Privacy Policy

PRIVACY POLICY

Broker Seva Platform

Effective Date: April 1, 2025

Last Updated: March 2026

Applicable to: Mobile Application and Website (brokerseva.com)

IMPORTANT: PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE BROKER SEVA PLATFORM (MOBILE APPLICATION AND/OR WEBSITE), REGISTERING AN ACCOUNT, OR SUBMITTING ANY DATA, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USING THE PLATFORM.

1. About This Policy and Our Company

This Privacy Policy (“Policy”) is published by [BROKER SEVA PRIVATE LIMITED] (“Company,” “we,” “us,” or “our”), the owner and operator of the Broker Seva platform, including the mobile application and the website accessible at brokerseva.com (collectively, the “Platform”).

This Policy governs the collection, storage, processing, use, disclosure, and protection of Personal Data and other information submitted to or collected by us through the Platform. It is published in compliance with:

• The Information Technology Act, 2000 (“IT Act”) and the rules framed thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);
• The Digital Personal Data Protection Act, 2023 (“DPDP Act”) and any rules/regulations issued thereunder from time to time;
• Any other applicable laws and regulations of the Republic of India.

2. Key Definitions

For purposes of this Policy, the following terms have the meanings assigned below:

“Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.

“Sensitive Personal Data or Information (SPDI)” means passwords, financial information (e.g., bank account, credit/debit card details), physical or mental health information, or any information received in confidence — as defined under the SPDI Rules.

“Platform” means the Broker Seva mobile application and website (brokerseva.com) collectively.

“User,” “you,” or “your” means any person (real estate broker, agent, or other individual) who accesses, registers on, or uses the Platform.

“Data Fiduciary” means the Company, which determines the purpose and means of processing Personal Data.

“Data Principal” means the User, whose Personal Data is processed.

“Consent” means a clear, affirmative, free, specific, and informed agreement to the processing of Personal Data for a specified purpose.

3. Information We Collect

We collect various categories of information in connection with your use of the Platform. By using the Platform, you expressly consent to such collection.

3.1 Information You Provide Directly

• Identity and Contact Data: Full name, mobile number, email address, and profile photograph.
• Professional Information: Real estate broker registration details, RERA registration number (if applicable), agency/company name, years of experience, and professional credentials.
• Property Listings and Land Bank Data: Property addresses, descriptions, photographs, videos, price details, area measurements, property type, ownership documents (to the extent voluntarily uploaded), and other listing-related information you choose to submit.
• Buyer/Seller Requirements: Requirement details, budget ranges, preferred locations, property type preferences, and any other information entered in the Requirements Manager.
• Network and Communication Data: Messages, referral information, broker syndicate interactions, and other communications sent through the Platform.
• Payment and Billing Information: Subscription plan details, billing name and address, payment method information. Note: Full payment card data is processed by our third-party payment gateway (Razorpay) and is NOT stored by us on our servers.
• Any other information you voluntarily provide through forms, surveys, or support requests.

3.2 Information Collected Automatically

• Device and Technical Data: Device type, operating system and version, unique device identifiers (UDID, IMEI where permitted), mobile network information, browser type, and IP address.
• Location Data: With your explicit prior consent, we may collect real-time or approximate GPS/location data to enable location-based property search and proximity features. You may withdraw location permission through your device settings at any time; however, certain Platform features may be affected.
• Usage and Analytics Data: Pages and features accessed, time spent, search queries, listing interactions, click patterns, and feature usage statistics.
• Log Data: Server logs, crash reports, performance data, and error logs.
• Cookies and Similar Technologies: The web application may use cookies, web beacons, local storage, and similar tracking technologies. Please refer to our Cookie Policy (Section 14) below.

3.3 Information Received from Third Parties

• Referral information from other brokers who refer you to the Platform.
• Information from authentication providers (e.g., Google Sign-In), limited to what you authorise during sign-in.
• Publicly available government property and registry data used to enrich listings.

4. Purposes of Processing and Legal Basis

We process your Personal Data for the following purposes, on the following legal bases:

• Account Creation and Management: To register, verify, and manage your User account. (Legal Basis: Consent; Contract.)
• Platform Services: To enable core features including property listings, land bank management, buyer-seller matching, requirements manager, broker network, property sharing, and broker syndicate. (Legal Basis: Contract; Consent.)
• Payment Processing: To manage subscriptions, process transactions, send invoices, and manage billing. (Legal Basis: Contract; Legal Obligation.)
• Location-Based Features: To provide geolocation-based property search and proximity matching. (Legal Basis: Explicit Consent — obtained separately at the time of use.)
• Communications and Notifications: To send service notifications, updates, alerts, and support communications. (Legal Basis: Contract; Legitimate Interest.)
• Marketing and Promotions: With your separate opt-in consent, to send promotional material about new features, plans, and offers. You may opt out at any time. (Legal Basis: Consent.)
• Safety, Security, and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, misuse, or illegal activity on the Platform. (Legal Basis: Legitimate Interest; Legal Obligation.)
• Legal Compliance: To comply with applicable Indian laws, court orders, regulatory directions, or government requests. (Legal Basis: Legal Obligation.)
• Analytics and Platform Improvement: To analyse usage patterns and improve Platform functionality, user experience, and features. (Legal Basis: Legitimate Interest.)
• Dispute Resolution: To investigate complaints and resolve disputes. (Legal Basis: Legitimate Interest; Legal Obligation.)

5. Disclosure and Sharing of Your Information

We do not sell, rent, or trade your Personal Data to third parties for their independent marketing purposes. We may share your information only in the following circumstances:

5.1 With Other Platform Users

The Platform is designed to facilitate broker networking. Accordingly:

• Public listing information (property details, photos, listing broker’s name and professional contact details) may be visible to other registered Users of the Platform.
• Broker profile information that you choose to make public will be visible within the Broker Network.
• You are solely responsible for any information you voluntarily make public on the Platform. We are not responsible for how other Users use publicly shared information.

5.2 With Service Providers and Processors

We engage trusted third-party vendors and service providers who assist in operating the Platform. These include, without limitation:

• Cloud infrastructure providers (e.g., database hosting, file storage, server management);
• Payment gateway providers (Razorpay or equivalent);
• Analytics providers (e.g., PostHog);
• Error tracking and monitoring tools (e.g., Sentry);
• Communication and notification service providers;
• Customer support tools.

All third-party processors are contractually obligated to maintain confidentiality and security standards consistent with this Policy and applicable law. They are permitted to use your data only to perform services on our behalf.

5.3 Legal and Regulatory Disclosures

We may disclose your Personal Data to government authorities, law enforcement agencies, courts, or regulators when:

• Required by law, court order, or mandatory legal process;
• Necessary to enforce our Terms of Service or protect our rights;
• Required to prevent fraud, illegal activity, or protect the safety of any person;
• Required under the DPDP Act, IT Act, or other applicable legislation.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, asset sale, or insolvency, your Personal Data may be transferred as a business asset, subject to the acquirer’s commitment to maintain this Policy or provide equivalent protections. You will be notified of any such transfer.

5.5 With Your Consent

We may share your information with other parties with your prior written or electronic consent for purposes not described in this Policy.

6. Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. General retention periods are as follows:

• Active account data: Retained for the duration of your account and for 3 years thereafter, unless longer retention is required by law.
• Transaction and billing records: Retained for a minimum of 7 years in compliance with Indian accounting and tax laws.
• Property listing data: Retained for the duration your listing is active, plus 1 year after deletion.
• Communication logs: Retained for up to 2 years.
• Log and analytics data: Retained for up to 1 year in identifiable form; may be retained in anonymised/aggregated form indefinitely.

Upon expiry of the applicable retention period, Personal Data will be securely deleted, anonymised, or rendered non-identifiable, except where retention is required by applicable law.

7. Data Security

We implement industry-standard technical, administrative, and physical safeguards to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. These measures include, without limitation:

• Encryption of data in transit (TLS/SSL) and at rest;
• Secure access controls, role-based access, and authentication mechanisms;
• Regular security assessments and vulnerability monitoring;
• Use of reputed, compliant cloud infrastructure providers.

HOWEVER, NO METHOD OF TRANSMISSION OVER THE INTERNET OR ELECTRONIC STORAGE IS COMPLETELY SECURE. WE DO NOT GUARANTEE ABSOLUTE SECURITY OF YOUR DATA. By using the Platform, you acknowledge and accept this inherent risk. In the event of a data breach affecting your rights, we will notify you as required under the DPDP Act and applicable law.

8. Your Rights as a Data Principal

Subject to applicable law, you have the following rights with respect to your Personal Data:

• Right to Access: You may request confirmation of whether we process your Personal Data and obtain a summary of the data held by us.
• Right to Correction: You may request correction or updating of inaccurate or incomplete Personal Data.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to Grievance Redressal: You have the right to have grievances addressed promptly. See Section 12.
• Right to Nominate: Under the DPDP Act, you may nominate an individual to exercise your rights in the event of your incapacity or death.

To exercise any of the above rights, please contact us at the details in Section 12. We will respond within the timeframe prescribed by applicable law. We reserve the right to verify your identity before processing any request.

9. Minors and Children

The Platform is intended exclusively for real estate professionals and individuals who are at least 18 years of age. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware that Personal Data of a minor has been collected without verifiable parental consent, we will take immediate steps to delete such data. If you believe we have inadvertently collected such information, please contact us immediately at privacy@brokerseva.com.

10. Third-Party Websites and Services

The Platform may contain links to third-party websites, applications, or services. This Policy does not apply to such third-party platforms. We have no control over, and assume no responsibility for, the privacy practices, content, or policies of any third-party platforms. We strongly encourage you to review the privacy policies of any third-party platforms you visit. YOUR USE OF THIRD-PARTY PLATFORMS IS ENTIRELY AT YOUR OWN RISK.

11. User-Generated Content and Third-Party Data

When you upload property listings, photographs, documents, or other content to the Platform, you represent and warrant that:

• You have the legal right, title, and authority to upload such content;
• The content does not infringe the intellectual property, privacy, or other rights of any third party;
• If the content contains Personal Data of third parties (e.g., property owners, clients), you have obtained all necessary consents required under applicable law, including the DPDP Act, to share such data with us;
• The content complies with all applicable laws.

You shall indemnify and hold harmless the Company from any claims, losses, liabilities, or expenses arising out of any breach of the above representations. We are not responsible for the accuracy, legality, or privacy compliance of any content submitted by Users.

12. Grievance Officer and Contact Information

In accordance with the IT Act, SPDI Rules, and DPDP Act, we have designated a Grievance Officer to address complaints and queries related to this Policy:

Grievance Officer: [Name – To Be Updated Upon Company Registration]

Company: [BROKER SEVA PRIVATE LIMITED]

Address: [Registered Office Address, City, Maharashtra, India – PIN]

Email: privacy@brokerseva.com

Response Time: We will acknowledge your complaint within 72 hours and resolve it within 30 days of receipt, as required by applicable law.

For complaints relating to Personal Data processing under the DPDP Act, you may also approach the Data Protection Board of India (once constituted) in accordance with the procedures established under the DPDP Act.

13. Changes to This Privacy Policy

We reserve the right to amend, update, or replace this Policy at any time at our sole discretion, to reflect changes in our practices, technology, legal requirements, or for any other reason. The updated Policy will be posted on the Platform with a revised ‘Last Updated’ date.

Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the revised Policy. If the changes are material, we will provide you with prominent notice (via in-app notification, email, or other appropriate means) prior to the changes taking effect. If you do not agree to any changes, you must discontinue use of the Platform and may request deletion of your account.

14. Cookie Policy

The web application component of the Platform (brokerseva.com) may use cookies and similar tracking technologies to enhance your experience. Types of cookies used:

• Essential/Strictly Necessary Cookies: Required for the Platform to function correctly (e.g., authentication session cookies). These cannot be disabled.
• Analytics and Performance Cookies: Help us understand how users interact with the Platform (e.g., PostHog analytics). These are subject to your consent.
• Functional Cookies: Remember your preferences and settings for a better experience.

You may control cookie settings through your browser settings or our cookie consent manager (where available). Please note that disabling certain cookies may limit your ability to use some features of the Platform. We do not use cookies for third-party advertising or sell cookie-derived data to advertisers.

15. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

• THE COMPANY SHALL NOT BE LIABLE FOR ANY LOSS, DAMAGE, OR HARM ARISING FROM UNAUTHORISED ACCESS TO YOUR ACCOUNT DUE TO YOUR FAILURE TO SAFEGUARD YOUR CREDENTIALS.
• THE COMPANY SHALL NOT BE LIABLE FOR ANY DISCLOSURE OF PERSONAL DATA THAT YOU VOLUNTARILY SHARE WITH OTHER USERS OR MAKE PUBLICLY AVAILABLE THROUGH THE PLATFORM.
• THE COMPANY SHALL NOT BE LIABLE FOR THE ACTS OR OMISSIONS OF THIRD-PARTY SERVICE PROVIDERS, EXCEPT TO THE EXTENT REQUIRED BY APPLICABLE LAW.
• THE COMPANY SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF OR RELATED TO YOUR USE OF THE PLATFORM OR THIS POLICY.
• THE COMPANY’S TOTAL AGGREGATE LIABILITY UNDER THIS POLICY, TO THE EXTENT PERMITTED BY LAW, SHALL NOT EXCEED THE AMOUNT PAID BY YOU TO THE COMPANY IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

16. Governing Law and Dispute Resolution

This Policy shall be governed by and construed in accordance with the laws of the Republic of India. Any dispute, controversy, or claim arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of the courts located in [City], Maharashtra, India.

Before initiating legal proceedings, the parties agree to attempt resolution through good-faith negotiation for a period of 30 days from written notice of the dispute. Disputes not resolved through negotiation may be referred to arbitration under the Arbitration and Conciliation Act, 1996, as amended, with the seat of arbitration in [City], Maharashtra, India.

17. Entire Agreement

This Policy, together with the Terms of Service and any other agreements or policies published on the Platform, constitutes the entire agreement between you and the Company with respect to the subject matter herein and supersedes all prior communications, agreements, or understandings.

18. User Acknowledgement

BY USING THE BROKER SEVA PLATFORM, YOU EXPLICITLY ACKNOWLEDGE AND CONFIRM THAT:

• You have read and understood this Privacy Policy in full;
• You are at least 18 years of age and have the legal capacity to consent;
• You voluntarily consent to the collection, processing, storage, and use of your Personal Data as described in this Policy;
• Where you have submitted Personal Data of third parties (e.g., property owner information), you confirm you have obtained all required consents from those individuals;
• You understand that certain features of the Platform will not function without the data collection described herein.

[BROKER SEVA PRIVATE LIMITED] | brokerseva.com | privacy@brokerseva.com

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