PRIVACY POLICY

1. INTRODUCTION AND SCOPE

Rohom Realty (“Rohom Realty”, “Rohom”, “we”, “us” or “our”, as the context may require) respects your privacy and is committed to handling Personal Data in a lawful, fair, transparent and responsible manner.

This Privacy Policy (“Privacy Policy” or “Policy”) explains how we may collect, receive, use, process, store, disclose, share, retain and protect Personal Data in connection with our business, projects, operations, Website, digital platforms and interactions with you.

This Policy applies to Personal Data collected through or in connection with our website at www.rohomrealty.com and any webpages, microsites or digital platforms operated under or in connection with the Rohom Realty brand (collectively, the “Website”); enquiries and registrations of interest; project visits, exhibitions, events and promotional activities; telephone calls, emails, SMS, WhatsApp and other communications; bookings, allotments, agreements, transactions, possession and post-possession interactions; channel partners, brokers and intermediaries; landowners, development partners, consultants, contractors and other business counterparties; recruitment and employment; customer relationship management systems, forms, portals and databases; and information lawfully received by us from third parties or other sources.

References to “Rohom Realty”, “Rohom”, “we”, “us” or “our” shall, where the context so requires, include Rohom Realty and the relevant entities or persons associated with projects or activities undertaken under the Rohom Realty brand.

For the purposes of this Policy, “Personal Data” shall have the meaning assigned to it under applicable law and generally means data about an individual who is identifiable by or in relation to such data.

By accessing our Website or voluntarily providing Personal Data to us, you acknowledge that you have had the opportunity to read and understand this Privacy Policy. Personal Data will be processed in accordance with applicable law and, where required, on the basis of appropriate consent or other lawful grounds available to us.

2. PERSONAL DATA WE MAY COLLECT

The nature of Personal Data collected by us will depend upon your interaction with Rohom and the purpose for which such information is required. We may collect the following categories of Personal Data:

2.1 Identity and Contact Information

This may include your name, photograph, signature, age, gender, date of birth, nationality, PAN, Aadhaar details where lawfully required and permitted, passport or other government-issued identification, KYC documentation, mobile and telephone numbers, email address, residential or correspondence address and other relevant contact particulars.

2.2 Customer and Property-Related Information

This may include property preferences, project or unit of interest, configuration preferences, budget range, investment requirements, source of enquiry, site-visit records, booking and application details, allotment information, transaction history, correspondence, agreements, registration, possession and handover information, customer-service requests and post-handover interactions.

2.3 Financial and Transaction Information

Where applicable, this may include bank account information, payment and transaction records, payment schedules, loan-related documentation where assistance or coordination is sought, refunds, invoicing details, tax or statutory-payment information and other information reasonably required for a transaction.

We do not intend to unnecessarily collect or retain confidential payment credentials where payments are processed directly by banks, payment gateways or other authorised service providers.

2.4 Channel Partner, Broker, Consultant and Intermediary Information

This may include individual and business contact details, organisation or firm particulars, RERA registration and other professional registrations, KYC and onboarding documents, agreements, lead and transaction information, brokerage, commission, fees and incentives, performance information and related financial or statutory records.

2.5 Landowner, Development Partner and Business Counterparty Information

This may include identification, contact, ownership, title-related, authority, contractual, financial and other relevant information relating to landowners, co-owners, development partners, contractors, consultants, vendors, advisers, other business counterparts and their representatives.

2.6 Recruitment and Employment Information

Where applicable, this may include résumés, educational and professional qualifications, employment history, references, identification and contact details, onboarding records, compensation, bank and statutory information, attendance, designation, roles and responsibilities, performance-related information and other employment or workforce-management records.

2.7 Marketing and Communication Information

This may include enquiries, requests for brochures or project information, registrations of interest, communications through telephone, email, SMS or WhatsApp, feedback, surveys, customer-support interactions, participation in events or campaigns and communication preferences.

2.8 Technical and Usage Information

When you use our website or digital platforms, we or service providers acting on our behalf may automatically collect information such as IP address, device and browser information, operating system, access logs, cookies and similar technologies, referring or exit pages, pages viewed, duration of visits, navigation and interaction information and other technical or usage information relating to the Website.

2.9 Communications With Us

We may retain communications made through contact forms, telephone, email, WhatsApp, SMS, social media, virtual assistants, customer-support channels and other electronic or physical communications. Where permitted by law and appropriate notice has been provided, communications may also be monitored or recorded for quality, security, training, evidence or compliance purposes.

3. HOW WE COLLECT PERSONAL DATA

We may collect Personal Data:

Directly from you, including when you submit an enquiry, register an interest in a project, request information, arrange a site visit, make a booking or purchase, provide documentation, correspond with us, attend an event, participate in a survey or campaign, enter into a transaction or submit an employment application;

Automatically, through our website, digital platforms, server logs, cookies, analytics tools and similar technologies; and

From third parties or other lawful sources, including channel partners, brokers, authorised sales representatives, consultants, professional advisers, landowners or development partners, contractors, vendors, banks, payment providers, advertising or analytics platforms, social-media platforms, event organisers, publicly available sources, government or regulatory records and other persons through whom you have interacted with us or expressed interest in our projects or services.

Where another person provides Personal Data relating to you, we expect such person to have the necessary authority or lawful basis to provide such information.

4. HOW WE MAY USE PERSONAL DATA

We may collect, use and process Personal Data for purposes connected with our business and operations, including:

4.1 Projects, Enquiries and Customer Transactions

To plan, develop, market, sell, lease or manage real-estate projects; respond to enquiries; provide project information; arrange site visits; identify customer requirements; manage applications, bookings, allotments, documentation, agreements, payments, registration, possession and handover; provide customer support; coordinate with banks or financial institutions where requested; and otherwise administer customer or prospective customer relationships.

4.2 Marketing and Communications

Subject to applicable law and consent requirements, to provide information about projects, launches, offers, events, campaigns and other products or services which may be relevant to you; undertake customer research; measure campaign effectiveness; and communicate through telephone, email, SMS, WhatsApp or other appropriate channels.

You may opt out of promotional communications through an available unsubscribe or opt-out mechanism or by contacting us. Transactional, service-related or legally necessary communications may continue where required.

4.3 Channel Partners and Business Relationships

To onboard, verify, engage and manage channel partners, brokers, real-estate agents, consultants, intermediaries, landowners, development partners, contractors, vendors and other counterparties, including lead management, regulatory verification, documentation, commissions and brokerage, project execution and other commercial or professional activities.

4.4 Recruitment and Employment

To assess candidates, conduct recruitment and onboarding, administer employment or professional relationships, payroll, attendance, performance, statutory compliance, workplace administration, security and separation.

4.5 Website and Internal Business Operations

To operate, secure and improve our Website, systems and services; analyse Website traffic and usage; troubleshoot technical issues; maintain records; undertake internal administration, accounting, audits, reporting, analytics, risk management, security, fraud prevention, quality control and business planning.

4.6 Legal and Regulatory Purposes

To comply with applicable laws and regulatory requirements, including real-estate and RERA requirements, taxation, accounting, KYC, registration, employment and other statutory obligations; respond to lawful directions or proceedings; establish, exercise or defend legal rights or claims; investigate fraud or misconduct; and protect our personnel, customers, property, projects, systems and business interests.

4.7 Other Related Purposes

For purposes incidental or reasonably related to those stated above, any purpose notified to you at the time of collection, or any other purpose permitted under applicable law.

5. BASIS OF PROCESSING

We process Personal Data on the basis of consent where required, where you voluntarily provide information for a specified purpose, for uses recognised or permitted under applicable law, and where processing is otherwise necessary or permitted for our lawful business, contractual, statutory or regulatory purposes.

Where processing is based upon your consent and applicable law permits withdrawal of such consent, you may withdraw it in the manner made available to you. Withdrawal will not affect processing lawfully undertaken before such withdrawal.

Where particular Personal Data is necessary to process an enquiry, undertake a transaction, comply with law or provide a requested service, failure to provide such information or withdrawal of the relevant consent may prevent us from processing or continuing the relevant request, transaction or service.

6. DISCLOSURE AND SHARING OF PERSONAL DATA

We do not sell or rent Personal Data as a standalone commercial product.

We may, however, disclose or share Personal Data to the extent reasonably required for the purposes described in this Policy with:

• Our authorised personnel and internal teams, including sales, marketing, customer relations, accounts, legal, projects, administration, information technology, human resources and management;

• The relevant promoter, developer, project entity or person associated with the project in respect of which you have made an enquiry, undertaken a transaction or otherwise interacted with us;

• Service providers and professional advisers, including providers of Website hosting, cloud services, information technology, CRM systems, communications, marketing, analytics, payment processing, banking, accounting, auditing, legal, architectural, engineering, project-management and other professional or operational services;

Channel Partners, Brokers, Sales intermediaries and referral partners, where relevant to an enquiry, site visit, lead, transaction or customer interaction;

Project and Transaction counterparts, including landowners, Development Partners, Consultants, contractors, architects, engineers, facility managers and other persons involved in the relevant project or transaction;

Banks, Financial Institutions and payment service providers, where relevant to payments, transactions, financing or verification;

Governmental, statutory, regulatory, judicial or law-enforcement authorities, where required or permitted by applicable law; and

Other appropriate persons, where disclosure is required in connection with a proposed or completed project transfer, financing, restructuring, development arrangement, sale or acquisition of a business or asset, enforcement of legal rights, prevention of fraud, protection of persons or property, your consent or instructions, or any other lawful purpose.

Where appropriate, third parties processing Personal Data on our behalf may be subject to contractual, confidentiality, security or data-protection obligations.

7. COOKIES AND TRACKING TECHNOLOGIES

Our website and digital communications may use cookies, pixels, analytics tools and similar technologies to operate and secure the Website, remember preferences, understand Website usage, improve user experience, analyse traffic and measure advertising or campaign performance.

You may manage or disable cookies through your browser or device settings and, where available, through any preference facility offered on our Website. Disabling certain cookies may affect Website functionality or user experience.

8. THIRD-PARTY WEBSITES AND SERVICES

Our Website or communications may contain links to or integrations with third-party websites, social-media platforms, payment providers, map services or other online services.

Such third parties operate independently of us and may have their own privacy practices. This Privacy Policy does not govern Personal Data that you provide directly to an independent third party, and you should review the applicable privacy policy and terms of any such service before providing Personal Data to it.

We are not responsible for the privacy, security or content practices of independent third-party websites or services merely because a link or integration is made available through our Website.

9. DATA SECURITY AND STORAGE

We take reasonable technical, organisational, administrative and physical measures designed to protect Personal Data under our control against unauthorised access, disclosure, misuse, loss, alteration, destruction or other unauthorised processing.

Personal Data may be stored or processed on systems operated by us or by third-party service providers in India or other jurisdictions, subject to applicable law.

Where appropriate, service providers processing Personal Data on our behalf may be required to maintain reasonable confidentiality, security or data-protection safeguards.

However, no method of transmission over the internet or electronic storage is completely secure, and absolute security of information cannot be guaranteed.

10. DATA RETENTION

We may retain Personal Data for as long as reasonably necessary for the purpose for which it was collected; for an ongoing transaction, service or relationship; for accounting, audit, record-keeping or contractual purposes; to comply with legal or regulatory requirements; to establish, exercise or defend legal rights; or for such other period as may be permitted under applicable law.

When Personal Data is no longer required and there is no lawful reason for retaining it, we will take reasonable steps to delete, destroy, anonymise or otherwise dispose of it appropriately.

11. YOUR RIGHTS AND CHOICES

Subject to applicable law, including the Digital Personal Data Protection Act, 2023 and the rules framed thereunder as and when the relevant provisions apply, you may have the right to:

• Access information regarding Personal Data being processed about you; correct, complete or update inaccurate or incomplete Personal Data; request erasure where continued retention is not required for a lawful purpose; withdraw consent where the relevant processing is based upon consent; modify or opt out of promotional communications; and raise a grievance regarding the handling of your Personal Data.

• Applicable rights may be subject to legal exceptions, verification requirements and procedures prescribed from time to time.

12. CHILDREN’S PERSONAL DATA

Our website and general marketing activities are not specifically directed towards children.

Personal Data relating to a minor may nevertheless be processed where legitimately required in connection with a property transaction, family or ownership arrangement, employment-related matter or other lawful business activity. Any such Personal Data will be handled in accordance with applicable law.

If you believe that Personal Data relating to a minor has been provided to us improperly, you may contact us at the details stated below.

13. CHANGES TO THIS PRIVACY POLICY

We may amend, update or modify this Privacy Policy from time to time to reflect changes in our business, Website, technology, data practices or applicable law.

The revised Privacy Policy will be posted on this Website and, unless otherwise required by law, will become effective upon publication or from such other date as may be specified.

We encourage you to review this Privacy Policy periodically to remain informed about how we handle Personal Data.

Where applicable law requires separate notice or consent in relation to a material change, we will take such steps as may be required.

14. GRIEVANCE REDRESSAL AND CONTACT US

If you have any questions regarding this Privacy Policy or the manner in which your Personal Data is handled; wish to exercise a right available under applicable law; wish to modify your communication preferences; or have a complaint or grievance regarding our collection, use, disclosure, storage, retention or processing of Personal Data, you may contact us at:

Rohom Realty
1401, Supreme Headquarters
14th & 33rd Road, Bandra (West)
Mumbai – 400050, Maharashtra, India
Email / Grievance Redressal: info@rohomrealty.com
General / Sales Enquiries: sales@rohomrealty.com
Telephone: +91 22 6857 3887 | +91 22 4668 2121
Mobile: +91 91170 90099

We may request reasonable information to verify your identity or authority before processing a request relating to Personal Data.

15. GENERAL

This Privacy Policy should be read together with the applicable Website Terms and Conditions of Use, Important Disclaimer and any project-specific, transaction-specific or service-specific terms, notices, forms, consents or agreements applicable to a particular interaction.

Where a specific privacy notice or consent applies to a particular activity, such specific notice or consent shall apply to that activity to the extent of any inconsistency with this general Privacy Policy, subject to applicable law.

Nothing in this Privacy Policy shall prevent any collection, retention, disclosure or processing of information that is required or permitted under applicable law.