Donation Policy

Second Circle Project Foundation
(A Company Registered Under Section 8 of the Companies Act, 2013)
Effective Date: July 19, 2025
This Donation Policy outlines the principles and procedures governing donations received by Second Circle Project Foundation (“we,” “us,” or “our”), a company incorporated under Section 8 of the Companies Act, 2013. We are committed to transparency, ethical fundraising, and responsible use of funds to achieve our mission, in strict adherence to the statutory requirements applicable to Section 8 companies.

Our Commitment to Donors and Statutory Compliance
Second Circle Project Foundation is deeply grateful for the generosity of our donors. Your contributions are vital to our mission of providing comprehensive post-diagnosis support to People Living with HIV (PLHIV), empowering them to lead healthier, more fulfilling lives and fostering an inclusive community. As a Section 8 Company, we operate on a not-for-profit basis, and our core commitment, as mandated by the Companies Act, 2013, is to:

Apply all profits/income solely for our objects: Any income, including donations, is utilized exclusively for promoting our charitable and social welfare objectives, as outlined in our Memorandum of Association.
Prohibit dividend distribution: No part of our profits or income shall be distributed as dividends or any form of remuneration to our members or directors.
Transparency and Accountability: We maintain stringent financial records and adhere to the reporting requirements of the Ministry of Corporate Affairs (MCA) and other relevant authorities, ensuring that funds are utilized effectively, ethically, and in alignment with our
registered objectives.
Respect for Privacy: Protecting your personal information as outlined in our Privacy Policy.
Responsiveness: Acknowledging your donations promptly and providing necessary documentation.

2. Types of Donations Accepted
Second Circle Project Foundation accepts various forms of donations to support our work, consistent with our not-for-profit status:

Monetary Donations:
Online Donations: Via credit/debit cards, UPI, net banking, or other digital payment methods on our secure website.
Bank Transfers (NEFT/RTGS/IMPS): Direct transfers to our designated bank account.
Cheques/Demand Drafts: Payable to “Second Circle Project Foundation.”
Cash Donations: We accept cash donations up to INR 2,000/- as per Indian Income Tax regulations for tax exemption eligibility under Section 80G. For amounts exceeding INR 2,000/-, donations must be made through non-cash modes (e.g., cheque, online transfer) to
qualify for tax benefits.
In-Kind Donations: We may accept donations of goods, services, or assets that align with our operational needs and program requirements, provided they contribute to the furtherance of our charitable objects, particularly in supporting PLHIV. Examples may include educational supplies, nutritional supplements, medical equipment (non-prescription), computers, office equipment, professional services (e.g., counseling, legal aid), etc. All in-kind donations will be subject to assessment for suitability and utility before acceptance. We reserve the right to decline in-kind donations that do not meet our needs or incur
excessive handling costs.
Corporate Matching Gifts: We encourage donors to explore matching gift programs offered by their employers. Please check with your company’s HR department for details on their matching gift policies.
Legacy Gifts/Bequests: We welcome discussions regarding planned giving, including bequests, trusts, and other deferred gifts. These contributions will be used strictly in furtherance of our Section 8 company’s objectives. Please contact us directly for more
information on how to arrange such contributions.

3. Donation Use and Allocation (Adherence to Section 8 Principles)
In accordance with Section 8 of the Companies Act, 2013, all funds, including donations, received by Second Circle Project Foundation shall be applied solely for the promotion of our stated charitable objects related to providing post-diagnosis support for PLHIV.
Unless otherwise specified by the donor for a particular project or campaign, all donations received will be allocated to the Second Circle Project Foundation’s general fund. This allows us the flexibility to deploy resources where they are most needed to support our
ongoing programs, operational costs, and administrative expenses, ensuring the sustainability and effectiveness of our initiatives, all of which directly contribute to our not-for-profit objectives for PLHIV support.
If a donor wishes to designate their donation to a specific project or program (e.g., a specific counseling initiative, nutritional support program, or advocacy campaign for PLHIV), they should clearly indicate this at the time of donation. While we will make every effort to honor
such designations, Second Circle Project Foundation, in alignment with its constitutional documents as a Section 8 Company, reserves the right to reallocate funds if the designated program is oversubscribed, discontinued, or if circumstances make it impossible or
impractical to use the funds as originally intended. In such rare cases, and after due consideration by the Board of Directors, we will inform the donor and offer alternative uses or, if requested, a refund.

4. Tax Exemption (Section 80G of the Income Tax Act, 1961)
Second Circle Project Foundation is registered under Section 12A and approved under Section 80G of the Income Tax Act, 1961. This means that monetary donations made to us are eligible for tax deduction benefits for Indian taxpayers, subject to the provisions of
Section 80G.

Eligibility: Donors must provide their full name, address, and PAN (Permanent Account Number) to receive an 80G certificate. Without a valid PAN, the donation may not qualify for tax exemption.
Cash Donation Limit: Cash donations exceeding INR 2,000/- are not eligible for tax deduction under Section 80G.
Donation Certificate (Form 10BE): We will issue a donation certificate (Form 10BE) to eligible donors for their records to claim tax deductions. This certificate will be provided within the stipulated timeframe as per Income Tax regulations, typically by May 31st of the
financial year following the donation.

5. Donation Acknowledgement and Receipts

All donations, regardless of amount or type, will be acknowledged promptly.
For monetary donations, a formal receipt will be issued via email or postal mail (as per donor preference) upon successful processing of the donation.
For in-kind donations, an acknowledgement letter will be provided.

6. Refund and Cancellation Policy

Donations to Second Circle Project Foundation are generally non-refundable. Once a donation is made, it is considered a firm commitment to support our charitable activities.
However, we understand that errors can occur. In cases of genuine error, such as a duplicate transaction or incorrect amount, a donor may request a refund within [e.g., 7-15] days of the donation date.
Refund requests must be submitted in writing (email preferred) to grievances@secondcircleindia.org and include:
Donor’s full name and contact information.
Date of donation.
Amount of donation.
Transaction reference number (if applicable).
Reason for the refund request.
All refund requests will be reviewed by our team on a case-by-case basis. If a refund is approved, the amount will be credited back to the original payment method within 7 working days. Any transaction charges incurred during the initial donation or refund process may be borne by the donor.
No refunds will be issued for donations made for specific campaigns once the funds have been disbursed for that campaign’s objectives.

7. Donor Privacy
Second Circle Project Foundation respects the privacy of its donors. All personal information collected from donors will be handled in accordance with our comprehensive Privacy Policy, available on our website www.secondcircleindia.org. We do not sell, rent, or share donor lists with third parties.

8. Anonymous Donations
We accept anonymous donations. However, please note that anonymous donations will not be eligible for tax exemption benefits under Section 80G, as a valid PAN and donor details are required for issuing the necessary tax certificate.

9. Refusal of Donations
Consistent with our obligations as a Section 8 Company, Second Circle Project Foundation reserves the right to refuse any donation that:

Does not align with our mission of providing post-diagnosis support for PLHIV, or our values or ethical principles.
Comes from a source deemed illegal, unethical, or could damage the reputation of the organization (e.g., proceeds from criminal activities).
Is conditional in a way that is not feasible or appropriate for the organization, or which attempts to impose conditions contrary to the provisions of Section 8 of the Companies Act, 2013 (e.g., conditions for private benefit of members).
Involves undue influence or conflict of interest.
Is made for a purpose that is outside the scope of our registered objectives as a Section 8 Company.
In such cases, the decision to refuse a donation will be made by [e.g., the Board of Directors/relevant committee] and communicated to the potential donor if their identity is known.

10. Foreign Contributions (FCRA Compliance)
If Second Circle Project Foundation receives foreign contributions (donations from outside India), we shall comply strictly with the provisions of the Foreign Contribution (Regulation) Act, 2010 (FCRA) and its rules. This includes, but is not limited to, maintaining a separate
bank account for foreign contributions and filing all mandatory annual returns with the Ministry of Home Affairs (MHA). Donors providing foreign contributions acknowledge and agree to these compliance requirements.

11. Contact Information
For any questions regarding this Donation Policy, or to discuss a donation, please contact us:

Second Circle Project Foundation
A4/230 DDA Flat Paschim Vihar
New Delhi-110063, India
Info@secondcircleindia.org
Mobile: +91-8527274277, Tel: 011-43047136
Grievance Officer:
Karandeep Pupneja
Director@secondcircleindia.org
Mob: +91-9953312533

12. Changes to This Donation Policy
Second Circle Project Foundation reserves the right to amend or update this Donation Policy at any time, in compliance with the Companies Act, 2013, and other relevant laws. Any changes will be posted on our website and become effective immediately upon posting. We encourage donors to review this policy periodically.