Privacy Policy
Effective date: June 2026
Governing law: Information Technology Act 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, Digital Personal Data Protection Act 2023 (to the extent notified and in force)
Who this policy applies to
This policy applies to all visitors to esgbroadcast.com and esgbroadcast.in and to all subscribers to the ESG Broadcast newsletter. It is published by InCircularity Pro LLP (Ahmedabad, Gujarat, India; CIN ACF-6555) — the data fiduciary under the DPDP Act 2023.
What personal data we collect and why
Browser notifications. If you choose to enable browser notifications, we store the technical subscription token issued by your browser (endpoint URL and encryption keys). No name or email address is collected through this channel. You can revoke this at any time through your browser's notification settings, which will automatically deactivate the subscription on our side.
Newsletter subscribers. We collect email addresses and optionally first names from visitors who subscribe to the ESG Broadcast newsletter. Where you choose to subscribe using your Google account (via Google One Tap), your email address is passed to us by Google's identity service — we receive only your email address and do not receive any other Google account data. We collect subscriber email addresses solely for the purpose of sending the weekly ESG intelligence newsletter. We do not use subscriber data for any other purpose. We do not sell, share, or transfer subscriber data to any third party except as necessary to deliver the newsletter through our email service provider (currently Brevo, operated by Sendinblue SAS, France). Our email service provider processes subscriber data solely to deliver emails on our behalf and is contractually prohibited from using it for any other purpose.
ESG milestone submissions. When a company submits an ESG milestone claim through our Broadcast Your ESG form, we collect the submitter's name, work email address, and designation; the company name and stock listing details; the initiative or standard claimed; a description of the milestone; and the URLs provided for source verification. We collect this information solely for editorial verification and potential publication. We do not use submission contact details for marketing purposes. We respond to submissions only if we proceed to publication or require clarification. Submission data is retained in our editorial records for 24 months from the date of submission. Details of how verification is conducted are set out in our Technology & Editorial Transparency disclosure.
Anonymous analytics. We collect anonymous visit analytics on individual ESG profile pages hosted on affiliated platforms operated by our technology partner InCircularity Systems (GOVERNiC, BFSIdecarb, WhizzX). These consist of aggregated visit counts and referrer domain information only. No personally identifiable information about page visitors is collected, stored, or shared.
We do not collect cookies beyond what is strictly necessary for the website to function. We do not use third-party tracking cookies, advertising cookies, or cross-site tracking technologies. We do not use Google Analytics or any similar behavioural tracking service.
Legal basis for processing
We process ESG milestone submission data on the basis of legitimate interests — specifically, the submitting company's interest in having its verified ESG achievement considered for publication, and our interest as an editorial platform in verifying factual claims before publication. Submitters may request deletion of their submission data at any time by writing to [email protected], provided the submission has not already been used as the basis for a published article.
We process subscriber email addresses on the basis of consent. Subscribers provide their email address voluntarily and may withdraw consent at any time by clicking the unsubscribe link in any newsletter email or by writing to [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Data storage and residency
Subscriber personal data is stored in India on servers located in India. We do not transfer subscriber personal data outside India except where required to deliver emails through our email service provider's infrastructure. Where such transfer occurs, it is covered by appropriate contractual protections.
Data retention
We retain subscriber data for as long as the subscriber remains active. When a subscriber unsubscribes, we mark their record as inactive and retain the email address for 12 months for compliance and audit purposes, after which it is permanently deleted. Subscribers may request immediate deletion by writing to [email protected].
Your rights
Under applicable Indian law and to the extent the DPDP Act 2023 provisions are in force, you have the right to access the personal data we hold about you, to correct inaccurate data, to withdraw consent, and to have your data erased subject to legal retention requirements. To exercise any of these rights, write to [email protected] with the subject line "Data Request." We will respond within the timeframe required by applicable law.
Children
This website is not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately.
Changes to this policy
We may update this policy from time to time. The effective date at the top of this page reflects the date of the most recent update. We will notify subscribers of material changes by email.
Contact
InCircularity Pro LLP (CIN ACF-6555) Ahmedabad, Gujarat, India [email protected]