Privacy Policy

01 General

In this Privacy Notice, the following definitions are used:

• "Data" shall mean personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws) about you, which we collect, receive or otherwise process in connection with your use of our website and/or the Platform.
• "Cookies" means a small file placed on your device by our website or Platform when you either visit or use certain features of our website or Platform. A cookie generally allows a website or mobile application to remember your actions or preference for a certain period of time.
• "Data Protection Laws" shall mean any applicable law for the time being in force relating to the processing of Data.
• "Partners" shall mean select third parties (including Aurum Group Entities) with whom we have contracts for the businesses described in this Privacy Policy.
• "Service Providers" includes entities which provide services to and to whom we may disclose your Data for a specific purpose pursuant to a written contract.
• "Aurum Group Entity" shall mean Aurum RealEstate Developers Limited, and its subsidiaries, affiliates, associate companies and joint venture companies.
• "User or you" shall mean the natural person who accesses our website or Platform.

This Privacy Policy primarily explains how we use your personal data when we act as a controller of your Data. Where we act as a "processor" on behalf of Aurum Group Entity or other participating entity (i.e. the "controller"), please refer to the relevant privacy policy of the relevant participating entity for information about how they use your Data.

• a) This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
• b) This document is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011 that require publishing the rules and regulations, privacy policy and Terms of Use for access or usage of the website or Platform. https://www.aurumrealestate.in/
• c) The headings of each section in this Policy are only for the purpose of organizing the various provisions under this Policy in an orderly manner, and shall not be used by either Party to interpret the provisions contained herein in any manner. Further, it is specifically agreed to by the Parties that the headings shall have no legal or contractual value.
• d) The use of the Website/Platform by the User is solely governed by this Policy as well as the Terms of Use ("Terms", available at www.aurumrealestate.in.com/terms), and any modifications or amendments made thereto by the Company from time to time, at its sole discretion. The User expressly agrees and acknowledges that the Terms and Policy are co-terminus, and that expiry / termination of either one will lead to the termination of the other.
• e) The User unequivocally agrees that this Policy and the aforementioned Terms constitute a legally binding agreement between the User and the Company, and that the User shall be subject to the rules, guidelines, policies, terms, and conditions applicable to any service that is provided by the Website, and that the same shall be deemed to be incorporated into the Terms, and shall be treated as part and parcel of the same. The User acknowledges and agrees that no signature or express act is required to make these Terms and the Policy binding on the User, and that the User's act of visiting any part of the Platform/Website constitutes the User's full and final acceptance of the Policy and the aforementioned Terms.
• f) The Parties expressly agree that the Company retains the sole and exclusive right to amend or modify the Policy and the aforementioned Terms without any prior permission or intimation to the User, and the User expressly agrees that any such amendments or modifications shall come into effect immediately. The User has a duty to periodically check the Policy and Terms, and stay updated on their provisions and requirements. If the User continues to use the Website following such a change, the User will be deemed to have consented to any and all amendments / modifications made to the Policy and Terms. In so far as the User complies with the Policy and Terms, he/she is granted a personal, non-exclusive, non-transferable, revocable, limited privilege to enter, access and use the Website/Platform.

02 What We Collect

We collect Data for various purposes set out in this Privacy Policy.

This Data includes, without limitation, the following categories:

• (a) Contact information: first and last name, email address, postal address, country, phone number and other similar contact data.
• (b) Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.
• (c) Technical information: website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
• (d) Product and service information: Your website or Platform account number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
• (e) Your reviews, feedback and opinions about our products, programmes and services.
• (f) Loyalty programme information: your loyalty information, account details, profile or password details and any frequent flyer or travel partner programme affiliation.
• (g) Transaction information: date of the transaction, transaction amount, transaction history and related details.
• (h) Other information (which may include sensitive personal information or special category personal data): Age, sex, date of birth, marital status, nationality, details of government identification documents provided, occupation or any other personal information provided by you.

The User expressly agrees and acknowledges that the Company collects and stores the User's personal information, which is provided by the User from time to time on the Website, including but not limited to the User's user name, passwords, email address, name, address, age, date of birth, sex, nationality, shopping preferences, browsing history, etc., as well as any images or other information uploaded/published by the User on the Website. The User is aware that this information will be used by the Company/Platform to provide services and features targeted at the User, that are most likely to meet the User's needs, and also to customize and improve the Website to make its user's experiences safer and easier.

If the User chooses to post messages / reviews / feedback anywhere on the Website, including but not limited to message boards, chat rooms, other message areas, etc., the User is aware that any and all such information provided / uploaded will be collected and stored by the Company indefinitely, and that such retained information may be used to resolve disputes, provide customer support, troubleshoot problems, etc., and that such information, if requested, may be provided to judicial or governmental authorities of requisite jurisdiction, or otherwise used by the Company/Website/Platform as permitted by applicable laws.

Nothing contained herein shall be deemed to compel the Website/Company/Platform to store, upload, publish, or display in any manner content/reviews/surveys/feedback submitted by the User, and the User hereby expressly authorises the Website/Company/Platform to remove from the Website any such content, review, survey, or feedback submitted by the User, without cause or being required to notify the User of the same.

03 How We Collect Data

We collect Data in the following ways:

• a. Information You Give Us: We receive and store any information you enter on our website or Platform or give us in any other way. Please see the section below, titled "Data Shared by You" for more information.
• b. Automatic Information We Collect: We use "cookies", pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled "Data That is Collected Automatically" for more information.
• c. E-mail Communications: We often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
• d. Automatic Information We Collect from Other Websites: We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement.
• e. Information from Other Sources: We may obtain information from other sources. An example of this is when you authorize a third-party website (such as the website of another Aurum Group Entity) to interact directly with our website or Platform to provide or receive information about you.

You can make choices about our collection and use of your Data. For example, you may want to access, edit or remove your Data on our website or Platform. When you are asked to provide Data, you may decline. For more information, please see the section below, titled "Your Rights and Choices".

The User is aware that a 'Cookie' is a small piece of information stored by a web server on a web browser so it can later be traced back from that particular browser, and that cookies are useful for enabling the browser to remember information specific to a given user, including but not limited to a User's login identification, password, etc.

The User is further aware that the Website uses data collection devices such as cookies on certain pages of the Website to help analyse web page flow, measure promotional effectiveness, and promote trust and safety. While the User is free to decline the Website's cookies if the User's browser permits, the User may consequently be unable to use certain features on the Website.

04 Data Shared By You

Platform may collect your Data in several ways from your use of our website or Platform. For instance:

• (a) when you register with us to receive our products and/or services;
• (b) when you conduct a transaction or attempt a transaction on our website or Platform;
• (c) when you complete surveys conducted by or for us;
• (d) when you elect to receive any communications (including promotional offers) from us;
• (e) from the information gathered by your visit to our website or Platform;

05 Data That Is Collected Automatically

• (a) We automatically collect some information when you visit our website or use Platform. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
• (b) Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details and language settings.
• (c) We may collect your Data automatically via Cookies, pixels and similar technologies in line with settings on your browser.
• (d) We automatically collect Log Data which may include information such as your IP address, browser type, operating system, referring web page, pages visited, location, mobile carrier, device, search terms, and cookie information.

06 With Whom We Share Personal And Sensitive Information

• (a) The User is aware that the Website/Platform may share the User's personal information with other corporate entities and affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts.
• (b) The User is aware that the Website/Company may disclose personal information if required to do so by law or if the Website/Company in good faith believes that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes.
• (c) The User is further aware that the Website/Company and its affiliates may share / sell some or all of the User's personal information with other business entities should the Company/Website (or its assets) plan to merge with, or be acquired by such business entity, or in the event of re-organization, amalgamation, or restructuring of the Company's business.

07 Our Use Of Data

Data collected by us may be used by us for the following reasons:

• (a) carry out our obligations arising from any contract entered into between you and us;
• (b) provide products and/or services and communicate with you, including through WhatsApp;
• (c) enable Aurum Group Entities and Partners to offer their products and/or services;
• (d) process, disclose, transmit, and/or share Data with Aurum Group Entities and other third parties;
• (e) provide you with offers, personalized services and recommendations;
• (f) operate, evaluate and improve our business, website and Platform;
• (g) generate aggregated data to prepare customer insights;
• (h) provide marketing and promotional campaigns to you based on your profile;
• (i) communicate with you and customize and improve our services;
• (j) enforce the terms of use of our website and Platform;
• (k) protect against and prevent fraud, illegal activity, harm and financial loss;
• (l) serve other purposes authorized or required by applicable law.

Where required under relevant Data Protection Laws, we may need to ensure that there is a legal basis to justify our processing of your Data.

• i. Contractual necessity: Where processing your Data is necessary for us to carry out obligations arising from contracts entered into between you and us.
• ii. Legitimate interests: We may process certain Data where necessary for purposes of legitimate interests pursued by us or a third party, except where overridden by your interests or fundamental rights.
• iii. Consent: Where required under relevant Data Protection Laws, we will seek to obtain your consent before undertaking certain processing activities.
• iv. Direct marketing: Where required by applicable law, we will obtain opt-in consent prior to sharing Data with third parties and undertaking certain marketing activities.
• v. Legal obligations: In certain circumstances we may disclose your Data for purposes of complying with a legal obligation.

You have the right to withdraw your consent to these activities. You can do so at any time, subject to applicable Data Protection Laws.

08 Minors

Our website and Platform do not offer products or services for use by minors. If you are under 18, you may use our website or Platform only with the involvement of a parent or guardian.

09 Sharing Of Data

We may share your Data with the following:

• (a) Partners: Data related to services, products, or applications provided by Partners may be shared with the relevant Partner.
• (b) Aurum Group Entities: We may share your Data with Aurum Group Entities for offering products, services, programmes or campaigns.
• (c) Service Providers: We may share your Data with Service Providers who provide services including data storage, analysis, security, customer service, profiling and payment processing.
• (d) Protecting Aurum: We may release Data when disclosure is reasonably necessary to comply with law, protect intellectual property, prevent fraud or protect individuals' vital interests.
• (e) Business Transfers: Your Data may be transferred as part of a sale, purchase, merger or acquisition involving subsidiaries or business units.
• (f) Third Parties: We may share Data where you request or authorize us to do so, where required by applicable law, or where required to operate and maintain the security of our website or Platform.

The sharing of your Data will be in line with the processes set out in this Privacy Policy.

10 Keeping Data Secure

We will use technical and organizational measures to safeguard your Data and we store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach.

The security of your Platform account depends on you keeping your account password(s), PINs and other access information confidential.

It is your responsibility to control access to your mobile device and Platform on your device and to alert us if you believe that the security of your Data has been compromised.

11 Retention Of Data

ASSPL retains Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website or Platform, or for other essential purposes such as complying with legal obligations, resolving disputes and enforcing agreements.

Even if we delete your Data, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

12 Where We Store Data

We may transfer your Data to recipients in India, where we are headquartered, and other countries. These countries may not have the same data protection laws as the country in which you initially provided the information.

If the GDPR/United Kingdom’s version of the GDPR applies to our processing of your Data, we will only process and/or transfer Data outside of the European Economic Area/United Kingdom where compliant with Data Protection Laws.

• (a) by way of a data transfer agreement incorporating relevant standard contractual clauses;
• (b) by transferring Data to a country found adequate by the European Commission;
• (c) where necessary for conclusion or performance of a contract between us and a third party;
• (d) where you have consented to the data transfer.

13 Your Rights And Choices

Depending on which country's laws are applicable to you, you may have various rights in relation to the Data that we hold about you.

• a) Right to Confirmation and Access – you may ask us to confirm what Data we hold about you and request modification, updating or deletion.
• b) Right to Rectification – you may request correction of inaccurate or incomplete Data.
• c) Right to Erasure – you may request that we erase your Data in certain circumstances.
• d) Right to Restrict Processing – you may request restriction of our processing of your Data in certain circumstances.
• e) Right to Object – you may object to processing of your Data where permitted by applicable law.
• f) Right to Data Portability – you may request transfer of certain Data to another third party.
• g) Right to Withdraw Consent – where processing is based upon consent, you may withdraw that consent at any time.
• h) Right to File Complaints – you may lodge a complaint with the relevant supervisory authority in your jurisdiction.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.

14 Processing Your Data

We take steps to ensure that your Data is processed according to the provisions of this Privacy Policy and the requirements of applicable law.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate written contracts with Aurum Group Entities, Partners and Service Providers that we share your Data with.

15 Severability

If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

16 Links To Other Websites

Our website and Platform may, from time to time, provide links to websites and applications of Aurum Group Entities and Partners whose privacy practices differ from those of ASSPL. We have no control over such websites and applications and are not responsible for their content.

This Privacy Notice applies to our website and Platform only.

17 Cookies, Pixels And Similar Technologies

Our website and Platform may place and access certain Cookies on your device. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device. We also use pixels and similar technologies to analyse traffic on our website and Platform to improve your experience.

18 Changes To This Privacy Policy

Our business changes constantly and our Privacy Notice will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website and Platform frequently to see recent changes.

The updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

19 How To Contact Us

20 User's Consent

By using the Website and/or by providing information to the Company through the Website, the User consents to the collection and use of the information disclosed by the User on the Website in accordance with this Policy, including but not limited to the User's consent to the Company/Website sharing/divulging the User's information, as per the terms contained herein above in Section 4 of the Policy.

21 Grievance Officer

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

22 Dispute Resolution And Jurisdiction

It is expressly agreed to by the Parties hereto that the formation, interpretation and performance of this Policy and any disputes arising here from will be resolved through Arbitration mechanism. It is further agreed to by the Parties that the contents of this Section shall survive even after the termination or expiry of the Policy and/or Terms.

In the event that the Parties are unable to reach such an amicable solution within thirty (30) days of one Party communicating the existence of a dispute to the other Party, the dispute will be resolved by arbitration.

Arbitration. In the event that the Parties are unable to amicably resolve a dispute by mediation, said dispute will be referred to arbitration by a sole arbitrator to be appointed by the Company, and the award passed by such sole arbitrator will be valid and binding on both Parties.

The Parties shall bear their own costs for the proceedings, although the sole arbitrator may, in his/her sole discretion, direct either Party to bear the entire cost of the proceedings. The arbitration shall be conducted in English, and the seat of Arbitration shall be the city of Mumbai in the state of Maharashtra, India.

The Parties expressly agree that the Terms, Policy and any other agreements entered into between the Parties are governed by the laws, rules and regulations of India, and that the Courts at Chennai shall have exclusive jurisdiction over any disputes arising between the Parties.