Surya Developers Limited (“Surya Developers” or “we”) takes the privacy of your information seriously. This Privacy Policy describes the types of personal information we collect from you through our website (including sub-domains and microsites). It also describes the purposes for which we collect that personal information, the other parties with whom we may share it, and the measures we take to protect the security of your data. It also tells you about your rights and choices concerning your personal information, and how you can contact us about our privacy practices. You are advised to carefully read this Privacy Policy before using or availing of any of our products and/or services.

GENERAL

In this Privacy Notice, the following definitions are used:

“Data” shall mean 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 and/or the Platform.

“Cookies” means a small file placed on your device by our website or Platform when you either visit or use certain features of our website or Platform. A cookie generally allows a website or mobile application to remember your actions or preferences for a certain period.

“Data Protection Laws” shall mean any applicable law for the time being in force relating to the processing of Data.

“Partners” shall mean select third parties (including Surya Group Entities) with whom we have contracts for the businesses described in this Privacy Policy.

“Service Providers” includes entities which provide services to and to whom we may disclose your Data for a specific purpose under a written contract.

“Surya Group Entity” shall mean Surya RealEstate Developers Limited, and its subsidiaries, affiliates, associate companies, and joint venture companies.

“User or you” shall mean the natural person who accesses our website or Platform.

This Privacy Policy primarily explains how we use your data when we act as a controller of your Data. Where we act as a “processor” on behalf of the Surya Group Entity or another participating entity (i.e., the “controller”), please refer to the relevant privacy policy of the relevant participating entity for information about how they use your Data.

2000. a) This document is an electronic record in terms of the Information Technology Act, 2000, and rules thereunder as applicable and the amended provisions about electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

1. b) This document is published by the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011, which require publishing the rules and regulations, privacy policy, and Terms of Use for access or usage of the website or Platform. https://www.suryarealestate.in/

1. c) The headings of each section in this Policy are only to organize the various provisions under this Policy in an orderly manner and shall not be used by either Party to interpret the provisions contained herein in

   any manner. Further, it is specifically agreed to by the Parties that the headings shall have no legal or contractual value.

   
   
   1. d) The use of the Website/Platform by the User is solely governed by this Policy as well as the Terms of Use (“Terms”, available at in/terms), and any modifications or amendments made thereto by the Company from time to time, at its sole discretion. The User expressly agrees and acknowledges that the Terms and Policy are co-terminus, and that expiry/termination of either one will lead to the termination of the other.
   
   
   1. e) The User unequivocally agrees that this Policy and the aforementioned Terms constitute a legally binding agreement between the User and the Company, and that the User shall be subject to the rules, guidelines, policies, terms, and conditions applicable to any service that is provided by the Website, and that the same shall be deemed to be incorporated into the Terms and shall be treated as part and parcel of the same. The User acknowledges and agrees that no signature or express act is required to make these Terms and the Policy binding on the User, and that the User's act of visiting any part of the Platform/Website constitutes the User's full and final acceptance of the Policy and the aforementioned Terms.
   
   
   1. f) The Parties expressly agree that the Company retains the sole and exclusive right to amend or modify the Policy and the aforementioned Terms without any prior permission or intimation to the User, and the User expressly agrees that any such amendments or modifications shall come into effect immediately. The User must periodically check the Policy and Terms and stay updated on their provisions and requirements. If the User continues to use the Website following such a change, the User will be deemed to have consented to any amendments/modifications made to the Policy and Terms. Insofar as the User complies with the Policy and Terms, he/she is granted a personal, non-exclusive, non-transferable, revocable, limited privilege to enter, access, and use the Website/Platform.

WHAT WE COLLECT

We collect Data for various purposes set out in this Privacy Policy.

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 patterns or trends, and other similar data.

(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 or Platform account 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, programs, and services.

(f)Loyalty program information: your loyalty 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 (which may include sensitive personal information or special category personal data): Age, sex, date of birth, marital status, nationality, details of government identification documents provided, occupation, or any other personal information provided by you.

The User expressly agrees and acknowledges that the Company collects and stores the User’s personal information, which is provided by the User from time to time on the Website, including but not limited to the User's user name, passwords, email address, name, address, age, date of birth, sex, nationality, shopping preferences, browsing history, etc., as well as any images or other information uploaded/published by the User on the Website. The User is aware that this information will be used by the Company/Platform to provide services and features targeted at the User, that are most likely to meet the User’s needs, and also to customize and improve the Website to make its user's experiences safer and easier.

MINORS

Our website and Platform do not offer products or services for use by minors. If you are under 18, you may use our website or Platform only with the involvement of a parent or guardian.

SHARING OF DATA

We may share your Data with the following (and for 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 by our obligations under our agreement with that entity):

(a)Partners: We may make available to you services, products, or applications provided by Partners for use on or through our website or Platform. If you choose to use such services, products or applications, Data related to these uses may be shared with such Partner.

(b)Surya Group Entities: We may share your Data with Surya Group Entities for them to make their products, services and /or applications available to you, to assist them in reaching out to you about their programs or campaigns and to process your queries and requests. If such Data is sensitive personal information or special category personal data, we will only share such Data with Surya Group Entities with your consent. Their use of your Data is subject to their own privacy policies.

(c)Service Providers: We may share your Data with Service Providers who may, in the course of providing their respective services, receive and process Data. Examples include storing and analyzing Data, protecting and securing our systems, providing search results and links, providing customer service, credit analysis, processing your Data for profiling, user analysis and payment processing.

These Service Providers will be required to only process Data by our instructions. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures.

(d)Protecting Surya: 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 Surya Group Entity's intellectual property rights; (c)to protect Surya 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)Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data may be transferred as part of such transactions.

(f)Third Parties: We may also share your Data with other third parties where:

1. a)You request or authorize us to do so;

1. b)We need to comply with applicable law or respond to valid legal processes; or

1. c)We need to operate and maintain the security of our website or Platform, including to prevent or stop an attack on our computer systems or networks.

The sharing of your Data will be in line with the processes set out in this Privacy Policy. Please note that Surya Group Entities and Partners may have privacy practices that differ from those of ASSPL. The use of your Data will be governed by their privacy statements when you provide Data on their websites.

KEEPING DATA SECURE

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 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 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 or App has been compromised.

RETENTION OF DATA

ASSPL retains 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 or 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 the exercise of your right as specified herein below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

WHERE WE STORE DATA

We may transfer your Data to recipients in India, where we are headquartered, and other countries. These countries may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Data to other countries, we will protect that information as described in this Privacy Notice, as disclosed to you at the time of data collection or as described in our program-specific privacy notice.

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

(d)where you have consented to the data transfer.

Thank you for visiting Surya Developers Website and reviewing our privacy policy. The policy is simple: We collect no personal information about you unless you choose to provide that information to us. We strictly do not share, give, transfer or sell any of your personal information to any third party.

In case, if you want to know about how we record non-personal information when you visit our site or how we use the information that you voluntarily submit, read further:

1. Non-Personal Information that we Record:

1. On visiting our website, if you just browse through read or download information, our site’s operating system will automatically record some general information about your visit.

1. The Internet domain for your internet service, such as “xyz.net” or “xyz.com”  if you are using private internet access account or if you connect from other domains.

1. The type of browser (such as “Internet explorer version x” or chrome”) that you are using.

1. The operating system that you are currently using (such as Windows, Unix, or Macintosh).

1. The time and date that you visit our site, and the webpages that you visit on our site.

1. The address of the previous website you were visiting, in case you linked us from another website.

This purpose of recording this information is for statistical analysis, to help make our site more useful to visitors. Individual information is not recorded by this tracking system.

Cookies

We use "cookies" on certain Surya Developers pages to help you use our website interactively. If you are wondering what is a cookie?. It is a small file that a website transfers to your computer’s hard disk, usually to keep track of you while you are connected to that site.

Cookies of Surya Developers web pages do not collect information about you, but just the "browser" session. The webpages dynamic features becomes easier for you to use because of the cookie, it prevents the cycle of having to provide the same information again as you browse from one page to another.

Remember in order to protect your privacy, be sure to close your browser entirely after you have finished conducting your business with a website that uses cookies. In case you are concerned about the potential misuse of information gathered by cookies placed in your system, set your browser to prompt you before it accepts a cookie. Almost all internet browsers have settings that help you identify cookies.

When you send us an email, the message usually contains your return email address. Email is not necessarily secure against interception. If you include personally – identifying information in your email because you want to address issues specific to your situation, we may use that information in responding to your request. It is important you send only information necessary to help us process your request.

Information collected from Interactive Forms Some of our web pages have interactive forms that allow you to voluntarily submit personal information (such as your e-mail address, name, or organization). This happens when you are inquiring and downloading company projects and brochures. In those cases, all submitted information is used only for the purposes for which it is intended and is not made available to any third party.

When you voluntarily send us electronic mail, we will keep a record of this information so that we can respond to you. We only collect information from you when you register on our site or fill out a form. Also, when filling out a form on our site, you may be asked to enter your: name, e-mail address or phone number. You may, however, visit our site anonymously. In case you have submitted your personal information and contact details, we reserve the rights to Call, SMS, Email or WhatsApp about our products and offers, even if your number has DND activated on it.

Links to Other Sites:

Our policy mentioned above discloses the privacy practices for Surya Developers website. However, Surya developers provides links to other websites. When you leave Surya Developers website, you will be going to sites that are beyond our control. These websites may send their own cookies to users, collect data or solicit personal information. The privacy policies and procedures described here for Surya Developers do not apply to any other external links. It is advisable to read the privacy policies of any site you link from ours, especially where you share any personal information. Be informed. The best person qualified for your privacy is you.