Introduction

RealEstate Talk Limited is a private limited company formed, organized, and registered in the United Kingdom, bearing company number: 12834415, having its registered office at Premier Business Centre 47-49 Park Royal Road London, NW10 7LQ and marketed and represented in India by Rete BPO Services Private Limited, having CIN number: U74999MH2022PTC396007, having registered office at 4th floor, Bhairav Milestone, Plot – 15, Road No. 16, Wagle Industrial Estate, Thane 400 604 (“RealEstate Talk”/ “we”/ “our”/ “us”).

We provide digital marketplace for our members so that they can advertise properties online on “RealEstate Talk” a website, mobile application and web application (“Platform”). “Our members” include individual landlords, property investors, individual property buyers, tenants, new homes developers and overseas property owners, property service providers such as mortgage advisors, solicitors, surveyors, removal, builders, architects etc. We are not an estate agency. References to “you”, “users”, “your” and/or “yours” shall mean the users/members and whose personal data are collected by us whether directly and/or indirectly either visiting to the Platform or from any third party.

Please read this policy carefully to understand our practices with respect to personal data.

Please also refer to our Cookie Policy which explains the use of cookies and other web tracking devices via our website.

  1. Scope of the Privacy Policy
    1. This privacy policy (the “Privacy Policy”) applies to all personal information (also referred as personal data) processing activities carried out by RealEstate Talk either through the use of any websites owned, operated, managed and controlled by RealEstate Talk and/or any mobile applications owned, operated, managed and controlled by RealEstate Talk and/or any web applications owned, operated, managed and controlled by RealEstate Talk and/or through any of its social media pages.
    2. RealEstate Talk is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide) through the use of our website and/or mobile applications and/or web application.
    3. We will not knowingly disclose your personal information to third parties, except as provided in this Privacy Policy. We will take reasonable steps to protect the personal information we collect from you.
    4. When you visit the Platform, you are not required to provide any personal information unless and until you choose to create an account/register and avail our services.
    5. We respect individuals’ rights to privacy and to the protection of personal information and are committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to explain how our organization uses the personal data we collect from you in connection with our business and services and when you use our Platform. If you do any or all of the following, you indicate that you have read, understood, and agreed to this Privacy Policy:

      a. explicitly accepting this Privacy Policy such as by ticking a checkbox;
      b. accessing the Platform;
      c. creating an account on the Platform;
      d. accessing an account on the Platform;
      e. subscribing to a plan or making payment;
      f. contacting the Platform;
      g. undertaking any other action that involves interacting with the Platform.
    6. “Personal information and/or Personal Data” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Policy from time to time. When we do, we will communicate any changes and publish the updated Privacy Policy on our Platform. We would encourage you to visit our Platform regularly to stay informed of the purposes for which we process your information and your rights to control how we process it. We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
  2. How we obtain your personal data?
    1. As part of our business practices and the services we provide, we regularly receive personal data from you. You directly provide us with most of the data we collect. We generally collect your personal data in the following ways:
      • when you use our services.
      • from you and any devices (including mobile devices) you use when you register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or dispute resolution or when you otherwise correspond with us.
      • Some of this personal data we collect are necessary to enter into our Terms of Use. The provision of all other personal information is voluntary but may be necessary in order to use our services, such as the offer details or contact information, pictures needed to post as an advertisement of the property and services.
      • When you browse or interact with our website(s) or use any of our services from our mobile application(s).
      • When you provide your personal data to us in other circumstances, such as when you request details about or attend a company sponsored event, or correspond to us as part of any email or marketing campaigns.Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
      • Use or view our website(s) via your browser’s cookies.
      • Information that we gather through cookies or similar tracking tools (e.g. pixels) when you use our Platform. Advertising or targeting cookies or similar technologies may also be used to track your responses to particular adverts, messages or forms, which helps us to ensure we present you with the most relevant content in the future.
    2. While ordinarily, you would provide us with your personal data directly, in some cases, we may collect data about you from other sources as follows:
      • We may gather your data from publicly available sources, such as the press, the electoral register, company registers and online search engines.
      • We may gather your data when you log in to our Platform through any social media network, e.g. Facebook, Google, etc.
      • We may gather information from you when you contact our customer services team.
  3. The personal data that we process
    We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We limit the collection and processing of information necessary to achieve one or more of our legitimate purposes as identified in this policy document.
    1. Personal information may include:
      • basic personal information, including name, address, contact details, personal and professional title.
      • contact information, such as your physical address, email address and phone number(s).
      • financial information, including account and transactional information. We may use different Payment gateway for the payment of our services.
      • visual images and personal appearance (such as profile pictures).
      • technical information (including your IP address), such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically.
      • information you may provide to us for the purposes of attending meetings and events organized and sponsored by us.
      • any additional information provided voluntarily by you, such as feedback, surveys, or user-generated content.
    2. Personal data also includes data that you give us when you use our services or register for an account with us:
      • Identifying information such as your name, addresses, telephone numbers or email addresses when you register for an account with us.
      • Information you provide when posting an ad, responding to an ad or other transaction-based content that you generate or that is connected to your account as a result of a transaction you are involved in.
      • Additional information we are required or authorized by applicable national laws to collect and process in order to authenticate or identify you or to verify the information we have collected.
    3. Personal data also includes data that we collect automatically when you use our services or register for an account with us:
      • We collect information about your interaction with our services, your advertising preferences, and your communications with us. This is information we receive from devices (including mobile devices) you use when you access our services. This information could include the following: Device ID or unique identifier, device type, ID for advertising, and unique device token.
      • Location information, including location information from your mobile device. Please note that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.
      • Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
    4. Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.
    5. Unless specifically requested, we ask that you do not send us and you do not disclose, on or through the Platform or otherwise to us, any sensitive personal information, including any of the following: (i) racial or ethnic origin; (ii) political opinions; (iii) religion; (iv) ideological or other beliefs; (v) physical, physiological and mental health condition; (vi) sexual orientation; (vii) biometrics information or genetic characteristics; (viii) national identification numbers/Aadhar card number; (ix) OTP; or (x) any other sensitive personal data information.
    6. You understand that you shall be solely responsible for the accuracy and truthfulness of the personal information shared with us. In the event you are sharing any personal information on behalf of a third person, you represent and warrant that you have the necessary authority to share such personal information with us and we shall not be responsible for verifying the same. You understand and acknowledge that such personal information shall be subject to the terms and conditions of this Privacy Policy.
    7. You understand that you shall be solely responsible for the accuracy and truthfulness of the personal information shared with us. In the event you are sharing any personal information on behalf of a third person, you represent and warrant that you have the necessary authority to share such personal information with us and we shall not be responsible for verifying the same. You understand and acknowledge that such personal information shall be subject to the terms and conditions of this Privacy Policy.
  4. How we use your personal data
    We use the data we obtain from you (subject to choices you make) to
    operate, provide, improve, understand, customize, support, market our Services,
    provide you with a personalized experience on our sites,
    contact you about your account,
    provide you customer service,
    provide you with personalized advertising and marketing, and
    to detect, prevent, mitigate, and investigate fraudulent or illegal activities.
    Additionally, we use the personal data we collect from you for a range of different business purposes and according to different legal bases of processing.
    Below is a summary of how we use your data:
    1. We use the information we have, to operate and provide our services, including providing customer support, and improving, fixing, and customizing our services. We understand how people use our services and analyse and use the information we have to evaluate and improve our services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
    2. We verify accounts and activity and promote safety and security on our services, such as by investigating suspicious activity or violations of our Terms, and to ensure our services are being used legally.
    3. We use the information we have to communicate with you about our services and features and let you know about our terms and policies and other important updates. We may provide you marketing for our services.
    4. We help users, who use our services, measure the effectiveness and distribution of their services and messages and understand how people interact with them on our services.
    5. We use your personal information to pursue our legitimate interests provided that such interests are not overridden by your interests or your fundamental rights and freedoms. We have implemented controls to balance our interests with your rights. This includes:
      • Processing that is necessary for purposes of the legitimate interests of RealEstate Talk.
      • For any purpose related to the foregoing or for any purpose for which you provided the personal data to us.
      • Improving our services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience.
      • Contact you via email, postal mail or telephone in order to offer you coupons, discounts and special promotions, poll your opinions through surveys or questionnaires and inform you about our services, as authorized by applicable law.
      • Contact you about public policy matters, or other current events, related to your ability to use our services. This could include an invitation to join a petition, letter writing, call or other sort of public policy related campaigns.
      • Deliver targeted marketing, service updates, and promotional offers based on your communication preferences.
    6. If you have given us your express consent, we may process your personal data for additional purposes. Additional purposes for which we may process your personal data may include:
      • Communicating with you with respect to legal developments, announcements, events in relation to our products and services which may be of interest to you.
      • Distributing surveys or marketing materials.
      • Gathering information regarding your preferences to improve the quality of our communications and interaction with you, such as through website analytics or the tracking of our client publications. and
      • Any other purpose for which you have given consent.
      • You have the right to withdraw your consent at any time and we will honour the same.
  5. Changes to the way we use your information
    From time to time, we may change the way we use your information. Where we believe you may not reasonably expect such a change, we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes, it may not be possible for us to continue to operate your account and/or provide certain products and services to you.
  6. How we share your personal data
    1. You share your information as you use and communicate through our services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our services. We may disclose your personal data to other members of the RealEstate Talk corporate family and/or to third parties. This disclosure may be required for us:
      • to provide you access to our services,
      • to comply with our legal obligations,
      • to enforce our Terms of Use,
      • to facilitate our marketing and advertising activities, or
      • to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our services.
    2. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.
    3. We do not provide the phone numbers of the users on our Platform. However, if you have used email address or phone number in the “Name” or “Nick Name” fields in your profile, this may be visible to other users of the Platform. The in-built chat functionality can be used to communicate with other users of the Platform. You may decide to share your contact details directly to other users via chat message however we do not recommend the same.
    4. Users and businesses with whom you communicate may store or reshare your information (including your phone number or messages) with others on and off our services.
    5. We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms.
    6. If you interact with a third-party service linked through our services, you may be providing information directly to such third party. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
    7. We may also disclose your personal data to the following parties for the following purposes:
      • a. Financial institutions and partners: Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions, payment processing and customer support). These third-party financial institution partners will use your personal information to send you marketing communications only if you have requested their services. When you use any of our paid services, your data may also be disclosed to service providers. We encourage you to check their policies with regards to data management before using their services.
      • b. Law enforcement, legal proceedings, and as authorized by law:
        • To comply with our legal requirements, enforce our Terms of Use, respond to claims that any advert listing or other content violates the rights of others, or protect anyone’s rights, property, or safety.
        • To law enforcement or governmental agencies, or authorized third-parties, in response to a verified request or legal process relating to a criminal investigation or alleged or suspected illegal activity or any other activity that exposes us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, User ID history, device ID, IP address, fraud complaints, offers and listing history.
        • To credit agencies or bureaus as authorized by applicable national laws (e.g. information on late or missed payments or other defaults on your account that may be reflected in your credit report or file).
        • To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal basis, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.
      • c. Change of Ownership: If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our Privacy Policy and standards. In the event of a merger/amalgamation/de-merger and/or takeover, we will make every effort to ensure that the new entity follow this Privacy Policy with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this Privacy Policy, you will receive prior notification of the processing of your personal information for the new purposes.
    8. Irrespective of how we obtain your personal data, it may be shared among all the offices within RealEstate Talk. Our Privacy Policy requires all offices to ensure a level of data protection at least as protective as those mandated by the applicable law in the territory in which RealEstate Talk operates and user having presence.
    9. Please note that all data mentioned herein including but not limited to Google user data are stored, shared, processed in the ways as mentioned in this document and not in any other way.
  7. Keeping your personal data secure
    1. We will take appropriate technical and organizational measures against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data in accordance with our internal security procedures covering its storage, access and destruction.
    2. We will securely store your data in our Google Cloud store. Standard security provisions of Google Cloud Store will be in place. The database access is also secured using Google authentication service. Although we provide appropriate technical 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. We do not recommend that you disclose your personal information with third parties, and in case you do, you are solely responsible for the same.
  8. How long do we retain your personal data
    1. We retain your personal information for as long as it is reasonably required to provide the services you have requested, or for other essential purposes, such as complying with our legal obligations, resolving disputes, and enforcing our policies. We may retain your personal data for an additional period to the extent deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary to assert or defend legal claims during any relevant retention period.
    2. By providing you with products or services, we create records that contain your information, such as customer account records, activity records, etc. These records can be held in variety of media (physical or electronic) and formats.
    3. We manage our records to serve our customers well (for example, for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
    4. Retention periods for records are determined based on the type of record, the nature of the activity, product, or service and the applicable local legal or regulatory requirements. We normally keep customer account records for up to 2 years after your relationship with us ends, whilst other records are retained for shorter periods. Retention periods may be changed from time to time based on business or legal and regulatory requirements. However certain data may be retained for longer periods if necessary for recordkeeping purposes, and there may also be residual information that will remain in our databases and on other records, which will not be removed. Please note that there might be latency in deleting the personal data from our servers. In addition, we do not delete from our servers’ files that are common with other users.
    5. We will delete your personal data in reasonable time and you may choose to withdraw your consent (where applicable), provided that we are not legally required or otherwise permitted to continue to hold such data.
    6. We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence if needed.
    7. If you would like further information about how long we keep your information, please contact us at dataprotection@RealestateTalk.online)
  9. Interaction Between You and Platform
    1. We are interested in your views, and we value the Feedback (defined below) we receive from You. However, we do not have control or are responsible for any such Feedback or the personal information which you make available through the Platform. We encourage you to be careful regarding the personal information you disclose in this way.
    2. Subject to any applicable law, any communication or feedback sent by you to the Platform (including without limitation testimonials, reviews, comments, contents, feedback etc. collectively “Feedback”) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for purpose. We can use the feedback including without limitation any ideas, inventions, concepts, techniques or know-how disclosed therein, for any purpose including without limitation developing, and/or marketing services.
    3. You agree that you will not assert any ownership right of any kind in the Feedback (including without limitation copyright, patent, trademark, unfair competition, moral rights, or implied contract) and you hereby irrevocably waive the right to receive any financial or other consideration in connection with the Feedback, including without limitation acknowledgment of you as the source of the Feedback.
  10. Indemnification
    In addition to the indemnification commitment provided in Terms of Use, User agrees to indemnify us, our partners, affiliates, officers, agents and employees and hold us harmless from and against any claims and demand, including reasonable attorney’s fees, made by any third party due to arising out of or relating to:
    i. accuracy and correctness of personal information and contents that user submits or shares through the Platform;
    ii. User’s violation of this Privacy Policy;
    iii. User’s violation of any rights of another User.
  11. Reservation Of Rights
    All rights not expressly granted in this Privacy Policy are reserved by us. Nothing contained in this Privacy Policy shall be construed as conferring by implication, estoppels or otherwise any license or right under any copyright, patent, trademark or other intellectual property right of RealEstate Talk or any other person or to User.
  12. Limitation Of Liability
    Platform will not be liable for any damages, direct or indirect, incidental or consequential, and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data and loss of your personal information) and for use of or inability to use Services of any kind that is offered or to provide indemnity or any other remedy to you or any third party. We make reasonable efforts to ensure that the Platform is free from defects or viruses. It is your responsibility to ensure that you use the correct devices for accessing and using the Platform and to protect from anything that may damage it.
  13. Governing Law and Disputes
    This Privacy Policy is governed by and construed according to the laws of India, and the courts in Thane, Maharashtra shall have exclusive jurisdiction to entertain any proceedings in any way relating to or concerning this Privacy Policy or any rights, duties, obligations or liabilities arising there under to the exclusion of all other courts in India.
  14. Your rights regarding your personal data
    We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

    The right to access – You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
    The right to rectification – You have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
    The right to erasure – You have the right to request us to erase your personal data, under certain conditions.
    The right to restrict processing – You have the right to request us to restrict the processing of your personal data, under certain conditions as well as the right to lodge a complaint with supervisory authorities regarding the processing of your personal data.
    The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
    The right to data portability – You have the right to request us to transfer the data that we have collected to another organization, or directly to you, under certain conditions.

    If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, or any questions or comments regarding this policy or our handling of your personal data, please contact us at our email (support@RealEstateTalk.online).
    Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you.
  15. Other Relevant Privacy Information
    1. Communication tools: We may scan messages automatically and check for spam, viruses, phishing and other malicious activity, illegal or prohibited content or violations of our Terms of Use, this Privacy Policy or our other policies.
    2. Children’s Privacy: Our Platform is general audience websites and not intended for persons below the age of 18. We do not knowingly collect personal information from users deemed to be children under their respective national laws.
    3. Third Party Privacy Practices: This Privacy Policy is restricted to our handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party or visit a third party website via a link from our Services, their privacy policy and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information.
  16. Updates
    We reserve the right to amend this Privacy Policy from time to time to reflect changing legal requirements or our processing practices. We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our services. Any such changes will be posted on this Platform and will be effective upon posting.