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Mahindra Lifespace Developers Limited, having its registered office at 5th Floor, Mahindra Towers, Dr. G. M. Bhosale Marg, Worli, Mumbai – 400 018 (“we” “us” “our” “MLDL”) is committed to protecting the privacy and security of your personal data. Your privacy is important to us. This Privacy Policy (“Policy”) applies to all services offered by us to all individuals (“you”, “your” or “user”). This Policy shall be referred and read as an integral part of the Terms of Use of the MLDL Website (“Website”).

This Policy explains how we collect, store, disclose, share, and use information that personally identifies when you visit our Website and how you can exercise your privacy rights.

Before using our Website or availing any of our products and/or services, you are advised to carefully read this Policy and the Terms of Use of our Website. If you do not agree with the terms of this Policy or Terms of Use, please do not access this Website. By visiting and/or using our Website, you are consenting to process your personal data in the manner as set forth in this Policy.

DATA PRIVACY DISCLAIMER

The scope of this policy is limited to the product and/or services provided by us within the territory of India and applies to users who request for these products and/or services within the Indian territory.

PERSONAL DATA THAT WE COLLECT

When you interact with us, we collect different types of information from you based on the type of interaction.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data.

“Processing”, “Processed”, “Process” in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment, or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.

Any personal data provided by you will not be considered as private and confidential if it is freely accessible in the public domain like any comments, messages, blogs, available on social media platforms like Facebook, Twitter etc.

We endeavour to collect only such information that is reasonably necessary to perform our services for you, deliver our products to you or to respond to your enquiries.

LINKS TO SOCIAL MEDIA AND THIRD-PARTY SITES

The Website may contain links to other websites whose privacy practices differ from those of MLDL. We have no control over such websites and are not responsible for the privacy policies/notices/statements or the content of such websites even if:

· You accessed the third-party website using links from our Website; or

· You accessed our Website using links from a third-party website.

If you provide your personal data to any third-party website, then the use of your personal data is governed by their privacy policies. This Policy applies to our Website only. We encourage you to be aware when you leave our Website and to read the privacy policies of other websites that you may choose to visit.

BASIS FOR PROCESSING YOUR PERSONAL DATA

We use your personal data only if we have a legal basis for doing so. In case, we wish to use your personal data for purposes other than set out above, we shall seek specific consent from you in a separate process prior to processing your personal data for such additional purposes.

We shall use your personal data for legal and regulatory purposes, such as:

(i) To ensure compliance with our legal obligations and to also comply with our obligations towards public authorities;

(ii) To enforce our terms and conditions;

(iii) To enforce any legal right or claim;

(iv) For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention or prevention of fraud;

(v) For our internal and external audit requirements and for information security purposes;

As otherwise described to you at the time of collection of your personal data.

PRIVACY NOTICE

As you interact with us for products and services, we collect different types of information from you based on your interaction. The purposes for which we process your personal data will depend on the circumstances in which we collect it. We endeavour to inform you why we are collecting your personal data and how we intend to use that information.

Please refer to the respective privacy notices to understand the collection of personal data and purposes of such collection by us.

5A. Our Website

This Privacy Notice applies to all products and/or services offered by us to all userswhen they access, browse, or use our Website.

1. PERSONAL DATA WE COLLECT

a. IDENTIFIERS INFORMATON

If you interact with us to enquire about a property, or address any grievance, we may collect the following personal data from you directly:

· Name
· Mobile Number
· Email ID

If you interact with us to explore a career opportunity, we may collect your personal data mentioned in the section above along with the following personal data:

· Date of Birth
· Current City Location
· Current Company Name
· Current Company Designation
· Graduation Degree
· Post Graduation Degree
· Resume/CV
· LinkedIn Profile

b. ELECTRONIC INFORMATION

In general, you may interact with our Website without providing personal data. Our Website makes use of cookies and other tracking technologies to collect information about you, the device you are using to interact with our Website, and how you interact with our Website. These tools may collect the following information about you and the device you are using during your visit on our Website:

· The IP address of the device used to access the website
· Your GPS location, if allowed by you
· The date and time of access
· The website from which access was obtained, as well as the search term used, as applicable
· The name and URL of the accessed file
· The search queries used
· Your devices operating system (shown by the user agent)
· The browser you are using (shown by the user agent)
· The type of device, if access is obtained through a mobile phone
· The transmission protocol used

There is no obligation to provide the personal data that we ask you for. However, if you do not provide your personal data, you will not be able to make use of all the features and functions of the Website or use the products and /or services offered thereon.

2. PURPOSE OF COLLECTION OF YOUR PERSONAL DATA

We collect your personal data for the following purposes:

a. To provide you with our products and services to:

· Make this Website and its content available to you and to further optimize & develop it

· Provide you with information that we or other third-party may offer you on our Website

· Respond to an enquiry or concern raised by you

· Provide you with career opportunities

· Assist you to get in touch with the PR team

· Notify you about changes to our Websites or any products and/or services that we or other third-party service providers offer or provide through it

b. For our internal business purposes to:

· Monitor the use of our Websites

· Receive feedback to help in further development of our services

· Improve the user experience on the Websites

· Be able to recognize, prevent and investigate attacks on our Websites

· Protect our rights and legitimate interests

c. For marketing to:

· Notify you about any new products or enhancements to our services, if you opt in for the same

· Deliver marketing and event related communications to you across various platforms, such as emails, telephones, text messaging, or WhatsApp, if you opt in for the same

5B. Services at Property Location

This Privacy Notice applies to the services offered by us to all userswhen you use the services provided by us at the property location.

1. PERSONAL DATA WE COLLECT

(a) IDENTIFIERS INFORMATON

If you interact with us to enquire about a property, we may collect the following personal data from you directly:

· Name

· Mobile Number

· Email ID

· Residential Address

· Pin Code

· Date of Birth

· Designation

· Organization

· Office Address

If you interact with us to book a property, and to avail the post-booking services, we may collect the information mentioned in the section above along with the following:

· Alternate Mobile Number

· PAN Card

· Aadhaar Card

· Ration Card

· Overseas Citizenship of India (OCI) Card

· Passport

· Voter ID

· Electricity Bill

· Bank Details

· Form 16B

2. PURPOSE OF COLLECTION OF YOUR PERSONAL DATA

We collect your personal data for the following purposes:

a. To provide you with our products and/or service to:

· Respond to an enquiry or concern raised by you

· Book property of your choice

b. For our internal business purposes to:

· To receive feedback to help in further development of our services

· Manage products and/or services and other personalized features

· Respond to queries or requests submitted by you when you want to exercise your rights with respect to your personal data that was given to us

c. For marketing to:

· Alert you of any new property or enhancements to our services, if you opt in for the same

Deliver marketing and event related communications to you across various platforms, such as emails, telephones, text messaging, and WhatsApp, depending on your preferred mode of correspondence, if you opt in for the same.

SHARING/DISCLOSURE OF PERSONAL DATA

As far as this is necessary for the purposes set out above, we will share your personal data with the following recipients who either have a need to know and who will process it for us based on our instructions and for no other purpose:

6.1 Mahindra companies and potential partnerships: Our businesses around the world are supported by different teams and functions, and personal data will be made available to them, if necessary, for the provision of products and/or services, account administration, sales and marketing, customer and technical support, and business and product development. All our employees and contractors are required to follow our data protection and security policies when handling personal data. Your personal data might also have to be shared in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

6.2 External service providers: Occasionally, to provide our products and/or services, it is necessary to collaborate with external service providers. We may use these service providers to assist us with some features or functions of our Website and Application. These external service providers shall process your personal data on our behalf subject to appropriate safeguards only insofar as it is necessary for them to provide their services to us. Our prior authorisation is required before they are permitted to transfer responsibility for processing personal data to a third party.

We only share your personal data with recipients that have an adequate level of data protection by implementing appropriate technical and organizational security measures, or we take measures to ensure that all recipients provide an adequate level of data protection as prescribed by applicable law. We do not sell your personal data to anyone.

6.3 Courts and public authorities: We will share personal data when required for the following purposes:

· To comply with legal obligations and respond to requests from government agencies, including law enforcement agencies and other public authorities.

· To prevent or detect or investigate offences or cyber incidents or for the prosecution or punishment of offences.

· To raise or defend against legal claims.

To protect our users, systems, and products and/or services.

PERSONAL DATA TRANSFER, STORAGE AND PROCESSING GLOBALLY

We operate globally and may transfer your personal data to Mahindra Group affiliates or third parties in territories outside India for the purposes described in this Policy in accordance with applicable data protection laws, provided that no such restriction is notified by the Government/ appropriate authority.

ACCURACY OF YOUR PERSONAL DATA

You agree to provide us with accurate personal data at all times and you will notify us promptly upon any changes to your personal data.

SECURITY MEASURES

We implement reasonable technical and organizational measures in relation to the information and personal data that is processed by us. We take reasonable measures to protect all personal data from unauthorized processing or accidental disclosure, alteration, misuse, destruction or loss or unauthorized access and modification that compromises the confidentiality, integrity, and availability of such data.

While we endeavour to always protect our systems, websites, operations and information against unauthorized access, use, modification, and disclosure, due to the inherent nature of the Internet, we cannot guarantee that any information, during transmission or while stored on our systems, will be safe and secure from intrusion by others.

You too have an important role in protecting your personal data. You should not share your user id, password or other authentication data provided to you with anyone. If you have any reason to believe that your user id or password has been compromised, please contact us immediately by using the contact details given in paragraph titled QUESTIONS/ CONTACT INFORMATION below.

YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL DATA

We respect your right to access and control your personal data, and we will respond to requests to exercise your rights under applicable laws and, where applicable, will correct, update, or erase your personal data.

Please note that applicable law might require that we cannot comply with every request. We will be required to retain your personal data due to legitimate business/ regulatory/ statutory retention requirements despite your request for erasure.

You have the following rights:

· Right to access information about your personal data: At any point, you can contact us for a summary of your personal data we hold about you, the processing activities undertaken with respect to such personal data, the identities of all those persons with whom your personal data has been shared by us along with the description of the personal data so shared, and any other information related to your personal data and its processing.

· Right to request correction: If your personal data is incomplete, inaccurate, misleading, or out of date, you can inform us about the same and your personal data will be corrected, completed, or updated, as the case may be.

· Right to request erasure: If you believe that we should discontinue the use of your personal data, you have the option to request the deletion of your personal data, unless retention is necessary for compliance with any law for the time being in force.

· Right of grievance redressal: In case of any grievance, you can seek redressal of the same as per paragraph titled GRIEVANCE REDRESSAL hereinbelow.

· Right to nominate: In the event of death or incapacity to exercise these rights, you can nominate any other individual to exercise such rights.

· Right to withdraw your consent to process your personal data: You can withdraw your consent easily by contacting us using the contact details given below in paragraph titled QUESTIONS/ CONTACT INFORMATION. The withdrawal of consent previously granted for the processing of personal data does not affect the lawfulness of the processing until the withdrawal. However, opting out will result in cessation of the respective services.

For exercising any of your rights, you can contact us using the contact details provided in paragraph titled QUESTIONS/ CONTACT INFORMATION. We will need you to furnish proof of your identity before you can exercise these rights. MLDL may not be able to process any requests made in the event you fail to establish your identity, or if MLDL is unable to authenticate your identity.

It is important that the personal data we hold about you is accurate and updated. Please write to us if the personal data given to us changes during the period for which we hold it.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your personal data which we have collected for as long as we reasonably consider it necessary for achieving the abovementioned purposes and as is permissible under applicable law. This is determined on a case-to-case basis.

We will delete your personal data whenever you request us to do so. However, we may archive and/or retain your personal data for as long as there are statutory retention obligations or potential legal claims are not yet time barred.

SAFEGUARDING THE PRIVACY OF CHILDREN

We do not knowingly collect or solicit personal data from minors. Our products and services are not designed for any person who is under 18 years of age, and we do not knowingly permit such persons to register for products and/ or services or share information through any of the web forms without verifiable consent from minors’ parents or lawful guardians. Further, we do not undertake tracking or behavioural monitoring of children or targeted advertising directed at children.

If we learn that we have collected personal data from a minor without verified parental consent, we will erase such personal data.

If you believe that a child under 18 years may have provided us their personal data, please contact us using the contact details provided in paragraph titled QUESTIONS/ CONTACT INFORMATION.

QUESTIONS/ CONTACT INFORMATION

If you have questions or comments regarding this Policy or want to exercise any of your rights or express your grievances regarding the processing of your personal data, please contact us using the contact details given below:

Mahindra Lifespace Developers Ltd.

Mahindra Towers, 5th Floor,

Dr. G. M, Bhosale Marg, Worli,

Mumbai – 400018, India

Infosecmldl@mahindra.com

GRIEVANCE REDRESSAL

If you have any grievances against our processing of your personal data, you may lodge your grievance with the Grievance Officer/Data Protection Officer as per details provided in paragraph titledQUESTIONS/ CONTACT INFORMATION above.

If you are not satisfied with the resolution provided you may log your complaint with the Data Protection Board of India following the procedure prescribed by them.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Policy at our sole discretion at any time. Any material changes to this Policy will be posted on this page. We encourage you to review this Policy regularly for such changes. The updated Privacy Policy will take effect as soon as it has been updated.

This Policy was last updated as of 25th October 2024.