Privacy Policy

PRIVACY AND DATA PROTECTION POLICY

Effective Date: September 27, 2026
Last Updated: October 12, 2026

1. PREAMBLE AND APPLICABILITY
   This Privacy and Data Protection Policy (“Policy“) governs the collection, processing, storage, and transfer of personal data by True North Realty Advisors (hereinafter referred to as the “Data Fiduciary“, “Company“, “we“, “us“, or “our“) operating through its website, www.truenorthrealtypartners.com (the “Platform“).

    

   This Policy applies to all visitors, prospective buyers, investors, and clients (hereinafter referred to as the “Data Principal“, “Data Subject“, “User“, “you“, or “your“). By accessing the Platform, engaging our advisory services, or submitting your information, you signify your informed and explicit consent to the terms outlined herein.
   
   
2. REGULATORY FRAMEWORK
   This Policy is formulated in compliance with:

• The Digital Personal Data Protection Act, 2023 (DPDP Act).
• Section 43A of the Information Technology Act, 2000 and the IT (SPDI) Rules, 2011.
• The Consumer Protection (E-Commerce) Rules, 2020.
• The General Data Protection Regulation (EU) 2016/679 (GDPR), applicable extraterritorially to our NRI and international clients.
  
  

3. STRICTLY VOLUNTARY COLLECTION (NO AUTOMATED HARVESTING)
   True North operates on a principle of explicit, opt-in data collection. We do not deploy automated data extraction tools, background profiling algorithms, or unauthorized scraping mechanisms to capture your personal data.

   We strictly collect data only when it is voluntarily, explicitly, and knowingly shared by you through our consultation forms, WhatsApp integrations, direct emails, or telephonic discussions. If you merely browse our Platform without submitting an inquiry, True North does not automatically capture or extract your personal identity.
   
   

4. CLASSIFICATION OF DATA COLLECTED
   When you explicitly choose to engage our proprietary “GUIDE” framework and real estate advisory services, we collect the following categories of voluntarily submitted data:

• Identity & Contact Data: Full name, residential address, email address, mobile number, and country of residence/citizenship.
• Financial & Profiling Data: Budgetary constraints, investment capacity, configuration requirements, financing preferences, and employment / professional status shared voluntarily during consultations.
• Documentary Data: KYC documents (PAN, Aadhaar, Passport) required strictly at the time of booking or execution of an Agreement for Sale with developers.
  
  

5. LAWFUL BASIS AND PURPOSE OF PROCESSING
   We process your explicitly shared data strictly under the principles of consent, contractual necessity, and legitimate business interests to:

• Facilitate Advisory Services: To curate real estate portfolios and schedule site visits.
• Developer Coordination: To share lead registration data (Name, Phone Number, Email) with Tier-1 developers to tag the client to True North Realty, ensuring our “Zero Brokerage” model operates smoothly.
• Communication & Negotiation: To transmit project layouts, AI layout models, pricing sheets, and negotiate unit selection on your behalf.
• Legal & Regulatory Compliance: To maintain records as mandated by MahaRERA (Registration No. A041182603410).
  
  

6. DATA SHARING AND THIRD-PARTY DISCLOSURE
   We do not sell, monetize, or unlawfully trade your personal data. Data may be shared with:

• Principal Developers: Specifically, developers shortlisted by you for site visits (e.g., Piramal Realty, L&T, Prestige Group) for registration and booking documentation.
• Infrastructure & SaaS Providers: Third-party cloud hosting providers, server infrastructure managers, and Customer Relationship Management (CRM) platforms used to operate our business.
• Statutory Authorities: Law enforcement agencies or courts of competent jurisdiction when mandated by applicable law.
  
  

7. HOSTING INFRASTRUCTURE & ABSOLUTE DISCLAIMER OF LIABILITY
   The Platform is entirely hosted, operated, and maintained on servers and cloud infrastructure owned and managed by independent third-party service providers.

   Passive Server Logs: While True North does not automatically capture your data, standard internet communication protocols dictate that your browser automatically transmits basic, non-identifiable routing data (such as IP addresses and browser types) to the third-party server hosting this website to allow the pages to load.

   Disclaimer: By utilizing this Platform, you expressly acknowledge and agree that True North exercises no administrative, physical, or technical control over the proprietary server infrastructure of these third-party hosts or their passive server logs. True North explicitly disclaims any and all liability—direct, indirect, vicarious, or consequential—arising from independent data collection, unauthorized third-party disclosures, server breaches, ransomware attacks, or cybersecurity failures originating at the infrastructure or hosting level.
   
   

8. DATA SECURITY PROTOCOLS (THIRD-PARTY RELIANCE)
   Because True North operates via third-party digital infrastructure, the physical and network security of your data is fundamentally governed by the security protocols, firewalls, and encryption standards deployed by our independent hosting and CRM vendors.

   Our internal security measures are strictly administrative, consisting of restricting internal access to client data to authorized advisors on a strict “need-to-know” basis and implementing internal access controls. Given the inherent vulnerabilities of the internet, True North cannot guarantee absolute data security. Any transmission of personal information is done entirely at your own risk.
   
   

9. CROSS-BORDER DATA TRANSFERS
   To ensure website availability, disaster recovery, and data redundancy, our third-party infrastructure providers may route, back up, or securely transfer data to server locations outside the territory of India. We rely on standard contractual safeguards to ensure that such cross-border data flows are conducted lawfully.
   
   
10. DATA RETENTION POLICY
    We retain personal data only for the duration necessary to fulfill the purposes outlined in this Policy.

• Active Prospects/Clients: Retained for the duration of the advisory engagement and up to the final possession of the property.
• Statutory Records: Financial and transaction records are retained for a minimum of 8 years.

  Upon expiry of the retention period, data is deleted from our active CRM systems. (Note: Residual encrypted copies may temporarily remain in third-party automated server backups for disaster-recovery purposes, over which True North has no immediate deletion control).
  
  

11. RIGHTS OF THE DATA PRINCIPAL / DATA SUBJECT
    Subject to statutory exemptions, you are vested with the following rights:

• Right to Information & Access: To obtain a summary of your processed data.
• Right to Correction & Erasure: To request the rectification of inaccurate data and demand the deletion of your data (“Right to be Forgotten”).
• Right to Withdraw Consent: To withdraw consent at any time, which may limit our ability to provide continued advisory services.
• Right of Grievance Redressal: To register a complaint with our Grievance Officer.

  To exercise any of these rights, a formal request must be submitted via email to the Grievance Officer.
  
  

12. AMENDMENTS TO THIS POLICY
    We reserve the right to unilaterally update or amend this Policy to reflect changes in legal frameworks or third-party vendor policies. Continued use of our services post-modification constitutes affirmative acceptance of the revised Policy.
    
    

13. CONTACT DETAILS & GRIEVANCE REDRESSAL
    In accordance with the IT Rules, 2011, and the DPDP Act, 2023, the details of the Grievance Officer are provided below:

    Name: Saumil Rambhia (Co-Founder & Legal Head)
    Designation: Grievance & Data Protection Officer
    Email: admin@truenorthrealtypartners.com
    Registered Address: LG 18, Avior Corporate Park, LBS Rd, Mulund West, Mumbai 400080
    Contact Number: +91 9969930409 / 9322022161