of users who access our website and to prevent the collection of personal information from children under the age of 13.
- Parental Consent: If we collect personal information from children under the age of 13, we will obtain verifiable parental consent before collecting, using, or disclosing that information.
- Security Measures: IR Digital Media has implemented reasonable security measures to protect the personal information of all users, including children, in accordance with the requirements of New York Section 2-D.
- Employee Training: All employees of IR Digital Media who have access to personal information, including information from children, have been trained on COPPA and New York Section 2-D regulations and their responsibilities for protecting that information.
- Data Retention: IR Digital Media will retain personal information collected from children in accordance with COPPA and New York Section 2-D regulations.
IR Digital Media is committed to upholding the privacy rights of children and to ensuring that we comply with COPPA and New York Section 2-D. If you have any questions or concerns about our compliance with these laws, please contact us at [email protected].
General Data Protection Law (LGPD) of Brazil
IR Digital Media is committed to protecting the privacy rights of individuals in accordance with the General Data Protection Law (LGPD) of Brazil, which became effective on August 15th, 2021.This policy outlines the measures that IR Digital Media has taken to ensure compliance with the LGPD.
- Collection and Use of Personal Data: IR Digital Media will only collect, use, and process personal data for legitimate and specific purposes, which will be clearly communicated to the data subject prior to collection. Personal data will not be used for purposes other than those for which it was collected without the prior consent of the data subject.
- Data Security: IR Digital Media has implemented appropriate technical and organizational measures to protect personal data against unauthorized access, use, alteration, or destruction. These measures include, but are not limited to, firewalls, encryption, and regular backups.
- Data Retention: IR Digital Media will retain personal data for only as long as necessary to fulfill the purposes for which it was collected, in accordance with the LGPD. After this period, personal data will be securely deleted or destroyed.
- Data Subject Rights: IR Digital Media recognizes the rights of data subjects under the LGPD, including the right to access, rectify, and delete their personal data, as well as the right to data portability and to object to the processing of their personal data.
- Data Protection Officer: IR Digital Media has designated a Data Protection Officer (DPO) who is responsible for ensuring compliance with the LGPD and for advising the company on its obligations under the law.
- Third-Party Data Processors: IR Digital Media will only transfer personal data to third-party data processors who provide adequate guarantees of security and protection of personal data, in accordance with the LGPD.
- Data Breaches: In the event of a data breach, IR Digital Media will notify the relevant authorities and affected data subjects without undue delay.
IR Digital Media is committed to upholding the privacy rights of individuals and to ensuring that we comply with the LGPD. If you have any questions or concerns about our compliance with this law, please contact our Data Protection Officer at [email protected].
The Canadian Consumer Privacy Protection Act (CPPA)
IR Digital Media is committed to protecting the privacy rights of individuals in accordance with the Canadian Consumer Privacy Protection Act (CPPA). This policy outlines the measures that IR Digital Media has taken to ensure compliance with CPPA.
- Collection and Use of Personal Data: IR Digital Media will collect, use, and disclose personal information in a transparent and reasonable manner, and only for the purposes for which it was collected. Individuals will be informed of the specific purposes for which their personal information will be used.
- Data Security: IR Digital Media has implemented appropriate technical and organizational measures to protect personal data against unauthorized access, use, alteration, or destruction. These measures include, but are not limited to, firewalls, encryption, and regular backups.
- Data Retention: IR Digital Media will retain personal data for only as long as necessary to fulfill the purposes for which it was collected, in accordance with CPPA. After this period, personal data will be securely deleted or destroyed.
- Individual Rights: IR Digital Media recognizes the rights of individuals under CPPA, including the right to access, modify, and delete their personal information.
- Third-Party Data Processors: IR Digital Media will only transfer personal data to third-party data processors who provide adequate guarantees of security and protection of personal data, in accordance with CPPA.
- Data Breaches: In the event of a data breach involving personal data, IR Digital Media will notify the relevant authorities and affected individuals without undue delay.
IR Digital Media is committed to upholding the privacy rights of individuals and to ensuring that it complies with CPPA in all its data handling practices.
Code of Ethics for Digital News Websites
- Accuracy and Fairness: Digital news websites in India shall strive to provide accurate, balanced and impartial information to the public. Any inaccuracies or errors in reporting must be promptly corrected.
- Objectivity: Digital news websites must avoid conflicts of interest and maintain objectivity in their reporting. They must not engage in sensationalism, distortion, or manipulation of information.
- Independence: Digital news websites must maintain independence from political, commercial, and other interests that may interfere with their ability to report the news objectively.
- Confidentiality: Digital news websites must respect the confidentiality of sources and protect the identity of individuals who provide information on condition of anonymity.
- Respect for Privacy: Digital news websites must respect the privacy of individuals, including the right to privacy of public figures. They must avoid publication of personal information that is not relevant to the public interest.
- Sensitivity: Digital news websites must be sensitive to issues related to ethnicity, gender, religion, and other sensitive topics, and avoid spreading hate speech or promoting discrimination.
- Responsibility: Digital news websites must accept responsibility for their actions and the impact that their reporting may have on individuals and the public. They must take appropriate measures to correct any harm caused by their reporting.
- Transparency: Digital news websites must be transparent in their reporting practices, including the sources of their information, and any potential conflicts of interest.
This Code of Ethics for Digital News Websites in India serves as a guideline for responsible journalism and is intended to promote the highest standards of journalism and to protect the rights of individuals and the public.
The Digital Personal Data Protection Act, 2023
At IR Digital Media, we are committed to protecting the privacy of our users and the security of their personal data. This Privacy Policy outlines the information we collect, how we use it, and your rights in relation to your personal data as per the Digital Personal Data Protection Act, 2023.
2. Information We Collect
2.1. Personal Information: We may collect personal information such as your name, email address, and contact information when you provide it to us.
2.2. Usage Information: We collect information about how you use our website, including your IP address, device information, and browsing history.
2.3. Cookies: We use cookies and similar technologies to collect information about your preferences and browsing behavior.
3. How We Use Your Information
3.1. Provide Services: We use your personal information to provide you with our services and to communicate with you.
3.2. Improve User Experience: We may use your information to improve our website and enhance your user experience.
3.3. Marketing: With your consent, we may send you promotional materials, newsletters, or updates.
4. Data Sharing and Disclosure
4.1. Third Parties: We may share your information with third parties who assist us in providing our services. We ensure that these third parties also comply with the Digital Personal Data Protection Act, 2023.
4.2. Legal Obligations: We may disclose your information to comply with legal obligations or protect our rights, privacy, safety, or property.
5. Your Rights
5.1. Access and Correction: You have the right to access and correct the personal information we hold about you.
5.2. Withdraw Consent: You can withdraw your consent for the use of your personal information at any time.
5.3. Deletion: You have the right to request the deletion of your personal data.
6. Security
We take reasonable measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.
7. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Please check this page periodically for any changes.
8. Contact Us
If you have any questions or concerns about this Privacy Policy or our data handling practices, please contact us
The Indian Information Technology (IT) Act, 2000
The Indian Information Technology (IT) Act, 2000 provides the legal framework for e-commerce, digital signatures, and cybercrime in India. As a website operating in India, it is important to comply with the provisions of the IT Act to ensure the protection of personal data and secure online transactions.
The following provisions should be incorporated in the policy of a website operating in India as per the Indian IT Act, 2000:
- Collection of Personal Data: The website must provide clear and concise information on the types of personal data it collects and the purposes for which the data will be used. The website must obtain the consent of the users for the collection and processing of their personal data.
- Data Security: The website must implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, and disclosure.
- Data Retention: The website must only retain personal data for as long as it is necessary for the purpose for which it was collected, after which it must be securely deleted.
- Data Transfer: The website must ensure that personal data is not transferred to any country outside India, unless the country in question provides an adequate level of protection for personal data.
- Notification of Breaches: The website must promptly notify the concerned authorities and affected individuals in case of a breach of personal data.
- Digital Signatures: The website must use secure methods, such as digital signatures, to authenticate electronic transactions and ensure the security of sensitive data.
- Compliance with Cybercrime Laws: The website must comply with the provisions of the IT Act relating to cybercrime, including hacking, phishing, and the spreading of malware.
- User Responsibility: The website must inform users of their responsibility for protecting their personal data and the consequences of any unauthorized disclosure of sensitive information.
This policy should be made available to all users of the website and should be regularly reviewed and updated to ensure compliance with the latest provisions of the Indian IT Act, 2000.
Interest-Based Ads Policy
This policy outlines the practices of IR Digital Media regarding the collection, use, and disclosure of data for interest-based advertising. Our goal is to provide you with a clear understanding of how and why we use your data for interest-based advertising and to give you control over that use.
Definitions:
- Interest-based advertising – refers to the practice of using data from a user’s online activity to deliver advertisements that are tailored to the user’s interests.
- Data: refers to information collected from a user’s device, including but not limited to, demographic information, location data, and browsing history.
Data Collection: IR Digital Media collects data from users to deliver interest-based advertising. We use various technologies to collect this data, including but not limited to, cookies, web beacons, and device identifiers. We may also collect data from third-party sources to supplement our data.
Use of Data: IR Digital Media uses the data collected to deliver interest-based advertising that is relevant and tailored to a user’s interests. We may also use the data for research and analytics purposes to better understand how users interact with our services.
Disclosure of Data: IR Digital Media does not sell or rent user data to third parties for their own marketing purposes. However, we may share data with third-party advertising partners to deliver interest-based advertising on our behalf. These partners are contractually obligated to use the data only for the purpose of delivering advertisements on our behalf and are not permitted to use the data for their own marketing purposes.
Control Overuse of Data: IR Digital Media gives users control over the use of their data for interest-based advertising. Users can opt-out of interest-based advertising by modifying their device settings or by visiting the Digital Advertising Alliance’s opt-out page.
Security of Information
IR Digital Media takes reasonable steps to protect the security of your information. We use a variety of security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
Changes to This Policy
IR Digital Media may make changes to this Policy from time to time. When we make changes, we will update the “Last Updated” date above. We encourage you to periodically review this Policy for the latest information on our privacy practices.
Contact Us
If you have any questions about this Policy, please contact us at [email protected]
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