Privacy Policy Framework

Date: March 31, 2023

1. Introduction

This Privacy Policy (hereinafter referred to as “Policy”) provides a framework as to how Digirealty Technologies Private Limited(hereinafter referred to as “us”, “we”,“our” or “Company”) collects, uses, stores, processes, and sharesany Personal Information (Information that identifies or can be used to identify, contact, or locate a user to whom such information pertains including but not limited to name, address, phone number and email address)to provide Services (herein defined below)on the BelleViemobile platform of the Company and shall include all associated firmware, applications, software, websites, APIs, products, and services that are connected to the platform (collectively referred to as “Platform”). The Policy shall be applicable on:
  1. those who intend to make a purchase or have placed an order through the Platform (“Buyers”);
  2. those who intend to offer products for sale or are selling the products to Buyers on the Platform (“Sellers”); and
  3. societies which provide their residents access to the Platform for availing the Services (“Societies”).
The Buyers,Sellers and Societies shall be collectively referred to as the “User” (or “you”, “your”, and “yourself”). The Company is committed to security and management of Personal Information, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that your privacy is protected through the lawful and appropriate means for handling the personal information. To avail the services and content provided by the Company or Sellers registered with the Platform, whether free or paid (“Platform Service”), the Buyer shall create an account on the Platform (“Account”). It is important to understand that by using the Platform, you hereby agree and confirm that you have read, understood, and acknowledged the terms of this Policy. The Policy is a reference document and does not create any legal rights or binding obligations.“Services” means the Platform and the Platform Services owned, developed, distributed, or offered by the Company or a Seller on the Platform.

2. Scope

This Policy is applicable to the Platform and to the Users who register on the Platform for providing or for availing the Services. It is advisable that you read this Policy carefully, because if and whenever you use our Platform, your Personal Information will be processed in accordance with this Policy.By using the Services, you agree to the terms of this Policy. You shouldnot use the Services if you donot agree with this Policy or any other agreement that governs your use of the Services.This Policy is limited only to Personal Information that the Company collects from its Users who access the Platform and does not apply to any such information collected from the Company from its employees..

3. Eligibility

  1. The Platform is not intended for children. Therefore, if you are using the Platform, you agree that you are 18 (eighteen) years or older. However, if the applicable laws for the time being in force require that you must be older than 18 (eighteen) years to lawfully use the Services on the Platform, then such older age shall apply as the applicable minimum age.If we become aware that any Personal Information is provided by a person under the age of 18 (eighteen) years without verification of parental consent, we shall take necessary steps to remove such information from our servers.
  2. Further, in case you are under the age of 18 (eighteen) years, you hereby acknowledge that you are accessing this Platform under the supervision of your parent or legal guardian and have their express permission to use the Services.

4. Collection of Personal Information

  1. We shall collect Personal Information about you from various sources including from the device through which you are accessing the Platform and web beacons. The sources of collection of your Personal Information shall also include your interactions while using the Platform, credit check databases, background check providers, record verification providers, real estate brokers and such other parties in the real estate sector.
  2. The Company uses, stores, and processes your Personal Information for the following purposes:
    1. to provide and administer the Services seamlessly;
    2. to enhance and improve the quality of Services;
    3. internal operational purposes such as spam and abuse prevention and enforcing content license restrictions;
    4. for safety and security purposes such as we may use your Personal Information to protect us or the Platform from any illegal or prohibited activities;
    5. for the performance of a contract such as undertaking the purchase contract for the Services that you have availed through the Platform;
    6. to manage your requests regarding any issues that you face while accessing the Platform;
    7. to offer users personalized content based on their request, search history, and key words used in navigating the Platform, as well as usage history on the Platform;
    8. to comply with the legal obligations such as we may collect a Seller’s information regarding place of establishment and bank account information for identity verification and other legal purposes;
    9. provide Personal Information collected on the Platform to Company’s affiliates, other third parties, including those who are working with the Company; and
    10. for other purposes including but not limited to data analysis, observing usage trends and to evaluate and improve the Services on the Platform or any other services offered by the Company.
  3. When you sign up with the Platform to access the Services, you generally give us the following information:
    1. your name, email address,contact number and any government document for verification;
    2. transaction-related information when you respond to any offers available on the Platform;
    3. information which you provide on the Platform when you contact us for any help/assistance; and
    4. any other information you enter or upload into our system while using the Platform.
  4. To provide you a safe, efficient, smooth and customized experience, for you to take advantage of certain features available on the Platform including any services offered by Sellers, you may be asked to complete an online registration form which will provide us with the abovementioned information. In the event you register with us, you will also be asked to choose a ‘user identity’ (or username) and form a password to identify yourself and access Services during future uses of the Platform.
  5. We collect information about the Buyer’s purchase history, retailer preferences, leasing details, apartment rental history and their previous transactions and preferences.
  6. We may collect some additional information regarding the usage data such as the pages of Services that you visit, time spent on those pages, unique device identifiers and other similar diagnostic data. This can help us to customise the Services according to your needs and help enrich your experience on the Platform.We may use a variety of technologies that automatically record specific technical information when you visit or access our Platform. Such collection of personal information allows us to troubleshoot concerns, promote safe services, inform you about offers and products and protect us against errors.
  7. Due to the nature of Services provided on the Platform, the Sellers must register on the Platform and provide us with such information which is necessary to list the Services which they will provide to the Buyers on the Platform.
  8. To measure traffic and usage trends for the Platform and to learn more about the demographics of our Users, we may gather analytics data or make use of external analytics tools. We might potentially collaborate with other partners to leverage technologies that help us deliver the Services and improve user experience. The terms of use and privacy policies of any external services used by the Company, as well as any relevant legislation, shall apply to those services.
  9. If you choose to post messages on the Platform’s message boards, chat rooms or other message areas or leave feedback, we will collect and store such information you provide to us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and inquiries, and troubleshoot problems and improve the Services.
  10. To improve user experience, you may choose to provide us with information by adding optional information on the Platform, by responding to surveys and posting to community forums.
  11. We may also request additional PersonalInformation from you under specific circumstances such as when you apply for a rental or lease or buy a property of the Company by using the Platform. Such Personal Information may include but is not limited to a government issued document, financial information, employment information and rental history details.
  12. We may also collect demographic information such as your ethnicity, gender, housing status, household size, annual income, household type, and your desired housing characteristics or location or community
  13. We shall collect payment information and the payment details only if you make a payment for any of the Services provided on the Platform. When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. Hence, we cannot guarantee that transmissions of your payment-related information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us. We assume no liability or responsibility for disclosure of your payment information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
  14. We may contact you via tele-call, email, SMS, multimedia message service (MMS) or other forms of communication for, inter alia, informing you of new service/ product offerings, and collecting feedback in relation to the Platform and the use of the Services, or sharinginformation with you about certain promotions or features in relation to the Platform. You may receive such communication only when you have registered as a User on the Platform.
  15. If we are involved in a merger, acquisition, due diligence, reorganization, bankruptcy, or liquidation where the Company’s business will not continue as a going concern, receivership, sale of the Company’s assets, or transition of the Services to another provider, then your Personal Information may be transferred as part of such a transaction as permitted by applicable laws and/or contract. The use of your Personal Information following any of these events will be governed by the policies in effect at the time the applicable Personal Information was collected.
  16. We may collect information about your activity, or activity on devices associated with you, on the Platform using certain tracking technologies such as cookies, application program interfaces, web beacons and software development kits. This tracking data may be used for the following purposes:
    1. providing useful features for simplifying your experience when you return to the Platform for example feeding your delivery address for future availing of Services;
    2. monitor, evaluate and optimize the use and operations of the Platform; and
    3. deliver relevant content and advertising based on your preferences and usage patterns.
  17. If you choose to register with the Platform through your social media account, you consent that we may collect, store, and utilise the personal information you give us through the social networking interface in line with this Policy.
  18. Additionally, we shall provide you with certain choice about how we use your Personal Information You can opt out of some of the uses of your Personal Information such as advertising tools, online tracking, and promotional emails. However, even if you opt out of getting promotional emails, we will still send you emails regarding details of any services that you avail on the Platform.
  19. We reserve the right to combine the Personal Information we have gathered offline with the information we have collected online.Or, we may combine information we currently have with information we gather from an external source. We may combine your information with the information of other customers to better understand preferences and trends over time or to conduct any research and analysis.
  20. You may at any time choose to provide a written notice to the Company to revoke the consent given by you to share Personal Information with Sellers or any other third parties who are working with the Company. Upon receipt of such notice, we may not continue to provide you with the Services (or any part thereof).
  21. While accessing the Services, you may come across website links or advertisements from other websites that are not operated by us. If you click on any such website links or advertisements, you will be directed to that external website. We have no control over the information collected, stored, and processed by any such external website and assume no responsibility for the same. We, therefore, recommend that you check the policy of each website you visit to better understand your rights and obligations especially when you are submitting any type of content on those third-party websites.

5. Storage and Processing of Personal Information

  1. The Personal Information collected by us will be mostly stored electronically.All such Personal Information shall be transmitted and stored by us in encrypted form in accordance with all the applicable laws to ensure the secrecy and confidentiality of the Personal Information and such information shall not be shared or used except as provided herein.
  2. Subject to relevant regulations, we may engage into arrangements with third parties (in or outside India) to store or process yourPersonalInformation. Any Personal Information transferred to such third parties for processing will only be done if such third parties already have in place such reasonable security standards as may be necessary to avoid any breach or leak of your Personal Information. By accepting this Policy, you expressly consent to and authorise the sharing of your Personal Information with such third parties for storage and processing.
  3. We may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we shall try to delete your Personal Information quickly upon receipt of the request for deletion of such Personal information by you. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers’ files that you have in common with other Users.

6. Sharing of Personal Information

  1. The Company may transfer your Personal Information to any government authority or a law enforcement agency for the following purposes:
    1. for ensuring compliance with provisions of any Act for the time being in force;
    2. for prevention and detection of an offence;
    3. recovery of any debt owed by you to the Company or any other Users in respect of any of the Services; and
    4. upon an order of a judicial or quasi-judicial body.
  2. The Company may transfer, disclose, or share Personal Information of the Buyers with any Sellers registered on the Platform. The Company will make all reasonable efforts to ensure that any such Seller with whom Personal Information is shared enters suitable arrangements with confidentiality obligations that are consistent with this Policy and any other appropriate security measures and on the condition that the Seller use such Personal Information only on behalf of the Company and pursuant to our instructions (such Sellers may use other non-personal information for their own benefit). However, it must be noted that the Company shall not be responsible for any breach of misuse of Personal Information of Buyers by any such Sellers.
  3. Where permitted by law, the Company may provide Personal Information of the Users to joint marketers with whom we have a marketing arrangement. We shall have suitable arrangements with such joint marketers to ensure that there is no misuse of Personal Information and prohibit such joint marketers from making unauthorized or unlawful use of Personal Information.
  4. The Company may share your relevant payment information with:
    1. payment service providers and payment gateways to process payments and facilitate chargebacks or refunds; and for other purposes associated with the acceptance of credit and debit cards; and
    2. with any government agency or upon any order of a judicial or quasi-judicial body for the purpose of prevention and detection of a fraud.
  5. The Company may share your Personal Information with its groupcompanies (which includes our parent, subsidiaries, affiliates, and any other business units) for improving the user experience and providing details about latest offers from the group.

7. Rights and Duties of the User

  1. You shall have the following rights while accessing the Platform:
    1. for reviewing your Personal Information and/or update, correct or amend inaccurate, deficient or incomplete Personal Information, you can contact us at support@bellevie.lifeand we will make reasonable efforts to update the same (to the extent feasible for the Company);
    2. if you no longer want to access the Services provided by the Platform you can request that we erase your Personal Information and close your account. However, any requests for erasure will be acted upon only in accordance with the applicable laws; and
    3. if you face any issues with accessing the Platform you have a right to register a grievance by sending us an email at support@bellevie.life. We will make all reasonable efforts to ensure that your grievance is duly addressed. However, we may refuse requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, may compromise an ongoing investigation, or are impractical.
  2. While adhering to the abovementioned rights, you shall also have the following duties while accessing the Services provided on the Platform:
    1. you shall not furnish any false particulars or impersonate any other person while registering with the Platform;
    2. you shall not make any unauthorised or illegal use of the Platform; and
    3. while accessing the Services provided on the Platform you shall make sure that the payment in respect of those services have been duly made on your behalf.

8. Security and Confidentiality

  1. The Company shall take all reasonable security practices and procedures including but not limited to managerial, operational, and technical to ensure that your Personal Information is protected. We have implemented technology and policies with the objective of protecting your Personal Information from unauthorized access and improper use and shall update these measures as new technology becomes available, as appropriate. We further take back-up of our systems periodically to avoid loss of data. Although we provide appropriate firewalls and protections, our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we take no liabilities or responsibilities for it.
  2. We are strongly committed to protect the information which you share with us while registering or using the Platform. Any of your Personal Information shall not be used or shared other than for the purposes to which you have given your consent either under this Policy or while using the Platform.
  3. Additionally, you are requested to help us protect the confidentiality of your Personal Information by maintaining the secrecy of the user identity and password that we provide to you for accessing the Services on the Platform. If you share your user identity and password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal data and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. We disclaim any liability arising from your failure to do so.

9. Consent

In the event you do not consent to sharing your Personal Information with us for provision of the Services (or any part thereof), we reserve the right to restrict or deny the provision of such Services (or any part thereof).

Where your consent is the basis of processing of your Personal Information, you may withdraw your consent at any time by sending a communication to our email address at support@bellevie.life. The withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. If you withdraw your consent and restrict processing of any Personal Information, the Company may not be able to provide you with the Services (or any part thereof).

10. Disclaimer

  1. The Company shall not be liable to the User for any loss or damage caused because of any disclosure of any information concerning the User’s account and anyonline transactions made using credit or debit cards. Any Personal Information shared by you which is not asked by the Company either during registration or for the purposes of providing the Services shall amount to wilful and intentional furnishing of such information and the Company shall not be liable for breach of such information;
  2. Since the internet is not fully safe and secure, we cannot promise that your use of the Platform will be completely safe either. Any information that you share while registering and/or accessing the Platform is at your own risk. We store Personal Information (or a part thereof) only as long as the purpose for which such information was collected is no longer being served, and the retention of such information is no longer necessary for legal compliances or business purposes. The security of your Personal Information is important to us and we shall strive to use all reasonable means to protect your Personal Information, however, we cannot guarantee its absolute security;
  3. You hereby consent to our collection, use, storing and sharing of your Personal Information as per this Policy. If you use the Services on behalf of someone else, you represent that you are authorised by such individual or are legally authorized to:
    1. accept this Policy on that individual’s behalf; and
    2. consent on behalf of such individual to our collection, use and disclosure of such individual’s Personal Information as described in this Policy.
  4. Due to the various issues that can occur in the electronic distribution of information and due to the limitations inherent in providing information obtained from multiple sources, there may be delays, omissions, or inaccuracies in the content provided on the Platform or delay or errors in functionality of the Platform. As a result, we do not represent that the information posted on the Platform is correct in every case;
  5. Buyer acknowledges thatservices offered by various Sellers are available on the platform. We may have formed partnerships or alliances with some of the Sellers or Societies from time to time to facilitate the provision of certain Services provided to Buyers. However, the Buyer should acknowledge and agree that at no time are we making any representation or warranty on behalf of a Sellerand/ or a Society, nor will we be liable to anyBuyer for any consequences or claims arising from or in connection with Services. The Buyer hereby disclaims and waives any rights and claims that they may have against us with respect to suchservices offered by any Seller and/or Society;
  6. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation /fraud / negligence of the information disclosed shall lie on us nor will we be in any way responsible to verify any information obtained from you; and
  7. We shall not be liable to you or anyone else for any losses or injury arising out of or relating to the information provided on the Platform. In no event will we or our employees and affiliates be liable to you for any decision made or action taken by your reliance on the information provided on the Platform.

11. Review

The Company may conduct such periodical review of this Policy as it deems necessary without giving any prior notification to the Users.Any changes made pursuant to such review shall comply with all the laws for the time being in force.The Company shall post any changes to this Policy on its website at https://bellevie.life/privacy-policy/ to ensure that the Users are made aware of any such changes. If the User continues to use the Services after the effective date of any change, then the access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Policy.

12. Contact Information

If you are facing any issues while accessing the Platform or need any other assistance regarding the use of the Platform you can send an email with your query at support@bellevie.life. You can also write to 176-412, Floor-4, 17GVardhaman Chamber, Cawasji Patel Rd, Horniman Circle, Fort, Mumbai–400011. We assure you that we will make all reasonable efforts to address your queries and/ or grievances as soon as possible.