Privacy Policy

1. Introduction

Debmedia Technologies LLP ("Company," "we," "us," or "our"), trading as FunnelProfitX, respects your privacy. This Privacy Policy explains how we handle personal information on this website and when you buy and download our digital products, including SwipeInboxEmpire PLR.

By using this website or buying a product you acknowledge this policy. If you do not agree with it, please do not use the website.

2. Company Information

• Legal Name: Debmedia Technologies LLP
• Type of Entity: Limited Liability Partnership registered in India
• Brand: FunnelProfitX
• Registered Address: 117/4 Vivekananda Road, Kolkata – 700011, West Bengal, India
• Privacy Contact: legal@debmediaenterprise.com
• Data Controller: For the purposes of data protection law, Debmedia Technologies LLP is the data controller responsible for your personal information.

3. Information We Collect

We keep what we collect to the minimum needed to deliver your purchase and support you. We do not create user accounts, and we do not ask for sensitive personal data.

3.1 When You Buy

When you buy through WarriorPlus, we receive an order notification containing:

• Your name and email address
• The order or transaction ID
• The product and offers you purchased, the amount and the currency
• The payment status (for example paid or refunded) and dates.
• We do not receive or store your card number or bank details. Payment is handled by WarriorPlus.

3.2 When You Contact Support

When you use the support form we collect your name, email address, the product and order ID you give us, your subject and message, and our replies to you.

3.3 When You Download

We record which file was downloaded, when, and a hashed (not directly readable) version of your IP address. We use this to enforce download limits and to detect misuse of download links.

3.4 Technical Data

Like most websites, our server and hosting provider record technical data such as IP address, browser type, device, the pages requested and timestamps. We use this for security and troubleshooting.

3.5 Cookies and Analytics

See the Cookies section below.

4. How We Use Your Information

We use your information to:

• Confirm your payment and give you access to the products you bought
• Send you your purchase and delivery emails
• Answer your support questions and process refund requests
• Detect and prevent fraud, abuse, chargebacks and unauthorised sharing of download links
• Keep proper business, tax and accounting records
• Keep the website secure and working properly, and understand how its pages perform
• Comply with legal obligations.

We do not sell your personal data and we do not use it for automated decisions that significantly affect you.

5. Legal Basis for Processing Personal Data

We process your personal data based on one or more of the following legal grounds:

5.1 Consent: You have given explicit consent for us to process your personal data for specific purposes (e.g., marketing communications, cookies, newsletter subscriptions).

5.2 Contractual Necessity: Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., providing Services, processing payments, delivering Products).

5.3 Legal Obligation: Processing is required to comply with legal obligations under Indian law or other applicable jurisdictions (e.g., tax compliance, regulatory reporting, responding to legal requests).

5.4 Legitimate Interests: Processing is necessary for our legitimate business interests or those of a third party, provided such interests are not overridden by your rights and freedoms (e.g., fraud prevention, network security, business analytics, improving Services).

5.5 Vital Interests: Processing is necessary to protect vital interests of you or another person (e.g., emergency situations).

5.6 Public Interest: Processing is necessary for tasks carried out in the public interest or in exercise of official authority (rarely applicable to our business).

6. How We Share Your Information

We Do Not Sell Your Personal Data. We never sell, rent or trade your personal information to third parties for their marketing purposes.

We share information only as needed to run the service:

• WarriorPlus: processes your payment and sends us your order details. WarriorPlus handles your data under its own terms and privacy policy
• Hosting and infrastructure providers that store the website and its data
• Email delivery providers that send purchase and support emails on our behalf
• Analytics or advertising measurement tools, only if and when we enable them (see Cookies below)
• Professional advisers, courts, tax or law-enforcement authorities when the law requires it or to protect our legal rights.

Providers act on our instructions and may use your data only to provide their service to us.

7. International Data Transfers

We are based in India. Your personal data may be processed in India and in other countries where our hosting, email and payment providers operate, including WarriorPlus. Data protection laws in those countries may differ from the laws where you live.

When we transfer personal data across borders, we use appropriate safeguards where the law requires them, such as contractual protections with providers (including Standard Contractual Clauses for transfers from the EU where they apply). If you are in the EU, UK or another region with transfer rules, you can ask us about the safeguards used by contacting legal@debmediaenterprise.com.

8. Data Retention

We keep personal data only as long as needed for the purposes in this policy or as the law requires:

• Purchase and payment records: up to 7 years, for tax and accounting compliance
• Support messages: up to 24 months after the request is closed
• Download records: up to 24 months
• Server and security logs: for a limited period, then deleted or anonymised
• Marketing opt-in and opt-out records, if we send marketing: for as long as needed to respect your choice.

When data is no longer needed, we delete it or anonymise it.

9. Data Security

We take reasonable technical and organisational steps to protect the personal data we hold from unauthorised access, loss, misuse, alteration or disclosure. These include:

• Serving this website over HTTPS so that data is encrypted in transit
• Keeping order, support and download records outside the publicly accessible part of the website
• Using signed, expiring links for downloads, and storing only a hashed form of IP addresses in download and support records
• Not storing card or bank details, which are handled by WarriorPlus
• Limiting access to the data to people who need it to run the business.

Data Breach Notification: If a data breach affects your personal data in a way that creates a risk to you, we will notify you and the relevant authorities as required by applicable law, including within 72 hours of becoming aware where GDPR or the Indian IT Rules require it. We will describe what happened, what data was involved, what we are doing about it and what you can do to protect yourself.

No Guarantee of Security: Despite our measures, no system is 100% secure. We cannot guarantee absolute security against all threats.

10. Cookies and Similar Technologies

Our pages do not need cookies to let you browse, buy or download, and our own download and support pages do not set tracking cookies.

We may add analytics (such as Google Analytics) or advertising measurement tools (such as a Meta Pixel) to measure visits and the performance of our marketing. If we enable them, they may set cookies or similar identifiers on your device. Where the law requires your consent, we will ask for it first and honour your choice.

You can control cookies at any time in your browser settings: you can delete existing cookies, block new ones, or ask your browser to tell you before one is set. Blocking cookies will not stop you from downloading products you bought. Browser help pages explain how to do this for each browser.

Third parties such as WarriorPlus set their own cookies on their own pages, under their own policies.

11. Your Rights and Choices

You have important rights regarding your personal data. You may exercise these rights by contacting us at debmedia@gmail.com.

11.1 Right to Access

What You Can Request:

• Confirmation of whether we process your personal data
• Copy of your personal data in our possession
• Information about how we use and share your data
• Categories of data we collect and process
• Sources from which we obtained your data
• Purposes of processing
• Recipients or categories of recipients.

How to Request: Email debmedia@gmail.com with "Data Access Request" in subject line. We will respond within 30 days.

Free Access: First request is free. Subsequent excessive or repetitive requests may incur reasonable administrative fees.

11.2 Right to Rectification

You have the right to correct inaccurate or incomplete personal data:

• Update or correct your information by contacting us
• Request correction by contacting support
• Provide evidence supporting the correction
• We will update data within 15 days of verification.

11.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data when:

• Data is no longer necessary for the purposes collected
• You withdraw consent and there's no other legal basis
• You object to processing and there are no overriding legitimate grounds
• Data has been unlawfully processed
• Deletion is required for legal compliance.

Exceptions: We may refuse deletion if we need the data for:

• Compliance with legal obligations (e.g., tax records)
• Establishment, exercise, or defense of legal claims
• Fulfillment of contractual obligations
• Fraud prevention and security.

11.4 Right to Restrict Processing

You may request restriction of processing when:

• You contest accuracy of data (restricted until verified)
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data but you need it for legal claims
• You object to processing (restricted pending verification of legitimate grounds).

11.5 Right to Data Portability

You have the right to:

• Receive your personal data in structured, commonly used, machine-readable format (CSV, JSON)
• Transmit your data to another service provider
• Request direct transmission where technically feasible.

Scope: Applies to data you provided and we process based on consent or contract, in automated systems.

11.6 Right to Object

You may object to processing based on legitimate interests, including:

• Direct marketing (we will stop immediately)
• Profiling for marketing purposes
• Processing based on legitimate interests (we will cease unless compelling grounds exist)
• Automated decision-making.

11.7 Withdrawal of Consent

Where processing is based on consent, you may withdraw consent at any time:

• By contacting us
• Via unsubscribe links in emails
• By contacting us directly
• Through privacy preference center.

Effect of Withdrawal: Withdrawal does not affect lawfulness of processing before withdrawal. We may continue processing on other legal bases if applicable.

11.8 Managing Communication Preferences

Marketing Communications:

• Opt out via unsubscribe link in emails
• Update your preferences by contacting us or using the unsubscribe link
• Contact us to remove from all marketing lists.

Transactional Communications: You cannot opt out of essential service communications (such as purchase confirmations, download links and payment receipts) as these are necessary for us to deliver what you bought.

12. Rights Under Indian Law

12.1 Information Technology Act, 2000

We comply with the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Your Rights Include:

• Right to review personal information collected
• Right to correct or update personal information
• Right to withdraw consent for certain processing
• Right to opt-out of marketing communications
• Right to file complaints with the Grievance Officer.

12.2 SPDI Rules Compliance

Sensitive Personal Data or Information (SPDI): Under Indian law, SPDI includes:

• Passwords and financial information (bank accounts, credit/debit cards)
• Physical, physiological, and mental health condition
• Sexual orientation
• Medical records and history
• Biometric information
• Any other information deemed sensitive under IT Rules.

SPDI Protection: We collect SPDI only with your consent and for lawful purposes. SPDI is protected with enhanced security measures.

Disclosure of SPDI: We do not disclose SPDI to third parties without your consent, except:

• When required by law
• To government agencies with legal authority
• For fraud prevention with your interest in mind.

12.3 Grievance Officer Information

Grievance Redressal Mechanism: In accordance with IT Rules 2011, we have designated a Grievance Officer to address privacy concerns:

Grievance Officer

Name: Debasis Bhattacharjee, Founder

Email: legal@debmediaenterprise.com

Alternative Email: legal@debmediaenterprise.com

Address: Debmedia Technologies LLP, 117/4 Vivekananda Road, Kolkata – 700011, West Bengal, India

Filing a Complaint:

• Email the Grievance Officer with detailed complaint
• Include your contact information and order details
• Describe the privacy concern or data protection issue
• Provide supporting evidence if applicable
• We will acknowledge within 24 hours and resolve within 30 days.

13. Rights Under GDPR (For EU Users)

If you are located in the European Union (EU), European Economic Area (EEA), or United Kingdom (UK), you have additional rights under the General Data Protection Regulation (GDPR):

13.1 Lawful Processing

We process your personal data only when we have a lawful basis (see Section 5):

• Consent for marketing and cookies
• Contract performance for service delivery
• Legal obligation for tax and regulatory compliance
• Legitimate interests for analytics, security, and improvement
• Vital interests for emergency situations.

13.2 Data Protection Rights

Your GDPR Rights:

• Right to Information: Be informed about data collection and use
• Right of Access: Obtain copy of your data (within 1 month)
• Right to Rectification: Correct inaccurate data (within 1 month)
• Right to Erasure: Request deletion in certain circumstances
• Right to Restrict Processing: Limit processing in certain situations
• Right to Data Portability: Receive data in portable format
• Right to Object: Object to processing based on legitimate interests
• Rights Related to Automated Decision-Making: Not be subject to solely automated decisions with significant effects without human involvement.

13.3 Complaints with Supervisory Authorities

If you believe we have violated your GDPR rights, you have the right to lodge a complaint with:

• Your local data protection supervisory authority in the EU/EEA/UK
• The lead supervisory authority where we have our main establishment (if applicable)
• Contact details for EU supervisory authorities: https://edpb.europa.eu/about-edpb/board/members_en

GDPR Representative: If required, we will appoint an EU representative. Contact details will be provided upon request.

Data Protection Officer (DPO): We may appoint a DPO as required by GDPR. Contact: legal@debmediaenterprise.com

14. Rights Under CCPA/CPRA (For California Users)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

14.1 Right to Know

You have the right to request disclosure of:

• Categories of personal information collected
• Specific pieces of personal information we hold
• Categories of sources from which we collected data
• Business or commercial purposes for collecting data
• Categories of third parties with whom we share data
• How long we retain each category of information.

Request Process: Submit request via email to legal@debmediaenterprise.com or through our web form. We will respond within 45 days (extendable to 90 days with notice).

14.2 Right to Delete

You may request deletion of personal information we collected, subject to exceptions for:

• Completing transactions or providing requested services
• Detecting and resolving security incidents
• Debugging and repairing functionality
• Complying with legal obligations
• Internal uses reasonably aligned with your expectations
• Exercise of free speech or research purposes.

14.3 Right to Opt-Out

Sale of Personal Information: We do NOT sell your personal information. If this changes, we will update this policy and provide opt-out mechanisms.

Sharing for Cross-Context Behavioral Advertising: You may opt out of sharing for targeted advertising through:

• Cookie preference center on our website
• Global Privacy Control (GPC) signal (we honor GPC)
• Email request to legal@debmediaenterprise.com.

Sensitive Personal Information: You may limit use of sensitive personal information to purposes necessary for service delivery.

14.4 Non-Discrimination Policy

No Discrimination for Exercising Rights: We will not discriminate against you for exercising CCPA/CPRA rights, including:

• Denying goods or services
• Charging different prices or rates
• Providing different quality of services
• Suggesting you will receive different prices or quality.

Permissible Differences: We may offer financial incentives (discounts, rewards) for providing data or charge different prices for different service tiers, provided the difference is reasonably related to the value of the data.

Authorized Agents: You may designate an authorized agent to make CCPA/CPRA requests on your behalf. We may require verification of authorization.

Verification Process: To protect your privacy, we will verify your identity before processing rights requests using:

• Email confirmation to registered email
• Verification of your order ID and email address
• Matching information you provide with our records
• Additional verification for sensitive requests.

15. Marketing Emails

We send transactional emails (such as your purchase confirmation and download link) because they are part of delivering what you bought.

We send promotional emails only where you have agreed to receive them or where the law allows it, for example to existing customers about similar products. Every promotional email contains an unsubscribe link. After you unsubscribe, we keep a record of that choice so we respect it.

16. Children's Privacy

Our products and website are not intended for people under the age of 18 (or the age of majority where you live, if higher). We do not knowingly collect personal information from children. If you are under 18, please do not buy our products, contact support or give us any personal information.

If you believe a child has given us personal information, contact us at legal@debmediaenterprise.com with the details. We will look into it promptly and delete the information if it is confirmed. For users in the United States, we do not knowingly collect data from children under 13 and we follow COPPA.

17. Third-Party Links

Our pages may link to other websites, including WarriorPlus. We do not control those websites and are not responsible for their content or privacy practices. Please read their policies before you give them any information.

18. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top shows when it last changed. If we make a significant change, we will take reasonable steps to tell you, for example by a notice on this website.

19. Contact and Complaints

To exercise your rights, ask a question or make a complaint about how we handle your data, contact us:

• Operator: Debmedia Technologies LLP (trading as FunnelProfitX)
• Registered address: 117/4 Vivekananda Road, Kolkata – 700011, West Bengal, India
• Product support: use the Support page of this website
• Legal and privacy matters: legal@debmediaenterprise.com
• General enquiries: debmedia@gmail.com

We will respond within the time required by the law that applies to you. If you are not satisfied, you may also complain to your local data protection authority.