1. Introduction

This Data Usage Policy (“Policy”) explains how Ultra Luxurious Residences (“we,” “us,” or “our”) collects, uses, processes, and protects information when you visit our website [website URL] (“Service”). We are committed to protecting your privacy and ensuring transparency about our data practices.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, username, and password when you create an account
• Contact Information: Details you provide when contacting us through forms, email, or support channels
• Profile Information: Any additional information you choose to add to your profile
• User-Generated Content: Comments, reviews, posts, or other content you submit
• Payment Information: Billing details and payment method information (processed securely through third-party payment processors)

2.2 Information Collected Automatically

• Usage Data: Pages visited, time spent on pages, click patterns, and navigation paths
• Device Information: Browser type, operating system, device type, screen resolution, and language preferences
• Location Data: General geographic location based on IP address
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, and similar technologies
• Log Data: IP addresses, access times, referring URLs, and error logs

2.3 Information from Third Parties

• Social Media: Information from social media platforms when you connect your accounts or use social login features
• Analytics Partners: Aggregated demographic and usage data from analytics services
• Marketing Partners: Information to help us understand user preferences and improve our services

3. How We Use Your Information

We use collected information for the following purposes:

3.1 Service Provision

• Provide, maintain, and improve our website and services
• Process transactions and manage your account
• Respond to your inquiries and provide customer support
• Personalize your experience and content recommendations

3.2 Communication

• Send service-related notifications and updates
• Deliver marketing communications (with your consent where required)
• Respond to your comments, questions, and requests
• Send newsletters and promotional materials

3.3 Analytics and Improvement

• Analyze usage patterns to improve our website functionality
• Conduct research and analytics to enhance user experience
• Monitor and analyze trends, usage, and activities
• Test new features and functionality

3.4 Legal and Regulatory Compliance

• Comply with legal obligations and regulatory requirements
• Meet Real Estate Regulatory Authority (RERA) compliance requirements
• Maintain records for regulatory reporting and audits
• Facilitate due diligence processes for property transactions
• Protect against fraud, abuse, and security threats
• Enforce our terms of service and policies
• Resolve disputes and troubleshoot problems

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist us in operating our website and services, including:

• Cloud hosting and infrastructure providers
• Analytics and measurement services
• Email marketing platforms
• Payment processors
• Customer support tools

4.2 Business Transfers

In the event of a merger, acquisition, sale, or other business transfer, your information may be transferred as part of that transaction.

4.3 Legal and Regulatory Requirements

We may disclose information when required by law, legal process, or regulatory authorities, including:

• Comply with court orders, subpoenas, or government requests
• Meet RERA (Real Estate Regulatory Authority) disclosure and reporting requirements
• Respond to inquiries from real estate regulatory bodies
• Facilitate property transaction documentation and verification
• Investigate potential violations of our terms of service
• Protect the rights, property, or safety of our company, users, or others
• Prevent fraud or other illegal activities

4.4 Consent

We may share information for other purposes with your explicit consent.

5. Data Retention

We retain your information for as long as necessary to:

• Provide our services and maintain your account
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Fulfill the purposes outlined in this policy

Specific retention periods vary by data type:

• Account Data: Retained while your account is active and for up to [X years] after closure
• Usage Data: Typically retained for [X months to X years] for analytics purposes
• Communication Data: Retained for [X years] for customer service and legal purposes
• RERA Compliance Data: Retained as per RERA requirements and applicable state regulations (typically 5-10 years)

6. Your Rights and Choices

Depending on your location, you may have the following rights:

6.1 Access and Portability

• Request access to the personal information we hold about you
• Obtain a copy of your data in a portable format

6.2 Correction and Updates

• Update or correct inaccurate or incomplete information
• Modify your account settings and preferences

6.3 Deletion

• Request deletion of your personal information (subject to legal obligations)
• Close your account and remove associated data

6.4 Restriction and Objection

• Restrict processing of your information in certain circumstances
• Object to processing based on legitimate interests

6.5 Marketing Communications

• Opt out of marketing emails using unsubscribe links
• Manage communication preferences in your account settings

7. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Employee training on data protection practices
• Incident response procedures

However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. International Data Transfers and Indian Compliance

If you are located outside India, please note that your information may be transferred to and processed in India with appropriate safeguards in place for such transfers.

For users in India, we comply with applicable provisions of:

• Information Technology Act, 2000 and its amendments
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• Real Estate (Regulation and Development) Act, 2016 (RERA) and respective state RERA rules
• Personal Data Protection Bill (when enacted)

We ensure that sensitive personal data or information (SPDI) as defined under Indian law receives enhanced protection and is processed in accordance with applicable regulations. Additionally, we maintain transparency and disclosure standards as required under RERA for all real estate-related activities and transactions.

9. Children’s Privacy

Our services are not intended for children under [13/16] years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website performance and usage
• Provide personalized content and advertising
• Ensure website security and functionality

You can manage cookie preferences through your browser settings, though this may affect website functionality.

11. Third-Party Links and Services

Our website may contain links to third-party websites or integrate with external services. This policy does not apply to those third parties, and we encourage you to review their privacy policies.

12. Updates to This Policy

We may update this policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes through:

• Email notifications to registered users
• Prominent notices on our website
• Updates to the “Last Updated” date above

13. Contact Information

If you have questions, concerns, or requests regarding this policy or our data practices, please contact us:

Email: contact@ultraluxuriousresidences.com
Address: 201, Gulshan Chambers, Baner, Pune 45
Phone: +91 917 517 0147
Data Protection Officer: [DPO Contact Information] (if applicable)

14. Legal Basis for Processing

For users in India: We process personal data in compliance with the Information Technology Act, 2000 and related rules, as well as RERA (Real Estate Regulatory Authority) requirements, ensuring:

• Lawful collection and processing of sensitive personal data or information
• Compliance with RERA disclosure and transparency requirements
• Appropriate consent mechanisms for data collection
• Compliance with data retention and security requirements
• Adherence to transfer restrictions for sensitive personal data
• Maintenance of records for regulatory compliance and audit purposes

For users in the European Union: We process personal data based on:

• Consent: When you provide explicit consent for specific purposes
• Contract: To fulfill our contractual obligations to provide services
• Legitimate Interest: For analytics, security, and business operations
• Legal Obligation: To comply with applicable laws and regulations

This policy is designed to be comprehensive but should be reviewed by legal counsel to ensure compliance with applicable laws in your jurisdiction.