SWAN REALTY - PRIVACY POLICY
Introduction
At Swan Realty, we are committed to protecting the privacy of our users ("You/Your"). This Privacy Policy explains how we collect, use, and disclose personal data when you use our website. It outlines the types of information we gather, how we collect it, how we use it, and the measures we take to protect your data. This Privacy Policy applies to all users of the website, including prospective clients, clients, and any other individual whose data is processed through the website. We may use your personal data based on your consent, to fulfil contractual obligations, for performance of a contract or steps taken at your request prior to entering into a contract.
What Personal Data Do We Collect?
Information You Provide Directly:
- Account Information: When you create an account, we collect your name, email address, and any other registration information you provide.
- Contact Information: Information you provide when you contact us or use in-website communication features, including contact details, names, and any information you share in messages.
- Profile Information: Any information you choose to add to your user profile within the Website.
- Business-Related Data: Information on purchases, services, feedback, or other business interactions you carry out through the Website.
Information We Collect Automatically:
- Device Information: Specific information about the mobile device/laptop you use, including:
- Device identifiers (e.g., IP address, IMEI number, MAC address, device ID, push notification token)
- Operating system version
- Hardware model
- Mobile network information
- Usage Information: Data related to how you interact with the website, such as:
- Features you use
- Content you view
- Frequency and duration of your website usage
- Interaction history within the app
- Error logs and crash reports
- Location Information: We may collect your device's location if you consent. This location may be precise or approximate (e.g., through GPS or other location services)
- Cookies and Similar Technologies: The Website may use cookies, mobile advertising identifiers, or similar technologies for various functions.
- Website Activity: Information about the application and your activities within it, such as installed applications and network connections.
- In-Website Messaging and Communication Information: Transcripts, metadata of communications, and records of all communications made via the Website.
- Log Data: Information such as your IP address, browser type, the time and date of your visits, the pages you view, and other usage statistics.
Permissions: Depending on your device's operating system, certain permissions may be requested. This may include permissions related to your, location, and other device capabilities.
Compliance with Digital Personal Data Protection Act, 2023 (DPDP Act, 2023):
The following steps shall be followed to ensure compliance with DPDP Act, 2023:
- Reporting mechanisms - Introduction of a system to allow employees and users to report potential breaches or policy violation.
- Regular Internal Audits - Regular audit shall be conducted of our data processing activities to identify and address any compliance lacunae.
In the event of a breach, we shall notify both the Data Protection Board of India (DPBI) and affected individuals at the earliest. This shall include:
- Timely notification: The DPBI will be notified within 72 hours of discovering a significant breach, as required under DPDP Act.
- Notifying the Affected individual: If the nature of the breach causes harm to the individual's right to freedom, we will make the effort to inform them without undue delay, detailing the nature of the breach, potential consequences and measures taken to mitigate the impact.
Compliance with the Information Technology Act, 2000:
In accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, Swan Realty implements reasonable security practices and procedures to protect your personal and sensitive personal data. Sensitive Personal Data may include, among other things, financial information (such as payment details), government-issued identification information (where legally required), and any other information classified as sensitive under applicable law. Such data is collected only with your consent, used strictly for the purposes for which it was collected, and disclosed only with your consent or as required by law. We maintain technical, operational, and managerial safeguards in line with recognized industry standards to protect such information from unauthorized access, alteration, disclosure, or destruction.
What Is the Purpose of Collecting Personal Data?
We may collect, use, disclose, and process your personal data for the following purposes:
- Account Management: To manage your user account, provide customer service, and enable features of the Website.
- Service Delivery: To provide you with the products, services, and functionalities you request, including purchases, communications, and business transactions.
- Personalization: To customize your experience within the Website based on your preferences and usage.
- Communication: To respond to your inquiries, provide updates, and facilitate communication with you and other users of the Website.
- Payment Processing: To process payments and complete transactions within the Website.
- Troubleshooting: To identify and resolve technical issues and debug the Website.
- Security: To protect the Website, users, and our systems from misuse, fraud, and other illegal activities.
- Research and Development: To improve the Website, our products, and services, including analysing user trends and preferences.
- Marketing: To provide you with information about new features, promotions, and services that may be of interest (with your consent if required).
- Analytics: To track Website usage, evaluate performance, and gather statistical data to enhance functionality.
- Compliance: To comply with legal obligations.
- Enabling Push Notifications and In-website Messaging:: Sending you push notifications or in-website messages and providing in-website communications functionality.
Use of Information Based on Your Consent:
- Marketing, Promotional and customer relationship purposes, including sending promotional communications, special offers if you have consented to receive the same; and
- Any other purposes for which we have your consent.
Cookies and Similar Technologies:
We use cookies and similar technologies (such as mobile advertising identifiers) in our website to:
- Recognize you when you use the Website.
- Remember your preferences.
- Provide tailored advertising.
- Analyse Website performance.
- Combat fraud.
- Support other essential functionalities.
You may be able to control the use of cookies or device identifiers through your mobile device’s settings, but please be aware that disabling these might affect the functionality of the Website. We will obtain your consent before using non-essential cookies (e.g., for targeted advertising) and provide you with cookie preference options
Who Will Receive Your Personal Data?
We may share your personal data with other organizations in the following circumstances:
- If required by law or public authority.
- To establish, exercise, or defend our legal rights (including preventing fraud).
- During a business restructuring, sale, or transfer (e.g., a takeover or merger).
- With authorized personnel within Swan Realty and its affiliates for data processing and storage, providing you with access to services, customer support, making decisions about service improvements, and content development.
- Within Swan Realty and its affiliates, on a need-to-know basis.
- With credit reporting agencies and debt collectors (to verify your creditworthiness for orders with invoices or to collect outstanding invoices, as permitted by applicable law).
- With third-party service providers for marketing, advertising, communications, infrastructure, hosting, IT services, personalization, credit card transaction processing, customer service, debt collection, and data analysis. We do not allow them to use or disclose your personal data for purposes other than providing their services.
- We may also process your personal data without consent in circumstances permitted under the DPDP Act, 2023, such as compliance with legal obligations, responding to medical emergencies, or for employment-related purposes.
- Where we transfer data internationally, we implement safeguards such as standard contractual clauses or equivalent safeguards in accordance with applicable laws, including the DPDP Act, 2023.
- In the event of a significant data breach that is likely to cause harm to individuals, we will notify the Data Protection Board of India and affected individuals within 72 hours, in accordance with the DPDP Act, 2023.
How Long Will Your Personal Data Be Retained For?
We process and store your personal data as long as it is necessary to provide the Website’s functionalities, to manage your business relationship with us, and to meet statutory obligations. If your personal data is no longer required for those purposes or statutory obligations, it will be erased regularly unless further processing is necessary, such as to preserve evidence under applicable data protection laws or in the context of legal statutes of limitations.
How We Protect Your Personal Data?
We use technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, and unauthorized access. We continually enhance our security procedures as new technologies become available.
How Do We Protect Children’s Privacy?
If you are under 18, you are not authorized to use the Website without parental or guardian consent and supervision. We do not knowingly collect personal data from children under 18 without the consent of a parent or guardian. If you believe we have collected data about a child under 18, please contact us so that we can take appropriate steps to delete it. Our website also complies with the relevant provisions of the DPDP Act regarding children's data.
- Parental control: Obtaining verifiable parental consent before collecting personal data from children under 18 years of age.
- Age Verification: We will ensure that data collection mechanisms have an age- verification process to prevent the collection of data from children who are underage without appropriate consent.
What Are Your Rights?
You have the following rights:
- Right of access: To the personal data we hold about you.
- Right of rectification: To correct inaccurate personal data, including the right to have incomplete personal data completed.
- Right to erasure: To have your personal data erased, unless there is an open order.
- Right to restrict processing: You can ask us to limit how your data is used in certain cases.
- Right to object against profiling: You can object if we use your data for profiling or automated decisions.
- Right to data portability: You can request your data in a machine-readable format and transfer it elsewhere.
- RRight to withdraw: You can withdraw consent anytime, but services may be affected.
We will strive to grant these rights within one month whenever reasonably possible and required. You can also withdraw your consent to direct marketing or to our general data processing at any time, and in certain situations, you can ask us to delete your data. However, we may not be able to continue providing services to you if you withdraw your consent or ask for full deletion.
We may reject unreasonable requests, those not required by law, those that are extremely impractical or those that could expose us to operational risks. We take reasonable measures to destroy or de-identify personal information securely when it is no longer needed.
Will Profiling Take Place?
Generally, your personal data will not be processed automatically for evaluating personal aspects (profiling). If we need to process your data for automated individual decision-making profiling, we will specifically inform you and inform you of your rights as required by law.
Can The Privacy Policy Change?
Swan Realty retains the discretion to update this Privacy Policy at any time. We will revise the "updated date" at the bottom of the policy. Please check this page regularly for changes and to remain informed about how we protect your data. You are considered to have acknowledged and agreed to any amended version of this Privacy Policy. You acknowledge it's your responsibility to check this Privacy Policy periodically for modifications.
How Can You Contact Us?
If you are dissatisfied with how we have processed your personal data, have questions about data processing, or wish to exercise your rights, please contact us:
- Phone: +91 (22) 4196 6700
- Email: frontdeskbkc@swan.co.in
- Address: Office No. 71, 7th Floor, NCL Building, BKC, Bandra (E), Mumbai- 400 051.