CALCUTTA DEBATING CIRCLE · Registered Non-Profit Trust · Kolkata, West Bengal, India
This Privacy Policy explains how the Calcutta Debating Circle ("CDC") collects, uses, stores, and protects your personal data and what rights you hold under Indian law. It should be read alongside our Terms of Use. By using the CDC Site or registering for any CDC event, you acknowledge that you have read and understood this Policy.
1.
WHO WE ARE
The Calcutta Debating Circle ("CDC") is a non-profit trust registered under the Indian Trusts Act, 1882, with its registered office in Kolkata, West Bengal, India. CDC is the Data Fiduciary as defined under Section 2(i) of the Digital Personal Data Protection Act, 2023 ("DPDP Act") in respect of all personal data collected from users of its Site and participants in its programmes.
CDC is not a Significant Data Fiduciary under Section 10 of the DPDP Act unless subsequently designated by the Central Government. CDC does not process personal data for commercial profit.
Organisation
Calcutta Debating Circle
Type
Registered Non-Profit Trust — Indian Trusts Act, 1882
"Personal Data"
any data by which or in relation to which a natural person can be identified, as defined under Section 2(t) of the DPDP Act, 2023.
"Sensitive Personal Data (SPDI)"
passwords; financial information; health data; sexual orientation; biometric data; and any other category under Rule 3 of the IT (SPDI) Rules, 2011.
"Data Principal"
the natural person to whom Personal Data relates — i.e., You.
"Data Fiduciary"
CDC, as the entity that determines the purpose and means of processing Personal Data.
"Data Processor"
a third party that processes Personal Data on behalf of CDC under a written contract.
"Consent"
a free, specific, informed, unconditional, and unambiguous indication of wishes given through a clear affirmative act, per Section 6, DPDP Act, 2023.
"Site"
all digital services operated by CDC, including calcuttadebatingcircle.com and ticket.calcuttadebatingcircle.com.
3.
LEGAL BASIS FOR PROCESSING
CDC processes Personal Data on the following legal bases:
Consent (Section 6, DPDP Act 2023): for newsletter subscriptions, event registrations, and optional programme features;
Legitimate Uses (Section 7, DPDP Act 2023): for compliance with court orders, legal obligations, employment purposes, or other specified legitimate uses;
Legal Obligation: for tax, accounting, and regulatory compliance under Applicable Law;
Vital Interests: where necessary to protect the life or safety of any person.
4.
WHAT PERSONAL DATA CDC COLLECTS
(A)
Data You Provide Directly
When You interact with the Site or attend a CDC programme, CDC may collect:
Identity data: full name, date of birth, gender, photograph;
Contact data: email address, postal address, telephone number;
Educational and professional data: institution, occupation, year of study, qualifications;
Usage data: pages viewed, time on pages, links clicked, search queries on the Site;
Approximate location data: derived from IP address.
(C)
Sensitive Personal Data
CDC does not knowingly collect SPDI unless expressly required and separately consented to. Where SPDI is sought, this will be clearly indicated at the point of collection.
(D)
Children's Data
CDC does not knowingly collect Personal Data from children under 18 without verifiable parental or guardian consent, per Section 9 of the DPDP Act, 2023. Where a programme is directed at minors, CDC will implement appropriate age-verification and consent mechanisms.
5.
HOW CDC USES YOUR PERSONAL DATA
CDC processes Personal Data only for the following specific, lawful purposes:
To administer and operate the Site and CDC's debate programmes, workshops, and events;
To process event registrations, membership applications, and ticket purchases;
To send event notifications, programme updates, and newsletters where You have consented;
To communicate with You regarding Your Account, queries, or feedback;
To maintain historical records of CDC events and participant histories for archival purposes;
To comply with legal obligations, including tax, accounting, and reporting requirements;
To protect the security and integrity of the Site and prevent fraud or abuse;
To improve the Site on the basis of aggregated, anonymised analytics that do not identify individuals.
CDC WILL NEVER USE YOUR PERSONAL DATA FOR COMMERCIAL ADVERTISING, BEHAVIOURAL PROFILING FOR THIRD-PARTY MARKETING, OR ANY PURPOSE INCONSISTENT WITH CDC'S NON-PROFIT OBJECTS WITHOUT YOUR EXPLICIT CONSENT.
6.
SHARING AND DISCLOSURE OF PERSONAL DATA
(A)
We Do Not Sell Your Data
CDC does not sell, rent, trade, or otherwise transfer Your Personal Data to any third party for commercial purposes.
(B)
Data Processors
CDC engages the following categories of third-party Data Processors, each bound by written data processing agreements requiring compliance with the DPDP Act, 2023:
Payment gateway providers: to process event and membership payments;
Email service providers: to send notifications, newsletters, and transactional communications;
Cloud hosting providers: to host the Site and store data in secure server environments;
Video hosting platforms (e.g., YouTube/Google): to host and publish CDC event recordings.
(C)
Lawful Disclosures
CDC may disclose Personal Data without prior consent only where required by a court order, law enforcement request, or lawful direction of a competent authority; necessary to protect the safety of any person; necessary to enforce CDC's legal rights; or required in connection with any restructuring of the Trust.
(D)
Cross-Border Transfers
Where Personal Data is transferred outside India, CDC shall ensure compliance with Section 16 of the DPDP Act, 2023 and any applicable notifications restricting such transfers.
7.
HOW LONG WE KEEP YOUR DATA
After the applicable retention period, Personal Data will be securely deleted or anonymised. You may request earlier erasure as described in Section 9.
Account Data
Active account period plus 2 years after closure
Event Records
Retained indefinitely — part of CDC's historical archive
Payment Records
Minimum 7 years (Income Tax Act, 1961)
Newsletter Data
Until consent is withdrawn or You unsubscribe
Correspondence
3 years from last communication
Technical / Log Data
90 days from collection
8.
HOW WE PROTECT YOUR DATA
CDC implements reasonable security practices and procedures as required under Rule 8 of the IT (SPDI) Rules, 2011 and the DPDP Act, 2023, including:
encryption of data in transit using TLS/HTTPS;
access controls limiting Personal Data access to authorised personnel on a strict need-to-know basis;
regular security assessments of the Site and hosting infrastructure;
written data processing agreements with all third-party processors requiring equivalent security standards.
In the event of a Personal Data breach likely to result in risk to Data Principals, CDC shall notify the Data Protection Board of India and affected individuals in accordance with Section 8(6) of the DPDP Act, 2023, within prescribed timelines.
NO METHOD OF ELECTRONIC TRANSMISSION OR STORAGE IS 100% SECURE. WHILE CDC USES COMMERCIALLY REASONABLE MEANS TO PROTECT YOUR DATA, ABSOLUTE SECURITY CANNOT BE GUARANTEED.
9.
YOUR RIGHTS AS A DATA PRINCIPAL
Under the DPDP Act, 2023 and related Indian legislation, You have the following rights:
Right to Access — Section 11, DPDP Act 2023
Request a summary of the Personal Data CDC holds about You, the purposes of processing, and the identities of Data Processors or third parties with whom it has been shared. CDC will respond within 30 days.
Right to Correction and Completion — Section 12, DPDP Act 2023
Request correction of inaccurate, incomplete, or outdated Personal Data. CDC will correct or supplement data as required, having regard to the purposes of processing.
Right to Erasure — Section 12, DPDP Act 2023
Request erasure of Personal Data no longer necessary for the purposes of collection, subject to CDC's legal retention obligations and its right to maintain historical archives of public debate events.
Right to Withdraw Consent — Section 6, DPDP Act 2023
Withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of prior processing but may restrict access to certain Site features.
Right to Grievance Redressal — Section 13, DPDP Act 2023
Have data-related grievances addressed by CDC's Grievance Officer (Section 11). Grievances unresolved within 30 days may be referred to the Data Protection Board of India under Section 27 of the DPDP Act.
Right to Nominate — Section 14, DPDP Act 2023
Nominate another individual in writing to exercise your data rights on your behalf in the event of your death or incapacity.
To exercise any of the above rights, submit a written request to the Grievance Officer in Section 11. Mark the subject: "DATA PRINCIPAL RIGHTS REQUEST". CDC will respond within 30 days.
10.
COOKIES AND TRACKING TECHNOLOGIES
(A)
Types of Cookies
The Site uses the following categories of cookies:
Strictly necessary cookies: required for Site operation (session management, authentication). Cannot be disabled.
Functional cookies: remember Your preferences to enhance experience (e.g., language, previously viewed events).
Analytics cookies: collect anonymised usage data to help CDC improve the Site. No individual is identified. CDC uses Google Analytics.
CDC does not use behavioural advertising or third-party tracking cookies.
(B)
Your Cookie Choices
You may disable non-essential cookies through your browser settings or our cookie preference centre on the Site. Disabling cookies may affect certain Site features.
(C)
Third-Party Cookies
Third-party services embedded in the Site (such as YouTube video players) may set their own cookies. Please refer to the relevant third party's privacy policy.
11.
GRIEVANCE OFFICER AND DATA PROTECTION CONTACT
In compliance with the DPDP Act, 2023, the IT Act, 2000, and the Intermediary Rules, 2021, CDC designates the following Grievance Officer for all data-related queries and complaints:
Grievance Officer — Calcutta Debating Circle (Data Protection)
Name: [To be formally appointed by the Trustees and named here]
Designation: Grievance Officer and Data Protection Contact
Address: 42/1A, Harish Mukherjee Road, Bhawanipur, Kolkata – 700 025, Kolkata, West Bengal, India
Email: debatingcirclecalcutta@gmail.com
Phone: +91 81007 79401
Acknowledgement timeline: Within 24 hours of receipt
Resolution timeline: Within 30 days for data rights requests (15 days for general intermediary grievances per Rule 3(2)(d) of the Intermediary Rules, 2021)
Escalation: Unresolved complaints may be referred to the Data Protection Board of India under Section 27 of the DPDP Act, 2023.
12.
THIRD-PARTY SERVICES AND LINKS
The Site may link to or embed content from third-party platforms including YouTube (Google LLC), Facebook, and event-booking services. CDC is not responsible for the privacy practices of any third-party platform and encourages You to read the relevant privacy policies before providing personal data to any third party.
CDC's video content is hosted on YouTube under a separate agreement. Your interaction with YouTube content is governed by Google's Privacy Policy (https://policies.google.com/privacy).
13.
GOVERNING LAW AND JURISDICTION
This Privacy Policy and all disputes arising out of or in connection with it, including disputes relating to the collection, use, storage, or disclosure of your Personal Data, are governed by the laws of India. All such disputes are subject to the exclusive jurisdiction of the courts at Kolkata, West Bengal, India. No other court in any other jurisdiction shall have authority to entertain any claim or dispute arising under this Privacy Policy.
Where a dispute is not resolved through the Grievance Officer process in Section 11, the parties may seek recourse from the Data Protection Board of India under the DPDP Act, 2023, or from the courts at Kolkata, West Bengal, India, as appropriate. You and CDC irrevocably submit to the jurisdiction of those courts for the determination of any such dispute.
14.
CHANGES TO THIS PRIVACY POLICY
CDC may update this Privacy Policy from time to time to reflect changes in law or our practices. Updated versions will be published on the Site with the revised effective date. Where a change materially affects your rights, CDC will use reasonable efforts to notify registered Users by email at least 14 days before the change takes effect. Continued use of the Site constitutes acceptance of the revised Policy.
15.
HOW TO CONTACT US
For any query, concern, or rights request relating to this Privacy Policy, please contact:
Data Protection Enquiries — Calcutta Debating Circle
Email: debatingcirclecalcutta@gmail.com
Phone: +91 81007 79401
Website: calcuttadebatingcircle.com
Postal: 42/1A, Harish Mukherjee Road, Bhawanipur, Kolkata – 700 025, Kolkata, West Bengal, India
For formal Data Principal rights requests or grievances, please mark your correspondence:
"FOR ATTENTION: GRIEVANCE OFFICER — DATA PROTECTION"
