Privacy Policy

1. Introduction

This Privacy Policy ("Policy") explains how ("VTP Realty," "we," "us," or "our") collects, uses, shares, and protects your personal data when you interact with our website, landing pages, and related services. We are committed to safeguarding your privacy and handling your personal data in a transparent and secure manner, in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), and other applicable laws.  

By accessing our website or using our services, you consent to the practices described in this Policy. We may update this Policy periodically to reflect legal, regulatory, or operational changes. Any updates will be communicated through our website or other appropriate channels.  

2. Definitions

To help you understand this Policy, here are some key terms:

• Personal Data: Any information that can identify you, directly or indirectly. This includes, but is not limited to, your name, contact details, IP address, and online identifiers.  
• Sensitive Personal Data: Certain categories of personal data that require heightened protection, such as precise location information, financial data, biometric data, or health information.  
• Data Principal: This refers to you, the individual whose personal data is being processed.  
• Data Fiduciary: This is VTP Realty, the entity that alone or jointly with others determines the purpose and means of processing your data. We are responsible for ensuring your data is handled lawfully.  
• Data Processor: Any entity that processes personal data on behalf of VTP Realty.  

3. Data We Collect

We collect various types of personal data to provide and improve our services. This data may be collected directly from you or automatically as you interact with our platforms.  

3.1. Information You Provide Directly: When you interact with our website or landing pages, such as submitting an inquiry form, registering for an account, or communicating with us, you may provide:

• Contact Information: Your name, email address, phone number, and mailing address.  
• Inquiry Details: Information you provide in your messages or inquiries about properties, services, or sales.  
• Account Information: Usernames and passwords if you create an account.  

3.2. Information Collected Automatically: As you browse our website, we may automatically collect certain information through cookies, web beacons, and similar tracking technologies ("information surf"). This includes:

• Device and Usage Data: Your IP address, browser type, operating system, pages viewed, time spent on pages, and referring URLs.  
• Geolocation Data: Approximate or precise location information derived from your IP address or device settings, used for location-based advertising and personalized recommendations. This is considered sensitive data in many jurisdictions and requires explicit consent.  
• Consumer Shopping Patterns and Interests: Data on products viewed, items added to cart, and other browsing behaviors.  
• Login Information: To keep you logged in or remember your preferences.  

4. How We Use Your Data (Purposes of Processing)

We collect and process your personal data only for specific, clearly defined, and lawful purposes. We will not use your data for unrelated purposes without obtaining your fresh consent.  

Your data is used for the following purposes:

• To Respond to Your Inquiries: To process and respond to your questions, requests, or inquiries submitted through our forms.  
• To Provide Services and Sales Communications: To deliver information about properties, services, and sales relevant to your interests.  
• For Marketing and Promotional Communications: To send you updates, exclusive offers, and information about VTP Realty projects via email and SMS, where you have provided explicit consent.  
• For Personalized Marketing and Advertising: To provide personalized property recommendations and targeted advertisements, including location-based advertising, based on your browsing activity and approximate location data, where you have provided explicit consent.  
• To Improve Our Website and Services: To analyze website usage, understand user behavior, and enhance your experience on our platforms.  
• To Comply with Legal Obligations: To fulfill any legal or regulatory requirements.  

5. Lawful Basis for Processing

Under the DPDP Act, we process your personal data primarily based on your consent.  

• For activities like marketing, sales communications, and personalized advertising (including location-based advertising), we will obtain your explicit, informed, specific, unconditional, and unambiguous consent, demonstrated through a clear affirmative action.  
• The DPDP Act prohibits pre-ticked boxes or implied consent from inactivity (e.g., merely browsing a website).  
• Consent cannot be made a precondition for accessing a service or product unless the data processing is strictly necessary for the delivery of that specific service or product. Public parts of a website should remain accessible even if a user declines consent for non-essential data processing.  
• In limited circumstances, the DPDP Act allows for "legitimate uses" where consent is not required (e.g., for legal compliance, medical emergencies, or employment purposes). However, our core commercial activities, such as advertising and marketing, typically require your consent.  

6. How We Share Your Data

We may share your personal data with third parties only for the purposes outlined in this Policy and where legally permissible. This may include:

• Service Providers: Third-party companies that perform services on our behalf, such as marketing agencies, CRM providers, IT support, and analytics providers. These providers are obligated to protect your data and use it only for the purposes we specify.  
• Legal and Regulatory Authorities: When required by law, court order, or to protect our rights, property, or safety.  
• Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred as part of that transaction.

7. Your Rights as a Data Principal

The DPDP Act grants you significant rights over your personal data. We are committed to honoring these rights:  

• Right to Access: You have the right to request a summary of your personal data that we are processing and the manner in which we are doing it.  
• Right to Correction and Completion: You can request us to correct, complete, or update any inaccurate, incomplete, or outdated personal data we hold about you.  
• Right to Erasure: You can request the deletion of your personal data when it is no longer necessary for the purpose for which it was collected, or if you withdraw your consent and there is no other lawful basis for its retention.  
• Right to Withdraw Consent: You have the right to withdraw your consent at any time. The process for withdrawing consent will be "as easy as giving consent". Upon withdrawal, we will cease processing your data unless its retention is specifically mandated by another law.  
• Right to Grievance Redressal: If you have any concerns or issues regarding the processing of your personal data, you have the right to raise a grievance with us. We are obligated to respond to your grievances within a prescribed timeframe. You are generally required to exhaust this internal redressal opportunity with VTP Realty before escalating your complaint to the Data Protection Board.  
• Right to Nominate: You have the right to nominate another individual who can exercise your rights on your behalf in the event of your death or incapacity.  

To exercise any of these rights, please contact our Grievance Officer using the details provided in the "Contact Us / Grievance Redressal" section below. We will process your request within or as required by law.  

8. Data Security

We implement robust technical and organizational measures to protect your personal data from unauthorized access, loss, alteration, disclosure, or destruction. These measures include:  

• Encryption: Using encryption protocols (e.g., AES-256) for sensitive data.  
• Access Controls: Restricting access to personal data based on role and necessity.  
• Regular Audits: Conducting regular security assessments and compliance reviews.  
• Incident Response: Maintaining procedures to address potential data breaches promptly.  
• Multi-Factor Authentication (MFA): Implementing MFA to prevent unauthorized access.  

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or until you withdraw your consent, unless a longer retention period is required or permitted by law. After the retention period, your data will be securely deleted or anonymized.  

10. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or legal guardian and believe that your child has provided us with personal data, please contact us immediately, and we will take steps to remove such information from our records. The DPDP Act specifically prohibits behavioral tracking, targeted advertising, and any processing detrimental to children under 18 years of age, requiring verifiable parental consent for their data.  

11. Cookies and Tracking Technologies

This section details how VTP Realty uses cookies and similar tracking technologies on its website and landing pages. These technologies are essential for website functionality, analytics, and delivering personalized advertising experiences.  

11.1. What are Cookies? Cookies are small text files stored on your device (computer, tablet, mobile phone) by websites you visit. They record your local settings and browsing history. While some cookies are essential for a website to function, others collect data for various purposes, including advertising.  

11.2. Types of Cookies We Use and Data Collected: We categorize cookies based on their purpose to provide you with granular control over your privacy preferences.  

11.3. How We Use Advertising Data (User Use Cases): The data collected through cookies and other tracking technologies fuels various advertising strategies designed to increase relevance and engagement.  

• Behavioral Targeting: We analyze your browsing history, search terms, and interactions across our website and, where permissible, other online platforms to deliver personalized content and advertisements that are more relevant to your interests.  
• Retargeting (Remarketing): If you have previously visited our website or interacted with our brand (e.g., viewed a property, added an item to a cart but did not complete a purchase), we may display targeted advertisements to you on other websites or social media platforms to remind you of your interest and encourage re-engagement. This is often done using a "pixel" that places a cookie on your browser.  
• Lookalike Audiences: We may use data from our existing customer base (e.g., email lists, website activity, YouTube engagement) to identify new potential customers who share similar characteristics. This allows us to expand our reach to individuals who are more likely to be interested in VTP Realty's offerings.  
• Geolocation-Based Advertising: With your explicit consent, we may use your approximate or precise location data to deliver highly relevant, location-specific content and advertisements, such as promoting properties near your current location.  

11.4. Third-Party Cookies and Data Sharing: Some cookies on our website are placed by third-party service providers (e.g., advertising networks, analytics providers, social media platforms) to help us deliver and measure our advertising campaigns. These third parties may collect data about your browsing activity across different websites to provide personalized ads. We ensure that any third parties with whom we share data are committed to data protection standards.  

11.5. Managing Your Cookie Preferences: You have the right to control your cookie preferences. Our cookie consent banner, which appears when you first visit our website, provides options to:  

• Accept All: Consent to the use of all cookies as described in this policy.
• Reject Non-Essential: Opt-out of cookies that are not strictly necessary for the website's operation (e.g., analytics, advertising, social media cookies).
• Customize Settings: Select which specific categories of cookies you consent to.

You can change or withdraw your cookie consent at any time by clicking the "Cookie Settings" link typically found in our website's footer or privacy center. Upon withdrawal, we will cease the collection and processing of data through the affected cookies.  

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of any significant changes by posting the updated Policy on our website with a revised "Last Updated" date. We encourage you to review this Policy periodically.  

13. Contact Us / Grievance Redressal

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Grievance Officer:  

Grievance Officer Details: 

Name: Rohit Varude 

Email: rohit.varude@vtprealty.in  

Address:  VTP Realty VTP House, Nagar Rd, next to Shakti Sports, Kargil Vijay Nagar, Wadgaon Sheri, Pune, Maharashtra 411014  

Phone: 02066850000

We are committed to addressing your concerns promptly and effectively.