Privacy Policy

This Privacy Policy ("Policy") describes how FundProp Ventures Private Limited, a company incorporated under the Companies Act, 2013, having its registered office at New Delhi, National Capital Territory of Delhi, India, together with its subsidiaries and affiliates ("FundProp," "we," "us," or "our"), collects, uses, discloses, and safeguards personal information and sensitive personal data in connection with our website, mobile applications, and related services through which we offer information about, and facilitate investment in, real estate-related Offerings (collectively, the "Platform"). This Policy applies to visitors, registered users, and investors on the Platform (collectively, "you") and is published in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. By accessing or using the Platform, you acknowledge the data practices described in this Policy.

1. Information We Collect

We collect the following categories of personal data:

• Identity and Contact Data— name, date of birth, mailing and email address, phone number, government-issued identification (including Aadhaar, wherever voluntarily provided and permitted by law, Permanent Account Number (PAN), and passport details), collected for account registration and to satisfy "Know Your Customer" and anti-money-laundering obligations under Applicable Law.
• Financial and Investment Data— bank account and IFSC details, income, net worth, investor-qualification status, source of funds, investment amounts, holdings, and transaction history related to real estate Offerings, which may constitute "sensitive personal data or information" under Applicable Law.
• Verification Data — information obtained from identity-verification agencies and credit information companies (including under the Credit Information Companies (Regulation) Act, 2005) to confirm your identity and eligibility to invest.
• Device and Usage Data — IP address, browser and device type, operating system, pages viewed, referring URLs, and interactions with the Platform, collected automatically through cookies and similar technologies.
• Communications Data — records of correspondence, customer support requests, and survey responses.

2. Sources of Information

We collect information directly from you when you create an Account, complete a subscription for an Offering, or communicate with us; automatically through your use of the Platform; and from third-party sources, including identity-verification providers, credit information companies, banks, and property Sponsors, to the extent necessary to process your investment and satisfy our legal and regulatory obligations under Applicable Law.

3. How We Use Your Information

We use personal information for the following purposes:

• to create and administer your Account and process subscriptions to real estate Offerings;
• to verify your identity, eligibility, and investor-qualification status, and to detect and prevent fraud, money laundering, and other unlawful activity;
• to comply with applicable securities, tax, foreign exchange, and anti-money-laundering laws and to respond to regulatory or law-enforcement requests from Indian authorities;
• to communicate with you regarding your Account, investments, distributions, and Platform updates;
• to provide customer support and respond to your inquiries;
• to maintain, secure, and improve the Platform, including through analytics and testing; and
• to send marketing communications about new Offerings or features, where permitted, and subject to your consent-withdrawal and opt-out rights described in Section 8.

4. Legal Basis for Processing; Consent

We process your personal data on the basis of your consent, given at the time of registration or submission of information, and, where applicable, for the performance of the subscription agreement you enter into in connection with an Offering, for compliance with our obligations under Applicable Law, and for our legitimate uses as recognized under the DPDP Act. You may withdraw consent for processing at any time, subject to the effect such withdrawal may have on our ability to provide the Platform or to comply with our legal and regulatory obligations, as further described in Section 8.

5. How We Share Your Information

We do not sell your personal information. We may disclose personal information to the following categories of recipients, each acting under confidentiality and, where required, data protection obligations:

• Sponsors and their fund administrators, in connection with the specific Offering you invest in, and only to the extent necessary to process your subscription and maintain your investment records;
• banks, escrow agents, custodians, and payment aggregators, to facilitate the transfer of investment funds and distributions;
• identity-verification agencies and credit information companies, for KYC and fraud-prevention purposes;
• professional advisors, including legal counsel, auditors, and tax advisors;
• SEBI, the Reserve Bank of India, the Financial Intelligence Unit-India, courts, and other government or regulatory authorities, where required by Applicable Law, summons, or legal process, or to protect the rights, property, or safety of FundProp, our users, or the public;
• a successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality commitments consistent with this Policy; and
• service providers who perform functions on our behalf, such as hosting, analytics, and customer relationship management, under contractual confidentiality and data-protection obligations, including any Data Processing Agreement required under Applicable Law.

6. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to operate the Platform, remember your preferences, authenticate your session, and analyze usage patterns. You may configure your browser to refuse some or all cookies, or to alert you when cookies are being set; however, certain features of the Platform may not function properly without them. We do not currently respond to "Do Not Track" browser signals.

7. Data Retention

We retain personal information for as long as necessary to provide the Platform, to satisfy the purposes described in this Policy, and to comply with applicable legal, tax, accounting, and securities recordkeeping requirements under Applicable Law, which for investment-related records may extend for a period of years following the termination of your Account or the conclusion of an Offering. Where retention is no longer necessary, and no legal obligation requires continued storage, we will securely delete, anonymize, or aggregate the information.

8. Your Rights as a Data Principal

Under the Digital Personal Data Protection Act, 2023, you, as a "Data Principal," have the right to: (a) obtain a summary of the personal data we hold about you and the processing activities undertaken; (b) request correction, completion, and updating of your personal data; (c) request erasure of your personal data that is no longer necessary for the purpose for which it was processed, subject to our legal and regulatory recordkeeping obligations; (d) withdraw your consent at any time, with the same ease with which it was given; (e) nominate another individual to exercise these rights in the event of your death or incapacity; and (f) file a grievance with us and, if unresolved, with the Data Protection Board of India established under the DPDP Act.

To exercise any of these rights, contact our Grievance Officer at privacy@fundprop.com. We will verify your identity before fulfilling your request and will respond within the timeframe required by Applicable Law, and in any event no later than thirty (30) days from receipt of a verifiable request.

9. Data Security

We implement reasonable security practices and procedures as required under the Information Technology Act, 2000 and the rules framed thereunder, including administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction, such as encryption of data in transit, access controls, and periodic security assessments. No method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security of your information. In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required under the DPDP Act.

10. Cross-Border Data Transfers

FundProp is based in India, and personal information we collect is primarily processed and stored in India. Where processing by our service providers requires the transfer of personal data outside India, we will do so only to jurisdictions permitted under the Digital Personal Data Protection Act, 2023 and any notification issued by the Central Government thereunder, and subject to appropriate contractual and technical safeguards.

11. Children's Privacy

The Platform is not directed to, and we do not knowingly collect personal information from, individuals under the age of eighteen (18). If we become aware that we have collected personal information from a person under eighteen (18) without verifiable parental or lawful guardian consent, as required under the DPDP Act, we will take steps to delete such information promptly.

12. Third-Party Links

The Platform may contain links to websites and services operated by Sponsors or other third parties. This Policy does not apply to, and we are not responsible for, the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party site before providing your personal information.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the revised Policy on this page, update the "Last updated" date above, and, for material changes, provide additional notice such as an email notification. Your continued use of the Platform after the effective date of any revision constitutes your acknowledgment of the revised Policy.

14. Grievance Officer; Governing Law; Contact Us

In accordance with the Information Technology Act, 2000 and rules made thereunder, and the Digital Personal Data Protection Act, 2023, the Grievance Officer of FundProp may be contacted at the registered office of FundProp Ventures Private Limited, New Delhi, National Capital Territory of Delhi, India, or at privacy@fundprop.com. This Policy is governed by the laws of India, and the courts at New Delhi, India shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy.

For general questions, concerns, or requests regarding this Policy or our data practices, please also visit our Contact page.