Privacy Policy

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Siliguri Circle Privacy Policy

Last Updated: May 1, 2025

1. INTRODUCTION AND OVERVIEW

Welcome to Siliguri Circle (“Company,” “we,” “our,” or “us”). We operate the website located at https://siliguricircle.com (the “Website” or “Service”). We are committed to protecting your personal data and respecting your privacy rights.

This Privacy Policy is a comprehensive legal document designed to explain in detail what information we collect, how we use it, under what circumstances we disclose it, and the rigorous safeguards we implement to keep it secure. It also outlines your explicit legal rights regarding your personal data under various global data protection jurisdictions, including the Indian Digital Personal Data Protection Act (DPDPA), the European Union’s General Data Protection Regulation (GDPR), and United States state privacy laws such as the California Consumer Privacy Act (CCPA/CPRA).

By accessing, browsing, or interacting with siliguricircle.com, you explicitly acknowledge that you have read, understood, and agreed to the terms outlined in this Privacy Policy. If you do not agree with any terms within this document, you must immediately cease all use of our Website and Services.

2. THE DATA CONTROLLER AND CONTACT INFORMATION

For the purposes of applicable data protection laws, the entity responsible for the collection and processing of your personal data is:

Website Name: Siliguri Circle
Operating URL: https://siliguricircle.com
Corporate: Siliguri Circle (Sole Proprietorship)
Physical Mailing Address: Siliguri Circle HQ, 734001, West Bengal, India
Designated Data Protection Officer (DPO) / Grievance Officer: Mr. E Datta
Official Privacy Email Contact: hello@siliguricircle.com

If you have any questions, concerns, or complaints regarding this policy or our data handling practices, or if you wish to exercise any of your statutory rights, please reach out to our Grievance Officer/DPO via the email address listed above. We will respond to all valid legal inquiries within the statutory timelines required by your local jurisdiction (e.g., within 30 days under GDPR/DPDPA).

3. FULL CATEGORIES OF DATA WE COLLECT

We collect various types of information from and about users of our Website. This information falls into two broad categories: Personally Identifiable Information (PII) which can be used to identify you, and Non-Personally Identifiable Information (Non-PII) which consists of anonymized or aggregated data.

A. Information You Voluntarily Provide to Us

  • Identity and Contact Data: This includes your first name, last name, username, email address, phone number, and social media handles. We collect this when you register an account, subscribe to newsletters, submit a contact form, or comment on articles.
  • Profile Data: Your username, password (which is heavily encrypted and unreadable by us), profile pictures, interests, preferences, feedback, and survey responses.
  • User-Generated Content (UGC): Any text, images, or audio-visual media you upload, post, or publish on the website via forums, comment fields, community boards, or review sections.
  • Marketing and Communications Data: Your explicit preferences regarding receiving marketing materials from us, our affiliates, or third-party advertising networks, alongside your communication preferences.

B. Information Automatically Collected via Technology

When you navigate siliguricircle.com, our servers and third-party tracking tools automatically log data regarding your device and your interactions with our platform.

  • Technical and Device Data: Your Internet Protocol (IP) address, login data, browser type and version, time zone setting, location data (generalized down to country, region, or city level), browser plug-in types and versions, operating system, and hardware model.
  • Usage and Behavioral Data: Detailed analytics regarding how you navigate our platform, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Website; page response times, download errors, duration of visits to specific pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

C. Sensitive Personal Data Notice

We do not intentionally collect or process any Sensitive Personal Data (such as biometric data, health records, sexual orientation, religious or philosophical beliefs, political opinions, or criminal history) as defined under the GDPR or DPDPA. Please do not submit any sensitive personal data in comment sections, forums, or contact forms. If we discover we have inadvertently collected such data, it will be deleted immediately.

4. SOURCES OF DATA COLLECTION

We utilize multiple distinct methodologies to gather the information described in the section above:

Data Collection Sources
Direct Input Forms, comments, and registrations
Automated Tools Cookies, server logs, analytics
Third Parties Ad networks, social platforms

7. DATA SHARING, DISCLOSURE, AND THIRD-PARTY RECEIVERS

We do not sell, rent, lease, or trade your personally identifiable data to third parties for financial gain. However, we do share specific datasets with trusted external service providers to help run our business, stay legally compliant, and serve ads.

A. Operational Service Providers (Processors)

We utilize third-party vendors to assist with our core technical operations. These entities are strictly contractually bound to process your data only under our explicit direction and are entirely barred from using it for any independent purpose:

  • Cloud Hosting Infrastructure: E.g., Hostinger, Bluehost, AWS, or DigitalOcean, to store website assets and databases securely.
  • Email Delivery Systems: E.g., Mailchimp, SendGrid, or Brevo, to distribute newsletters and service notifications.
  • Security & CDNs: E.g., Cloudflare, to block malicious web traffic, prevent scraping, and optimize page load speeds globally.
  • Content Moderation: Third-party automated spam filters (such as Akismet) to scan and reject comment section spam.

B. Advertising and Analytics Platforms

We stream pseudonymized tracking data (such as cookie IDs and IP addresses) to:

  • Google AdSense & Ad Exchange: To display contextual and behavioral ads.
  • Google Analytics: To evaluate aggregated traffic metrics.

C. Statutory and Legal Disclosures

We will disclose your personal data if required to do so by applicable law, or in the good faith belief that such action is necessary to:

  • Comply with a legal obligation or a valid governmental order (e.g., from an Indian court, law enforcement agency, or statutory body).
  • Protect and defend the rights, property, or safety of Siliguri Circle, its owners, users, or the general public.
  • Prevent or investigate potential fraud, cybersecurity incidents, or terms of service violations.

8. IN CASE OF ANY OF OUR COMPANY SILIGURI CIRCLE AND ANY OF THE RELATED COMPANY WITH SILIGURI CIRCLE DATA OR SERVER HACKED OR THEFT

Siliguri Circle as a company/sole-prop. or any of it's Admins and Super Admins are not responsible in any case(s) of data hack or theft and server hack or theft, and are not bound to any legal, personal, professional or other consequences, explainations and proceedings or responsible at all.

9. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Siliguri Circle is operated out of India. Our servers and data repositories may be located outside of your native country or jurisdiction (for instance, within cloud datacenters located in the United States, Singapore, or the European Union).

By utilizing our Website, you explicitly understand and consent to the transfer of your information to servers located outside your home country. We ensure that all international data transfers comply with appropriate legal safeguards. If you are a resident of the European Economic Area (EEA) or the United Kingdom, we safeguard your data transfers using the European Commission’s Standard Contractual Clauses (SCCs) alongside strict technical encryption protocols.

10. COMPREHENSIVE DATA RETENTION PROTOCOLS

We will retain your personal data only for as long as is strictly necessary to fulfill the specific purposes outlined in this Privacy Policy, unless a longer retention window is mandated or permitted by statutory law (such as tax laws, corporate accounting mandates, or litigation holds).

Our precise data retention thresholds are as follows:

  • User Account Profile Data: Retained for the active lifespan of your registered account. If an account remains completely dormant for a continuous period of 24 months, it will be queued for automated deletion or permanent anonymization.
  • Public Comments and Forum Content: Retained indefinitely to maintain the logical continuity of discussion threads, unless you formally request its deletion.
  • Contact Form Submissions and Support Emails: Retained for a maximum period of 12 months following the complete resolution of your query, allowing us to reference past context if you follow up.
  • Server Logs & Technical Data: Retained for 90 days to detect cybersecurity threats and audit system performance, after which it is automatically overwritten or purged.

11. INFORMATION SECURITY PROTOCOLS

We prioritize the security of your data. We implement standard physical, administrative, and technical security measures designed to protect your personal data from accidental loss, unauthorized access, alteration, or disclosure:

  • Transport Layer Security (TLS/SSL): All data transmissions to and from siliguricircle.com are forced over an encrypted HTTPS connection.
  • Password Hashing: User passwords are encrypted using state-of-the-art cryptographic hashing protocols (e.g., bcrypt or Argon2) rendering them completely unreadable to anyone, including our own database administrators.
  • Access Minimization: Internal access to user personal data is restricted exclusively to authorized personnel who require that data to perform their job duties.
  • Vulnerability Mitigation: We run regular software updates, security patches, and malware scans to protect against potential digital exploits.

Disclaimer: While we employ professional-grade tools to safeguard your data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

12. YOUR REGULATORY PRIVACY RIGHTS BY JURISDICTION

A. Your Rights Under the Indian Digital Personal Data Protection Act (DPDPA)

As a web platform operating out of India, we comply with the DPDPA. As a Data Principal, you have the following rights:

  • Right to Summary of Personal Data: You have the right to request a summary of the personal data being processed by us and the processing activities undertaken.
  • Right to Correction and Erasure: You have the right to correct inaccurate data, complete incomplete records, or request the erasure of personal data that is no longer necessary for the purpose it was collected.
  • Right of Grievance Redressal: You have the right to register a complaint with our designated Grievance Officer regarding any perceived non-compliance. If you are unsatisfied with our response, you may escalate your complaint to the Data Protection Board of India (DPBI).
  • Right to Nominate: You have the right to nominate any other individual to exercise your rights in the event of your death or incapacity.

B. Your Rights Under the European Union GDPR & UK Data Protection Act

If you are located inside the European Economic Area (EEA) or the United Kingdom, you possess the following rights:

  • Right to Access (Article 15 GDPR): Request copies of your personal datasets.
  • Right to Rectification (Article 16 GDPR): Demand immediate correction of incorrect or outdated data.
  • Right to Erasure / "Right to be Forgotten" (Article 17 GDPR): Request permanent deletion of your data from our active systems.
  • Right to Restrict Processing (Article 18 GDPR): Freeze the processing of your data while keeping it stored under specific conditions.
  • Right to Data Portability (Article 20 GDPR): Request that we package your data into a structured, machine-readable format to move to another provider.
  • Right to Object (Article 21 GDPR): Object to our processing of your data for reasons based on our legitimate interests or direct marketing.
  • Right to Lodge a Complaint: You have the right to bring a claim before a recognized European Data Protection Supervisory Authority in your country of residence.

C. Your Rights Under United States State Privacy Laws (CCPA/CPRA, etc.)

If you reside in California, Colorado, Virginia, or other US states with comprehensive privacy laws, you have specific rights:

  • Right to Know / Access: Request disclosure of the specific categories and pieces of personal data collected about you over the past 12 months.
  • Right to Deletion: Request deletion of personal data collected from you, subject to certain exceptions.
  • Right to Opt-Out of the Sale or Sharing of Personal Data: We do not sell your personal data for money. However, using third-party cross-contextual behavioral advertising cookies may qualify as "sharing" under California law. You can opt out of this by choosing to decline advertising cookies in our cookie consent banner.
  • Right to Non-Discrimination: We will never deny services, alter pricing, or provide a lower quality of service if you choose to exercise your legal privacy rights.

To exercise any of these global privacy rights, email us at [hello@siliguricircle.com] with the subject line "Privacy Rights Request" and specify your country/state of residence.

13. CHILDREN'S PRIVACY PROTECTION

Protecting the safety and privacy of young children online is a core priority for us. Siliguricircle.com is a general audience informational and community website; it is not structured for, directed toward, or intended for use by children under the age of 13 (or under the age of 18 as per Indian DPDPA minors' consent provisions).

We do not knowingly collect, harvest, or solicit any Personally Identifiable Information from minors. If you are a parent or legal guardian and discover that your child has submitted personal information to our website without your authorization, please contact us at [hello@siliguricircle.com] immediately. We will take swift, priority measures to scrub all such records from our databases and servers.

15. POLICIES REGARDING SYSTEMIC CHANGES AND UPDATES

We reserves the absolute right to modify, amend, rewrite, or update this Privacy Policy at any time to reflect updates to our data handling practices, technological infrastructure changes, or shifting legal and regulatory frameworks globally.

When structural changes are enacted, we will update the "Last Updated" timestamp located at the very top of this document. If the modifications are material (such as changing how we use your information or adding new tracking systems), we will provide a more prominent alert. This may include displaying a clear notification banner on our homepage or emailing registered users directly.

We highly encourage you to review this Privacy Policy periodically to stay informed about how we safeguard the information we collect. Your continued use of siliguricircle.com after any updates go into effect constitutes your formal acceptance of the revised policy.

16. CONTACT MECHANISMS FOR LEGAL AND PRIVACY INQUIRIES

If you have any questions, comments, or technical feedback concerning this Privacy Policy, or if you need to submit a data erasure or access request, please contact us using one of the methods below:

Official Privacy/DPO Email Contact: hello@siliguricircle.com

Online Contact Portal: https://siliguricircle.com/Contact-Us

Physical Mail Enquiries:

Attn: Privacy Compliance / Grievance Officer
Siliguri Circle
Siliguri Circle HQ
Siliguri, 734001, West Bengal
India