PRIVACY POLICY

Tool Users (EBS Screen, ESG SmartNAV, GRM+SE Toolkit, 1+Assessment Platform)

When you use our digital tools, we may collect:

• Account Information: Name, email, organisation, and professional role, to register and manage your access.
• Project and ESG Data: Inputs such as location coordinates, land use details, biodiversity or forest data, and environmental/social screening parameters.
• Grievance Data (GRM+SE Toolkit): Complaints, supporting documents, community concerns, and, if provided, personal identifiers of complainants.
• Outputs: Reports, dashboards, and analytics generated by the tools, which are stored to provide services to clients.

Public and Open Data Sources

Our tools also process third-party data that is lawfully available, including:

• Creative Commons licensed datasets – e.g., GIS and environmental layers, used and modified in line with license terms.
• Government publications and notifications – such as official gazette notices, environmental clearance documents, biodiversity reports, and forest notifications.
• Scientific and technical references – where permitted under law or open license.
• To ensure transparency, each tool has metadata documentation that lists its data sources, license terms, and attribution requirements.
• All geospatial datasets are handled in compliance with the Geospatial Data Policy, 2021 (India).

Why We Use This Data

• Operate our website and ensure its security.
• Provide access to and functionality of our tools.
• Generate reports for our digital solutions/tools/platforms.
• Support compliance with applicable national regulatory frameworks and international standards.
• Improve our tools and services, including through anonymised or aggregated research and benchmarking.

Safeguards on Sensitive Data

Some data processed by our tools may involve sensitive personal or community information, particularly in grievance submissions or biodiversity/forest impact assessments. Such data are:

• Handled with strict confidentiality
• Anonymised wherever possible
• Shared only as necessary to provide services or meet legal obligations

Data Use, Sharing, and Retention

SI uses and shares data only for lawful, specific purposes, and retains it only as long as necessary. Our approach follows the Digital Personal Data Protection Act, 2023 (India), the Privacy Act, 2018 (Nepal), and, where applicable, international standards including the IFC Performance Standards, Equator Principles, World Bank Environmental, Health and Safety (EHS) Guidelines, and the Asian Development Bank (ADB) Safeguard Policy Statement.

How We Share Data

Data may be shared under the following conditions:

• Internal Use: With SI staff, strictly on a need-to-know basis.
• Third-party Service Providers: With hosting providers, analytics services, or communication platforms, under strict contractual safeguards.
• Clients: Project and grievance data entered into our tools are available to the client organisations using the tools; they are responsible for how such data are used or disclosed.
• Legal and Regulatory Authorities: Where disclosure is required under applicable national regulatory frameworks.
• International Transfers: If data are stored or processed outside India or Nepal, safeguards such as contractual clauses are applied.
• No Sale of Data: SI does not sell, rent, or trade personal, project, or grievance data.
• Where geospatial data are processed, such use is strictly in compliance with India’s Geospatial Data Policy, 2021, and other applicable national regulatory frameworks.

Grievance Data Protections

Grievances may include sensitive personal or community information. To protect complainants:

• Anonymous submissions are supported where enabled by the client.
• Identifiable data is kept confidential and restricted to authorised users.
• Reports or dashboards only use anonymised or aggregated grievance information.
• Clients remain responsible for acting on grievances in compliance with applicable national regulatory frameworks and international standards.

Data Retention Periods

• Website Logs: Stored up to 30 days for security monitoring
• Tool Accounts: Retained for the contract period plus one year
• Project and ESG Data: Retained up to 5 years, consistent with monitoring obligations under IFC and ADB safeguards
• Grievance Data: Retained up to 5 years after resolution, then anonymised
• Research and Benchmarking: Only anonymised or aggregated data may be retained indefinitely
• Once retention periods expire, data are securely deleted or anonymised to prevent identification

Your Rights and Contact

SI respects the rights of individuals, clients, and stakeholders regarding their personal, project, and grievance data. We ensure that these rights are protected under applicable national regulatory frameworks and international standards.

Your Rights

Depending on the laws of your country (India, Nepal, or others where our services are used), you may have the following rights:

• Right of Access – to know what personal or project-related data we hold about you.
• Right of Correction – to request updates or corrections if your information is inaccurate.
• Right of Deletion – to request that your personal data be deleted, unless retention is required by law, regulation, or contract.

• Right to Withdraw Consent – where we process data based on your consent (e.g., cookies, newsletters, grievance submissions), you may withdraw it at any time.
• Right to Object – in some cases, you may object to how we process your data, particularly for analytics or research.

Please note that certain rights may be subject to limitations under applicable laws, or may not apply where SI acts only as a service provider and the client is the data controller (e.g., in the case of grievance data).

Our Responsibilities

• SI will process all rights requests in accordance with applicable national regulatory frameworks (India and Nepal).
• Where SI acts as a data processor (for SI’s digital solutions), we will forward your request to the client organisation (the data controller).
• We will respond to valid rights requests within legally required timelines.

Contact Us

If you have questions about this Privacy Policy, or if you wish to exercise your rights, you can contact us at:

Sustainability Intelligence Private Limited
12th Floor, Godrej Waterside, Tower 2, DP 5, DP Block, Sector V,
Bidhannagar, Kolkata West Bengal – 700091.

Email: [email protected]
Phone: +91 9830094463

Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, applicable laws, or industry standards. The latest version will always be published on our website. For significant updates, we will notify registered users directly.