1. Introduction

Welcome to Elbroz Media Pvt Ltd (“we,” “us,” “our,” or “Company”). We respect your privacy and are committed to protecting your personal data through our compliance with this policy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website www.elbroz.com or use any of our related services (collectively, the “Services”).

Please read this policy carefully to understand our practices regarding your data. By accessing or using our Services, you consent to the practices described in this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Services.

2. Applicability and Jurisdiction-Specific Provisions

As a global company, we adhere to the data protection laws applicable in the countries we operate in. This policy is designed to provide transparency and inform you of your rights under:

• United States: We comply with the California Consumer Privacy Act (CCPA) as amended by the CPRA, and other applicable state laws. We also adhere to the Children’s Online Privacy Protection Act (COPPA) regarding information from children under 13.

• United Kingdom & European Economic Area (EEA): We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR).

• Canada: We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Canadian Anti-Spam Legislation (CASL).

• South Africa: We recognize and adhere to the principles of the Protection of Personal Information Act (POPIA).

• Australia: We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Specific rights for these regions are detailed in the “Your Data Protection Rights” section.

3. Information We Collect

We collect information that you provide directly to us and information collected automatically when you use our Services.

A. Personal Information You Provide:
We collect personal information you voluntarily provide, such as when you register, contact us, or make a purchase. This includes:

• Identifiers: Full name, email address, postal address, phone number, username, and similar contact data.

• Commercial Information: Records of products or services purchased, obtained, or considered, and other purchasing or consuming histories.

• Professional Information: If you apply for a job, your resume, cover letter, and other employment details.

• Content: Any communications you send to us (e.g., customer support inquiries, feedback).

B. Information Collected Automatically:
When you interact with our Services, we automatically collect:

• Technical Data: Your Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, platform, and other technology on the devices you use.

• Usage Data: Information about your interaction with our Services, including the pages you visited, links you clicked, time spent on pages, and the dates and times of your visits.

• Location Data: We may derive your approximate location from your IP address.

C. Information from Third Parties:
We may receive information about you from third-party services, such as:

• Analytics Providers: Like Google Analytics.

• Social Media Platforms: If you interact with us on social media or log in through a service like Facebook or Google.

• Business Partners: With whom we may offer co-branded services or engage in joint marketing activities.

D. Cookies and Similar Tracking Technologies:
We use cookies, web beacons, and similar tracking technologies to collect and store information. For more details, please see our dedicated Cookie Policy section below.

4. How We Use Your Information

We use the information we collect for the following business and operational purposes:

• To Provide and Maintain Our Services: To create and manage your account, process transactions, provide customer support, and fulfill your requests.

• To Improve and Personalize Our Services: To understand how our Services are used, develop new products and services, and personalize your experience by presenting content tailored to your interests.

• To Communicate With You: To send you service-related emails (e.g., account verification, updates, security alerts), respond to your comments and questions, and, where you have opted-in, send you marketing and promotional communications.

• For Analytics and Reporting: To analyze trends, track user movements, and gather demographic information for aggregate use to improve our Services.

• For Marketing and Advertising: To deliver targeted advertising on our Services and on third-party websites.

• For Security and Fraud Prevention: To protect our Services, users, and business from fraud, security threats, and other malicious activity.

• To Comply with Legal Obligations: To comply with applicable laws, regulations, legal processes, or governmental requests.

5. Legal Basis for Processing (GDPR/UK GDPR/POPIA)

If you are located in the EEA, UK, or South Africa, we process your personal data based on the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., marketing emails).

• Contract Performance: To fulfill a contract we are about to enter into or have entered into with you.

• Legitimate Interests: For our legitimate business interests, such as improving our Services, security, and marketing, provided that your fundamental rights do not override those interests.

• Legal Obligation: To comply with a legal obligation we are subject to.

6. How We Share and Disclose Your Information

We may share your information in the following situations:

• Service Providers: We share data with trusted third-party vendors, service providers, and contractors who perform services for us (e.g., payment processing, data analysis, email delivery, hosting services).

• Business Transfers: In connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates: We may share your information with our parent company, subsidiaries, joint ventures, or other companies under common control with us.

• Advertising Partners: We may share limited information with third-party advertising partners to serve targeted ads.

• Legal Requirements: We may disclose your information where required to do so by law, court order, or governmental authority.

• With Your Consent: We may disclose your personal information for any other purpose with your explicit consent.

We require all third parties to respect the security of your data and to treat it in accordance with the law.

7. International Data Transfers

Your personal information may be transferred to, stored, and processed in countries other than your country of residence, including India and the United States, where our servers are located and our central database is operated. These countries may have data protection laws that are different from the laws of your country.

Whenever we transfer your personal data out of your home jurisdiction, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs) approved for use in the EEA/UK.

• Relying on Adequacy Decisions by the relevant authorities.

• For transfers to the US, we ensure vendors are certified under the EU-U.S. Data Privacy Framework (DPF) where applicable.

• Adhering to cross-border principles under frameworks like the APEC Cross-Border Privacy Rules (CBPR) System.

You can contact us using the details below to obtain more information about the specific mechanism we use for international data transfers.

8. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right to Access & Data Portability: The right to request copies of your personal data and to receive it in a structured, machine-readable format.

• Right to Rectification: The right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

• Right to Erasure (“Right to be Forgotten”): The right to request that we erase your personal data, under certain conditions.

• Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions.

• Right to Object to Processing: The right to object to our processing of your personal data, particularly for direct marketing purposes.

• Right to Withdraw Consent: Where we rely on consent to process your data, you have the right to withdraw that consent at any time.

• Right to Non-Discrimination (CCPA): We will not discriminate against you for exercising any of your rights.

• Right to Opt-Out of Sale/Sharing (CCPA): The right to direct a business that sells or shares personal data to stop doing so.

To exercise any of these rights, please contact us using the details in the “Contact Us” section. We will respond to all legitimate requests in accordance with applicable laws. We may need to verify your identity before processing your request.

9. Cookies and Tracking Technologies

What are Cookies?
Cookies are small data files placed on your device when you visit our site. We use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your device until you delete them).

How We Use Cookies:

• Essential Cookies: Necessary for the website to function and cannot be switched off.

• Analytics/Performance Cookies: Allow us to count visits and traffic sources to measure and improve performance.

• Functionality Cookies: Enable enhanced functionality and personalization.

• Targeting/Advertising Cookies: Set by our advertising partners to build a profile of your interests and show you relevant ads.

Managing Cookies:
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly.

Upon your first visit to www.elbroz.com, you will be presented with a cookie consent banner where you can manage your preferences and consent choices, as required by laws like GDPR and CASL.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

11. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include encryption, access controls, and secure servers. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, transmission of personal information to and from our Services is at your own risk.

12. Children’s Privacy

Our Services are not intended for children under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personally identifiable information from children. If you are a parent or guardian and believe your child has provided us with personal data, please contact us. If we learn we have collected personal data from a child without verification of parental consent, we will take steps to delete that information.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. We will also provide notice via email or a prominent notice on our Services prior to the change becoming effective, if the changes are material. You are advised to review this Privacy Policy periodically for any changes.

14. Contact Us & Grievance Officer

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your legal rights, please contact our designated Privacy Officer at:

Email: support@elbroz.com
Address: Elbroz Media Pvt Ltd, H-161, Suite No- 203, BSI Business Park, Sector 63, Noida, Uttar Pradesh 201301, India