Privacy Policy
Privacy Policy
Effective Date: 01-Jan-2025
Last Updated: 01-Jan-2025
1. Introduction
Digital Media and Analytics Centre (dMAC) is committed to protecting the privacy and security of our users, clients, and visitors. Therefore, this Privacy Policy outlines our practices for collecting, using, maintaining, and disclosing information collected from users of our digital platforms and services. We strive to ensure transparency in our data practices and empower users with control over their personal information.
Our commitment to privacy extends beyond mere compliance with laws and regulations – it is fundamental to our business ethics and values. We believe in building trust through transparent privacy practices and responsible data stewardship.
By using our services, you agree to the terms of this Privacy Policy. If you do not agree with these terms, please refrain from using our platforms or providing us with your personal information.
2. Scope and Applicability
This Privacy Policy applies to all information collected through:
- Our official website www.dMAC.ac.pk.
- Social media accounts and platforms operated by dMAC.
- Mobile applications developed and maintained by dMAC.
- Digital marketing services provided to clients.
- Analytics tools and platforms used in our services.
- Client data processing activities.
- Newsletter and email communications.
- forms and surveys.
- Customer support interactions.
This policy applies regardless of the device or method used to access our services.
3. Legal Framework
dMAC operates in compliance with applicable laws and regulations, including:
- Pakistan Laws
- Prevention of Electronic Crimes Act (PECA) 2016
- Electronic Transactions Ordinance 2002
- Pakistan Telecommunications Act 1996
- International Laws
- General Data Protection Regulation (GDPR) Compliance
i. General Data Protection Regulation (GDPR) Compliance
dMAC adheres to the General Data Protection Regulation (GDPR). Below is a general breakdown of our GDPR compliance framework:
a) Lawful Basis for Processing
We process personal data only under the following lawful bases, as defined by GDPR:
- Consent: Explicit consent for marketing communications, newsletter subscriptions, and non-essential cookies. Example: When you opt-in to receive updates about new courses or promotions.
- Contractual Necessity: Processing required to fulfill services (e.g., course enrollment, payment processing, and account management). Example: Collecting payment details to complete your course registration.
- Legitimate Interests: Balancing our business needs with user rights, such as fraud prevention, network security, and service improvements. Example: Analyzing anonymized website usage data to enhance platform performance.
- Legal Obligation: Compliance with applicable laws (e.g., tax reporting, regulatory audits etc.).
b) Data Minimization Principles
We collect only the data strictly necessary for specified purposes:
- Purpose Limitation: Data is collected for clear, explicit objectives (e.g., email addresses for account creation, payment details for transactions etc.).
- Relevance: We avoid requesting irrelevant information (e.g., we do not require marital status for course enrollment).
- Storage Restriction: Data is retained only as long as needed (e.g., payment information is deleted after 7 years to comply with financial regulations).
c) Privacy by Design and Default
We embed data protection into our systems and processes:
- System Design: Security features (e.g., encryption, access controls) are integrated during product development. Example: End-to-end encryption for all student-instructor communications.
- Default Settings: User accounts are configured with the highest privacy settings (e.g., opting out of non-essential cookies by default).
- Regular Audits: Annual reviews of IT infrastructure to align with evolving privacy standards.
d) Data Protection Impact Assessments (DPIAs)
We conduct DPIAs for high-risk processing activities:
- Risk Identification: Evaluating projects that involve large-scale data processing, sensitive data, or new technologies. Example: Assessing risks before launching AI-driven analytics tools.
- Mitigation Measures: Implementing safeguards such as pseudonymization or enhanced encryption.
- Documentation: Maintaining records of assessments and remedial actions for regulatory review.
e) Cross-Border Transfer Mechanisms
For international data transfers, we use GDPR-approved safeguards:
- Standard Contractual Clauses (SCCs): Legally binding agreements with third-party vendors (e.g., cloud providers like AWS).
- Adequacy Decisions: Transferring data to countries recognized by the EU as having adequate protections (e.g., Canada, Japan).
- Binding Corporate Rules (BCRs): For intra-organizational transfers within dMAC’s offices.
- User Consent: Explicit consent for transfers to non-adequate countries (e.g., for specialized analytics partnerships).
ii. Children’s Online Privacy Protection Act (COPPA):
dMAC complies with the Children’s Online Privacy Protection Act (COPPA) and other applicable laws to protect the privacy of minors. We do not knowingly collect, use, or disclose personal information from children under 13 years of age without verifiable parental consent.
a) Age Verification Mechanisms
To ensure compliance with COPPA, we implement the following age verification protocols:
- Age Screening
- Mandatory age prompts during account creation or service access.
- Date of birth verification for users registering for age-restricted services.
- Third-party age verification tools (e.g., AgeChecker.Net) for high-risk activities.
- Account Restrictions
- Automatic blocking of accounts created with birthdates indicating underage users.
- Limited functionality for unverified accounts until age confirmation is completed.
- Persistent Monitoring
- Regular audits of user accounts to identify potential underage users.
- AI-driven pattern recognition to flag suspicious account activity.
b) Parental Consent Procedures
For users under 13 years of age, we require explicit parental consent before processing any personal data:
- Consent Workflow
- Notification: Parents receive an email/SMS notification when a child attempts to register.
- Verification: Parents must submit:
- One. A signed consent form (digital or physical).
- Two. Government-issued ID for identity verification.
- Three. Proof of guardianship (e.g., birth certificate, court order).
- Confirmation: Parents receive a unique verification code to activate the child’s account.
- b) Consent Revocation
- Parents may withdraw consent at any time by contacting complaints@dMAC.ac.pk.
- All data collected from the child will be deleted within 30 days of revocation.
c) Children’s Data Protection Measures
We implement stringent safeguards to protect children’s data:
- Data Minimization
- Collect only essential information required for service delivery (e.g., username, parent’s email).
- Prohibit collection of sensitive data (e.g., geolocation, photos) from children.
- Access Controls
- Role-based access restrictions to limit internal staff access to children’s data.
- Encryption of all children’s data in transit and at rest (AES-256 standard).
- Retention Limits
- Children’s data is retained only for the duration of service use and deleted upon account closure.
- Annual reviews of stored data to ensure compliance with retention policies.
- Advertising Restrictions
- No behavioral advertising targeting children.
- Prohibition of third-party trackers on child-directed content.
d) Parental Rights
Parents/guardians have the following rights regarding their child’s data:
- Access: Request a copy of all data collected from their child.
- Correction: Update or correct inaccuracies in the child’s profile.
- Deletion: Request permanent deletion of the child’s data and account.
- Opt-Out: Block future data collection or processing activities.
To exercise these rights, parents may:
- Email to complaints@dMAC.ac.pk with the subject line: “COPPA Request – [Child’s Username]”.
- Call our helpline at +92 3326 113 555.
e) Educational Resources
To promote safe online experiences for children, we provide:
- Parent Guides
- “Protecting Your Child’s Privacy Online” handbook.
- Video tutorials on managing parental controls.
- Child-Friendly Content
- Age-appropriate privacy tutorials.
- Interactive modules on digital safety.
- School Partnerships
- Workshops for educators on COPPA compliance.
- Classroom resources for teaching digital literacy.
f) Staff Training
All dMAC employees handling children’s data undergo:
- Annual COPPA compliance training.
- Background checks and confidentiality agreements.
- Simulated scenarios for identifying and reporting COPPA violations.
4. Information We Collect
We collect and process the following types of information:
- Personal Information
- Identity Information: Full name, date of birth, national ID numbers, professional titles, and affiliations.
- Contact Information: Email address, phone numbers, postal address, and business address.
- Professional Information: Company name, job title, industry sector, and professional qualifications.
- Financial Information: Billing address, payment card details (processed securely through authorized providers), transaction history, and banking information for B2B services.
- Technical Information
- Device Information: IP address, browser type and version, operating system, device identifiers, and screen resolution.
- Usage Data: Pages visited, time spent on pages, navigation paths, click patterns, and feature usage statistics.
- Location Data: GPS data (with consent), IP-based location, and regional settings.
5. How We Use Your Information
We use collected information for the following purposes:
- Primary Purposes
- Service Delivery: Account creation and management, service personalization, performance optimization, technical support, and feature updates.
- Communication: Service updates, marketing communications (with consent), newsletter distribution, support responses, and event invitations.
- Analytics and Improvement: Service optimization, user experience enhancement, performance monitoring, market research, and product development.
- Legal Basis for Processing
- Contractual Necessity: Service delivery, account management, payment processing, and support provision.
- Legal Obligations: Tax compliance, business records, legal proceedings, and regulatory reporting.
- Legitimate Interests: Service improvement, security measures, fraud prevention, and market research.
- Consent: Marketing communications, cookie usage, location tracking, and profile enrichment.
6. Data Security
We implement and maintain appropriate technical and organizational security measures:
- Security Measures
- Encryption: TLS 1.3 for data in transit, AES-256 encryption for data at rest, and secure key management systems.
- Access Controls: Role-based access control (RBAC), multi-factor authentication (MFA), and regular access reviews.
- Network Security: Next-generation firewalls, intrusion detection systems, and 24/7 monitoring.
- Employee Security: Regular security training, background checks, and confidentiality agreements.
- Data Storage
- Storage Infrastructure: Tier-4 data centers, redundant systems, and regular security audits.
- Retention Policies: Data minimization principles, automated deletion processes, and compliance with legal requirements.
7. Third-Party Sharing
We share data with the following categories of third parties:
- Categories of Recipients
- Service Providers: Cloud hosting providers, payment processors, and analytics services.
- Business Partners: Integration partners, marketing agencies, and professional service providers.
- Legal Authorities: Law enforcement, regulatory bodies, and government agencies.
- Data Transfer Safeguards
- Contractual Measures: Data processing agreements and standard contractual clauses.
- Technical Measures: Encryption in transit, secure file transfer protocols, and access logging.
8. User Rights
You have the following rights regarding your personal data:
- Your Rights Include
- Right to Access: Request data copies and confirm processing activities.
- Right to Rectification: Correct inaccurate or incomplete data.
- Right to Erasure: Request deletion of your data (subject to legal constraints).
- Right to Portability: Receive your data in a structured, machine-readable format.
- Exercise of Rights
- Request Submission: Online form submission, email requests, or written requests.
- Verification Process: Identity verification and security checks.
9. Cookies and Tracking
We use cookies and similar technologies to enhance your user experience and analyze website usage. You can manage your cookie preferences through your browser settings or our cookie consent tool.
10. Children’s Privacy
dMAC does not knowingly collect data from individuals under 18 years of age without parental consent. If we become aware of such collection, we will take steps to delete the data promptly.
11. Social Media Integration
We maintain a presence on various social media platforms, including Facebook, Twitter, Instagram, and LinkedIn etc.. Our interactions on these platforms are governed by their respective privacy policies.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated via email or through our website. The updated policy will be effective as of the date indicated at the top of this document.
13. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at:
- Email: complaints@dMAC.ac.pk
- Phone: +92 3326 113 555
- Mailing Address: 9 Noon Avenue, Canal Road, Muslim Town, Lahore, Pakistan.
- For general inquiries, please email to info@dMAC.ac.pk.
14. Governing Law
This Privacy Policy is governed by the laws of Pakistan. Any disputes related to this policy will be resolved through mediation or arbitration in Lahore, Pakistan.