Privacy Policy
This Privacy Policy describes how Altrupact Ventures Private Limited (“Company”, “we”, “us”, “our”) collects, uses, shares, stores and otherwise processes Personal Data (as defined below) in connection with the Platform and Services. Please read this Privacy Policy together with the Terms of Use at (altrupact.com/terms-of-use) (“Terms of Use”) and the Disclaimer at (altrupact.com/disclaimer) (“Disclaimer”), each of which is incorporated by reference and forms part of the contractual framework governing your use of the Platform.
1. SCOPE AND APPLICABILITY
1.1 This Privacy Policy applies to Personal Data processed by the Company in relation to:
(a) your access to and use of (altrupact.com) and related features, pages and integrations (the “Platform”), and
(b) services, features and activities offered through or in connection with the Platform, including editorial engagement, publication workflows, submissions intake, newsletters, events, programs, open calls and related distribution (the “Services”).
1.2 This Privacy Policy applies to Users and Participants. Capitalized terms not defined in this Privacy Policy shall have the meanings assigned to them in the Terms of Use. For convenience, certain key terms are restated in Section 2 below. In case of any inconsistency between this Privacy Policy and the Terms of Use, the Terms of Use shall prevail to the extent permitted by applicable law.
1.3 This Privacy Policy does not apply to Third-Party Services (including Google Forms, Substack and social media platforms) except to the extent we process Personal Data received from them or shared with them in accordance with this Privacy Policy. Third parties may collect and process data independently under their own policies and terms.
2. DEFINITIONS
2.1 “Company”, “Platform”, “Services”, “Content”, “User”, “Participant”, “Submission”, “Partner Content” and “Third-Party Services” shall have the meanings set out in the Terms of Use.
2.2 “Personal Data” means any data about an individual who is identifiable by or in relation to such data, and includes “personal data” as defined under the Digital Personal Data Protection Act, 2023 (and rules or subordinate legislation thereunder, as amended or applicable) (“DPDP Act”). For avoidance of doubt, Personal Data may include information that directly identifies you (such as name and email address) and information that indirectly identifies you (such as device identifiers and online identifiers), as applicable.
2.3 “Processing” means any operation or set of operations performed on Personal Data, whether automated or otherwise, such as collection, recording, organization, storage, use, disclosure, sharing, transfer, erasure or destruction.
2.4 “Consent Manager” / “Cookie Banner” means the cookie consent and preference management interface presented on the Platform, including any link such as Cookie Settings.
3. APPLICABLE LAW AND INTERPRETATION
3.1 We intend to process Personal Data in accordance with applicable Indian law, including the DPDP Act, as amended or as applicable, and other applicable laws, rules and regulations. Certain obligations and user rights may evolve based on statutory rules, regulatory guidance and implementation timelines. Accordingly, we reserve the right to interpret and apply this Privacy Policy in a manner consistent with applicable law as in force from time to time.
3.2 Where we refer to legal bases or lawful grounds for processing, such references are intended to describe our approach under applicable Indian law and do not create any additional commitments beyond those required by law.
4. INFORMATION WE COLLECT
We may collect and process the following categories of Personal Data, as applicable to your interactions with the Platform and Services:
4.1 Name, email address, phone number, messaging handle (including WhatsApp), postal address (if provided), social media handles, profile links and similar contact identifiers.
4.2 Job title, company or organization name, industry, location, biography, professional history, education, portfolio links, fundraising or program participation information and related professional details that you provide.
4.3 Information and materials contained in a Submission, including responses to editorial questionnaires, narratives, quotes, images, logos, brand assets, documents, links and other materials submitted through Google Forms or other channels.
4.4 Emails, messages, call records (for example, time and duration), scheduling details, notes, correspondence history and other information you provide when you communicate with us or when we communicate with you for editorial consideration and related purposes.
4.5 Subscription status, preferences, engagement signals (for example, opens, clicks where available), opt-in and opt-out records and marketing communication preferences.
4.6 Pages viewed, interaction events, referrer URLs, timestamps, approximate location inferred from IP address, browsing activity on the Platform, error logs and performance data.
4.7 Device type, browser type, operating system, language, IP address, device identifiers and similar technical signals.
4.8 Cookie identifiers, pixel tags, SDK signals, local storage and similar tracking technologies that collect information about your device and your interaction with the Platform.
4.9 Where you engage with partner-related open calls, programs or events, we may collect limited information relevant to facilitating such engagement or measuring reach, subject to this Privacy Policy and applicable terms.
4.10 We may derive limited inferences from the above data to understand audience interests, improve Content relevance, measure effectiveness and support advertising and retargeting, subject to your cookie choices and applicable law.
4.11 We do not intend to request or require sensitive personal data in ordinary course for the Platform’s functioning. If you voluntarily provide sensitive data in a Submission or communication, you acknowledge that such disclosure is at your discretion and we may process it as necessary for the purposes for which it was provided, subject to applicable law and appropriate safeguards as practicable.
5. SOURCES OF PERSONAL DATA
5.1 When you browse the Platform, submit a form, email us, message us, subscribe to newsletters, apply for participation, provide a Submission or otherwise communicate with us.
5.2 Through cookies, pixels, tags, log files and similar technologies when you use the Platform, to the extent enabled.
5.3 We may receive information from third parties where you interact with our presence or content on such services (for example, Substack subscription data, social media engagement signals, embedded form submissions), subject to the third party’s settings, your choices and their policies.
5.4 We may collect limited professional information from publicly available sources (for example, websites, professional profiles, press pages) to identify and contact potential Participants or to contextualize editorial consideration, subject to applicable law.
6. PURPOSES OF PROCESSING
We may process Personal Data for the following purposes, as applicable:
6.1 To make the Platform available, deliver Content, administer features, manage forms, respond to requests and provide functionality.
6.2 To evaluate Submissions, shortlist Participants, conduct outreach, schedule conversations, request clarifications, draft and edit content, manage confirmations where we may seek them and prepare Content for distribution through the Platform, newsletters and social media.
6.3 To communicate with you regarding editorial engagement, queries, responses, clarifications, scheduling and operational messages.
6.4 To manage newsletter subscriptions and distribution through Substack or other tools, including sending newsletters, handling unsubscribes, maintaining suppression lists and measuring engagement metrics.
6.5 To understand how the Platform is used, evaluate performance, debug issues, develop new features and improve Content, Services and user experience.
6.6 To deliver and measure advertising, including interest-based advertising and retargeting, to the extent enabled and subject to applicable law.
6.7 To protect the Platform, detect misuse, prevent fraud, enforce policies and maintain integrity of our systems.
6.8 To comply with legal requirements, respond to lawful requests, exercise or defend legal claims and maintain records as required.
6.9 For internal administration, audits, reporting, financial and operational planning and corporate governance.
6.10 To evaluate, facilitate or implement a merger, acquisition, financing, reorganization, sale of assets or similar transaction, subject to applicable law and appropriate protections.
7. LAWFUL GROUNDS FOR PROCESSING
7.1 We process Personal Data based on one or more lawful grounds recognized under applicable Indian law, which may include:
(a) Where you provide consent through an affirmative act, including through forms, cookie banner choices, newsletter subscriptions or other opt-ins, subject to withdrawal rights and applicable law.
(b) Where permitted, we may process Personal Data for purposes such as operational communications, security, preventing fraud, maintaining records, responding to your requests and certain editorial outreach activities, as applicable and subject to law.
(c) Where processing is necessary to perform obligations under the Terms of Use or to take steps at your request prior to providing specific Services.
(d) Where processing is necessary to comply with legal obligations, court orders, governmental requests or to exercise or defend legal claims.
7.2 Where consent is the relevant ground, you may withdraw consent, subject to legal and operational limitations, and certain processing may continue where permitted or required by law.
8. COOKIES, ANALYTICS AND ADVERTISING
8.1 We may use cookies, pixels, tags, SDKs and similar technologies to operate the Platform, remember preferences, conduct analytics, provide security and support advertising and retargeting, to the extent enabled and subject to applicable law.
8.2 We may use, as applicable:
(a) Strictly necessary cookies required for core operations and security,
(b) Functional cookies to remember preferences and improve experience,
(c) Analytics/performance cookies to understand usage and measure performance, and
(d) Advertising/targeting cookies to support interest-based advertising, attribution and retargeting.
8.3 We intend to implement a Cookie Banner / Consent Manager on the Platform. Where available, you may use the banner and Cookie Settings to manage preferences for certain categories of cookies and similar technologies. You acknowledge that, due to technical limitations, configuration differences across devices and browsers and the evolving nature of third-party tracking technologies, the banner and settings interface may not identify or control every cookie, pixel, tag or similar technology in all circumstances.
8.4 You may withdraw or modify cookie preferences at any time using the Cookie Banner controls and Cookie Settings, where available. However, your browser and device settings are typically the most effective method to block, delete or limit cookies and similar storage technologies because they operate at the browser or device level. You may therefore use browser settings to refuse or remove cookies, clear stored data and disable certain tracking technologies. If you delete cookies or reset your browser, you may need to re-apply your preferences and certain Platform features may be affected. Certain Third-Party Services and advertising partners may provide separate opt-out mechanisms (for example, platform account settings or device advertising controls). Where such controls exist, you may choose to use them in addition to browser settings and our Cookie Banner.
8.5 We may use analytics providers to understand traffic and usage patterns, including by collecting device and usage information. These providers may set cookies or collect identifiers.
8.6 We may work with advertising partners and social media platforms to show ads, measure ad performance and enable retargeting. Such partners may use cookies, pixels and similar tools to collect or receive information from the Platform and elsewhere, subject to their terms and your settings. Where applicable, you may opt out through:
(a) the Cookie Banner or Cookie Settings,
(b) browser and device-level ad preference controls, and
(c) industry opt-out tools made available by advertising networks, where applicable.
Your choices may not eliminate all advertising and may result in less relevant advertising.
8.7 Some browsers transmit “Do Not Track” signals. As standards vary, the Platform may not respond uniformly to such signals, and you should use the Cookie Banner and browser settings for controls.
9. HOW WE SHARE PERSONAL DATA
9.1 We do not sell Personal Data. For clarity, “sell” means disclosing or transferring Personal Data to a third party for monetary consideration. This does not restrict our ability to share Personal Data with service providers, partners, affiliates or other recipients for legitimate business purposes as described below, including where we receive commercial value other than monetary consideration (for example, analytics services), subject to applicable law and your choices.
9.2 We may share Personal Data with the following categories of recipients, as applicable:
(a) Hosting providers, content delivery networks, email and communications providers, analytics providers, customer support tools, security vendors, form tools, scheduling tools and other vendors that process Personal Data on our instructions.
(b) We may use Substack for newsletter distribution at (altrupact.substack.com). Depending on the configuration, Substack may act as a processor or as an independent controller for certain data it collects. Your interactions with Substack are subject to Substack’s terms and privacy practices, and you should review them directly.
(c) Where we use Google Forms or similar tools for Submissions, Google may process data as a service provider under its terms and policies. Your interactions may be governed by Google’s terms and privacy practices, and you should review them.
(d) Ad networks, social media platforms, tag managers and measurement partners, subject to cookie consent settings and applicable law.
(e) Where necessary to facilitate a specific open call, program, initiative or event you engage with, we may share limited information with partners, typically on a need-to-know basis and subject to applicable terms. We may also share aggregated or de-identified analytics with partners where feasible.
(f) Law enforcement, regulators, courts or authorized third parties where we believe disclosure is necessary to comply with law, respond to lawful requests, enforce our terms, protect rights, safety and security, investigate fraud or address technical issues.
(g) Prospective buyers, investors, lenders, advisors and other participants in a corporate transaction, subject to confidentiality obligations and applicable law.
(h) Our group entities, affiliates and personnel on a need-to-know basis for operational purposes, subject to appropriate safeguards.
9.3 We may share aggregated, anonymized or de-identified information that cannot reasonably be used to identify an individual, subject to applicable law.
10. CROSS-BORDER TRANSFERS
10.1 We may process and store Personal Data in India and, as applicable, in other countries where our service providers, partners or infrastructure providers are located. This may result in cross-border transfers of Personal Data.
10.2 Where cross-border transfers occur, we may implement safeguards that we consider appropriate, such as contractual arrangements, access controls and security measures, subject to applicable law, including any restrictions that may be notified by the Government of India from time to time.
10.3 By using the Platform or providing Personal Data, you acknowledge that such transfers may occur as described in this Privacy Policy, subject to your rights and applicable law.
11. DATA RETENTION
11.1 We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, or unless retention is necessary for legal claims, audits, dispute resolution, security or enforcement.
11.2 Retention periods may vary based on factors such as: the nature and sensitivity of the data, the purpose of processing, the duration of editorial engagement, ongoing relationship (including newsletter subscription), legal obligations and operational needs.
11.3 We may retain Submissions and related communications for editorial records, future editorial consideration, compliance, audits and defense of claims, subject to applicable law. We do not undertake to delete all copies immediately upon request where retention is legally required or reasonably necessary.
11.4 Newsletter subscription data may be retained for as long as you remain subscribed and thereafter for a reasonable period to maintain suppression lists, recordkeeping and compliance.
11.5 Technical logs and analytics data may be retained for varying periods depending on operational needs, security requirements and vendor configurations.
12. SECURITY MEASURES
12.1 We implement reasonable technical and organizational safeguards intended to protect Personal Data against unauthorized access, disclosure, alteration, loss or destruction. Such safeguards may include access controls, encryption in transit where supported, administrative controls, vendor due diligence, logging and monitoring, backups and security practices appropriate to the nature of data and context.
12.2 Notwithstanding the above, no system can be guaranteed to be completely secure. You acknowledge that transmission over the internet and electronic storage involve inherent risks. To the maximum extent permitted by law, we disclaim liability for unauthorized access or breaches beyond our reasonable control.
13. YOUR RIGHTS AND CHOICES
13.1 Subject to applicable law (including the DPDP Act as amended or applicable), you may have certain rights in relation to your Personal Data, which may include the right to:
(a) access information about your Personal Data processed by us,
(b) request correction or updating of inaccurate or incomplete Personal Data,
(c) request erasure of Personal Data, where applicable,
(d) withdraw consent where processing is based on consent,
(e) opt out of marketing communications, and
(f) seek grievance redressal.
13.2 You may submit requests by contacting us at contact@altrupact.com. We may request information to verify your identity and to understand the scope of your request. We reserve the right to refuse or limit requests where permitted by law, including where requests are manifestly unfounded, excessive, impracticable or where retention is required by law.
13.3 Where processing is based on consent, you may withdraw consent, subject to legal and operational constraints. Withdrawal may affect our ability to provide certain Services, including editorial engagement and newsletters.
13.4 You may manage cookies through the Cookie Banner, Cookie Settings and browser settings as described in Section 8.
13.5 You may unsubscribe through links provided in emails or via Substack controls, subject to processing time and platform limitations. We may retain limited information to honor opt-out requests and maintain suppression lists.
14. COMMUNICATIONS
14.1 We may contact Participants and Users for editorial consideration and operational purposes through email, phone calls, WhatsApp or other messaging platforms, as applicable and subject to law and your preferences where required.
14.2 Where applicable, we may send promotional communications, including newsletters and announcements, subject to consent and opt-out mechanisms. Even if you opt out of promotional communications, we may still send non-promotional messages where reasonably necessary for operational, legal or security purposes.
14.3 Calls and messages may be initiated by our team or authorized representatives. We may maintain logs of communications for recordkeeping, quality, compliance and dispute management, subject to applicable law.
15. THIRD-PARTY LINKS AND EMBEDDED CONTENT
15.1 The Platform may include Third-Party Services such as embedded videos, social media widgets, forms and links. These third parties may collect information about you, including through cookies or other tracking technologies, independently of us.
15.2 We do not control third-party data practices and are not responsible for their privacy practices, content, security or terms. You should review the privacy policies and terms of the relevant third parties before interacting with those services.
16. CHILDREN’S PRIVACY
16.1 The Platform is not directed at children. We do not intend to knowingly collect Personal Data from children below the age threshold recognized under applicable Indian law for valid consent, including under the DPDP Act as amended or applicable.
16.2 If you believe a child has provided Personal Data to us without appropriate consent, you may contact us at contact@altrupact.com. We may take steps we consider appropriate, including deletion or restriction of such data, subject to applicable law and verification.
17. DATA MINIMISATION AND ACCURACY
17.1 We generally seek to collect Personal Data that is relevant for the purposes described in this Privacy Policy. However, the categories and scope of data collected may vary depending on how you interact with the Platform and Services, the features we offer from time to time and the information you choose to provide.
17.2 You are responsible for ensuring that information you provide is accurate and up to date to the extent relevant. Where you provide information about third parties, you represent that you have authority and a lawful basis to share such information.
18. CHANGES TO THIS PRIVACY POLICY
18.1 We may update this Privacy Policy from time to time at our sole discretion. Changes will be effective upon posting the updated Privacy Policy on the Platform and updating the “Last Updated” date.
18.2 Where we consider changes to be material, we may, as appropriate, provide additional notice, such as via a notice on the Platform or via email for subscribers, subject to feasibility and applicable law. Your continued use of the Platform after the update constitutes acceptance of the updated Privacy Policy to the extent permitted by law.
19. CONTACT AND GRIEVANCE REDRESSAL
19.1 For general queries regarding this Privacy Policy or our privacy practices, you may contact:
Email: contact@altrupact.com
19.2 If the Company appoints a Data Protection Officer or similar role as required or appropriate, you may contact:
Email: grievance@altrupact.com
19.3 In accordance with applicable Indian law, you may submit grievances to:
Grievance Officer Email: grievance@altrupact.com
19.4 We may acknowledge and respond to grievances within timelines prescribed under applicable law, where applicable. We reserve the right to seek clarifications, request verification and determine appropriate resolutions at our discretion, subject to law.
1. SCOPE AND APPLICABILITY
1.1 This Privacy Policy applies to Personal Data processed by the Company in relation to:
(a) your access to and use of (altrupact.com) and related features, pages and integrations (the “Platform”), and
(b) services, features and activities offered through or in connection with the Platform, including editorial engagement, publication workflows, submissions intake, newsletters, events, programs, open calls and related distribution (the “Services”).
1.2 This Privacy Policy applies to Users and Participants. Capitalized terms not defined in this Privacy Policy shall have the meanings assigned to them in the Terms of Use. For convenience, certain key terms are restated in Section 2 below. In case of any inconsistency between this Privacy Policy and the Terms of Use, the Terms of Use shall prevail to the extent permitted by applicable law.
1.3 This Privacy Policy does not apply to Third-Party Services (including Google Forms, Substack and social media platforms) except to the extent we process Personal Data received from them or shared with them in accordance with this Privacy Policy. Third parties may collect and process data independently under their own policies and terms.
2. DEFINITIONS
2.1 “Company”, “Platform”, “Services”, “Content”, “User”, “Participant”, “Submission”, “Partner Content” and “Third-Party Services” shall have the meanings set out in the Terms of Use.
2.2 “Personal Data” means any data about an individual who is identifiable by or in relation to such data, and includes “personal data” as defined under the Digital Personal Data Protection Act, 2023 (and rules or subordinate legislation thereunder, as amended or applicable) (“DPDP Act”). For avoidance of doubt, Personal Data may include information that directly identifies you (such as name and email address) and information that indirectly identifies you (such as device identifiers and online identifiers), as applicable.
2.3 “Processing” means any operation or set of operations performed on Personal Data, whether automated or otherwise, such as collection, recording, organization, storage, use, disclosure, sharing, transfer, erasure or destruction.
2.4 “Consent Manager” / “Cookie Banner” means the cookie consent and preference management interface presented on the Platform, including any link such as Cookie Settings.
3. APPLICABLE LAW AND INTERPRETATION
3.1 We intend to process Personal Data in accordance with applicable Indian law, including the DPDP Act, as amended or as applicable, and other applicable laws, rules and regulations. Certain obligations and user rights may evolve based on statutory rules, regulatory guidance and implementation timelines. Accordingly, we reserve the right to interpret and apply this Privacy Policy in a manner consistent with applicable law as in force from time to time.
3.2 Where we refer to legal bases or lawful grounds for processing, such references are intended to describe our approach under applicable Indian law and do not create any additional commitments beyond those required by law.
4. INFORMATION WE COLLECT
We may collect and process the following categories of Personal Data, as applicable to your interactions with the Platform and Services:
4.1 Name, email address, phone number, messaging handle (including WhatsApp), postal address (if provided), social media handles, profile links and similar contact identifiers.
4.2 Job title, company or organization name, industry, location, biography, professional history, education, portfolio links, fundraising or program participation information and related professional details that you provide.
4.3 Information and materials contained in a Submission, including responses to editorial questionnaires, narratives, quotes, images, logos, brand assets, documents, links and other materials submitted through Google Forms or other channels.
4.4 Emails, messages, call records (for example, time and duration), scheduling details, notes, correspondence history and other information you provide when you communicate with us or when we communicate with you for editorial consideration and related purposes.
4.5 Subscription status, preferences, engagement signals (for example, opens, clicks where available), opt-in and opt-out records and marketing communication preferences.
4.6 Pages viewed, interaction events, referrer URLs, timestamps, approximate location inferred from IP address, browsing activity on the Platform, error logs and performance data.
4.7 Device type, browser type, operating system, language, IP address, device identifiers and similar technical signals.
4.8 Cookie identifiers, pixel tags, SDK signals, local storage and similar tracking technologies that collect information about your device and your interaction with the Platform.
4.9 Where you engage with partner-related open calls, programs or events, we may collect limited information relevant to facilitating such engagement or measuring reach, subject to this Privacy Policy and applicable terms.
4.10 We may derive limited inferences from the above data to understand audience interests, improve Content relevance, measure effectiveness and support advertising and retargeting, subject to your cookie choices and applicable law.
4.11 We do not intend to request or require sensitive personal data in ordinary course for the Platform’s functioning. If you voluntarily provide sensitive data in a Submission or communication, you acknowledge that such disclosure is at your discretion and we may process it as necessary for the purposes for which it was provided, subject to applicable law and appropriate safeguards as practicable.
5. SOURCES OF PERSONAL DATA
5.1 When you browse the Platform, submit a form, email us, message us, subscribe to newsletters, apply for participation, provide a Submission or otherwise communicate with us.
5.2 Through cookies, pixels, tags, log files and similar technologies when you use the Platform, to the extent enabled.
5.3 We may receive information from third parties where you interact with our presence or content on such services (for example, Substack subscription data, social media engagement signals, embedded form submissions), subject to the third party’s settings, your choices and their policies.
5.4 We may collect limited professional information from publicly available sources (for example, websites, professional profiles, press pages) to identify and contact potential Participants or to contextualize editorial consideration, subject to applicable law.
6. PURPOSES OF PROCESSING
We may process Personal Data for the following purposes, as applicable:
6.1 To make the Platform available, deliver Content, administer features, manage forms, respond to requests and provide functionality.
6.2 To evaluate Submissions, shortlist Participants, conduct outreach, schedule conversations, request clarifications, draft and edit content, manage confirmations where we may seek them and prepare Content for distribution through the Platform, newsletters and social media.
6.3 To communicate with you regarding editorial engagement, queries, responses, clarifications, scheduling and operational messages.
6.4 To manage newsletter subscriptions and distribution through Substack or other tools, including sending newsletters, handling unsubscribes, maintaining suppression lists and measuring engagement metrics.
6.5 To understand how the Platform is used, evaluate performance, debug issues, develop new features and improve Content, Services and user experience.
6.6 To deliver and measure advertising, including interest-based advertising and retargeting, to the extent enabled and subject to applicable law.
6.7 To protect the Platform, detect misuse, prevent fraud, enforce policies and maintain integrity of our systems.
6.8 To comply with legal requirements, respond to lawful requests, exercise or defend legal claims and maintain records as required.
6.9 For internal administration, audits, reporting, financial and operational planning and corporate governance.
6.10 To evaluate, facilitate or implement a merger, acquisition, financing, reorganization, sale of assets or similar transaction, subject to applicable law and appropriate protections.
7. LAWFUL GROUNDS FOR PROCESSING
7.1 We process Personal Data based on one or more lawful grounds recognized under applicable Indian law, which may include:
(a) Where you provide consent through an affirmative act, including through forms, cookie banner choices, newsletter subscriptions or other opt-ins, subject to withdrawal rights and applicable law.
(b) Where permitted, we may process Personal Data for purposes such as operational communications, security, preventing fraud, maintaining records, responding to your requests and certain editorial outreach activities, as applicable and subject to law.
(c) Where processing is necessary to perform obligations under the Terms of Use or to take steps at your request prior to providing specific Services.
(d) Where processing is necessary to comply with legal obligations, court orders, governmental requests or to exercise or defend legal claims.
7.2 Where consent is the relevant ground, you may withdraw consent, subject to legal and operational limitations, and certain processing may continue where permitted or required by law.
8. COOKIES, ANALYTICS AND ADVERTISING
8.1 We may use cookies, pixels, tags, SDKs and similar technologies to operate the Platform, remember preferences, conduct analytics, provide security and support advertising and retargeting, to the extent enabled and subject to applicable law.
8.2 We may use, as applicable:
(a) Strictly necessary cookies required for core operations and security,
(b) Functional cookies to remember preferences and improve experience,
(c) Analytics/performance cookies to understand usage and measure performance, and
(d) Advertising/targeting cookies to support interest-based advertising, attribution and retargeting.
8.3 We intend to implement a Cookie Banner / Consent Manager on the Platform. Where available, you may use the banner and Cookie Settings to manage preferences for certain categories of cookies and similar technologies. You acknowledge that, due to technical limitations, configuration differences across devices and browsers and the evolving nature of third-party tracking technologies, the banner and settings interface may not identify or control every cookie, pixel, tag or similar technology in all circumstances.
8.4 You may withdraw or modify cookie preferences at any time using the Cookie Banner controls and Cookie Settings, where available. However, your browser and device settings are typically the most effective method to block, delete or limit cookies and similar storage technologies because they operate at the browser or device level. You may therefore use browser settings to refuse or remove cookies, clear stored data and disable certain tracking technologies. If you delete cookies or reset your browser, you may need to re-apply your preferences and certain Platform features may be affected. Certain Third-Party Services and advertising partners may provide separate opt-out mechanisms (for example, platform account settings or device advertising controls). Where such controls exist, you may choose to use them in addition to browser settings and our Cookie Banner.
8.5 We may use analytics providers to understand traffic and usage patterns, including by collecting device and usage information. These providers may set cookies or collect identifiers.
8.6 We may work with advertising partners and social media platforms to show ads, measure ad performance and enable retargeting. Such partners may use cookies, pixels and similar tools to collect or receive information from the Platform and elsewhere, subject to their terms and your settings. Where applicable, you may opt out through:
(a) the Cookie Banner or Cookie Settings,
(b) browser and device-level ad preference controls, and
(c) industry opt-out tools made available by advertising networks, where applicable.
Your choices may not eliminate all advertising and may result in less relevant advertising.
8.7 Some browsers transmit “Do Not Track” signals. As standards vary, the Platform may not respond uniformly to such signals, and you should use the Cookie Banner and browser settings for controls.
9. HOW WE SHARE PERSONAL DATA
9.1 We do not sell Personal Data. For clarity, “sell” means disclosing or transferring Personal Data to a third party for monetary consideration. This does not restrict our ability to share Personal Data with service providers, partners, affiliates or other recipients for legitimate business purposes as described below, including where we receive commercial value other than monetary consideration (for example, analytics services), subject to applicable law and your choices.
9.2 We may share Personal Data with the following categories of recipients, as applicable:
(a) Hosting providers, content delivery networks, email and communications providers, analytics providers, customer support tools, security vendors, form tools, scheduling tools and other vendors that process Personal Data on our instructions.
(b) We may use Substack for newsletter distribution at (altrupact.substack.com). Depending on the configuration, Substack may act as a processor or as an independent controller for certain data it collects. Your interactions with Substack are subject to Substack’s terms and privacy practices, and you should review them directly.
(c) Where we use Google Forms or similar tools for Submissions, Google may process data as a service provider under its terms and policies. Your interactions may be governed by Google’s terms and privacy practices, and you should review them.
(d) Ad networks, social media platforms, tag managers and measurement partners, subject to cookie consent settings and applicable law.
(e) Where necessary to facilitate a specific open call, program, initiative or event you engage with, we may share limited information with partners, typically on a need-to-know basis and subject to applicable terms. We may also share aggregated or de-identified analytics with partners where feasible.
(f) Law enforcement, regulators, courts or authorized third parties where we believe disclosure is necessary to comply with law, respond to lawful requests, enforce our terms, protect rights, safety and security, investigate fraud or address technical issues.
(g) Prospective buyers, investors, lenders, advisors and other participants in a corporate transaction, subject to confidentiality obligations and applicable law.
(h) Our group entities, affiliates and personnel on a need-to-know basis for operational purposes, subject to appropriate safeguards.
9.3 We may share aggregated, anonymized or de-identified information that cannot reasonably be used to identify an individual, subject to applicable law.
10. CROSS-BORDER TRANSFERS
10.1 We may process and store Personal Data in India and, as applicable, in other countries where our service providers, partners or infrastructure providers are located. This may result in cross-border transfers of Personal Data.
10.2 Where cross-border transfers occur, we may implement safeguards that we consider appropriate, such as contractual arrangements, access controls and security measures, subject to applicable law, including any restrictions that may be notified by the Government of India from time to time.
10.3 By using the Platform or providing Personal Data, you acknowledge that such transfers may occur as described in this Privacy Policy, subject to your rights and applicable law.
11. DATA RETENTION
11.1 We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, or unless retention is necessary for legal claims, audits, dispute resolution, security or enforcement.
11.2 Retention periods may vary based on factors such as: the nature and sensitivity of the data, the purpose of processing, the duration of editorial engagement, ongoing relationship (including newsletter subscription), legal obligations and operational needs.
11.3 We may retain Submissions and related communications for editorial records, future editorial consideration, compliance, audits and defense of claims, subject to applicable law. We do not undertake to delete all copies immediately upon request where retention is legally required or reasonably necessary.
11.4 Newsletter subscription data may be retained for as long as you remain subscribed and thereafter for a reasonable period to maintain suppression lists, recordkeeping and compliance.
11.5 Technical logs and analytics data may be retained for varying periods depending on operational needs, security requirements and vendor configurations.
12. SECURITY MEASURES
12.1 We implement reasonable technical and organizational safeguards intended to protect Personal Data against unauthorized access, disclosure, alteration, loss or destruction. Such safeguards may include access controls, encryption in transit where supported, administrative controls, vendor due diligence, logging and monitoring, backups and security practices appropriate to the nature of data and context.
12.2 Notwithstanding the above, no system can be guaranteed to be completely secure. You acknowledge that transmission over the internet and electronic storage involve inherent risks. To the maximum extent permitted by law, we disclaim liability for unauthorized access or breaches beyond our reasonable control.
13. YOUR RIGHTS AND CHOICES
13.1 Subject to applicable law (including the DPDP Act as amended or applicable), you may have certain rights in relation to your Personal Data, which may include the right to:
(a) access information about your Personal Data processed by us,
(b) request correction or updating of inaccurate or incomplete Personal Data,
(c) request erasure of Personal Data, where applicable,
(d) withdraw consent where processing is based on consent,
(e) opt out of marketing communications, and
(f) seek grievance redressal.
13.2 You may submit requests by contacting us at contact@altrupact.com. We may request information to verify your identity and to understand the scope of your request. We reserve the right to refuse or limit requests where permitted by law, including where requests are manifestly unfounded, excessive, impracticable or where retention is required by law.
13.3 Where processing is based on consent, you may withdraw consent, subject to legal and operational constraints. Withdrawal may affect our ability to provide certain Services, including editorial engagement and newsletters.
13.4 You may manage cookies through the Cookie Banner, Cookie Settings and browser settings as described in Section 8.
13.5 You may unsubscribe through links provided in emails or via Substack controls, subject to processing time and platform limitations. We may retain limited information to honor opt-out requests and maintain suppression lists.
14. COMMUNICATIONS
14.1 We may contact Participants and Users for editorial consideration and operational purposes through email, phone calls, WhatsApp or other messaging platforms, as applicable and subject to law and your preferences where required.
14.2 Where applicable, we may send promotional communications, including newsletters and announcements, subject to consent and opt-out mechanisms. Even if you opt out of promotional communications, we may still send non-promotional messages where reasonably necessary for operational, legal or security purposes.
14.3 Calls and messages may be initiated by our team or authorized representatives. We may maintain logs of communications for recordkeeping, quality, compliance and dispute management, subject to applicable law.
15. THIRD-PARTY LINKS AND EMBEDDED CONTENT
15.1 The Platform may include Third-Party Services such as embedded videos, social media widgets, forms and links. These third parties may collect information about you, including through cookies or other tracking technologies, independently of us.
15.2 We do not control third-party data practices and are not responsible for their privacy practices, content, security or terms. You should review the privacy policies and terms of the relevant third parties before interacting with those services.
16. CHILDREN’S PRIVACY
16.1 The Platform is not directed at children. We do not intend to knowingly collect Personal Data from children below the age threshold recognized under applicable Indian law for valid consent, including under the DPDP Act as amended or applicable.
16.2 If you believe a child has provided Personal Data to us without appropriate consent, you may contact us at contact@altrupact.com. We may take steps we consider appropriate, including deletion or restriction of such data, subject to applicable law and verification.
17. DATA MINIMISATION AND ACCURACY
17.1 We generally seek to collect Personal Data that is relevant for the purposes described in this Privacy Policy. However, the categories and scope of data collected may vary depending on how you interact with the Platform and Services, the features we offer from time to time and the information you choose to provide.
17.2 You are responsible for ensuring that information you provide is accurate and up to date to the extent relevant. Where you provide information about third parties, you represent that you have authority and a lawful basis to share such information.
18. CHANGES TO THIS PRIVACY POLICY
18.1 We may update this Privacy Policy from time to time at our sole discretion. Changes will be effective upon posting the updated Privacy Policy on the Platform and updating the “Last Updated” date.
18.2 Where we consider changes to be material, we may, as appropriate, provide additional notice, such as via a notice on the Platform or via email for subscribers, subject to feasibility and applicable law. Your continued use of the Platform after the update constitutes acceptance of the updated Privacy Policy to the extent permitted by law.
19. CONTACT AND GRIEVANCE REDRESSAL
19.1 For general queries regarding this Privacy Policy or our privacy practices, you may contact:
Email: contact@altrupact.com
19.2 If the Company appoints a Data Protection Officer or similar role as required or appropriate, you may contact:
Email: grievance@altrupact.com
19.3 In accordance with applicable Indian law, you may submit grievances to:
Grievance Officer Email: grievance@altrupact.com
19.4 We may acknowledge and respond to grievances within timelines prescribed under applicable law, where applicable. We reserve the right to seek clarifications, request verification and determine appropriate resolutions at our discretion, subject to law.