1. Who we are

[LEGAL ENTITY NAME], doing business as the NIT Raipur USA Alumni Association ("the

Association", "we", "us"), operates nitrusa.org. We are the party responsible for the

personal information described here.

Contact for privacy questions: [PRIVACY CONTACT EMAIL]

Postal: [MAILING ADDRESS]

This policy explains what we collect, why, who sees it, and what you can do about it. It

applies to the website and to the email we send you. It does not apply to sites we link to.

2. What we collect

You give us:

Information	When
Name, email address	Registration
Graduation year, branch/discipline	Registration and profile
Password (stored only as a cryptographic hash — we never see it)	Registration
Profile details you choose to add: photograph, city and state, employer, job title, phone number, postal address, social or professional links, biography, chapter	Your profile, at your option
Evidence you send to support a membership application	If your registration needs manual approval
Photographs, video links, blog posts, comments, and the descriptions attached to them	When you contribute them
Event responses [if RSVP is built — EVT-6 is open]	When you respond
Payment information [if payments are built — MEM-7 is open]	At checkout, by our payment processor, not by us
Messages you send us	When you write to us

We generate or observe:

• Account records: when you registered, when you were approved and by whom, when you last

signed in, your email verification status, your membership and dues status, and the privacy

choices you have made.

• An audit log of administrative actions taken on your account — approvals, role changes,

directory exports — recorded so the Association can account for its own decisions.

• Server logs: IP address, browser type, pages requested, timestamps. These are ordinary web

server records, kept for security and troubleshooting.

• A session cookie when you sign in, and a small number of functional cookies (§6).

We may receive from others:

• The Association's existing alumni roster, provided by the Association or by the

institute's alumni body, which may already contain your name, graduation year and branch.

This is how a registration can be approved automatically when your details match.

• `[CONFIRM whether any roster data comes from the institute or the India association, and on

what basis. If it does, this section must say so plainly, and §13 (your rights) must work for

someone who never registered at all.]`

What we deliberately do not collect: we do not ask for government identification numbers,

financial account details, health information, or any special-category data. Please do not put

such information into a free-text profile field.

3. Why we use it, and on what basis

Purpose	Information used
Create and administer your account; verify eligibility	Name, email, year, branch, evidence
Run the member directory so alumni can find each other	The profile fields you have chosen to show
Publish what you contribute — blogs, photos, videos	Your Content and your name as author
Send transactional email (verification, password reset, approval, receipts)	Email address
Send the newsletter, announcements and event notices, if you have not opted out	Email address, preferences
Collect dues and donations [if built]	Payment records
Keep the Site secure; investigate abuse; keep the audit record	Logs, account records
Comply with law, and with the Association's own governance obligations	As required

We do not use your information for advertising, and we do not sell it. We do not profile

members, and there is no automated decision-making that produces legal effects — a registration

that is not matched to the roster is approved by a person.

4. Who can see what

This is the part that matters most in a community portal, so it is set out explicitly.

Public — anyone on the internet:

• Content published publicly by the Association: announcements, news, events, newsletters.
• Blog posts, and the author's name on them.
• Nothing from the member directory. Nothing from a member profile. The members' area is not

indexed by search engines and is not reachable by guessing a URL.

Other approved members:

• Your name, graduation year, branch, chapter, profile photograph, and any office you hold.
• Only those further fields you have chosen to make visible. Contact details, postal

address and employer are hidden by default and stay hidden until you turn them on. Your

choice is applied everywhere the same way — in the directory, in search, on your profile, and

in any export.

Association administrators:

• Everything above, plus your email address, membership and dues status, and any evidence you

submitted. Administrators can export the directory in bulk; **every export is recorded in the

audit log**, and the ability is restricted to administrators.

**We do not disclose your information to other alumni associations, to the institute, or to any

third party for their own purposes**, except as described in §5.

5. Service providers, and other disclosure

We share personal information with a small number of providers who process it on our

instructions and for no purpose of their own:

Provider	What it handles	Where
Google Cloud Platform	Hosting, database, backups, encryption keys	United States (us-central1)
Amazon Web Services (SES)	Sending our email; bounce and complaint handling	United States (us-east-2)
MailPoet	Newsletter list management and sending	[CONFIRM — sub-processors and location]
[Payment processor]	Dues and donations, if built	[ ]

We may also disclose information:

• when the law requires it — a subpoena, court order, or lawful request. Where we are

permitted to tell you, we will;

• to protect people — where disclosure is necessary to prevent serious harm, or to

investigate a serious breach of the Terms of Service;

• to professional advisers — auditors, insurers, lawyers — under a duty of confidence; and
• to a successor if the Association merges with or transfers its activities to another

body, in which case we will tell you first and this policy continues to apply until it is

replaced.

**We do not sell personal information, and we do not share it for cross-context behavioural

advertising** — as those terms are defined under California law. We have never done so.

6. Cookies and tracking

We use:

• a session cookie so you stay signed in;
• functional cookies remembering small preferences, such as whether you last viewed a list

as a grid; and

• security cookies used by WordPress to protect forms against cross-site request forgery.

We do not use advertising cookies, and the site currently runs no third-party analytics. If

that changes, this policy will be updated before the change goes live, and you will be asked for

consent where consent is required.

`[IF ANY EU/UK MEMBERS: a cookie banner is required for anything beyond strictly necessary

cookies. The functional cookies above are arguably strictly necessary; analytics would not be.]`

7. Email

• Transactional email — verification, password resets, approval decisions, receipts — is

part of running your account and continues while your account is open.

• Optional email — newsletters, announcements, event notices — carries an unsubscribe link

in every message, and you can change your choices in your settings at any time. Unsubscribes

take effect immediately.

• We honour bounces and complaints: an address that hard-bounces is suppressed and not retried,

and a spam complaint is treated as an immediate and permanent opt-out from all optional

email.

• We authenticate our mail (SPF, DKIM and DMARC) so that messages claiming to be from us can be

checked.

8. How we protect your information

We take this seriously, and the specifics are these:

• Encryption in transit. HTTPS across the site; encrypted connections between the site, its

database and its backups.

• Encryption at rest. Storage-level encryption with customer-managed keys on the disks,

database, uploads and backups.

• Field-level encryption of the sensitive parts of your profile — phone number, postal

address, family details, dues history, and any registration evidence — so that those fields

are unreadable even to someone holding a copy of the database.

• Your name and email address are deliberately not field-encrypted, because sign-in

authenticates against your email and the directory needs to be searchable by name. We say

this plainly rather than implying more protection than exists.

• Access control on the server for every page, every interface, and every uploaded file.

Hiding a link is not treated as security.

• Private database. The database is not reachable from the public internet.
• Keys held separately from the data they protect, in a managed key service.
• No personal information in our application logs, in analytics, or in error reports.

No system is perfectly secure, and we do not claim otherwise. If a breach affects your personal

information we will notify you and the relevant authorities as the law requires, without undue

delay.

`[ADD, once decided: the Association's internal rules on who holds administrator accounts,

whether multi-factor authentication is mandatory for them, and how access is removed when an

officer's term ends. A policy is only as good as that.]`

9. How long we keep it

Record	Kept
Your account and profile	While your membership is active, and [PERIOD] after it ends
Content you published (blogs, photos, videos)	[Until you delete it / indefinitely as part of the Association's archive — DECIDE]
The Association's alumni roster	Indefinitely, as the Association's own historical record
Audit log of administrative actions	[PERIOD] — it exists to be a record, so it outlives the account it describes
Server logs	[30–90 days]
Financial records for dues and donations	As long as tax and accounting law requires, typically [7] years
Email suppression list (bounces, complaints)	Indefinitely — it is what stops us emailing you again

When we no longer need information we delete it or de-identify it so it can no longer be

connected to you.

10. Your choices

Whoever and wherever you are, you can:

• see and correct your profile at any time;
• control who sees what, field by field;
• opt out of optional email;
• ask us to delete your account; and
• ask us a question about any of this, at [PRIVACY CONTACT EMAIL].

11. If you live in California

Under the California Consumer Privacy Act as amended by the CPRA, you have the right to:

• know what personal information we have collected, the categories of source, the purpose,

and the categories of third party it has been disclosed to;

• access a copy of it;
• correct inaccurate information;
• delete it, subject to the exceptions the statute allows;
• opt out of sale or sharing — we do neither, so there is nothing to opt out of, and the

Site therefore carries no "Do Not Sell or Share" link;

• limit the use of sensitive personal information — we do not use any for purposes that

trigger this right; and

• not be discriminated against for exercising any of these rights. Nothing about your

membership changes because you asked.

How to exercise them: email [PRIVACY CONTACT EMAIL]. We will verify your identity —

usually by confirming control of the email address on your account — and respond within **45

days**, extendable once by a further 45 where necessary. An authorised agent may act for you

with written permission.

Categories collected in the last 12 months, in CCPA's own terms: identifiers; personal

information under Cal. Civ. Code §1798.80; internet activity; geolocation `[only to the extent

an IP address is treated as such]`; professional or employment information; education

information; and inferences [none — confirm].

`[CONFIRM APPLICABILITY: CCPA applies to a "business" meeting revenue or volume thresholds, and

non-profits are generally outside it. The Association may not be covered at all. My

recommendation is to honour these rights regardless — it is good practice, members expect it,

and it costs little — but the wording must not claim a statutory status that is wrong. Counsel

should settle whether this section is stated as obligation or as voluntary commitment.]`

12. If you live in the EU or the UK

[KEEP ONLY IF THE ASSOCIATION HAS MEMBERS THERE — alumni move abroad, so check before cutting.]

You have the rights of access, rectification, erasure, restriction, portability, and objection,

and the right to complain to your national data protection authority.

Our lawful bases are: contract (running your membership), legitimate interests

(operating the directory, securing the Site, keeping the Association's records), consent

(optional email, and any profile field you choose to make visible), and legal obligation.

Your information is stored in the United States. Transfers are made on the basis of

`[Standard Contractual Clauses with our providers / the EU–US Data Privacy Framework —

CONFIRM which applies to GCP and AWS for this deployment]`.

13. Other US states

Residents of `[Virginia, Colorado, Connecticut, Utah, Texas and other states with comprehensive

privacy laws]` have broadly similar rights of access, correction, deletion and portability, and

a right to appeal a refusal. Use the same contact address; we apply the same process to

everyone, whether or not a statute requires it in your state.

14. Children

The Site is for adults, and members must be at least 18. **We do not knowingly collect personal

information from anyone under 13**, and if we learn that we have, we delete it. If you believe a

child has given us information, write to [PRIVACY CONTACT EMAIL].

15. Changes to this policy

We will update this policy when what we do changes. If a change is material we will tell you by

email and by a notice on the Site before it takes effect. The date at the top says when it

last changed, and [we will keep previous versions available at LOCATION].

16. Contact

Questions, requests, or complaints:

[LEGAL ENTITY NAME]

[MAILING ADDRESS]

[PRIVACY CONTACT EMAIL]

If you are not satisfied with our response, you may complain to `[your state Attorney General /

your data protection authority]`.