Privacy Policy: Terms and FAQs

1. What is the privacy policy and what does it cover?
   1. In this privacy policy ( "Policy" ) we explain to you what information we collect from you, what we do with your information, and your rights over your information.
   2. We value your privacy and respect the importance of any information you share with us. Accordingly, we have formulated this Policy to inform you about how we collect, use, process, treat and share your data.
   3. To safeguard your privacy, we are guided by the following principles:
      1. Collecting information only for the purposes set out in this Policy;
      2. Collecting only limited information as is necessary and relevant for our purposes;
      3. Ensuring your ability to control your information as per this Policy; and
      4. Taking all reasonable steps to keep your information safe and secure.
   4. This privacy policy is a legal agreement between you, as a user of services, and us, i.e., Lyfebynary 0103 LLP. It is to be read with the Terms and Conditions which contains the general terms and conditions of your usage of our platforms and services.
   5. It is important to us that you understand and agree with this Policy before and at all times during which you use our services. If you need our help in understanding any aspect of this Policy, you may reach out to us at info@houzeguru.com for any clarifications.
   6. At all times, we assure you that your data will be handled by us in accordance with applicable law and the terms of this privacy policy, and data privacy is an important tenet of our organisation. We assure you that we will always collect and process your data in line with applicable legal standards and in accordance with this privacy policy.
   7. By accepting this Policy, you are providing your free, express, specific, informed, unconditional, unambiguous and voluntary consent for us to collect, use, process, treat and share your data in accordance with this Policy.

   This Policy is to be read with the Terms Of Use which contain the Terms and conditions for usage of Platform. When you come across any capitalised terms that are not defined in this Policy, such words have the meaning given to them in the Terms of Use.

2. Meaning of certain words

Unless the context implies another meaning, any reference to:

• "Company", “we", "us", "our" refers to Lyfebynary 0103 LLP and our platform, website and/or application.
• “Data Protection Act" refers to the Indian Digital Personal Data Protection Act, 2023 and the rules and regulations that may be notified under it from time to time.
• "information" or "data" refers to ‘personal data’ about you, i.e., data that we can use to identify you.
• "Platform" refers to the following websites: www.houzeguru.in, www.houzeguru.com and www.binarybrilliance.com as well as the mobile app named HouzeGuru available on both Apple app store and Google Playstore.
• "Policy" refers to this privacy policy.
• "you", "your" refers to you, i.e., a user of the Company’s platform.

When you come across any capitalised terms that are not defined in this Policy, such words have the meaning given to them in the Terms of Use.

Important Note: This Policy does not apply to non-personal data or if personal data held with us is anonymised such that one cannot ordinarily identify you individually using such data (for example, a table showing how many of our users are based in which city) and please note that applicable law does not deal with anonymised data.

3. What information do we collect?

We collect the following information about you:

1. Information you share with us;
2. Your activity on HouzeGuru mobile and any website comprising the Platform;
3. Information collected from and about your computer or handheld device;
4. Information about you that may be shared with us by third parties.

The data we hold may also include inferences we draw about you based on the above information, as well as certain combined information, datasets, and reports based on analysis of data of multiple persons, which may help us learn about our users as a whole and take business decisions.

We may also combine the information that we receive all these sources for the purpose set out in this Policy. We may also anonymize and/or de-identify information about you. This Policy does not cover non-personal information, including aggregated, anonymised and/or de-identified information and we are free to use and disclose the same. However, your rights under this Policy will apply for any data which could be used to identify you with high degree of certainty and accuracy.

1. Information shared by you includes details shared at the time of registering your account, as well as any other data submitted by you while using our services. This includes:
   1. Your profile details such as name, date of birth, nationality, gender, photograph, email ID, phone number, address, etc and similar details of your family members.
   2. Information submitted by you as part of the customer/user onboarding process or during your usage of our app, such as the names and salaries of domestic staff members; details of household assets (vehicles, appliances, etc.).
   3. All financial and payment related information such as bills and receipts of all kinds, spend information, and account/transaction statements (of banks, cards, accounts, retirement funds, etc.).
   4. Documents you may upload onto the app such as:
      1. identity cards (Aadhaar, PAN, passport, driver licence, voter ID, ration card, etc.);
      2. property documents;
      3. insurance documents;
      4. medical documents (including health reports, prescriptions, details of medications and medical devices);
      5. career-related documents such as résumés, applications, job letters;
      6. income tax filing documents; and
      7. investment related documents.
   5. Any other information you may provide us while communicating or interacting with us, including with customer support agents, feedback forms, or while co-operating with us in legal matters and investigations.

   It is solely your choice to share any of the above information with us.

2. While interacting with us, you may do many more things. We collect all details about such activities, including:
   1. Your clicks, views, searches and actions on our platform.
   2. Which features, services, content, advertisements and people you interact with.
   3. Content that you create on the Platform, including to-do lists and planning calendars created in the app, media from your camera / microphone/ storage (only where permitted by you or your device), such as in customer support chats.
   4. The time, frequency and duration of your usage of our platforms.
   5. What other users may mention about you.
3. We may receive information about you from third parties in various scenarios such as:
   1. if you have agreed to let such third party share such information with us;
   2. where we are permitted by law to obtain such information.

   The information collected through this method varies, and can include details such as websites you visit and your online activity, apps you use, your transactions / interactions on the platforms of entities we have partnered with, your engagement with advertisements, and details about your background.

   This includes, without limitation, information from public databases, business partners, joint marketing partners, and social media platforms.

   We also work closely with select third parties (including, for example, subcontractors and service providers, advertising networks, analytics providers, search information providers, and other service providers) and may receive information about you from such sources.

   We may receive some of the above information even if you are not a registered user on our website. To learn how such third-party entity handles your data, you may refer to the privacy policy of such third party.

4. We may automatically collect certain information from your device, such as:
   1. Device, software, browser and network information.

   Examples include IMEI and IMSI numbers, UUID, MAC/IP address, android/iOS/windows version, Wi-Fi and telecom provider, device signals such as internet/GPS connections and download speed, browser details and plug-ins, and date and time.

   2. Location data.
   3. Access to other apps and services such as SMS, storage and media, mic and camera, and contacts.
   4. Your login details and access to Google or Meta or any other social media account provider, if you are signing in through such third party services.
   5. Uniform Resource Locators (URL) clickstream with timestamp.
   6. What you're doing on your device. This includes whether our app/website is in the foreground, how long our platforms take to load, any errors we run into on your device, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
   7. Metadata, i.e., technical data associated with any content you submit. E.g. You can see the date and time and camera details linked to the images in your gallery.
   8. Information about your online activity collected by cookies and tracking technology (including pixels). We use this information to improve our Platform.
   9. Third parties may also use such cookies and tracking technology if you interact with any content provided by them through our Platforms. We strive to let you choose in advance to accept or deny such cookies.

   Learn more about cookies.

We may receive some of the above information even if you are not a registered user.

You may be able to limit access to some of this information by modifying your device and browser settings to minimize data sharing and permissions.

4. Why and how do we use your information?

We will only use your information for the purposes set out in this Policy. If we wish to use your information for any other purpose, we will only do so with your explicit prior permission.

1. To provide you with our services;
   1. to create, verify and maintain your user account, allowing you to log in to our platform and allowing us to conduct user onboarding;
   2. to provide you with our platforms and services (whether directly or via our partners), including to provide you with your dashboard, access to services when you log in, facilitating transactions, participate in interactive features of the platform;
   3. connecting your account to partner services as may be on-boarded by us from time to time, in the event you choose to avail such services and provide your consent for the same;
   4. sharing of information with our affiliated companies, if required to provide our services to you, in order to provide a seamless user experience. This will be done only to the extent required for us to avail intra-group services that enable us to enhance our offerings to you;
2. To improve and personalize our services;
   1. to improve and maintain our products, including to see if it is working well, fix issues, test new features, enhance security measures, and to conduct i nternal research on who are our users, what do they like to do, and how they behave online, so that we may better understand, protect and serve our users;
   2. for testing, marketing, research, analytics, statistics and user profiling, including generating reports on usage patterns and including measuring how well our features or any advertisements have worked;
   3. to personalize content and advertisements shown to you;
   4. for any marketing or promotional services;
   5. to develop or training any of our artificial-intelligence models based on user patterns and user behaviour;
   6. for analysing your usage patterns and providing you with benchmarking reports or other user-related insights;
   7. for testing, research, statistical and survey purposes, including to generate reports on our services and user base and usage patterns (which may also be shared with third parties).
3. To promote the safety and integrity of our platforms and users;
   1. to keep our platform safe by verifying users, identifying and investigating and preventing suspicious activities and carrying out internal operations such as troubleshooting and security checks;
   2. to enforce our legal rights, address violations of our terms, protect our personnel and property, maintain the integrity of our systems.
4. To stay in touch with you;
   1. to stay in touch with you, inform you of updates and offers, and to interact with you in the course of providing our services, to share surveys and obtain feedback, and to address your queries;
   2. to provide you with information about services we consider similar to those that you are already using, or have enquired about;
   3. to deal with enquiries and complaints;
   4. for obtaining confirmations from you such as transaction numbers / one-time passwords (OTPs).
5. Other mandatory or permitted purposes
   1. to carry out our duties/obligations arising from any contracts (including with you) or under applicable laws, including audits, search warrants, responding to audits, search warrants, court / tribunal orders, and legal requests from financial institutions, civil litigants, and law enforcement and other governmental agencies;
   2. to perform any other activities that we may be allowed to or required to perform under applicable laws; and
   3. any other purpose for which we may obtain your consent.

5. How do we share your information with third parties?

We do not sell your information to anyone. We may share your information with our partners with your permission as provided under this Policy, only for the purposes set out in this Policy such as ensuring we can provide better service to you.

Please select the following headings to learn more about how we may share your information.

1. Group entities

   Information about your activities is shared with our group companies and affiliates and appropriate employees, representatives, agents, and advisors as may be required in connection with our services. We may, from time to time, share information with entities which may use your information to help us provide our services to you include.

2. Advertisers

   We only share anonymised and aggregated information with advertising partners, such as user demographics, income and spend patterns, etc. This helps customize the advertisements displayed to certain categories of customers as a whole, without us sharing any specific details about users (such as their name or contact details) with the advertiser.

   However, if you interact with an advertisement and / or with any third-party application or webpage or form, then such third party may obtain the information provided by you and may also be able to contact you, and your information would be governed by the privacy policies and/or practices of such third-party advertiser.

3. Partner businesses and Service Providers

   In order to provide you our services, we work with various partner entities and also obtain services from various service providers to improve our products. In order to facilitate the services provided by us or to us, we may have to share your information with such partners and service providers. Examples of this include:

   1. Log-in information shared with Google or Meta or similar third party credentials allowing you to sign-in using their credentials.
   2. Information shared with payment service providers and intermediaries including wallets and card companies to facilitate your transactions.
   3. Information shared with service providers who help us with activities such as payment collection, KYC, testing the security of our systems, providing us digital infrastructure, investigating suspicious activity, facilitating the services, providing customer support, and marketing our products.
   4. Information shared with reputed cloud storage service providers for the purpose of securely storing our information including your data that may lie with us;
   5. Information shared with utility service providers whose bills you choose to pay via our platform;
   6. Information shared with service providers who help us generate research and analytics reports to improve our product.
4. Legal requests

   We may be requested or required to share information in some scenarios. Examples include:

   1. To carry out our duties obligations arising from any contracts (including with you) or under applicable laws, including audits, search warrants, responding to audits, search warrants, court / tribunal orders, and legal requests from financial institutions, civil litigants, and law enforcement and other governmental agencies.
   2. To enable a governmental authority to perform their functions or to provide you with benefits (if and as permitted under laws applicable to us).
   3. To enforce our terms and conditions.
   4. To address enquiries and requests from other users.
5. Critical medical requests

   If we are contacted during medical emergencies, we may share information with healthcare professionals or other responders or service providers for effectively responding to medical emergencies involving a threat to the life or immediate threat to the health of any individual.

6. General public
   1. Where you use our platform to voluntarily share your information publicly or otherwise agree to such sharing, we may also publish your information such that it is publicly available. Examples include:
   2. Where you share or create any content on a publicly-visible part of our platform, such as in a comments section of a blog, or when you submit any reviews or feedback about us or our services.
   3. When you participate in any contest or offer or campaign, and we publish your name / photo / content as a participant or winner.

6. Could we process data without your consent?

   Our rationale for processing your personal information is based on receipt of your consent for such processing, which is received by us upon your acceptance of this Policy and any other consents sought and provided from time to time or for any purposes under applicable law.

   We may process your personal information WITHOUT your consent only if it is necessary for one of the following reasons, and only if we are legally permitted to do so:

   1. for performing a contract / agreement with you or to which you are a part;
   2. for taking steps at your explicit request prior to entering into a contract or agreement;
   3. for compliance with legal and regulatory obligations;
   4. for complying with judgements, orders, awards, decrees, etc., issued by courts or similar authorities;
   5. for any employment-related purposes, or for keeping us safe from aspects such as corporate espionage, and/or theft of our trade secrets, intellectual property or classified information, or for allowing us to provide any service or benefit to you (if you are an employee).

7. What are your rights?

   You retain control over your information by exercising various rights given to you by law. We empower you to exercise your rights by Providing you all requisite information and issue resolution. You may ask us:

   1. to share with you a summary of your information that we are handling including the activities in which we are using your information;
   2. to share the names of other persons with whom we may have shared your information, along with a description of the information that was shared with them (unless if it was shared with persons authorised by law, for the purpose of preventing or dealing with any offences or cyber incidents);
   3. to correct, complete, update, any information about you that is inaccurate or misleading;
   4. to erase certain information we have about you, or to delete your entire account.

   Note: See clause on ‘How Long Do We Keep Your Information For’ to learn why we may not be able to delete every single bit of data about you;

   5. to withdraw your consent for us processing your data, where such information is being processed on the basis of your consent;
   6. to nominate another person who may exercise these rights on your behalf, in the unfortunate scenarios of your death or incapacity.

   If you are based in the European Union and if the rights under the European General Data Protection Regulation (“ GDPR ”) are available to you, then you may have the right to exercise additional rights that are provided to you and described in detail under the GDPR, which include:

   1. Right to access a copy of your personal data;
   2. Right to rectify or erase your data, or to restrict us from processing your information in certain scenarios (in each such case, we will notify any other persons with whom your data has been shared about such rectification, erasure, or restriction, unless doing so is impossible or takes disproportionate efforts);
   3. Right to object, on the grounds relating to your particular situation, or against any processing for the purpose of direct marketing;
   4. Right to data portability (regarding data we process on the basis of your consent or a valid legal contract with you); and
   5. Right to lodge a complaint to a supervisory authority about the processing of your personal data by us. You are free to lodge the complaint with a supervisory authority at the place of your habitual residence in the European Union or place of the alleged infringement.

   You agree that if you exercise some of your rights (including not providing certain data or requesting erasure of some data), we may not be able to provide you with some or all of our services, and may also impact the quality or utility of some of the services that we may continue to offer you.

   In such a scenario, we can make no warranties whatsoever in relation to our services. You agree that any and all loss of services and quality is acceptable to you, and you waive your rights to bring any claim under contract, statute, equity, or tort for deficient services, refund, or any other remedy.

8. How long do we keep your information for?

   We only keep your information for as long as we need to for providing our services, comply with our legal obligations, or to protect the interests of any other person.

   You may at any time request us to delete your information, in which case we will only retain information if we are required to for legal or safety reasons. Examples include:

   1. for enabling any person to comply with legal requests or legal obligations or if needed during any legal proceedings;
   2. for assisting with investigations by governmental authorities or financial institutions;
   3. for enabling us to investigate potential violations of our terms and conditions or any breach or contract or other violation of our rights; and
   4. to prevent harm to anyone or anything, and to protect ourselves, our rights, and our assets.

9. Are you a child or a person with disability?

Unless otherwise indicated, you are only allowed to use our Platform if you are 12(Twelve) years or older. We do not knowingly collect information from individuals under 18 (eighteen) years of age, without the consent of the parents/ legal guardians or unless the information is provided to us by the parents or legal guardian.

We understand the importance of safeguarding the information of persons with disability. If you are suffering from disability and have a lawful guardian under applicable laws, you may use our Platform only with the direct involvement of the lawful guardian. Such lawful guardian must provide us with verifiable guardian consent. In such a scenario, you, i.e., the person agreeing to this Policy and providing consent, confirm that you are the lawful guardian of such person.

10. Your use of a consent manager

    Once India’s Digital Personal Data Protection Act, 2023 comes into force:

    1. The law may allow entities known as ‘consent managers’ to register with the Data Protection Board of India.
    2. Such entities may (for a fee and as per their terms and conditions) act as a single point of contact allowing you to manage your consent given to various companies or services.
    3. You may give, manage, review or withdraw your consent given to us via such a consent manager, so long as such consent manager is validly registered with India’s Data Protection Board.

11. Your duties

While providing your information, we require you to adhere to the following basic rules:

1. comply with applicable laws while exercising your rights over your information;
2. not impersonate another person while providing information;
3. nor file false or frivolous grievance or complaint with us, or with a governmental authority;
4. furnish only such information as is verifiably authentic, while exercising your right to correct or erase your information.

While we require you to follow these rules as part of this Policy, please note that once the Data Protection Act comes into force, Indian law may also require you to follow such rules.

12. Are there scenarios where you may not be able to use your rights?

Data protection laws are designed to preserve your control over your information. However, in certain exceptional scenarios, you may not be able to enjoy the rights provided to you under law (and as mentioned in this Policy). These scenarios are prescribed under the Data Protection Act, and we have briefly summarised them in this section. We request your understanding in this regard, as we may not be able to assist with the exercise of your rights under this Policy under these scenarios, even prior to the Data Protection Act coming into effect.

1. You may not be able to rely on certain provisions of the law (and to the extent this Policy reflects such legal provisions) where the processing of your personal information is necessary for any of the following purposes:
   1. enforcing any legal right or claim;
   2. for courts, tribunals or other legally authorised bodies to perform any judicial, regulatory, supervisory or similar function;
   3. for preventing, detecting, investigating or prosecuting any offence or violation of any law;
   4. for a merger, corporate reorganisation, transfer of business, and similar corporate operations that are approved by a court, tribunal or other authority; or
   5. for discovering your financial information and balances, if you have failed to pay any money due to banks or other financial institutions.
2. If you are not in India, and your information is being processed pursuant to any contract (including this Policy) between you and any person based in India, then the rights available under Indian data protection laws (and to the extent such laws are provided under this Policy) may not be available to you.

13. What are cookies?

Our platform and third parties may use cookies, pixel tags, web beacons, mobile device IDs, 'fash cookies" and similar tools to collect and store information with respect to your use of our services as well as your interaction with third-party websites.

Cookies are files of information that get stored on your browser or device. Some cookies exist only during your current browsing session, whereas others survive even after you close your browser and help us remember your preferences the next time you log in. A pixel tag / web beacon is a tiny graphic embedded invisibly on a webpage, ad or email. It helps track activity on a webpage including number of clicks an ad or a feature gets, and helps access cookies. Other tools (often known as SDKs) perform similar functions on our mobile applications.

We may use cookies, pixel tags and similar technologies for purposes such as verifying who is logging in, remembering your preferences and settings, gauging what content, features, and ads get the most engagement, analysing user trends and interests, and checking whether our messages have been opened.

We may also allow third parties to provide analytics, advertising and other services to us. These entities may use cookies, web beacons, and other tools to identify your device when you visit our platforms, as well as when you visit other online sites and services. At present, we have allows the following entities to use cookies and other tools for the purposes set out below:

Name of entity:

Purpose:

Name of entity:

Purpose

We will update this Policy to inform you / take your fresh consent if we permit any other party to place cookies on our platform.

Please note that due to the nature of the internet, some third parties (such as advertising networks) may also use cookies, over which we have no control. Common example of such cookies are cookies that analyse performance of their ads to evaluate their success, or analyse your online behaviour for curating for you ads that you may like.

Your browser settings may allow you to accept or reject cookies. Many browsers may accept cookies by default.We encourage you to explore your browser’s settings and manage / change cookies-related settings as per your preferences. modify your browser’s. If your browser’s settings are accepting cookies or if you manually accept cookies on our platform while accessing our platform, you are consenting to our use of cookies and similar technologies.

If you disable or reject cookies, it may impact the extent of services we may be able to offer you. For example, you may not receive personalised information and may not be able to log in to certain services.

14. Changes to this Policy

We may update this Policy from time to time when required by law or due to business reasons and provide you with notice of the same. We encourage you to periodically review the Policy for the latest information on our privacy practices. By continuing to use our platform and services, you may be agreeing to amendments made to the Policy from time to time. By Continued use of the Website constitutes agreement of the User to the Website Terms and this Policy and any amendments thereto.

15. How to contact us or lodge a complaint?

    We are happy to address any concerns you may have about your information.

    If you have any questions about this policy or have any questions, complaints or requests regarding your information, you can contact our grievance officer:

    Prashant Katiyar

    prashant@houzeguru.com

    +91 99300 00170

    In case of any legal grievances concerning your information, applicable laws may require you to first engage with our grievance officer before you may approach the concerned regulator or other authority.

    In resolving your grievances, we will be guided by the following principles:

    1. Users should be treated fairly at all times.
    2. Issues raised by Users should be attended with courtesy and in time.
    3. Users should be provided with effective and satisfactory resolution within reasonable time period.
    4. Users should be informed of avenues to escalate their issues/ grievances if they are not fully satisfied with the response to their complaints.