Last updated: May 2026 · Version 3
1. Introduction & Data Fiduciary
1.1 This Privacy & Data Policy (the "Policy") governs the collection, processing, storage, use, and protection of personal data and content submitted through the website www.plasticshoonya.in and any associated digital properties (collectively, the "Platform").
1.2 The Platform is operated by Youth Action For Change Foundation ("YACF" or "the Foundation"), a not-for-profit organisation registered in India, through its programme branded Plastic Shoonya Schools (the "Programme"). The website domain plasticshoonya.in is registered to the founder and made available to the Foundation for the operation of the Programme. The brand name Plastic Shoonya is unregistered; the Programme operates under the institutional aegis of YACF.
1.3 For the purposes of the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the DPDP Rules, 2025, Youth Action For Change Foundation acts as the Data Fiduciary in respect of personal data processed through the Platform.
1.4 The scope of the Programme may, from time to time and at the Foundation's discretion, be expanded to encompass related themes — including, but not limited to, environmental sustainability, behavioural science and decision-making among young people, social responsibility, and civic awareness. This Policy applies to all such expanded activities and to any associated programmes, platforms, or digital products launched under the Plastic Shoonya or YACF identity.
2. Scope and Applicability
This Policy applies to:
- All schools and educational institutions that register on the Platform ("Registered Schools");
- All teachers, school coordinators, administrators, and staff who interact with the Platform on behalf of a Registered School ("School Representatives");
- All students who participate in the Programme under the supervision and account of a Registered School ("Participants");
- Parents or guardians of Participants ("Parents/Guardians"); and
- Any person who accesses, browses, or uses the Platform in any capacity.
By accessing or using the Platform, or by submitting any content on behalf of a school or its students, you confirm that you have read, understood, and agree to be bound by this Policy in its entirety.
3. Key Definitions
- "Platform" — the website www.plasticshoonya.in and all associated digital properties operated by or on behalf of the Foundation.
- "Programme" — the Plastic Shoonya Schools journey (Pehchaan, Soch, Karm, Sankalp) and any other challenge, activity, resource, module, or educational programme hosted on or administered through the Platform, including any future expansions or related programmes.
- "Registered School" — any school that has completed the registration and verification process and has been granted an active account on the Platform.
- "Submitted Content" — all materials uploaded, submitted, shared, or published through a school's account, including but not limited to photographs, videos, audio recordings, written work, artwork, posters, worksheets, project reports, presentations, audit responses, and Programme entries.
- "Identifiable Content" — any Submitted Content in which a Participant's face, full name, or other personally identifiable feature is visible or discernible without independent masking.
- "Personal Data" — any information relating to an identified or identifiable natural person, as defined under the DPDP Act, 2023.
- "Participant" — any student below the age of 18 whose data, work, or likeness is submitted through a Registered School's account.
- "DPDP Act" — the Digital Personal Data Protection Act, 2023, along with the DPDP Rules, 2025, and any amendments or notifications issued thereunder.
4. Account Registration — School-Only Access
4.1 All accounts on the Platform are institutional accounts and may only be created by a duly authorised representative of a school or educational institution using that institution's official email address or institutional credentials.
4.2 Individual students are strictly prohibited from independently creating accounts, logging in to the Platform, or directly submitting content. All student-facing activities must occur through, and under the direct oversight of, a Registered School's account and a School Representative.
4.3 By creating and using an account, the Registered School:
- Confirms that it is a duly constituted and functioning educational institution;
- Accepts this Policy on behalf of itself and all Participants whose data, work, or media will be submitted through its account;
- Warrants that it has obtained, and will maintain, verifiable parental/guardian consent for every Participant in the manner required under Section 9 of the DPDP Act and the DPDP Rules, 2025;
- Confirms that consent obtained covers the specific purposes described in this Policy, including the use of Submitted Content as described in Clause 11;
- Agrees to retain records of all consents and to produce them immediately upon request by the Foundation or any competent authority; and
- Confirms that the School Representative completing registration has the authority to bind the school to this Policy.
4.4 Authorised Acts. Once the school's account has been verified and activated, all activity carried out through that account — including uploads, submissions, and content posts — is conclusively deemed to be the authorised act of the Registered School. The Foundation is entitled to rely entirely on this assumption and bears no responsibility for verifying the identity or authority of any specific person operating the account on a day-to-day basis.
4.5 The Foundation reserves the right to reject, suspend, or permanently terminate any school account found to be in violation of this Policy, without notice and without liability.
5. Verification — Scope and Limitations
5.1 The Foundation operates a mandatory institutional verification process. Submission of the sign-up form on the Platform does not automatically activate an account. Activation is conditional upon successful completion of this process.
5.2 Upon receiving a sign-up submission from a school's official email address, the Foundation will contact the school via the registered email and/or by telephone at the number provided, to confirm that the registration has been made by a functioning educational institution and that the School Representative exists and is associated with that institution.
5.3 Scope of Verification. The verification process is limited exclusively to confirming institutional identity — i.e., that an actual school has created the account. This verification does not, and is not designed to:
- Confirm the identity or seniority of the specific individual acting as School Representative;
- Verify that any specific student's parent or guardian has provided consent;
- Audit, assess, or confirm the school's internal consent, safeguarding, or child protection processes;
- Guarantee the accuracy or completeness of any information provided in the registration form.
5.4 Beyond institutional identity verification, the Foundation proceeds on the assumption — which it is entirely entitled to make — that the account is operated by an authorised School Representative who has complied, and continues to comply, with all applicable parental consent, safeguarding, data protection, and child welfare obligations. The Foundation bears no liability for any failure by the school to meet these obligations.
5.5 The Foundation may decline any registration without providing reasons. The decision to grant or withhold access is entirely at its discretion and is final.
6. Platform Features and Public Visibility
6.1 The Platform contains the following publicly accessible features that do not require a user to be logged in:
- The Inspiration Board — displays photographs and activity descriptions submitted by Registered Schools, organised by Programme level (Pehchaan, Soch, Karm, Sankalp), alongside the school's name;
- The Leaderboard — displays participating school names, their city, and their level completion progress;
- The Resources teaser page — displays summary information about downloadable materials available behind login;
- General informational pages (Home, About, The Challenge, etc.).
6.2 Schools are aware of, and expressly acknowledge at the point of registration, that content submitted through their account may be displayed publicly on the Inspiration Board and other public-facing sections of the Platform, visible to any person with internet access anywhere in the world, without any login requirement.
6.3 The Foundation may also use Submitted Content across its other channels — including social media, print materials, donor communications, and programme documentation — as further described in Clauses 10 and 11.
7. Personal Data We Collect
7.1 Data provided by the Registered School
School name, type, board affiliation, address, and official contact details; name, designation, official email address, and telephone number of the School Representative; and details submitted during the verification process.
7.2 Data relating to student Participants
Submitted through the school's account: first names or pseudonyms; class and age group; written assignments, audit responses, decision maps, campaign reflections, and policy submissions; photographs and videos involving students; artwork and student-produced materials; participation logs and tier-completion records.
7.3 Automatically collected technical data
Standard technical data (IP addresses, browser type, device identifiers, access timestamps, and usage logs) is collected solely for the purpose of operating, securing, and improving the Platform. This data is not used for behavioural profiling, commercial analytics, or targeted advertising.
8. Inspiration Board, Masking & Deemed Consent
8.1 This Clause is of critical importance and should be read carefully by every Registered School before submitting any content involving identifiable students.
8.2 Public Display. Content uploaded to the Platform, including photographs and videos involving Participants, may be displayed publicly on the Inspiration Board and other public-facing sections of the Platform, without login or geographic restriction.
8.3 Masking Responsibility. If a Registered School wishes any Participant's face to be obscured or anonymised before public display, the school is solely responsible for masking, blurring, or otherwise concealing the relevant face(s) before uploading the content. The Foundation does not provide masking services and bears no obligation to mask, blur, or anonymise any content uploaded.
8.4 Foundation's Monitoring — Best Efforts Only. The Foundation will use reasonable efforts to review and monitor content uploaded to the Platform on a best-efforts basis only, subject to its operational capacity and resources. The Foundation does not warrant that any specific item of content will be reviewed before it is published or accessible on the Platform. The Foundation cannot, and does not, independently verify whether parental/guardian consent has been obtained for any individual visible in Submitted Content. Such monitoring as the Foundation may carry out shall not, under any circumstances, be construed as an assumption of legal responsibility for content uploaded by Registered Schools.
8.5 Deemed Consent — IMPORTANT. Where a Registered School uploads Submitted Content containing Identifiable Content — that is, content in which any Participant's face, full name, or other personally identifiable feature is visible or discernible without independent masking — it shall be conclusively presumed that:
- The school has obtained valid, informed, and verifiable parental/guardian consent for each such Participant, in the manner required by Section 9 of the DPDP Act and applicable child protection law;
- That consent specifically and expressly covers the public display of the relevant content on the Platform (including the Inspiration Board) and its further use by the Foundation as described in this Policy; and
- The school has confirmed, prior to upload, that no Parent/Guardian has objected to, withdrawn, or qualified that consent.
This deeming provision is final and not open to rebuttal. By uploading any Identifiable Content, the school confirms each of these matters.
8.6 No Liability for Identifiable Content. The Foundation accepts no liability of any kind in respect of any Identifiable Content uploaded by a Registered School. All consequences of any failure by the school to obtain, maintain, or document valid parental/guardian consent remain the sole responsibility of the school.
8.7 Removal at Discretion. The Foundation reserves the right, at its absolute discretion and without notice or liability, to remove, reject, or refuse to publish any Submitted Content that it considers, in its sole judgment, to be in violation of this Policy, applicable law, or inconsistent with the spirit of the Programme.
9. Children's Data — DPDP Act, 2023 Compliance
9.1 The Foundation treats the protection of children's personal data as a non-negotiable priority. All Participants are children within the meaning of the DPDP Act (persons below 18 years of age) and are accorded the highest level of protection.
9.2 Consistent with Section 9 of the DPDP Act and the DPDP Rules, 2025:
- No personal data of a Participant will be processed without verifiable parental/guardian consent;
- The Registered School is responsible for obtaining, documenting, and retaining such consent prior to the student's involvement in any Platform activity;
- The Foundation will not track, behaviourally monitor, commercially profile, or direct targeted advertising at any Participant; and
- All data relating to Participants will be processed only for the disclosed purposes in this Policy.
9.3 The school-only account structure described in Clause 4 is a deliberate design choice made in the interests of child safety and DPDP Act compliance. It ensures that no minor directly creates or operates an account, and that all Platform interactions involving students occur under institutional supervision.
9.4 In the event of a personal data breach involving children's data, the Foundation will notify affected schools and, as required, the Data Protection Board of India, within the timelines prescribed under applicable law.
Note to Schools: Before submitting any photograph, video, or material in which a student is identifiable, ensure you hold a signed media consent form from that student's parent or guardian that explicitly covers the uses described in Clause 11 of this Policy. A model consent form is available on request from the Foundation.
10. Purpose of Processing
Personal data and Submitted Content are processed for the following purposes only:
- To operate, administer, deliver, and improve the Programme and Platform;
- To verify Registered Schools and authorise account access;
- To assess Programme submissions, award completions, generate certificates, and maintain leaderboards and the Inspiration Board;
- To communicate with Registered Schools about the Programme, related events, and policy changes;
- For research, programme evaluation, and aggregated impact reporting — using anonymised data only;
- To use Submitted Content in awareness, educational, and advocacy materials on environmental, behavioural-science, and related youth-education themes; and
- To comply with applicable legal, regulatory, and reporting obligations.
No data is processed for targeted advertising, commercial profiling, or behavioural monitoring.
11. Ownership of Submitted Content — Intellectual Property
11.1 Assignment of Rights. By submitting, uploading, or sharing any Submitted Content on or through the Platform, the Registered School, on behalf of itself and the relevant Participants, hereby irrevocably and unconditionally assigns to Youth Action For Change Foundation (operating as Plastic Shoonya Schools) all rights, title, and interest in and to such Submitted Content — including all intellectual property rights, copyright, moral rights (to the extent waivable), rights in photographs and recordings, and all related rights subsisting therein — to the fullest extent permitted by law.
11.2 Perpetual Licence. Without prejudice to Clause 11.1, the Registered School grants the Foundation a worldwide, perpetual, royalty-free, sub-licensable, transferable, irrevocable licence to use, reproduce, modify, adapt, publish, translate, distribute, display, and otherwise exploit the Submitted Content in any form or medium now known or later developed, for the Foundation's lawful purposes.
11.3 Permitted Uses include, without limitation:
- Display on the Platform, including on the Inspiration Board and Leaderboard;
- Use in social media, marketing, fundraising, and donor communications;
- Use in print and digital publications, reports, presentations, and exhibitions;
- Use in awareness campaigns, educational materials, and curriculum resources;
- Use in research outputs, impact reports, and academic publications (anonymised where appropriate);
- Use in connection with any expanded YACF programme described in Clause 1.4.
11.4 School's Warranty. The Registered School warrants that it has the full right and authority — including all necessary parental/guardian consents — to make the assignment and grant the licence described in this Clause.
11.5 Indemnity for IP & Consent Failures. The Registered School shall indemnify, defend, and hold harmless the Foundation and each of its founders, officers, volunteers, and associated persons from and against any claim, liability, fine, penalty, cost, or expense (including legal costs) arising directly or indirectly from any failure to obtain valid parental/guardian consent for, or any third-party challenge to, the assignment and licence described in this Clause.
11.6 Responsible Exercise of Rights. The Foundation shall exercise its rights over Submitted Content in a manner consistent with the dignity, safety, and well-being of student Participants, and in compliance with applicable child protection legislation at all times.
12. Challenge Assessment and Programme Decisions — Finality
12.1 All evaluations, scoring, tier completions, leaderboard rankings, selection of featured schools, award of certifications or recognitions, assessment of Programme submissions, and any other Programme-related determination are made at the sole and absolute discretion of the Foundation.
12.2 Such decisions are final, conclusive, and binding on all participants. No correspondence will be entered into, and no challenge, objection, appeal, negotiation, litigation, arbitration, or other proceeding may be brought or maintained against the Foundation, or any of its associated persons, by any school, student, parent, or third party in respect of any such decision.
12.3 The Foundation reserves the right, in its sole judgment and without liability, to: (a) modify, suspend, or discontinue the Programme or any part of it at any time; (b) change the assessment methodology or award structure; (c) disqualify any school or Participant for breach of this Policy, submission of inaccurate, misleading, or fraudulent content, or conduct deemed inconsistent with the spirit of the Programme; and (d) withhold, cancel, or revoke any award, certification, or recognition already granted, should grounds for disqualification come to light after the fact.
13. Data Sharing and Disclosure
The Foundation does not sell personal data. We may share data only in the following limited circumstances:
- With technology and hosting service providers who process data on our behalf under appropriate data processing agreements;
- With partner organisations, sponsors, or government bodies for Programme delivery and reporting, subject to appropriate safeguards;
- On the public Leaderboard (school name, city, and tier-completion details only);
- On the public Inspiration Board (as described in Clauses 6 and 8);
- In connection with other YACF programmes, in accordance with the expanded-scope provision in Clause 1.4;
- Where required by law, court order, or direction of a competent authority; and
- In connection with any reorganisation, merger, or transfer of the Programme, subject to this Policy continuing to apply.
Individual student personal data will not be publicly displayed beyond what is inherent in Submitted Content uploaded by the school itself.
14. Data Retention
- Submitted Content assigned to the Foundation under Clause 11 may be retained indefinitely.
- School registration and verification records will be retained for a minimum of seven (7) years from the date of the school's last activity.
- Student Personal Data not forming part of Submitted Content will be deleted when no longer necessary for the purposes for which it was collected.
- Consent records must be retained by the school for a minimum of three (3) years after the Participant's last involvement in the Programme.
- Anonymised, aggregated research data may be retained indefinitely for ongoing analysis and academic use.
15. Rights of Data Principals
Parents/guardians acting on behalf of student Participants have the following rights under the DPDP Act, 2023:
- Right to access a summary of personal data held about their child;
- Right to correct or update inaccurate or incomplete personal data;
- Right to request erasure of personal data, subject to legitimate grounds for retention and any applicable legal obligation;
- Right to withdraw consent at any time — provided that withdrawal does not affect the lawfulness of prior processing, nor the irrevocable assignment of rights in Submitted Content under Clause 11;
- Right to nominate another individual to exercise rights on their behalf; and
- Right to lodge a complaint with the Data Protection Board of India.
Requests should be directed to us at the contact details in Clause 20. We will respond within the timelines prescribed under applicable law.
16. Data Security
The Foundation implements reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, disclosure, alteration, or destruction. These include restricted access controls, secure hosting, password hashing, and monitoring practices. However, no digital system is entirely immune to risk. Registered Schools are responsible for maintaining the security of their account credentials and must notify us immediately upon suspecting any unauthorised access or breach.
17. Disclaimer and Limitation of Liability
17.1 The Platform and Programme are provided on an "as is" and "as available" basis. To the fullest extent permitted by applicable law, the Foundation expressly disclaims all warranties, representations, and conditions of any kind, whether express or implied.
17.2 Neither the Foundation, nor any of its founders, officers, team members, volunteers, or associated persons, shall be liable for:
- Any loss, damage, or harm arising from the submission, publication, use, or display of Submitted Content uploaded by a Registered School;
- Any failure by a school to obtain, maintain, or produce required parental/guardian consents;
- Any violation of applicable law by a school in connection with content involving student Participants;
- Any claim arising from the public display of Identifiable Content submitted by a school;
- Any reliance by any party on materials, resources, or information provided through the Platform;
- Any indirect, incidental, special, consequential, or exemplary damages arising from participation in the Programme; or
- Any claim by a student, parent, or third party arising from content submitted by a school.
17.3 Indemnity. The Registered School indemnifies and holds harmless the Foundation and each of its founders, officers, team members, volunteers, and associated persons from and against any and all claims, liabilities, losses, damages, fines, penalties, costs, and expenses (including legal costs and fees) arising from: (a) the school's breach of this Policy; (b) any failure to obtain, maintain, or document required parental/guardian consents; (c) any content uploaded by the school in violation of applicable law or third-party rights; (d) any claim by a student, parent, or third party in connection with Identifiable Content submitted by the school; or (e) any act or omission of the school or its representatives in connection with the Programme.
17.4 The indemnity granted under this Clause 17 shall not be reduced, diminished, or affected in any way by reason of the Foundation having exercised its rights under Clause 8.4 to monitor Submitted Content. The school remains fully and exclusively responsible for the lawfulness and appropriateness of every item it uploads.
18. Changes to This Policy
The Foundation may update this Policy from time to time to reflect changes in Programme operations, applicable legal requirements, or the expansion of activities described in Clause 1.4. Material changes will be communicated to Registered Schools by email and through a prominent notice on the Platform. Continued use of the Platform following notification of a revised Policy constitutes acceptance of the updated terms.
19. Governing Law and Jurisdiction
This Policy is governed by and construed in accordance with the laws of India. Any dispute, claim, or controversy arising out of or relating to this Policy, the Platform, or the Programme shall be subject to the exclusive jurisdiction of the courts in New Delhi, India.
20. Contact and Grievance Redressal
For any queries, requests to exercise data rights, or complaints regarding this Policy, please contact:
We will endeavour to acknowledge all queries within 72 hours and resolve grievances within 30 days of receipt, as required under applicable law.
School Acknowledgement and Declaration
By completing the registration process and using the Plastic Shoonya Schools Platform, the authorised School Representative declares and confirms on behalf of the school that:
- They have read and understood this Privacy & Data Policy in its entirety;
- They accept this Policy on behalf of the school and all student Participants;
- The school has obtained, and will continue to obtain, verifiable parental/guardian consent for all Participants before involving them in the Programme or submitting any content involving them;
- The school has specifically informed parents/guardians that Submitted Content will become the property of YACF/Plastic Shoonya and may be used as described in Clause 11;
- The school accepts responsibility for the lawfulness and appropriateness of all content uploaded through its account as described in Clauses 6 and 8;
- The school accepts that all Programme assessments and decisions are final and binding as described in Clause 12;
- The School Representative is duly authorised to bind the institution to this Policy; and
- The school understands that access to the Platform is conditional upon satisfactory completion of the verification process described in Clause 5.
This Policy is issued by Youth Action For Change Foundation, operating through the Plastic Shoonya Schools initiative. For questions or concerns about this Policy, contact us using the details in Clause 20.
