Adani Realty and its affiliates (collectively, “we”) are engaged in the business of development and sale of residential, commercial, and social club properties. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or otherwise interact with our website available at https://www.adanirealty.com (collectively, “Platform”) or avail products or services that Adani Realty offers you on or through the Platform (collectively, the “Services”).
In this Policy, the services offered to you through the Platform are referred to as “Property Development and sale Services”. At Adani Realty, we are committed to protecting your personal data and respecting your privacy. To provide you with services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you. Please note that unless specifically defined in this Policy, capitalized terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://www.adanirealty.com/terms-and-conditions (“Terms”).
We do collect your personal information and process your personal data in accordance with the IT Act, 2000 (21 of 2000) and other national and state laws which relate the processing of personal data.
Please read this Policy in consonance with the Terms. By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.
1. DEFINITIONS AND KEY CONCEPTS
Personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws) about you, which we collect, receive, or otherwise process in connection with your use of our website/App and/or the Platform.
A small file placed on your device by our website/App or the Platform when you either visit or use certain features of our website/App or the Platform. A cookie generally allows a website or mobile application to remember your actions or preference for a certain period of time.
Data Protection Laws
Any applicable law for the time being in force relating to the processing of Data.
Select third parties (including Adani Group Entities) with whom we have contracts for the businesses described in this Privacy Notice.
Includes entities which provide services to us and to whom we may disclose your Data for a specific purpose pursuant to a written contract.
Adani Estate Management Pvt. Ltd., a company incorporated in India whose registered office is Atreco House, CBD Shantigram, Near Vaishnodevi Circle, SG Highway, Ahmedabad, Gujarat - 382421
Adani Group Entity
Adani Enterprises Limited, and its subsidiaries, affiliates, associate companies and joint venture companies.
User or you
The natural person who accesses or uses the Services through our website/App or the Platform.
Our status as controller or processor:
Our business involves:
(a) Development of residential, commercial and club properties
(b) Sale of residential, commercial and club propertiesFor the purposes of certain applicable Data Protection Laws, we will act as a "controller" when we use your Data for our own purposes and a "processor" when we use your Data for and under the instructions of a Group Entity and other participating entities.
2. WHAT DATA DO WE COLLECT ABOUT YOU
We collect Data for various purposes set out in this Privacy Notice.
This Data includes, without limitation, the following categories:
(a) Contact information: First and last name, email address, postal address, country, phone number and other similar contact data.
(b) Financial information: Payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data. It is clarified that we do not store any of your card details i.e., credit and debit card in our Application or website.
(c) Technical information: Website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
(d) Product and service information: Your website/App or Platform account membership number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
(e) Your reviews, feedback and opinions about our products, programmes, and services.
(f) Loyalty program information: Your loyalty membership information, account details, profile or password details and any frequent flyer or travel partner program affiliation.
(g) Transaction information: Date of the transaction, transaction amount, transaction history and related details.
(h) Other information: Age, sex, date of birth, marital status, nationality, occupation or any other personal information provided by you.
(i) Location information: Personal data collected during usage of service provided by us such as Maps and Navigation, cab services, or any other similar services which require processing of such data.
3. HOW WE COLLECT DATA
We collect Data in the following ways:
a. Information You Give Us: We receive and store any information you enter on our website App or the Platform or give us in any other way. Please see the section below, titled “Data Shared by You” for more information.
b. Information You Give to Transit Hotel: We receive and store any information you provide to the Transit Hotel available at our Platform.
c. Automatic Information We Collect: We use “cookies”, pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled “Data That is Collected Automatically” for more information.
d. E-mail Communications: We often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
e. Customer Care Support: We store data provided by you to our customer care support team including but not limited to the call recording.
f. Automatic Information We Collect from Other Websites: We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement.
g. Information from Other Sources: We may obtain information from other sources. An example is where we receive your Data from Adani Group Entities in connection with the Platform for the purposes of enrolment, offering you products, services and benefits on the Platform.
h. Information Previously Provided to Adani Group Entities: Where you have shared any information previously with any of the Group Entities and such Group Entity is permitted to further share such information, it will share such information with us. If such information is sensitive personal information or special category personal data, the Group Entity will only share such information with us with your consent. Regardless of the terms on which you had originally provided the information to a Group Entity, you acknowledge that: (a) we will collect such information from such Group Entity for the purposes set out in this Privacy Notice; (b) the Group Entity that provides such information to us is subject to its own compliance obligations under the Data Protection Laws, and (c) we are not responsible for any acts or omissions of such Group Entity in relation to any such compliance obligations under the Data Protection Laws.
i. We automatically collect purchase or content use history, which we sometimes aggregate with similar information from other customers to create features such as Best Seller, Top Rated, etc...
j. The information about usage of the App, including crash logs and usage statistics.
k. Information about the location of your device, including geolocation information.
l. Information such as your location is collected upon availing services which require processing of such data to provide the requisite service to you.
m. By using our App, you are agreeing that we may advertise your feedback on the App/ website and marketing materials.
n. We will retain your information as long as we require this to provide you with the goods and services and for such period as mandated by the concerned laws.
You can make choices about our collection and use of your Data. For example, you may want to access, edit or remove your Data on our website/App or the Platform. When you are asked to provide Data, you may decline. For more information, please see the section below, titled “Your Rights and Choices”.
4. DATA SHARED BY YOU
We may collect your Data in several ways from your use of our website/App or the Platform. For instance:
(a) when you register with us to receive our products and/or services.
(b) when you conduct a transaction or attempt a transaction on our website/App or Platform.
(c) when you complete surveys conducted by or for us.
(d) when you elect to receive any communications (including promotional offers) from us.
(e) from the information gathered by your visit to our website or the Our Platform.
(f) do not provide personal data about others unless you are authorized or required to do so by contract or applicable law.
5. DATA WE RECEIVED FROM OTHER SOURCES
We may receive personal data about you from other sources including but not limited to the information provided by you to us for availing any product or service available at the Platform, our affiliate, a person, or company/organization authorized by you to submit an application on your behalf, and/or publicly available sources. We’ll contact you to let you know we are processing your personal information.
6. DATA THAT IS COLLECTED AUTOMATICALLY
(a) We automatically collect some information when you visit our website/App or the Platform. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
(b) Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. We use this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of our website/App or the Platform.
(c) We may collect your Data automatically via Cookies, pixels and similar technologies in line with settings on your browser. For more information about Cookies, please see the section below, titled “Cookies, Pixels and Similar Technologies”.
7. OUR USE OF DATA
We use the information collected through this App, as described in this policy and we may use your information to:
I. Improve our services, App and how we operate our businesses.
II. Understand and enhance your experience using our App, products and services.
III. Personalize our products or services and make recommendations.
IV. Provide and deliver products and services you request.
V. Process, manage, complete, and account for transactions.
VI. Provide customer support and respond to your requests, comments, and enquiries.
VII. Create and manage the online accounts you manage on our App.
VIII. Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.
IX. Communicate with you about promotions, upcoming events, and news about products and services.
X. We may process your personal information without your knowledge or consent where required by applicable law or regulation for the purposes of verification of identity or for prevention, detection, or investigation, including of cyber incidents, prosecution, and punishment of offences.
XI. Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
XII. Protecting against, and preventing, fraud, illegal activity, harm, financial loss and other legal or information security risks.
XIII. Providing marketing and promotional campaigns to you based on your profile.
XV. In connection with loyalty programs owned and operated by us or by other Group Entities; and
XVI. Create a user profile based on data provided by you on using of the application.
Where processing your Data is necessary for us to carry out our obligations arising from any contracts entered into between you and us: If you enter into a contract with us in relation to any of our product or service offerings, including products or service offerings we offer to you directly on the Platform, we may process certain Data about you in order to perform our obligations under this contract, including to enable us to communicate with you about such products and/or services and to process your payment transactions.
Where processing your personal information is within our legitimate interests: We can process certain Data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of yours which require protection of your Data.
Where you give us your opt-in consent to process your personal information: In certain circumstances, where required under relevant Data Protection Laws, we will seek to obtain your consent before we undertake certain processing activities with your Data.
Where required under relevant Data Protection Laws (e.g. under direct marketing legislation), we will obtain your opt-in consent prior to sharing your Data with third parties and carrying out certain marketing activities (unless we are permitted by relevant Data Protection Laws to contact you without your opt-in consent in relation to goods and services which are similar to those which you have already purchased, used or interacted with).
You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in the section below, titled "Your Rights and Choices".
Where processing your personal information is necessary for our compliance with a legal obligation: In certain circumstances, we may disclose your Data for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation or compulsory legal request). We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see the section below, titled "Your Rights and Choices".
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Data.
Further, where required under relevant Data Protection Laws, we will only process special category personal data (as defined under Data Protection Laws) if there is a valid legal basis, which might involve obtaining your explicit consent.
Where we use or share or otherwise process your Data as a processor on behalf of a Group Entity or other participating entity (i.e., the controller) for the purposes of offering you access to Third Party Applications on the Platform or as part of any services that we provide to that entity, we do so under the instructions of that entity and that entity is responsible for ensuring that there is a legal basis for us to use or share your Data on its behalf (if such legal basis is required under relevant Data Protection Laws).
8. PERMISSIBLE AGE
a. The Services are not intended for users under the age of 18, unless permitted under applicable local laws (Permissible Age) or under the involvement of a parent or guardian. We do not knowingly collect any personal information from users or market to or solicit information from anyone under the Permissible Age. If we become aware that a person submitting personal information is under the Permissible Age, we will delete the account and any related information as soon as possible. If you believe we might have any information from or about a user under the Permissible Age, please contact us at Grievance.Realty@adani.com
b. This website is not directed at children under the age of 18 and We cannot distinguish the age of persons who access and use our website. If a minor (according to applicable laws) has provided us with Customer Data without parental or guardian consent, the parent or guardian should contact us (see Section 20) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.
9. SHARING OF DATA
We may share your Data in the following ways (and for the purposes of relevant Data Protection Laws, we may do so either as a controller in our own right or as a processor on behalf of and under the instructions of another entity in accordance with our obligations under our agreement with that entity):
a. We share your data with your consent or to complete any transaction or provide any product or service you have requested or authorized. We also share data with our affiliates and subsidiaries, with vendors working on our behalf.
b. We may employ other companies and individuals to perform functions on our behalf. The functions include fulfilling orders for products or services, delivering packages, sending e-mail, removing repetitive information from customer lists, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, scoring credit risk, and providing customer service.
c. Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data (including in relation to loyalty programs) may be transferred as part of such transactions.
d. Protecting Us: We may release Data when we believe that disclosure is reasonably necessary (a) to comply with a law, regulation or compulsory legal request; (b) to protect our or an Adani Group Entity's intellectual property rights; (c) to protect our against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests, or (e) in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organizations for fraud protection, risk management and dispute resolution.
e. Third Parties: We may also share your Data with other third parties where:
a) You request or authorize us to do so.
b) We need to comply with applicable law or respond to valid legal process or.
c) We need to operate and maintain the security of our website/App or Platform, including to prevent or stop an attack on our computer systems or networks.
f. We reserve our right to share the information collected within the Adani Group Entities and internal departments for promotional and marketing activities and communications.
g. Migration of Data: We may also process your data for other business and offerings controlled, maintained, governed and operated by Adani Digitals, thereby, Your Data (including in relation to any loyalty program(s) operated, maintained, and governed by Adani Digital including but not limited to “Adani One” or any of its group companies) may be migrated as part of such business transactions.
10. DATA SECURITY
We will use technical and organizational measures to safeguard your Data and we store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us by e-mail.
The security of your Platform account depends on you keeping your account password(s), PINs and other access information confidential. If you share your Platform account information with a third party, they will have access to your account and your Data.
It is your responsibility to control access to your mobile device and the Platform on your device, including keeping your password(s) and/or PIN confidential and not sharing it with anyone. It is also your responsibility to alert us if you believe that the security of your Data in the Platform has been compromised.
11. ANALYTICS AND TAILORED ADVERTISING
To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics etc. These service providers use the sort of technology described in the "Automatically-Collected Information" Section above. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate our users' use of the Services. We also use Google Analytics as described in the following section. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser add-on.
• Inform, optimize, and serve ads based on past visits to our website and other sites and
When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.
12. RETENTION OF DATA
We retain Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website/App or the Platform, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly. Even if we delete your Data, including on account of an exercise of your right under Clause 13 below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.
13. WHERE WE STORE DATA
If the GDPR/United Kingdom’s version of the GDPR applies to our processing of your Data, we will only process and/or transfer Data outside of the European Economic Area/United Kingdom where it is compliant with Data Protection Laws and the means of transfer provides adequate safeguards in relation to your Data, including for example:
(a) by way of a data transfer agreement incorporating the current relevant standard contractual clauses adopted in the European Economic Area/United Kingdom; or
(b) by transferring your Data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
(c) where it is necessary for the conclusion or performance of a contract between us and a third party and the transfer is in your interests for the purposes of that contract; or
14. YOUR RIGHTS AND CHOICES
Depending on which country’s laws are applicable to you, you may have various rights in relation to the Data that we hold about you. To get in touch with us about any of your rights under Data Protection Laws, please use the contact details set in the section below, titled “How to Contact Us”. We will seek to deal with your request without undue delay, and in any event, within any time limits provided for in Data Protection Laws (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.
You may be entitled to the following rights in relation to your Data:
a) Right to Confirmation and Access - you may ask us to confirm what Data we hold about you at any time, and request us to modify, update or delete such Data. You may also request a copy of the Data we hold about you.
b) Right to Rectification - you have the right to request that we rectify any inaccurate or incomplete Data that we hold about you, including by means of providing a supplementary statement.
c) Right to be Erasure - you have the right to request that we "erase" your Data in certain circumstances.
d) Right to Restrict Our Use of your Data - you have the right to request that we restrict our processing of your Data in certain circumstances, for example if you dispute the accuracy of the Data that we hold about you or you object to our processing of your Data (including where we process your Data for our legitimate interests, where permitted under applicable law).
e) Right to Object – this right enables you to object to us processing your Data where we do so for certain reasons.
f) Right to Data Portability - you have the right to request that we transfer your Data to another third party. This right of data portability only applies to certain types of Data.
g) Right to Withdraw Consent – where we have obtained your consent to process your Data for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your Data for this purpose.
h) Right to File Complaints – you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.
To get in touch with us about these rights, or for more information about managing your Data and promotional communications, please use the contact details set out in the section below, titled “How to Contact Us”.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.
15. PROCESSING YOUR DATA
We take steps to ensure that your Data is processed according to the provisions of this Privacy Notice and the requirements of applicable law.
17. LINKS TO THIRD PARTY SITES/APPS
I. Keeping track of items stored in your shopping basket.
II. Conducting research and diagnostics to improve the content, products, and services.
III. Preventing fraudulent activity.
IV. Improving security.
b. Our cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your shopping basket, proceed to checkout, or use any products or services that require you to sign in.
c. Approved third parties also may set cookies when you interact with Our services.
d. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.
f. You can prevent the storage of cookies by choosing a "disable cookies" option in your device settings. But this can limit the functionality of our services.
19. CHANGES TO THIS POLICY
We may change this policy from time to time. If we make any changes to this policy, we will change the "Last Updated" date above. You agree that your continued use of our services after such changes have been published to our services will constitute your acceptance of such revised policy. we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.
20. HOW TO CONTACT US
21. GRIEVANCE OFFICER
Please find below the details of the grievance officer:
Name: Mr. Vishal Shah
Email Id: Grievance.Realty@adani.com.
The grievance officer is identified above pursuant to the provisions of applicable laws including but not limited to the information Technology Act, 2000 and the Consumer Protection Act, 2019 and the rules enacted under those laws.