Legal
Privacy Policy
Bennett Coleman & Co. Ltd.
Privacy Policy
Bennett Coleman & Co. Ltd. ("BCCL", "we", "us", "our") is committed to protecting your privacy.
This Privacy Policy explains what personal data we collect from users, volunteers and participants of the #IamBengaluru - Volunteer for Parks initiative, how we use it, how we share and protect it, and the rights available to you in relation to your personal data.
This Privacy Policy is intended to comply with the Digital Personal Data Protection Act, 2023 and applicable rules, as may be in force from time to time.
By accessing the #IamBengaluru website, registering as a volunteer, RSVPing for an activity, accepting the Terms & Conditions, attending an on-ground volunteering activity, submitting information, or otherwise participating in the initiative, you acknowledge that you have read and understood this Privacy Policy.
This Privacy Policy should be read together with the Terms & Conditions for #IamBengaluru - Volunteer for Parks.
1. About the Initiative
#IamBengaluru - Volunteer for Parks is a citizen-led civic initiative by Bennett Coleman & Co. Ltd. through The Times of India, aimed at encouraging citizens to participate in the upkeep, beautification, activation and community-led improvement of parks and public green spaces in Bengaluru.
The initiative may be conducted in association with government authorities, civic bodies, implementation partners, NGO partners, resident welfare associations, educational institutions, corporate volunteer groups, community organisations, sponsors, vendors and other authorised partners.
The initiative includes both:
* Digital interactions through the #IamBengaluru website and related platforms; and
* On-ground volunteering activities at parks and public spaces.
2. Data We Collect
We collect personal data that is reasonably necessary to operate the initiative, enable volunteer participation, manage communications, coordinate on-ground activities, issue certificates, document impact and comply with applicable law.
The data we may collect includes:
2.1 Registration and Profile Data
* Name;
* Mobile number;
* Email address;
* Age group or age range;
* City/locality/area of residence;
* Preferred park, zone or volunteering location;
* Interest in activity categories;
* Institution, school, college, company, RWA or organisation name, where voluntarily provided;
* Any other information submitted by you while registering or updating your profile.
2.2 RSVP and Activity Data
* Activities viewed, selected or RSVPed for;
* Park name and location of selected activity;
* Date and time of volunteering activity;
* Attendance or check-in status;
* Volunteer hours contributed;
* Activity completion status;
* Cancellation, no-show or rescheduling information;
* Certificate or recognition eligibility;
* Feedback submitted after an activity.
2.3 Attendance, QR and Check-In Data
At on-ground activities, BCCL or authorised partners may record attendance through QR scans, check-in forms, volunteer lists, digital attendance tools or other approved mechanisms.
Such data may be used for:
* Attendance verification;
* Volunteer hour tracking;
* Certificate issuance;
* Safety coordination;
* Activity management;
* Impact reporting;
* Campaign analytics;
* Grievance or dispute resolution.
2.4 Communication Data
We may collect and retain:
* Communication preferences, where available;
* Records of confirmations, reminders, updates, certificates, impact updates and other messages sent to you;
* Responses to feedback surveys or campaign communication;
* Opt-out or unsubscribe requests for non-essential communications;
* Consent records, registration timestamps, communication logs and delivery records, where applicable.
2.5 Media and Participation Data
During on-ground volunteering activities, BCCL, its representatives or authorised partners may capture:
* Photographs;
* Videos;
* Voice recordings;
* Quotes, testimonials or statements;
* Name, city/locality, school/college/company/RWA details, where relevant;
* Participation details and volunteer stories.
Such media may be captured for editorial coverage, campaign documentation, volunteer recognition, impact reporting, public awareness and promotional use, as explained further in this Policy and the Terms & Conditions.
2.6 User-Generated Content
We may collect content voluntarily submitted by you, including:
* Photographs;
* Videos;
* Comments;
* Testimonials;
* Stories;
* Feedback;
* Artwork;
* Social media submissions or posts shared with the campaign.
2.7 Website and Technical Data
When you use the website, we may collect limited technical and usage information such as:
* Date and time of website access;
* Pages visited;
* Registration or RSVP timestamps;
* Device/browser type;
* Cookies or similar identifiers, where used;
* Error logs, security logs and system activity required for website operation and security.
2.8 Location Data
The website may use location-related information to help users discover volunteering opportunities near them.
Unless expressly enabled by the user through device or browser permissions, BCCL will generally rely on user-provided locality, preferred park, selected zone or selected activity location.
If the website requests access to device or browser location, such access will be used only after user permission is granted. Users may disable location access through their device or browser settings, though this may affect the ability to discover nearby volunteering opportunities.
2.9 No Sensitive Data for Ordinary Volunteer Registration
BCCL does not ask users to submit Aadhaar number, PAN, bank account details, payment details, passwords, OTPs, health records, caste, religion, political affiliation or other sensitive information for ordinary volunteer registration.
Users should not share such information with any individual, volunteer, NGO, RWA, sponsor, vendor, student coordinator, park champion or unofficial group claiming to represent #IamBengaluru unless the request is made through an authorised BCCL channel and is clearly necessary for a stated purpose.
3. How We Use Your Data
We may use your personal data for the following purposes:
3.1 Volunteer Registration and Participation
* To register you as a volunteer;
* To create and manage your user profile;
* To help you discover volunteering opportunities near you;
* To enable RSVP for park activities;
* To confirm your participation in selected activities;
* To manage attendance, check-ins and volunteer hours;
* To coordinate on-ground volunteering activities.
3.2 Communication and CRM
We may use your contact details to send you initiative-related communications through SMS, RCS, WhatsApp Business, phone calls, email or other lawful communication channels.
Such communications may include:
* Registration confirmations;
* OTP, login or authentication messages;
* RSVP confirmations;
* Event reminders;
* Venue, date or time updates;
* Event cancellation or rescheduling notices;
* Safety or operational instructions;
* Participation instructions;
* Thank-you messages;
* Volunteer certificates, badges or recognition;
* Impact updates;
* Information about future volunteering opportunities;
* Campaign announcements related to #IamBengaluru;
* Feedback requests and volunteer experience surveys.
3.3 Certificates, Recognition and Impact Reporting
We may use your data to:
* Issue volunteer certificates;
* Provide badges, wristbands or other recognition;
* Track volunteer hours;
* Recognise volunteers, park champions, student groups, RWAs, NGOs or community participants;
* Create impact reports, dashboards and campaign summaries.
3.4 Editorial, Media and Campaign Coverage
We may use photographs, videos, names, quotes, testimonials, participation details and user-generated content for:
* Editorial reports in The Times of India and other BCCL publications;
* BCCL websites and digital platforms;
* Social media posts, reels, stories and videos;
* Campaign films, video capsules and event documentation;
* Volunteer recognition stories;
* Impact stories and before-after documentation;
* Sponsor, partner and stakeholder presentations;
* Public awareness and promotional material related to the initiative.
3.5 Operational and Administrative Purposes
We may use your data to:
* Coordinate with NGO partners, civic bodies, RWAs, institutions and implementation partners;
* Manage park-level activities;
* Allocate volunteers to activities;
* Monitor attendance and activity completion;
* Improve website functionality and user experience;
* Resolve user queries or complaints;
* Prevent misuse, fraud, abuse or unauthorised activity;
* Comply with legal, regulatory or governmental requirements.
3.6 Analytics and Improvement
We may use aggregated or anonymised data to understand:
* Number of registered volunteers;
* Activity participation trends;
* Park-wise engagement;
* Zone-wise participation;
* Volunteer hours contributed;
* Activity completion rates;
* Website usage trends;
* Campaign impact.
Where data is aggregated or anonymised, it will not reasonably identify individual users.
4. Legal Basis for Processing
We process personal data for lawful purposes connected with operating the initiative, managing volunteer participation, communicating with users, documenting impact and complying with applicable law.
The legal bases may include:
4.1 Consent
By registering, accepting the Terms & Conditions, RSVPing for an activity, submitting your contact details, participating in the initiative, or voluntarily submitting content, you consent to the collection and use of your personal data as described in this Privacy Policy.
You specifically consent to receiving communications from BCCL and/or its authorised partners through SMS, RCS, WhatsApp Business, phone calls and email in relation to the initiative.
4.2 Voluntary Participation
Processing is required to enable your participation in the initiative, including registration, RSVP, attendance, activity coordination, reminders, certificates and volunteer recognition.
4.3 Legitimate Operational Purposes
We may process certain data for operational purposes such as safety coordination, campaign administration, fraud prevention, activity planning, service improvement, reporting and grievance handling.
4.4 Legal Compliance
We may process and retain data where necessary to comply with applicable law, court orders, government directions, regulatory requirements, audit obligations or legal claims.
4.5 Media and Campaign Documentation
Photographs, videos, testimonials and participation details may be processed for editorial, documentation, public awareness, campaign reporting and promotional purposes in connection with the initiative, subject to applicable law and consent requirements, especially for minors.
You may withdraw consent for non-essential processing or communications as described in this Policy. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.
5. Explicit Consent for Communications
By registering on the #IamBengaluru website, accepting the Terms & Conditions, submitting your contact details, RSVPing for an activity or participating in the initiative, you expressly consent to receive communications from BCCL and/or its authorised partners through:
* SMS;
* RCS;
* WhatsApp Business;
* Phone calls;
* Email;
* Other lawful communication channels, where applicable.
Such communications may be transactional, operational, informational or campaign-related.
You acknowledge that RCS and WhatsApp Business may be used for timely communication, including confirmations, reminders, event updates, venue changes, cancellations, safety instructions, certificates, impact updates and future volunteering opportunities.
You may opt out of non-essential or promotional communications where such option is provided. However, opting out of certain communication channels may affect our ability to send reminders, updates, certificates, event instructions or volunteering opportunity alerts.
Transactional, authentication-related, operational, safety-related or legally required communications may continue to be sent where necessary for your participation in the initiative, subject to applicable law.
BCCL may retain records of your consent, registration timestamps, communication preferences, opt-outs, communication logs and related records for compliance, audit, grievance redressal and proof-of-consent purposes.
6. Opt-Out and Communication Preferences
Users may opt out of non-essential communications by:
* Using the unsubscribe or opt-out option provided in the relevant message, where available;
* Writing to the campaign email ID;
* Following any other mechanism made available by BCCL.
Operational or transactional messages such as OTPs, RSVP confirmations, venue changes, event cancellations, timing changes, safety alerts and urgent instructions may still be sent where necessary for participation, safety or compliance.
7. Media, Photography and Name Usage
On-ground volunteering activities may be photographed, filmed, recorded, livestreamed or otherwise documented by BCCL, its representatives, photographers, videographers, journalists, partners, agencies or authorised third parties.
By attending or participating in an activity, you acknowledge that your:
* Name;
* Photograph;
* Video;
* Voice;
* Likeness;
* Statements;
* Testimonials;
* Participation details;
* City/locality;
* School/college/company/RWA name, where applicable,
may be captured and used by BCCL in connection with the initiative.
Such use may include publication or display in:
* The Times of India newspaper;
* Other BCCL newspapers, magazines or publications;
* BCCL websites, apps and digital platforms;
* Social media handles of BCCL and the campaign;
* Campaign films, video capsules, reels, stories and digital edits;
* Outdoor, print, digital, internal and external promotional material;
* Editorial reports, impact stories, newsletters and partner reports;
* Sponsor, partner or stakeholder presentations related to the initiative.
Because activities take place in public parks and public spaces, users may appear incidentally in crowd shots, background visuals or public event coverage.
Participants who do not wish to be photographed or filmed should inform the activity coordinator before the activity begins. BCCL will make reasonable efforts to accommodate such requests for identifiable individual coverage but cannot guarantee exclusion from all incidental, background, crowd or public venue imagery.
8. Social Media and User-Generated Public Content
If users tag #IamBengaluru, The Times of India, BCCL or campaign handles in public social media posts, BCCL may repost, share or feature such content in connection with the initiative, subject to platform terms and applicable law.
Users should not post personal data, photographs, videos or identifying details of other volunteers, especially minors, without appropriate consent.
Users should not use campaign hashtags or tags for unlawful, abusive, misleading, defamatory, political, commercial, promotional or harmful purposes.
9. Participation by Minors
The initiative may involve participation by students and minors under the age of 18.
In the case of minors:
* Participation should be with the consent and supervision of a parent, legal guardian, school, college or authorised institution, as applicable;
* BCCL may require additional consent forms or institutional permissions where necessary;
* Identifiable images, names, school/college names or participation details of minors may be used in accordance with applicable permissions and consent requirements;
* BCCL will not knowingly use children"s personal data for behavioural tracking, profiling or targeted advertising;
* Volunteers, third parties, student coordinators, RWAs, sponsors and other participants are not permitted to independently collect personal data, photographs, videos or contact details of minors during campaign activities without appropriate authorisation and consent;
* Parents or guardians may request correction, withdrawal or deletion of a minor"s personal data by contacting the Grievance Officer, subject to legal, operational, archival and publication-related limitations;
* BCCL may require proof of age, identity or guardianship where reasonably necessary for compliance or verification.
BCCL does not knowingly seek to collect more personal data from minors than is necessary for participation, safety and campaign administration.
10. Data Sharing
We do not sell your personal data.
We may share your personal data only where necessary for operating the initiative, managing volunteer participation, communicating with users, documenting impact, complying with law, or enabling authorised partners to perform their roles.
Data may be shared with:
* NGO partners and implementation partners;
* Civic bodies, government authorities or park representatives, where required for activity coordination or permissions;
* Resident welfare associations, educational institutions, corporate volunteer coordinators or community groups, where relevant to your participation;
* Technology vendors operating the website, CRM, registration, RSVP or attendance systems;
* Communication service providers for SMS, RCS, WhatsApp Business, phone calls and email;
* Event management, photography, videography, design, printing, certificate or logistics partners;
* BCCL group companies, internal teams, editorial teams, marketing teams and authorised personnel;
* Legal, regulatory, law enforcement or governmental authorities where required by law.
Sponsors may receive aggregated, anonymised or campaign-level impact reports. Individual-level personal data will not be shared with sponsors for their independent marketing unless specifically disclosed and consented to by the user or otherwise permitted under applicable law.
All third-party service providers engaged by BCCL are expected to process personal data in accordance with applicable data protection laws, confidentiality obligations and BCCL"s instructions, where applicable.
11. Safeguards Against Misuse, Unauthorised Collection and Impersonation
BCCL takes misuse, impersonation and unauthorised data collection seriously. Users should note the following safeguards:
11.1 No Unauthorised Data Collection
Volunteers, park champions, RWAs, sponsors, vendors, student coordinators and other participants are not authorised to independently collect, copy, store, circulate or use personal data of other participants unless expressly authorised by BCCL for a defined campaign purpose.
Any attendance, registration, certificate or volunteer tracking data should be collected only through BCCL-approved forms, systems or partner processes.
11.2 No Sensitive Data Requests
BCCL will not ask for passwords, OTPs, bank details, payment details, Aadhaar number, PAN, health records, caste, religion, political affiliation or other sensitive information for ordinary volunteer registration.
Users should not share such information in response to informal messages, unauthorised forms, unofficial WhatsApp groups, calls or links claiming to be associated with #IamBengaluru.
11.3 No Payment or Donation Requests
Participation in #IamBengaluru - Volunteer for Parks is free unless expressly stated by BCCL in writing through official channels.
Users should not make any payment, donation, UPI transfer, cash contribution or purchase based on requests from unauthorised persons claiming to represent the initiative.
BCCL shall not be responsible for payments made to unauthorised third parties.
11.4 Authorised Communication Channels
Users should rely only on official #IamBengaluru website links, BCCL-authorised communication handles, official email IDs, verified campaign phone numbers or communication channels expressly authorised by BCCL.
BCCL will not ask users to share passwords, OTPs, payment details, bank details or sensitive identity documents through informal messages.
11.5 Fraud and Impersonation Reporting
If users receive suspicious messages, payment requests, data requests, fake certificate links, unauthorised WhatsApp groups, phishing messages or communication from persons claiming to represent #IamBengaluru, they should report it to BCCL at iambengaluru@timesofindia.com.
BCCL may investigate and take appropriate action, including disabling access, removing participants, reporting misuse to authorities, issuing public clarifications or taking legal action.
11.6 Misuse of Other Participants" Data
Participants should not use contact details, photographs, videos, names or information of other volunteers for personal, commercial, political, promotional, recruitment, harassment or unauthorised purposes.
Misuse of another participant"s data may result in removal from the initiative and further action.
12. Data Retention
We retain personal data only 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.
Indicative retention periods are as follows:
* Registration and profile data: retained for the duration of your participation in the initiative and for a reasonable period thereafter for operational, audit, reporting or grievance purposes.
* RSVP, attendance and volunteer activity data: retained for campaign administration, certificate issuance, impact reporting, partner reporting and audit purposes.
* Communication records: retained for a reasonable period to manage user queries, opt-outs, communication logs, consent records and compliance requirements.
* Consent and preference records: retained for compliance, audit, grievance redressal and proof-of-consent purposes.
* Certificates and recognition data: retained for as long as required to issue, verify or maintain recognition records.
* Photographs, videos, testimonials and editorial material: may be retained for archival, editorial, campaign, documentation, reporting and promotional purposes, including after the activity or campaign period.
* Website logs and technical data: retained for security, analytics, troubleshooting and operational purposes for a reasonable period.
* Legal and compliance records: retained as required under applicable law, contractual obligations, audit requirements, dispute resolution or legal claims.
On expiry of the applicable retention period, personal data will be securely deleted, archived or anonymised, as appropriate.
13. Data Security
BCCL implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction.
Such measures may include access controls, restricted access to authorised personnel, contractual obligations on service providers, technical safeguards and internal security practices.
While BCCL takes reasonable precautions, no method of electronic transmission, communication or storage is completely secure. Therefore, we cannot guarantee absolute security of personal data.
Users are responsible for ensuring that the information they provide is accurate and that they use secure devices and networks when accessing the website.
14. Personal Data Breach or Security Incident
In the event of a personal data breach or security incident affecting user data, BCCL will take reasonable steps to assess, contain and remediate the incident.
Where required under applicable law, BCCL will make notifications to relevant authorities and/or affected users in accordance with applicable legal requirements.
15. Your Rights
Subject to applicable law, you may have the following rights in relation to your personal data:
* Right to access: You may request information about the personal data we hold about you.
* Right to correction: You may request correction of inaccurate or incomplete personal data.
* Right to erasure: You may request deletion of your personal data, subject to legal, operational, archival, publication and compliance requirements.
* Right to withdraw consent: You may withdraw consent for non-essential processing or communications, subject to limitations under applicable law.
* Right to grievance redressal: You may raise a grievance regarding processing of your personal data.
* Right to nominate: Where applicable under law, you may nominate another individual to exercise your rights in the event of death or incapacity.
To exercise any of these rights, please contact the Grievance Officer using the details provided in Section 20.
Please note that withdrawal of consent or deletion of certain data may affect your ability to participate in the initiative, receive reminders, obtain certificates, receive activity updates or access certain features.
Where your name, photograph, quote, video or participation detail has already been published in print, digital, social media, video, archival, editorial or campaign material, deletion or removal may not always be possible.
16. Cookies and Similar Technologies
The #IamBengaluru website may use cookies or similar technologies for website functionality, security, analytics, performance improvement, session management or user experience.
Users may control cookies through browser settings, where available. Disabling cookies may affect certain website functions, including login, registration, RSVP or user experience.
Where required by law, additional cookie notices or consent mechanisms may be displayed on the website.
17. Third-Party Links and Platforms
The website or campaign communication may contain links to third-party websites, maps, forms, social media platforms, partner pages, registration tools, communication platforms or other external services.
BCCL is not responsible for the privacy practices, terms, content, availability or security of third-party platforms.
Users are encouraged to review the privacy policies and terms of any third-party platforms they access.
18. International Transfers
Personal data is primarily intended to be processed in India. However, certain technology, cloud, communication, analytics or service providers may process or store data outside India, subject to applicable law.
Where such processing occurs, BCCL will take reasonable steps to ensure appropriate safeguards are in place, as required under applicable law.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in the initiative, website, communication practices, legal requirements, technology, partners or data processing practices.
The updated Privacy Policy will be published on the website with a revised effective date.
We encourage users to review this Privacy Policy periodically. Continued use of the website, registration, RSVP or participation in the initiative after any update constitutes acknowledgement of the revised Privacy Policy.
20. Grievance Officer and Contact
In accordance with the Digital Personal Data Protection Act, 2023 and applicable rules, the details of our Grievance Officer are as follows:
Grievance Officer -- Bennett Coleman & Co. Ltd.
The Times of India Building
Dr. D.N. Road
Mumbai - 400 001
Email: iambengaluru@timesofindia.com
Available on working days between 10:00 AM and 5:00 PM IST.
This document constitutes the Privacy Policy for #IamBengaluru - Volunteer for Parks operated by Bennett Coleman & Co. Ltd. It should be read in conjunction with the Terms & Conditions applicable to the initiative.