1.1. This Privacy Policy explains how Kirtiraj Sawant Realty (“Company”, “we”, “us”, “our”)
collects, uses, shares and protects personal data when you:
1.1.1. visit or use our website and any related pages, landing pages or microsites under our
control (collectively, the “Website”);
1.1.2. submit enquiry forms, “call me back” forms, WhatsApp or chat requests or similar lead
forms related to the Jambrung Valley project or any other project we may promote;
1.1.3. contact us by phone, SMS, WhatsApp, email or any other electronic means in relation
to our projects.
1.2. By using the Website or sharing your personal data with us, you agree to this Privacy Policy
and consent to the collection and use of your information as described here, to the extent
permitted by applicable law.
2. Applicability of Law:
2.1. This Privacy Policy is designed to align with applicable Indian laws on privacy and data
protection, including:
2.1.1. the Information Technology Act, 2000 and the Information Technology (Reasonable
Security Practices and Procedures and Sensitive Personal Data or Information)
Rules, 2011; and
2.1.2. the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection
Rules, 2025, to the extent applicable to our processing of digital personal data.
2.2. Where the law requires a higher standard than what is mentioned here, the legal
requirement will apply.
3. Definitions:
3.1. For this Privacy Policy:
3.1.1. “Personal Data” means any data that can identify you directly or indirectly
(for example: name, mobile number, email, location, IP address).
3.1.2. “Processing” means any operation performed on Personal Data
(collecting, storing, using, sharing, deleting and similar actions).
3.1.3. “You”, “User” or “Visitor” means a natural person who visits the Website
or submits data through it.
3.1.4. “Data Fiduciary” or “Data Controller” refers to us, where applicable, as the
entity deciding why and how your Personal Data is processed.
3.1.5. “Data Principal” or “Data Subject” refers to you as the individual whose Personal
Data is being processed.
4. What Data We Collect and Why:
4.1. We may collect and process the following categories of Personal Data for the purposes
indicated below:
4.1.1. Contact and identification data:
4.1.1.1. Examples: name, email address, mobile or phone number, city, country, preferred language.
4.1.1.2. How collected: enquiry or lead forms, “Enquire Now” or “Contact Us” forms, WhatsApp or call requests, direct communications.
4.1.1.3. Purpose: responding to your enquiries, arranging call-backs and site visits, sharing project details, offers and follow-ups, maintaining lead records.
4.1.1.4. Legal basis (illustrative): your consent, steps taken at your request prior to any contract, and our legitimate interests in responding to genuine leads.
4.1.2. Project and interest data:
4.1.2.1. Examples: project name (such as Jambrung Valley), configuration interest, budget range, preferred visit dates, specific requirements.
4.1.2.2. How collected: website forms, phone calls, emails, WhatsApp messages, in-person interactions recorded in our systems.
4.1.2.3. Purpose: understanding your requirements, preparing proposals, sharing relevant options, internal analytics and reporting, improving project planning.
4.1.2.4. Legal basis: your consent, pre-contract steps, and our legitimate interests in marketing and project management.
4.1.3. Communication content:
4.1.3.1. Examples: messages you type, queries, feedback, information or documents you voluntarily share, and related communication metadata.
4.1.3.2. How collected: website forms, emails, WhatsApp messages, SMS, phone call notes and similar channels.
4.1.3.3. Purpose: answering queries, improving responses and services, keeping records of interactions, handling disputes or complaints.
4.1.3.4. Legal basis: your consent, performance of pre-contract or contract, and our legitimate interests in quality control and record-keeping.
4.1.4. Technical and usage data:
4.1.4.1. Examples: IP address, browser type, operating system, device type, pages visited, time and date of visit, referring URL and similar information.
4.1.4.2. How collected: automatically via server logs, cookies and analytics tools when you access or use the Website.
4.1.4.3. Purpose: maintaining IT security, diagnosing issues, aggregating statistics on website usage, improving layout, performance and user experience.
4.1.4.4. Legal basis: our legitimate interests in security, analytics and improvement, and compliance with legal obligations where applicable.
4.1.5. Marketing and preference data:
4.1.5.1. Examples: consent and opt-ins, project preferences, whether you opened or clicked our messages, participation in campaigns or events.
4.1.5.2. How collected: website forms, consent checkboxes, marketing tools, analytics on communication interactions.
4.1.5.3. Purpose: sending tailored communication about current and future projects, offers and events; remarketing and audience segmentation where permissible.
4.1.5.4. Legal basis: your consent and our legitimate interests in communicating relevant offers and information where allowed by law.
4.1.6. Transactional and document data:
4.1.6.1. Examples: records of site visits, meeting notes, booking interest, and documents you voluntarily share during the sales or pre-sales process.
4.1.6.2. How collected: personal interactions, email, WhatsApp, uploading or sharing documents.
4.1.6.3. Purpose: conducting the sales process, internal review, legal and regulatory compliance (including RERA, tax and accounting), and defence of legal claims.
4.1.6.4. Legal basis: performance of pre-contract or contract, compliance with legal obligations and our legitimate interests in managing our business.
4.1.7. Sensitive or high-risk data (if any):
4.1.7.1. We generally do not seek to collect sensitive personal data (such as financial, health, biometric or official ID details) through the Website enquiry forms. If you voluntarily provide such information in free-text fields or attachments:
4.1.7.2. How collected: only if explicitly provided by you.
4.1.7.3. Purpose: only where specifically required for legal or contractual steps (for example, KYC at a later stage) and in accordance with applicable Indian laws.
4.1.7.4. Legal basis: your consent where required, compliance with law, and we otherwise seek to avoid collecting such data via the Website.
5. How We Collect Your Data:
5.1. We may collect Personal Data in the following ways:
5.1.1. Directly from you:
5.1.1.1. When you fill any form on the Website, such as “Enquire Now”, “Contact Us” or “Call Back”.
5.1.1.2. When you contact us by phone, SMS, WhatsApp, email or any other communication channel in relation to our projects.
5.1.1.3. When you visit our site office and our team records your details in digital or physical systems linked to website leads.
5.1.2. Automatically when you use the Website:
5.1.2.1. Server logs capture technical information such as IP address, browser, device, time of access and pages visited.
5.1.2.2. Cookies and similar technologies may store or access limited information from your browser for functionality and analytics, as explained below.
5.1.3. From third parties or public sources:
5.1.3.1. Real estate portals, channel partners, referring websites, digital marketing partners and similar sources that share leads with us.
5.1.3.2. Publicly available sources where you have posted your contact details for real-estate enquiries.
6. Contact Information & Communication Consent:
6.1. When you voluntarily send us electronic mail / fill up the form, we will keep a record of this information so that we can respond to you.
6.2. 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.
6.3. You may, however, visit our site anonymously.
6.4. 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.
7. Cookies and Similar Technologies:
7.1. We may use cookies and similar technologies in connection with the Website. These technologies may:
7.1.1. keep your session active and help basic navigation;
7.1.2. remember certain preferences where technically possible;
7.1.3. help us understand how visitors use the Website;
7.1.4. support improvement of page performance and user experience.
7.2. Most browsers allow you to block or delete cookies through their settings. If you do so, some Website features may not work as intended. We do not use cookies to directly read any data from your device beyond what your browser provides to the Website.
8. How We Use Your Personal Data:
8.1. Without limiting the generality of the above, we may use your Personal Data for the following purposes:
8.1.1. Responding to you:
8.1.1.1. Returning your calls, SMS, WhatsApp messages or emails.
8.1.1.2. Sharing brochures, floor plans, price information, offers and clarifications you request.
8.1.1.3. Providing information you specifically seek regarding Jambrung Valley or other projects associated with us.
8.2. Pre-sales and sales process:
8.2.1. Fixing appointments and site visits according to your convenience and our availability.
8.2.2. Understanding your budget, preferences and specific requirements.
8.2.3. Preparing and sending proposals or indicative commercial terms.
8.2.4. Maintaining internal records of leads, follow-ups and outcomes.
8.3. Marketing and communication:
8.3.1. Providing information on Jambrung Valley and other present or future projects by our company or channel partners, to the extent permitted by law.
8.3.2. Sending you promotional messages, festival offers, event invitations and reminders by Call, SMS, Email or WhatsApp, including communications sent to numbers registered under DND, based on the consent recorded through our forms and interactions.
8.3.3. Conducting remarketing or retargeting campaigns where allowed and technically supported.
8.4. Internal analysis and improvement:
8.4.1. Compiling anonymised or aggregated statistics about website usage and enquiry patterns.
8.4.2. Measuring marketing and campaign performance.
8.4.3. Optimising marketing expenditure and improving our communication strategies.
8.4.4. Improving project positioning and service quality based on insights derived from aggregated data.
8.5. Security and fraud prevention:
8.5.1. Monitoring for suspicious, abusive or unauthorised activity on the Website and related systems.
8.5.2. Protecting our systems, network, customers, staff and legitimate business interests.
8.5.3. Taking reasonable steps to prevent fraud or misuse of our services.
8.6. Legal, regulatory and dispute management:
8.6.1. Complying with RERA and other applicable laws, directions of authorities or courts.
8.6.2. Maintaining records for tax, accounting, audit and similar regulatory purposes.
8.6.3. Handling complaints, legal claims, arbitration, mediation or other proceedings, and maintaining evidence for such matters.
8.7. Where required by the Digital Personal Data Protection framework or other laws, we will rely on your consent or other lawful grounds recognised under Indian law to process your Personal Data.
9. Sharing and Disclosure of Personal Data:
9.1. We do not sell your Personal Data as a standalone asset. However, for the purposes described in this Privacy Policy, we may share your Personal Data with the following categories of recipients:
9.1.1. Group entities and affiliates:
9.1.1.1. Other businesses under common ownership or control with Kirtiraj Sawant Realty, for centralised lead management, analytics and cross-project communication where permitted and appropriate.
9.1.2. Channel partners and co-marketing partners:
9.1.2.1. RERA-registered brokers, sales partners or marketing agencies engaged to promote our project and assist you in the discovery and purchase process.
9.1.2.2. Real estate agents or aggregators who may coordinate with you for site visits or project information, in accordance with applicable laws and contractual obligations.
9.1.3. Service providers and processors:
9.1.3.1. IT hosting providers, CRM and lead management platforms, SMS or email or WhatsApp gateway providers, tele-calling centres, marketing and analytics service providers and similar vendors.
9.1.3.2. Such third parties are generally bound by contractual obligations to handle your data only for specified purposes and to maintain appropriate security measures consistent with applicable law and this Privacy Policy.
9.1.4. Professional advisers:
9.1.4.1. Lawyers, auditors, consultants and other professional advisers engaged by us, who are typically bound by confidentiality obligations.
9.1.5. Authorities and regulators:
9.1.5.1. Government departments, regulatory bodies, law-enforcement agencies, courts, tribunals or other authorities when required by law, direction, investigation or court order.
9.1.5.2. Disclosures we reasonably believe are necessary to protect our rights, safety, property or that of others, or to prevent fraud or security incidents.
9.1.6. Business transfers:
9.1.6.1. In connection with any merger, reorganisation, sale of business, joint venture, assignment, transfer or other corporate transaction involving our project or our business as a whole.
9.1.6.2. In such cases, Personal Data may be shared with potential or actual counterparties, subject to appropriate safeguards, and may become subject to the privacy policies of the acquiring or combined entity.
9.1.7. Where the law so requires, we will obtain your consent or provide you with appropriate notice before such sharing.
10. Cross-Border Transfers:
10.1. Our primary infrastructure is intended to be located in India. However, some of our service providers or business partners, such as cloud hosting services, analytics platforms or communication tools, may process or store Personal Data on servers located outside India.
10.2. Where such cross-border transfers occur, we will take reasonable steps to ensure that the recipient is subject to appropriate contractual, technical or organisational safeguards, to the extent required by applicable law and rules. By using the Website and providing your Personal Data, you consent to such cross-border transfers, where permitted by law.
11. Data Retention:
11.1. We will retain your Personal Data for the following durations:
11.1.1. for as long as is reasonably necessary to fulfil the purposes described in this Privacy Policy;
11.1.2. for any additional period required or permitted by applicable law, including limitation periods for legal claims, RERA, tax, accounting or audit requirements;
11.1.3. or until you withdraw consent in cases where consent is the only legal basis for processing and no overriding legal or legitimate interest requires further retention.
11.2. After the relevant retention period, we may delete, anonymise or irreversibly aggregate your data so that it no longer identifies you.
12. Data Security:
12.1. We implement reasonable technical and organisational measures designed to protect your Personal Data from unauthorised access, loss, misuse, alteration or destruction. These measures may include:
12.1.1. restricted access to Personal Data on a need-to-know basis;
12.1.2. user authentication, role-based access control and password protection in our systems;
12.1.3. use of reputable hosting providers with commercially reasonable security standards;
12.1.4. contractual obligations on service providers to maintain security safeguards and confidentiality.
12.2. However, no system is completely secure and transmission of information via the internet carries inherent risks. You are advised to take basic precautions such as:
12.2.1. not sharing one-time passwords, passwords or confidential details with unknown persons;
12.2.2. using updated and genuine devices, operating systems and browsers;
12.2.3. informing us promptly if you suspect any misuse of your data in connection with our project.
13. Children’s Privacy:
13.1. The Website and our marketing activities are not directed at persons below 18 years of age. We do not knowingly collect Personal Data from children through the Website.
13.2. If you are a parent or guardian and believe that a minor has shared Personal Data with us through the Website, please contact us using the details provided in this Privacy Policy. We will take reasonable steps to delete such data as required by law.
14. Third-Party Sites and Other Links:
14.1. The Website may contain links or references to third-party websites, applications, portals or social media pages, including map services, payment gateways, real estate portals and social networks.
14.2. These third-party sites and services are not controlled by us. Their privacy practices are governed by their own privacy policies and terms. We are not responsible for the content, security, data handling practices or privacy policies of such external sites.
14.3. You are advised to read the privacy policies and terms of any third-party website or service you visit or use before sharing your Personal Data with them.
15. Changes to This Privacy Policy:
15.1. We may update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements or technology.
15.2. The updated Privacy Policy will be made available on the Website with a revised “Last Updated” or similar reference. Your continued use of the Website or continued interaction with us after such updates will be treated as acceptance of the revised Privacy Policy, to the extent permitted by law.
16. Contact Details and Grievance Officer:
16.1. If you have any questions, requests or complaints relating to this Privacy Policy or our handling of your Personal Data, you may contact:
