PRIVACY POLICY

Last Updated: 6 June 2026 · Revised: 1 July 2026

1. INTRODUCTION

Delta Yards Realty Private Limited ("Company", "we", "us", or "our") values your privacy and is committed to protecting the personal information you share with us through our website, mobile application, and communication channels.

This Privacy Policy explains how we:

• Collect
• Use
• Process
• Store
• Disclose
• Protect
• Retain

your personal information when you access or use our website, mobile application, CRM systems, or any related services.

Applicable Legal Framework:

This Privacy Policy has been prepared in accordance with:

• The Digital Personal Data Protection Act, 2023 (DPDP Act)
• The Information Technology Act, 2000
• The Telecom Commercial Communications Customer Preference Regulations, 2018 (TRAI)
• The Indian Contract Act, 1872
• Other applicable laws of India

By accessing or using our website, mobile application, or Services, you:

• Acknowledge that you have read and understood this Privacy Policy
• Consent to the collection, use, storage, and disclosure of your personal information as described herein
• Agree to be bound by the terms of this Privacy Policy
• If you do not agree with this Privacy Policy, you should immediately discontinue using our Services.

2. ABOUT DELTA YARDS

Delta Yards Realty Private Limited is a real estate advisory, marketing, and customer relationship management company operating in Maharashtra, India, specialising in lead aggregation, campaign management, and property solutions for real estate developers and project partners.

Registered Office:

• 201, Samruddhi Plaza, 2nd Floor
• Mira Bhayander Road
• Bhayander East
• Thane, Maharashtra – 401105
• India

Contact:

• Email: info@deltayards.com
• Phone: +91 79770 37145

Data Protection Officer / Grievance Officer:

• Sangeeta Singh
• Email: info@deltayards.com
• (Subject to change)

3. INFORMATION WE COLLECT

We collect and process different categories of personal information depending on how you interact with our Services. The collection occurs through multiple channels and methods.

3.1 Information You Provide Directly

When you use our website, mobile application, or communicate with us, you may voluntarily provide:

Personal Identification: Full name Email address Mobile phone number Residential address Identification document details (Aadhar, PAN, Passport, etc.)

Real Estate Preferences: Property location preferences Property type preferences (residential, commercial, etc.) Budget and investment range Investment timeline Financing preferences Occupancy preferences

Business and Professional Information: Company/organisation name Job title or designation Department Professional email address Business phone number Years of experience Professional background

Enquiry and Communication Data: Enquiry subject and details Customer messages and feedback Support tickets and complaints Lead source information Preferred contact method

Additional Information: Any information voluntarily submitted through: Enquiry forms and registration forms Website contact forms Property booking forms Application forms Feedback surveys Telephone conversations (recorded with consent) Email and WhatsApp communications

3.2 Information Collected Automatically

When you use our Services, certain information is collected automatically without requiring your explicit input:

Technical Information: IP address (IPv4 and IPv6) Browser type and version Operating system Device type and model Device unique identifiers (IMEI, device ID) Mobile network details (carrier, signal strength) Device hardware specifications

Website and App Usage: Pages visited and time spent on each page Click activity and interaction patterns Features accessed and frequency of use Download and upload activities Search queries and filter selections Scroll depth and engagement metrics Referral URLs and entry pages Exit pages User session duration and frequency Form submission details Feature usage analytics

Location Information: Precise GPS location data (when location permission is granted) IP-based geolocation Cell tower location data Wi-Fi network locations accessed Device location at time of login

Location-Based Data (CRM-Specific): Employee check-in and check-out locations Precise latitude and longitude coordinates Location history and movement patterns Geofence entry/exit events Site visit locations Field activity locations Customer meeting locations Property viewing locations Time spent at each location

Photos and Media: Photographs captured during check-in/check-out Images uploaded via camera or photo gallery Metadata associated with photos (timestamp, location, device info) Video recordings (if applicable)

Device Sensors and Permissions: Camera access logs Photo gallery access logs Location services activation status Microphone access logs Calendar access (if permitted) Contact list access (if permitted)

Cookies and Tracking Technologies: Cookies (persistent and session-based) Web beacons and pixel tags Local storage data Analytics tracking identifiers Mobile advertising IDs Third-party tracking tags

3.3 Information Received from Third Parties

Where you choose to integrate or authorise third-party services with the App, we may receive information from those services, including:

Third-Party Integrations: Email service providers (Gmail, Outlook, etc.) Calendar services (Google Calendar, Outlook Calendar, etc.) Business applications and CRM systems Social media platforms (LinkedIn, Facebook, etc.) Data aggregation services Lead generation platforms Real estate portals and listing sites Channel partners and resellers Inbound referral sources

Information Received: Lead information and customer data Contact lists and communication history Calendar events and meeting details Social media profile information (where authorised) Campaign performance data Interaction history with third-party platforms Referral attribution data

Data Processing: We process all third-party data in accordance with applicable laws We do not warrant the accuracy or compliance status of third-party data You are responsible for ensuring you have rights to share third-party data with us

3.4 Information from Channel Partners and Inbound Sources

We may receive lead and customer information from:

• Real estate channel partners and resellers
• Co-marketing partners
• Affiliate networks
• Inbound referrals and word-of-mouth sources
• Business directories and listing sites
• Public databases and publicly available sources

We collect and process such information based on legitimate interest to expand our lead database and serve our real estate clients more effectively.

4. LOCATION INFORMATION AND TRACKING

4.1 Collection and Use of Location Data

Our mobile application may collect and process your location information, including precise GPS location data and geofence-based data, when you grant location permission through your device settings.

Location data is collected and used solely for legitimate business and operational purposes, including:

Attendance Management: Recording employee check-in and check-out times and locations Verifying employee work attendance and hours Generating attendance reports and analytics

Field Verification and Monitoring: Verifying employee presence at designated project sites Confirming attendance at customer meetings and property viewings Monitoring field representative activities and site visits Validating business claims and commitments

Field Activity Tracking: Tracking and recording real estate sales activities (site visits, lead meetings) Monitoring property viewing activities and customer interactions Recording field team movement and activity patterns Route optimisation for field representatives

Lead Management and CRM Operations: Recording customer visit locations associated with property enquiries Linking customer interactions to specific properties and locations Enabling location-based lead assignment and routing Tracking lead qualification and conversion by location

Operational Efficiency and Analytics: Monitoring operational efficiency and service delivery Analysing team productivity and performance by location Improving sales coverage and geographic strategy Generating location-based business intelligence

Compliance and Loss Prevention: Verifying authorised access to secure company locations Preventing unauthorised access or theft Identifying policy violations or misuse

4.2 Background Location Access

The App may collect location information:

During Active Use: Location is collected while the App is actively in use and open Collection occurs at periodic intervals (frequency varies by operational need)

Background Collection: For attendance management and field activity verification purposes, the App may collect location information while running in the background Background collection is subject to: User-granted location permission (foreground and background) Device-level permission settings (Android and iOS requirements) Company policy and operational necessity

Data Frequency: Location data may be collected continuously, periodically, or event-triggered Frequency depends on operational requirements and employee role Continuous tracking may occur during designated work hours or events

User Disclosure: You acknowledge that location tracking may occur in the background Users are notified of background location collection via app permissions and this Privacy Policy Disabling location services will prevent background tracking

4.3 Sharing and Retention of Location Data

Sharing Restrictions:

Location information is used only for legitimate business purposes and is never sold to third parties for commercial exploitation.

Location data may be shared only with:

• Authorised Company administrators and managers (on need-to-know basis)
• Internal CRM and business management systems (for operational use)
• Technology service providers supporting application functionality:
• Cloud hosting and infrastructure providers (AWS, Google Cloud, etc.)
• Analytics and data processing providers
• Security and backup service providers

Government authorities or regulatory bodies where required under applicable law (law enforcement, courts, etc.)

Location data is never shared with: Unauthorised third parties Competing businesses Marketing or data brokers Social media platforms Public directories

Retention of Location Data:

Location information is retained indefinitely for business operations but may be deleted at Delta Yards' sole discretion when:

• Data is no longer required for operational purposes
• Operational retention periods expire
• Users request deletion (subject to business necessity)
• Applicable law requires deletion

Specific Retention Scenarios: Active employee location logs: Retained indefinitely, can be archived after 2-3 years if needed Historical location trails: Retained indefinitely Customer visit locations: Retained indefinitely for lead relationship history Geofence event logs: Retained indefinitely

4.4 User Control and Rights

Enabling/Disabling Location Services:

You may disable location permissions at any time through:

• Device settings (Android/iOS location services)
• App-level permission settings
• Contacting the Company to request opt-out

Consequences of Disabling Location Access:

Disabling location services may affect or prevent the proper functioning of features including:

• Attendance Check-In and Check-Out (feature becomes unavailable)
• Site Visit Verification (location-based verification disabled)
• Lead Management Updates (location tagging unavailable)
• Field Activity Tracking (activity location recording disabled)
• Geofence-based Notifications (location alerts disabled)

Employee Acknowledgment:

Employees acknowledge that location tracking is a condition of employment/engagement for roles requiring field activity verification. Refusal to enable location services may impact job performance evaluation and work authorisation.

5. HOW WE COLLECT INFORMATION

We collect personal information through various channels and methods:

Direct Collection Methods: Website contact forms and enquiry forms Property enquiry and preference forms Newsletter subscription forms App registration and login Feature interaction and settings configuration Telephone conversations and voicemail messages Email communications and support tickets WhatsApp messages and conversations SMS communications

Automated Collection Methods: Cookies and web tracking technologies Analytics tools (Google Analytics, similar platforms) Device location services Camera and photo gallery access Social media pixel tracking Mobile app analytics

Workplace Collection Methods: Employee check-in and check-out activity Lead creation and updates within CRM Site visit records and field activity logs Attendance systems and time tracking Communication logs (calls, emails, messages) Location tracking during work hours Activity logs and audit trails

Third-Party Sources: Channel partners and affiliate networks Real estate portals and listing sites Lead generation and data aggregation services Social media platforms (user-authorised integrations) Email and calendar service integrations Marketing platforms (Meta, Google Ads, etc.) Public databases and publicly available information

6. PURPOSE OF DATA COLLECTION

The information collected through our Services is used solely for legitimate business purposes:

6.1 Primary Business Purposes

Customer Service and Sales: Responding to customer enquiries and support requests Providing real estate consultation and advisory services Recommending suitable real estate projects based on preferences Managing property enquiries and viewings Facilitating property transactions and bookings

Lead Management and CRM Operations: Creating and updating lead records Tracking lead interactions and conversion pipeline Assigning leads to sales representatives Monitoring lead status and follow-up activities Analysing lead quality and conversion metrics

Campaign Management and Marketing: Tracking marketing campaign performance Attributing leads to specific campaigns or channels Optimising ad spend and ROI across channels Creating audience segments for targeted marketing Conducting A/B testing and campaign experimentation

6.2 Internal Operations

Workforce Management: Managing employee attendance and time tracking Tracking employee location and field activities Monitoring employee productivity and performance Verifying employee presence at designated locations Generating payroll and compensation data

Business Intelligence and Analytics: Analysing lead data, sources, and conversion patterns Generating anonymised business intelligence reports Identifying market trends and customer preferences Optimising sales strategies and resource allocation Benchmarking performance across teams and locations

6.3 Improving Services

Service Enhancement: Improving customer experience and service quality Identifying pain points and service gaps Testing new features and functionality Optimising app performance and usability Training and improving AI systems and automation (Aarti voice AI, etc.)

6.4 Legal and Compliance

Regulatory Compliance: Complying with legal, regulatory, and contractual obligations Maintaining records for tax, accounting, and audit purposes Responding to legal requests from government authorities Enforcing our Terms and Conditions Protecting our legal rights and intellectual property

Data Security and Fraud Prevention: Detecting and preventing fraud, abuse, and unauthorised access Investigating security breaches and incidents Protecting against cyber threats and malicious activity Verifying user identity and authorisation

6.5 Marketing Communications

Promotional Communications: Sending promotional emails, SMS, and WhatsApp messages about new properties and offers Notifying about relevant real estate opportunities based on preferences Inviting to property showcases, events, and webinars Sharing market insights and educational content

Legal Basis for Marketing: Explicit opt-in consent (for leads from your own website/app) Legitimate interest (for identified prospects in target demographics) Third-party data (for leads from channel partners; you represent you have rights to contact) Service-related communications (status updates, confirmations, etc.)

7. LEGAL BASIS FOR DATA PROCESSING

We process personal information under the following legal bases as per the DPDP Act, 2023:

7.1 Consent

When consent is obtained: Website form submissions with consent checkbox App registration and account creation Opt-in to marketing communications Explicit permission for location tracking Third-party service integrations

Your right to withdraw consent: You may withdraw consent at any time using a process as simple as the process by which consent was provided Withdrawal does not affect processing carried out before withdrawal Withdrawal may limit access to certain features

7.2 Contract Performance

When processing is necessary to perform contract or services: Responding to property enquiries Providing real estate advisory services Processing property bookings and transactions Delivering CRM services to authorised users Managing service-related communications

7.3 Legitimate Interest

When Delta Yards has a legitimate interest to process data: Expanding our lead database and customer base Improving marketing effectiveness and campaign performance Preventing fraud and unauthorised access Protecting our intellectual property and legal rights Business intelligence and analytics Employee and field activity verification Operational efficiency and service improvement

8. PHOTOS AND MEDIA ACCESS

8.1 Collection and Use

The App may request access to your device camera and photo gallery for legitimate business purposes:

Attendance and Documentation: Capturing attendance photographs during check-in and check-out Recording evidence of employee presence and activity Documenting employee compliance with workplace policies

Lead and Customer Documentation: Uploading customer-related documents and supporting images Attaching photographs to lead records and customer profiles Documenting property visits and site conditions Recording customer interactions and meetings

Site Visit and Activity Documentation: Photographing properties and project sites Recording field activity and work completion Documenting customer engagement and interactions Creating visual records for CRM and reporting

8.2 Use and Sharing of Photos

Internal Use: Photos and media are used solely for operational and business purposes Images are stored in the CRM and associated with lead/customer records Photos are used for internal reporting and documentation

Restriction on Misuse: The Company does not use photos for unrelated purposes (e.g., facial recognition without consent, unauthorised social media posting) Photos are not shared with unauthorised third parties Photos are not used for marketing without specific consent

Sharing with Third Parties: Photos may be shared with real estate developers/builders in the context of site visits or customer interactions Photos may be shared with government/regulatory authorities if required by law Photos are not shared with marketing or data brokers

Privacy Respect: If photos contain identifiable individuals other than yourself, you represent that you have consent to include them You are responsible for obtaining necessary consents from individuals appearing in photos

8.3 Retention and Deletion

• Photos are retained indefinitely as part of lead records
• Photos may be deleted at Delta Yards' discretion or upon user request
• Deletion may not be possible if photos are integral to lead/customer documentation

9. COOKIES AND TRACKING TECHNOLOGIES POLICY

9.1 Use of Cookies

Our website may use cookies and similar tracking technologies, including:

• Session cookies (temporary, deleted when browser closes)
• Persistent cookies (remain on device for specified period)
• First-party cookies (set by Delta Yards domain)
• Third-party cookies (set by third-party services)
• Web beacons and pixel tags (tracking pixels embedded in content)
• Analytics tracking tags (Google Analytics, similar)
• Mobile app identifiers (unique device identifiers for app tracking)

9.2 Purposes of Cookies

Functional Purposes: Remembering login information and user preferences Maintaining user session and authentication Enabling form functionality and navigation Storing language and display preferences

Analytics and Performance: Understanding how users interact with website and app Measuring page views, click patterns, and user flow Identifying popular pages and features Analysing traffic sources and user journey Monitoring website performance and technical issues

Marketing and Advertising: Tracking marketing campaign performance and ROI Creating user segments for targeted marketing Enabling retargeting advertisements Measuring ad effectiveness across platforms

9.3 User Control and Consent

Cookie Management:

You may disable, manage, or delete cookies through:

• Browser settings (Chrome, Firefox, Safari, Edge, etc.)
• Mobile device settings
• Third-party cookie management tools
• Do Not Track browser signals (if supported)

Impact of Disabling Cookies:

• Functional cookies: Disabling may affect website navigation, form submission, and basic functionality
• Analytics cookies: Disabling prevents analytics but does not affect functionality
• Marketing cookies: Disabling prevents personalised advertising but allows general use

Consent for Non-Essential Cookies:

• Essential cookies are necessary for basic functionality and may be used without explicit consent
• Non-essential cookies (analytics, marketing) require explicit user consent via cookie consent banner
• Users may withdraw consent by updating cookie preferences at any time
• Continued use of website after cookie notice constitutes implied consent to essential cookies

9.4 Third-Party Cookies

• The Company does not control third-party cookies set by external services
• Third-party services may track users across multiple websites
• Users should review third-party privacy policies for details

The Company does not use cookies for cross-site behavioural profiling without consent where required by law

10. SHARING OF INFORMATION

Delta Yards Realty Private Limited does not sell your personal information to unauthorised third parties or data brokers.

10.1 Internal Sharing

Your information may be shared internally with:

• Authorised Delta Yards employees and team members who require access to perform official duties
• Management and supervisors for performance evaluation and operational purposes
• Finance and HR teams for payroll, benefits, and employment purposes
• Data protection and legal teams for compliance and legal matters
• Access is on a need-to-know basis and limited to authorised personnel.

10.2 Sharing with Real Estate Partners

Your information may be shared with:

• Real estate developers and builders with whom Delta Yards has partnerships
• Real estate project partners for lead management and sales follow-up
• Associated business entities engaged in property transactions

Such sharing is limited to: Lead information and customer preferences (for project matching) Contact information (name, phone, email) Property viewing and enquiry history (relevant to the property/project)

Restrictions: Builders cannot share your data with competing builders without consent Builders must comply with applicable privacy laws Builders must honour your privacy preferences and opt-out requests

10.3 Sharing with Technology and Service Providers

Your information may be shared with:

• Cloud infrastructure providers (AWS, Google Cloud, internal servers, etc.)
• CRM and business software providers (if using third-party platforms)
• Analytics and reporting tools (Google Analytics, business intelligence platforms)
• Communication service providers (WhatsApp Business, SMS gateways, email services)
• Customer support and ticketing systems
• Payment processors (for transaction processing, if applicable)
• Backup and disaster recovery providers
• Security and monitoring service providers

Contractual Obligations: All service providers are contractually obligated to process data only for authorised purposes Service providers must comply with applicable data protection laws Service providers must implement reasonable security measures Service providers cannot sub-process data without prior approval

10.4 Sharing with Government and Legal Authorities

Your information may be shared with:

• Government authorities and regulatory bodies (tax department, real estate regulators, etc.)
• Law enforcement agencies (police, CBI, etc.) in response to valid legal requests
• Courts and judicial authorities in response to subpoena or court order
• Compliance and regulatory bodies to fulfill legal obligations

Disclosure is limited to: Information required by applicable law Information necessary to protect public safety or national security Information to prevent fraud or criminal activity Disclosure is made only with proper legal authorization

10.5 No Cross-Border Data Transfers

Data Location:

Your data is processed and stored primarily in India across: Amazon Web Services (AWS) India regions Google Cloud India infrastructure Internal servers in India

International Transfers:

• Data may occasionally be transferred outside India for backup, disaster recovery, or legitimate operational purposes
• Any international transfer is made in compliance with applicable law
• You consent to such transfers when necessary for service delivery

11. DATA SECURITY

Delta Yards implements reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorised access, disclosure, alteration, misuse, destruction, and loss.

11.1 Security Measures

Technical Security: Encryption in Transit: Data transmitted between client and servers is encrypted using SSL/TLS protocols (minimum TLS 1.2) Encryption at Rest: Sensitive data stored in databases and servers is encrypted using industry-standard encryption algorithms Database Security: Database access is restricted through: Role-based access controls (RBAC) User authentication and authorisation Audit logging of database access Encryption of sensitive database fields

Administrative Security: User Access Controls: Employees have access limited to data required for their role Multi-Factor Authentication: App access requires MFA where applicable Password Policies: Strong password requirements and regular password changes Access Logging: All data access is logged and monitored for suspicious activity

Physical Security: Server Protection: Servers and infrastructure are protected in secure data centres with: Physical access controls (biometric locks, security cameras) Environmental controls (HVAC, fire suppression) Backup power (UPS, generators) Network Security: Firewalls, intrusion detection systems, and network segmentation protect infrastructure

Operational Security: Regular Security Reviews: Periodic security assessments and vulnerability testing Incident Response Plan: Procedures for responding to security breaches and incidents Employee Training: Regular security awareness and data protection training for all staff Vendor Security: Third-party vendors are required to meet minimum security standards Backup and Disaster Recovery: Regular data backups to prevent loss

11.2 Limitations of Security

No Absolute Guarantee:

While we implement reasonable security measures, no method of electronic transmission or storage can be guaranteed to be completely secure.

The Company: Cannot guarantee absolute security against all attacks Is not liable for security breaches beyond its reasonable control Is not responsible for security failures of third-party providers Does not warrant that security measures are breach-proof

Your Role in Security:

You are responsible for: Maintaining confidentiality of your login credentials Using strong, unique passwords Not sharing credentials with others Logging out of the app on shared devices Reporting suspicious activity immediately

12. DATA BREACH NOTIFICATION

In the event of a confirmed data breach or unauthorised access to personal information, Delta Yards shall:

12.1 Notification Timeline

• Notify affected users within 72 hours of becoming aware of the breach (as per DPDP Act, 2023)
• Notify regulatory authorities as required by applicable law
• Document the breach and maintain records for regulatory inquiry

12.2 Breach Notification Content

Breach notifications shall include:

• Nature of the breach: What type of data was compromised
• Data categories affected: Types of personal information exposed
• Scope of impact: Number of individuals affected (where known)
• Measures taken: Steps taken to secure systems and prevent recurrence
• User actions: Recommended steps users should take to protect themselves
• Contact information: How to reach the Company for further information

12.3 Breach Investigation

• The Company shall immediately investigate any suspected breach
• A forensic analysis shall be conducted to determine the scope and cause
• The Company shall cooperate with law enforcement and regulatory investigations
• The Company shall implement measures to prevent similar breaches

13. RETENTION OF INFORMATION

Delta Yards retains personal information for the duration necessary to fulfill the purposes described in this Privacy Policy and as required by applicable law.

13.1 Retention Categories and Periods

Lead and Customer Information: Active leads: Retained indefinitely as long as the relationship is active Converted/closed leads: Retained indefinitely for historical records Inactive leads: Retained indefinitely; may be archived but not deleted Retention basis: Business operations, analytics, relationship history, legal compliance

Location and Attendance Data: Active employee location logs: Retained indefinitely Historical location trails: Retained indefinitely Attendance records: Retained indefinitely Geofence event logs: Retained indefinitely Retention basis: Operational verification, performance monitoring, audit trails

Communication Records: Email communications: Retained indefinitely WhatsApp and SMS messages: Retained indefinitely (as logs) Call recordings: Retained indefinitely (if recorded with consent) Support tickets and enquiries: Retained indefinitely Retention basis: Lead management, dispute resolution, legal compliance

Business and Operational Records: Employee records: Retained indefinitely Site visit and activity records: Retained indefinitely Campaign performance data: Retained indefinitely Financial and transaction records: Retained as per tax law (generally 7 years minimum) Retention basis: Legal compliance, business operations, analytics

Website and Analytics Data: Cookie data: Retained per cookie expiry (session cookies: deletion on logout; persistent cookies: per retention policy) Website analytics: Retained indefinitely Usage logs: Retained indefinitely Retention basis: Analytics, performance optimisation, user experience

13.2 Discretionary Deletion

Delta Yards reserves the right to delete, anonymise, or archive personal information at any time for business, technical, or operational reasons, including:

• Storage optimisation and database management
• Improved system performance
• Archival of historical records
• Removal of redundant or obsolete data
• Technical systems upgrades or migration
• Users do not have the right to prevent such deletion unless prohibited by law.

13.3 User Requests for Deletion

Users may request deletion of their personal information under the following circumstances:

• Where retention is no longer necessary for the purpose of collection
• Where consent has been withdrawn
• Where data is inaccurate or incomplete
• Where processing violates applicable law

Deletion requests: Must be submitted in writing to info@deltayards.com Will be evaluated based on legal requirements and business necessity May be refused if deletion conflicts with legal obligations or legitimate business interests If approved, deletion shall occur within 30 days

14. USER RIGHTS UNDER DPDP ACT 2023

Subject to the provisions of the Digital Personal Data Protection Act, 2023 and other applicable laws, you may have the following rights regarding your personal information:

14.1 Right to Access

You have the right to: Request confirmation as to whether Delta Yards processes your personal information Request access to a copy of your personal information Understand how your information is processed and used

How to exercise: Submit a written request to: info@deltayards.com Include sufficient identifying information (name, email, etc.) Request will be processed within 30 days Information will be provided in a clear, easily understandable format

14.2 Right to Correction

You have the right to: Request correction of inaccurate or incomplete personal information Request updating of outdated information Request completion of incomplete records

How to exercise: Submit a written request specifying which information is incorrect Provide evidence of the correct information Corrections will be made within 30 days The Company may verify corrections before implementing

14.3 Right to Erasure

You have the right to request deletion of your personal information where: Data is no longer necessary for the purpose of collection Your consent has been withdrawn The data is inaccurate or has been processed unlawfully Retention violates applicable law

Limitations: Deletion may be refused if data is required for legal compliance Deletion may be refused if data is required for legitimate business interests Deletion of lead data may be refused as it is the property of Delta Yards (Section 6.2, Terms) Deletion of historical records may be refused for audit and compliance purposes

How to exercise: Submit a written request to: info@deltayards.com Specify which information to delete Decision will be provided within 30 days

14.4 Right to Data Portability

You have the right to: Request a copy of your personal information in a structured, commonly used, machine-readable format Transmit such data to another service provider without impediment

Limitations: Data portability does not apply to derived data or business intelligence Portability is limited to information you provided Data portability shall not affect the rights of other data subjects

How to exercise: Submit a written request to: info@deltayards.com Specify which information to export Data will be provided in CSV, JSON, or similar format within 30 days

14.5 Right to Withdraw Consent

You have the right to: Withdraw consent for processing based on your consent at any time Use a process that is as simple as the process by which consent was originally provided Withdraw consent without providing reasons

Effect of withdrawal: Processing based on consent shall cease Withdrawal does not affect legality of processing before withdrawal Withdrawal may affect access to certain features or services Withdrawal does not affect processing based on other legal bases (legitimate interest, legal obligation, etc.)

How to exercise: Click "unsubscribe" in marketing communications Update preferences in app settings Email: info@deltayards.com Withdrawal shall be effective immediately

14.6 Right to Grievance Redressal

You have the right to: Lodge a complaint if your personal information has been processed in violation of applicable law Seek redressal of privacy violations through the Company's grievance process Appeal to the Data Protection Board of India if unsatisfied with the Company's response

How to exercise: Submit a grievance to the Data Protection Officer: Name: Sangeeta Singh Email: info@deltayards.com Provide details of the violation and desired remedy The Company shall acknowledge within 10 days Resolution shall be attempted within 30 days If unresolved, lodge a complaint with the Data Protection Board of India

14.7 Right Against Automated Decision Making

You have the right to: Know if automated decision-making (including profiling) is being used Understand the logic, significance, and consequences of automated decisions Request human review of automated decisions

Automated Processes at Delta Yards: Lead scoring and prioritisation algorithms (if applicable) Lead assignment and routing automation Fraud detection systems Spam filtering and validation

How to exercise: Request information about automated decisions affecting you Submit request to: info@deltayards.com Manual review of decisions will be provided within 30 days

15. MARKETING COMMUNICATIONS AND PREFERENCES

15.1 Types of Communications

By submitting your information through our website, mobile application, enquiry forms, or other communication channels, you may receive:

Marketing Communications: Promotional emails about new properties and offers SMS messages about special promotions and updates WhatsApp messages about property opportunities Phone calls from our sales team In-app notifications about relevant projects

Service Communications: Confirmations of enquiries and registrations Updates on your lead status and interactions Request for feedback and reviews Appointment reminders and scheduling notifications Account-related alerts and notifications

15.2 Legal Basis for Marketing

Marketing communications are sent based on:

Explicit Opt-In Consent: For leads originating from your own enquiries on Delta Yards platforms For users who have opted in to marketing notifications Consent can be withdrawn at any time

Legitimate Interest: For identified prospects matching target demographics For individuals showing interest in real estate or properties Balancing the Company's interest in marketing against your privacy rights

Third-Party Data: For leads sourced from channel partners, referrals, or data providers You represent that you have consented to being contacted by real estate agents You can request opt-out at any time

15.3 TRAI Compliance

For telecom outreach (phone calls, SMS messages), we comply with:

• Telecom Commercial Communications Customer Preference Regulations, 2018
• National Do Not Call (NDNC) Registry
• Do Not Disturb (DND) preferences

We shall: Respect your DND/NDNC registration Not contact you if registered as "Do Not Call" Honour opt-out requests immediately Not engage in harassment or excessive calling

15.4 Opting Out of Marketing

You may opt out of receiving marketing communications at any time by:

Email Communications: Click the "unsubscribe" link in any marketing email Reply with "UNSUBSCRIBE" or "OPT OUT" Send written request to: info@deltayards.com

SMS Communications: Reply with "STOP" or "UNSUBSCRIBE" to any SMS Send written request to: info@deltayards.com

WhatsApp Communications: Reply with "OPT OUT" or "STOP" to any message Save our contact and block notifications Send written request to: info@deltayards.com

Phone Communications: Request to be added to Do Not Call list during call Send written request to: info@deltayards.com Register with NDNC registry: www.donotcall.gov.in

App Notifications: Disable notifications in app settings Turn off notification permissions in device settings

Response Timeline: Opt-out requests shall be processed within 48 hours Confirmation of opt-out shall be provided

15.5 Service Communications Exception

Opting out of marketing does not affect service-related communications, including:

• Transactional emails and confirmations
• Account security alerts and notifications
• Password reset and account recovery
• Legal notices and policy updates
• Mandatory regulatory communications
• Resolution of customer complaints

16. EMPLOYEE AND TEAM MEMBER PRIVACY

16.1 Employee and Contractor Tracking

This Privacy Policy applies to all individuals using the App, including:

• Delta Yards employees
• Contract employees and temporary staff
• Freelancers and independent contractors
• Outsourced service providers

16.2 Location Tracking of Team Members

Delta Yards implements location tracking for team members for legitimate operational purposes, including:

• Attendance verification and time tracking
• Field activity verification and monitoring
• Productivity and performance evaluation
• Route optimisation and efficiency improvement
• Security and loss prevention

16.3 Employee Notification and Consent

Employees acknowledge and consent to location tracking through:

• Receipt of this Privacy Policy during onboarding
• Acceptance of employment terms and conditions
• Granting of location permissions in device settings
• Explicit acknowledgment by team member

Employees should understand: Location is tracked during work hours and field activities Location may be tracked in the background Location data is retained indefinitely Location data is used for operational and performance purposes Disabling location services may impact employment

16.4 Employee Rights

Employees retain the rights listed in Section 14, including:

• Right to access their location data and activity records
• Right to request correction of inaccurate data
• Right to request deletion (subject to business necessity)
• Right to request data portability
• Right to lodge grievances regarding location tracking

To exercise rights: Contact the Data Protection Officer: Sangeeta Singh (info@deltayards.com) Submit request with sufficient identifying information Requests will be processed within 30 days

17. MINORS AND CHILDREN

17.1 Age Restriction

The Services provided by Delta Yards Realty Private Limited are intended only for individuals who are:

• 18 years of age or older
• Possess legal capacity to enter into a binding agreement

17.2 No Collection from Minors

The Company does not knowingly collect, process, or store personal information belonging to individuals under the age of 18 years.

17.3 Accidental Collection

If the Company becomes aware that personal information belonging to a minor has been collected, such information shall be:

• Deleted or anonymised as soon as reasonably practicable
• Removed from all databases and systems
• Not used for any purpose

17.4 Parental Notice

Parents, guardians, or individuals with custody of minors who believe a minor has provided personal information to the Company may:

• Contact the Company immediately at: info@deltayards.com
• Provide evidence of the minor's identity
• Request immediate deletion of the minor's information
• Response Timeline: Deletion requests will be processed within 10 business days.

18. AUTOMATED DECISION-MAKING AND PROFILING

18.1 Automated Processes

The App may use automated decision-making systems, including:

• Lead Scoring: Automated algorithms that assign scores to leads based on engagement, demographics, and conversion likelihood
• Lead Assignment: Automated routing of leads to sales representatives based on criteria
• Fraud Detection: Automated systems that identify suspicious or fraudulent activities
• Content Personalization: Automated recommendations based on user behaviour and preferences

18.2 Your Rights

You have the right to:

• Know if automated decision-making is being applied to your data
• Understand the logic and criteria used in automated decisions
• Receive explanation of significance and consequences of automated decisions
• Request human review of any automated decision affecting you
• Challenge or contest automated decisions

18.3 How to Exercise Your Rights

To request information about automated decision-making or request human review:

• Submit a written request to: info@deltayards.com
• Specify which automated decision you are inquiring about
• Include sufficient identifying information
• Request will be processed within 30 days
• Human review will be provided if requested

19. CHANGES TO THIS PRIVACY POLICY

Delta Yards Realty Private Limited reserves the right to amend, modify, update, or replace this Privacy Policy from time to time to reflect:

• Changes in legal and regulatory requirements
• Changes in our business operations and services
• Advances in technology and security practices
• User feedback and privacy enhancements

19.1 Notification of Changes

Material changes will be communicated through one or more of the following methods:

• Publication of the updated Privacy Policy within the App
• Publication of the updated Privacy Policy on the Company's website (www.deltayards.com)
• Email notification to registered users at their registered email address
• In-app notification or alert
• Telephone or SMS notification (for major changes)
• Minor changes (clarifications, corrections) may be published without advance notice.

19.2 Effective Date

• Non-material changes become effective immediately upon publication
• Material changes become effective 30 days after notification, unless a different date is specified

Your continued use of the Services after the effective date of any revised Privacy Policy constitutes your acceptance of the updated Privacy Policy

19.3 Your Right to Reject Changes

If you do not agree with the revised Privacy Policy:

• You must immediately discontinue using the Services
• Contact the Company to request account closure
• You will no longer have any rights to use the App

20. GOVERNING LAW AND DISPUTE RESOLUTION

20.1 Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of India, without regard to its conflict of law principles.

The interpretation and enforcement shall be guided by:

• The Digital Personal Data Protection Act, 2023
• The Information Technology Act, 2000
• All applicable laws of India

20.2 Jurisdiction

The courts located in Mira Bhayander, Maharashtra, India shall have exclusive jurisdiction over matters arising out of or relating to this Privacy Policy.

20.3 Dispute Resolution Process

Step 1: Informal Resolution

The parties agree to make reasonable efforts to resolve any privacy dispute through:

• Good-faith discussions and negotiations
• Direct communication between representatives
• Mediation (if either party requests)
• Duration: 30 days from notification of the dispute
• Step 2: Arbitration

If informal resolution fails, the dispute shall be finally resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996:

• Venue: Mira Bhayander, Maharashtra, India
• Language: English
• Arbitrator: Single arbitrator mutually appointed or appointed per law
• Confidentiality: Proceedings and award are confidential
• Step 3: Regulatory Complaint

If not satisfied with the Company's resolution, you may lodge a complaint with:

• Data Protection Board of India (established under DPDP Act)
• State Consumer Protection Authority (under Consumer Protection Act)
• National Consumer Disputes Redressal Commission

21. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

21.1 Privacy Queries and Requests

If you have any questions, concerns, or requests relating to this Privacy Policy, you may contact Delta Yards using the details below:

Delta Yards Realty Private Limited

• Registered Office: 201, Samruddhi Plaza, 2nd Floor
• Mira Bhayander Road
• Bhayander East
• Thane, Maharashtra – 401105
• India

• Email: info@deltayards.com
• Phone: +91 79770 37145

Website: www.deltayards.com

21.2 Data Protection Officer and Grievance Officer

For privacy-specific grievances and complaints:

Data Protection Officer / Grievance Officer: Name: Sangeeta Singh Email: info@deltayards.com Designation: Data Protection Officer and Grievance Redressal Officer Note: Subject to change; Company will notify of any changes

21.3 Response Timeline

The Company shall:

• Acknowledge all enquiries and complaints within 10 business days
• Respond to grievances within 30 days of receipt
• Process data rights requests within 30 days as per DPDP Act
• Prioritise urgent and time-sensitive matters

21.4 Escalation

If you are not satisfied with the Company's response:

• You may request escalation to Company leadership
• You may lodge a complaint with the Data Protection Board of India
• You may seek relief through the courts in Mira Bhayander, Maharashtra
• You may file a consumer complaint with relevant authorities

22. GRIEVANCE OFFICER AUTHORITY

The Data Protection Officer / Grievance Officer (Sangeeta Singh) has the authority to:

• Receive and acknowledge all privacy-related complaints and grievances
• Investigate privacy violations and breaches
• Implement corrective measures to address violations
• Coordinate with legal and technical teams for remediation
• Maintain records of all complaints and resolutions
• Communicate with complainants regarding status and resolution
• Escalate to management if necessary

23. CONSENT

23.1 Explicit Consent

By accessing, registering for, or using the Delta Yards website, mobile application, or any of the Services provided by Delta Yards Realty Private Limited, you:

• Acknowledge that you have read and fully understood this Privacy Policy
• Certify that you are at least 18 years of age
• Provide explicit consent to the collection, use, processing, storage, and disclosure of your personal information in accordance with this Privacy Policy
• Acknowledge that your data may be processed across multiple cloud providers and internal servers
• Acknowledge that your location may be tracked for operational purposes
• Acknowledge that your data may be retained indefinitely
• Acknowledge that anonymised data may be shared across projects and builders
• Acknowledge the risks associated with electronic data transmission and storage

23.2 Withdrawal of Consent

You may withdraw this consent at any time by:

• Email to: info@deltayards.com
• Written notice to the registered office
• In-app settings (where available)
• Phone: +91 79770 37145

Effect of withdrawal: Withdrawal applies prospectively only Processing before withdrawal remains lawful Withdrawal may affect your access to Services Withdrawal does not affect processing based on other legal bases

23.3 No Consent = No Service

If you do not agree with this Privacy Policy and do not wish to provide consent:

• You must not use the Services
• You must discontinue accessing the App
• You may request account deletion and data removal

24. FOR MORE INFORMATION

For additional information about how we collect, use, store, and protect user data, please refer to:

• Terms and Conditions: Available on our website and in-app
• Cookie Policy: Detailed in Section 9 of this Privacy Policy
• DPDP Act Compliance: See Section 14 (User Rights)
• Data Security Details: See Section 11
• Company Website: www.deltayards.com
• END OF PRIVACY POLICY

• Version: 2.0 (Revised 1 July 2026)
• Status: Production Ready
• Jurisdiction: India

Applicable Laws: Digital Personal Data Protection Act, 2023 | Information Technology Act, 2000 | TRAI Regulations, 2018 | Arbitration and Conciliation Act, 1996

• Last Reviewed: Wednesday, 1 July 2026
• Next Review Date: 1 July 2027 (Annual Review Recommended)