1. Introduction

Purearth Infrastructure Limited (“Purearth”, “we”, “our”, or “us”), a company incorporated under the laws of India and having its registered office at Central Square, 20, Manohar Lal Khurana Marg, Bara Hindu Rao, Delhi – 110006, is committed to protecting the privacy and personal data of all individuals who interact with our website, digital platforms, and services.

This Privacy Policy explains how we collect, use, store, share, and protect information about you when you visit our website (www.purearth.in), make an enquiry, submit a form, attend a site visit, or otherwise engage with Purearth Infrastructure Limited or any of its projects, including The Amaryllis and Central Square.

This Policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDPA), and applicable rules thereunder. By using our website or providing us with your personal data, you consent to the practices described in this Policy.

If you do not agree to the terms of this Privacy Policy, please do not use our website or submit personal information to us.

2. Definitions

For the purpose of this Policy, the following terms shall have the meanings ascribed to them:

• “Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDPA, 2023.
• “Sensitive Personal Data” includes financial information such as bank account details, passwords, physical and physiological health information, sexual orientation, medical records, biometric data, and similar information as notified.
• “Data Fiduciary” refers to Purearth Infrastructure Limited, which determines the purpose and means of processing personal data.
• “Data Principal” refers to the individual to whom the personal data relates — i.e., you, the user.
• “Processing” means any operation or set of operations carried out on personal data, whether or not by automated means.
• “Consent Manager” means a board-registered entity enabling consent as provided under the DPDPA, 2023.

3. Information We Collect

We collect information in the following ways and categories:

3.1 Information You Provide Directly

• Full name, email address, and mobile/phone number submitted via enquiry forms, callback requests, or registration pages.
• Postal address and city of residence when provided for correspondence or site visit scheduling.
• Preferred apartment configuration, budget range, and purchase intent details shared during consultations.
• Identification documents (PAN card, Aadhaar, passport) when required for regulatory compliance under RERA, PMLA, or income tax laws.
• Financial information, including home loan pre-approval details, when voluntarily shared to facilitate a transaction.
• Correspondence, feedback, or complaints submitted via email, phone, or our website contact forms.

3.2 Information Collected Automatically

• IP address, browser type and version, operating system, referring URL, and pages visited.
• Time and duration of visit, clickstream data, and interaction with website features.
• Device identifiers and geolocation data (if enabled by your browser settings).
• Cookies, web beacons, pixel tags, and similar tracking technologies (see Section 9 for details).

3.3 Information from Third Parties

• Data received from property portals, real estate aggregators, or channel partners through whom you may have expressed interest in our projects.
• Publicly available information from social media platforms where you have interacted with our official accounts.
• Referral data from co-brokers or individual referrers who have provided your contact details with your prior consent.

4. How We Use Your Information

We use the personal data we collect for the following purposes, relying on the legal bases described in Section 5:

4.1 Sales & Project Enquiries

• To respond to your enquiries about our residential and commercial projects.
• To schedule site visits, walkthroughs, and consultations at your convenience.
• To provide you with pricing, floor plans, brochures, and other project documentation.
• To process expressions of interest, booking applications, and allotment letters.

4.2 Marketing & Communications

• To send you information about our current and upcoming projects, events, and launches.
• To keep you updated on construction progress, possession timelines, and project milestones.
• To conduct surveys and obtain feedback to improve our services and offerings.
• To send you newsletters, promotional materials, and special offers, where you have opted in.

4.3 Legal & Regulatory Compliance

• To comply with the Real Estate (Regulation and Development) Act, 2016 (RERA) and applicable state regulations.
• To fulfil obligations under the Prevention of Money Laundering Act, 2002 (PMLA) and related Know Your Customer (KYC) requirements.
• To respond to court orders, government requests, or law enforcement enquiries as required by law.
• To maintain proper books of account and statutory records as mandated under the Companies Act, 2013.

4.4 Business Operations

• To manage and improve our website, digital platforms, and customer-facing systems.
• To analyse usage patterns and conduct internal analytics for business planning purposes.
• To detect, prevent, and investigate fraudulent or unauthorised activity.
• To manage relationships with channel partners, brokers, and third-party service providers.

5. Legal Basis for Processing

Under the Digital Personal Data Protection Act, 2023, we process your personal data on the following legal bases:

• Consent: Where you have explicitly given us consent to process your data for a specific purpose (e.g., receiving marketing communications). You may withdraw consent at any time.
• Contractual Necessity: Where processing is necessary to perform a contract to which you are a party, or to take pre-contractual steps at your request (e.g., processing a booking application).
• Legal Obligation: Where processing is required to comply with a legal obligation to which we are subject under Indian law.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

6. Disclosure and Sharing of Information

We do not sell your personal data to third parties. We may share your information in the following limited circumstances:

6.1 Service Providers & Partners

• Technology vendors, CRM platforms, and cloud service providers who process data on our behalf under contractual data processing agreements.
• Marketing agencies and digital advertising platforms engaged to run targeted campaigns.
• Home loan and financial institutions to facilitate your financing enquiry, where you have consented.
• Legal, accounting, and audit firms engaged to provide professional services to us.

6.2 Channel Partners & Brokers

Where you have been referred to us by a registered channel partner or co-broker, we may share relevant information with that partner for the purposes of managing your enquiry and any resulting transaction.

6.3 Group Companies

We may share information with affiliated entities within the Purearth group, including DCM Limited and associated companies, for internal business and administrative purposes, subject to the same level of data protection.

6.4 Legal Requirements

We may disclose your personal data to courts, tribunals, regulatory authorities (including RERA, SEBI, Income Tax authorities), law enforcement agencies, or other government bodies where required by law or in response to a valid legal process.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting requirements.

• Enquiry data (name, phone, email): Retained for 3 years from the date of last contact, unless a transaction is initiated.
• Transaction and booking data: Retained for a minimum of 8 years from the date of transaction completion, in compliance with the Companies Act, 2013 and RERA requirements.
• KYC and identity documents: Retained for 5 years post-transaction completion in compliance with PMLA requirements.
• Website analytics and cookies: Retained for 12 months from the date of collection.
• Marketing preferences and communication records: Retained for 3 years from the date of last interaction.

Upon expiry of the applicable retention period, we will securely delete or anonymise your personal data.

8. Your Rights as a Data Principal

Under the Digital Personal Data Protection Act, 2023, and applicable Indian law, you have the following rights in relation to your personal data:

• Right to Access: You may request a summary of the personal data we hold about you and how it is being processed.
• Right to Correction: You may request correction of any inaccurate, incomplete, or outdated personal data we hold.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal.
• Right to Grievance Redressal: You have the right to have your grievances addressed by our Grievance Officer (see Section 12).
• Right to Nominate: You may nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.

To exercise any of the above rights, please contact our Grievance Officer at the details provided in Section 12. We will respond to your request within 30 days of receipt.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. They help websites function properly, remember your preferences, and provide information to website operators.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the operation of our website. These cannot be disabled.
• Performance & Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics). All data collected is aggregated and anonymous.
• Functional Cookies: Allow our website to remember choices you have made (e.g., language or region preferences).
• Targeting & Advertising Cookies: Used to deliver relevant advertisements and track the effectiveness of marketing campaigns on platforms such as Google, Meta (Facebook/Instagram), and LinkedIn.

9.3 Managing Cookies

You may control and/or delete cookies at any time through your browser settings. Disabling certain cookies may affect the functionality of our website. You may also opt out of targeted advertising through the relevant platform settings (e.g., Google Ad Settings, Facebook Ad Preferences).

10. Third-Party Links

Our website may contain links to third-party websites, portals, or social media platforms. This Privacy Policy does not apply to those third-party websites, and we are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party websites you visit.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These include:

• SSL/TLS encryption for all data transmitted between your browser and our website.
• Restricted access to personal data on a need-to-know basis, with role-based access controls.
• Regular security assessments, vulnerability scans, and penetration testing of our digital infrastructure.
• Contractual data protection obligations imposed on all third-party service providers.

While we take reasonable steps to protect your data, no method of transmission over the internet is entirely secure. We cannot guarantee absolute security, and you provide data at your own risk.

12. Grievance Officer

In accordance with the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023, we have appointed a Grievance Officer to address your concerns regarding this Privacy Policy and the processing of your personal data.

Grievance Officer

Purearth Infrastructure Limited

Central Square, 20, Manohar Lal Khurana Marg, Bara Hindu Rao, Delhi – 110006

Email: legal@purearth.in

Phone: 011-30132200

Office Hours: Monday to Friday, 9:30 AM to 6:00 PM IST

We will acknowledge your grievance within 48 hours and endeavour to resolve it within 30 days of receipt.

13. Children’s Privacy

Our website and services are not directed at individuals under the age of 18 years. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a person under 18, we will take steps to delete such data promptly. If you believe we have collected data from a minor, please contact our Grievance Officer immediately.

14. Cross-Border Data Transfers

Your personal data is primarily stored and processed in India. Where data is transferred to servers or service providers located outside India (for example, cloud infrastructure providers), we ensure that appropriate contractual safeguards are in place in accordance with applicable Indian law and any notified frameworks under the DPDPA, 2023.

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Any material changes will be notified on our website with the revised effective date. Your continued use of our website following the posting of changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of India. Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the courts located in New Delhi, India.