Legal
Privacy Policy
Last updated: 2 September 2026
This Privacy Policy explains how [Developer Legal Name] (“we”, “us”, “the Developer”) collects, uses, shares and protects personal information when you visit codenamesecretambegaon.com (the “Site”) or register your interest in the pre-launch residential project referred to by the codename “Secret” at Ambegaon, Pune (the “Project”).
We process personal data in accordance with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as applicable. By using the Site or submitting the enquiry form, you agree to this Policy.
1. Information we collect
Information you give us
When you submit the enquiry form on the Site, we collect:
- Name
- Mobile number
- Email address (optional)
- Your consent to be contacted, and the date and time it was given
Please do not send us financial information, identity documents, or any sensitive personal data through this Site. We do not ask for it at this stage and do not need it to respond to your enquiry.
Information collected automatically
When you browse the Site we may automatically record:
- IP address, approximate location, browser and device type, and operating system
- Pages viewed, time spent, and the link or advertisement that brought you here
-
Campaign parameters attached to the link you clicked —
utm_source,utm_medium,utm_campaign,utm_content,utm_term,gclidandfbclid— so that we know which campaign your enquiry came from - Which button you used to open the enquiry form
2. How we use your information
We use the information above to:
- Respond to your enquiry and share details of the Project with you
- Contact you by telephone call, SMS, email or WhatsApp about the Project, its launch, pricing, plans, offers and site visits
- Arrange and follow up on site visits and meetings
- Maintain a record of your enquiry and of the consent you gave us
- Measure how our advertising performs and improve the Site
- Comply with applicable law and to establish, exercise or defend legal claims
We do not sell your personal data. We do not use it for automated decision-making that produces legal effects for you.
3. Consent and DNC / NDNC
The enquiry form carries a consent declaration. By ticking it and submitting the form, you expressly authorise us and our authorised representatives and channel partners to contact you about the Project by call, SMS, email and WhatsApp — even if your number is registered on the National Do Not Call (DNC / NDNC) register or under the TRAI Telecom Commercial Communications Customer Preference Regulations. This consent is given voluntarily and overrides that registration for the limited purpose of this Project.
You may withdraw this consent at any time — see Your rights. Withdrawal is not retrospective: it does not affect anything lawfully done before you withdrew.
4. Enquiries sent through WhatsApp
Where the Site is configured to pass your enquiry to us over WhatsApp, or where you choose to contact us using a WhatsApp button on the Site, your message and the details you have entered are transmitted through WhatsApp’s service and are handled under WhatsApp’s and Meta’s own privacy terms, over which we have no control. Your mobile number becomes visible to us through that chat.
If you would rather not use WhatsApp, please call us on +91 9011 09 4545 or write to [privacy@yourdomain.com] instead.
5. Who we share it with
We may share your information with:
- Our group companies, employees and authorised sales representatives, and the registered channel partners or brokers appointed for the Project, so that they can respond to your enquiry
- Service providers who work on our behalf — customer relationship management (CRM) and lead-management platforms, telephony and SMS providers, email services, website hosting and analytics providers
- Advertising platforms such as Google and Meta, in the form of measurement and conversion signals, where those tools are enabled on the Site
- Courts, regulators, or law-enforcement and government authorities, where we are required to do so by law or to protect our rights
- A successor entity, in the event of a merger, restructuring or transfer of the Project or the business
We require our service providers to use your data only for the purposes we specify and to protect it with appropriate safeguards.
6. Cookies and tracking
The Site uses cookies and similar technologies. Strictly necessary storage is used to remember, for the duration of your browser session, that the enquiry form has already been shown to you, so that it does not pop up repeatedly. This is stored in your own browser and is not transmitted to us.
Where enabled, analytics and advertising tools — such as Google Analytics and the Meta pixel — set their own cookies to measure traffic and campaign performance. These are controlled by those third parties under their own privacy policies.
You can block or delete cookies through your browser settings. Doing so will not prevent you from using the Site or submitting an enquiry.
7. How long we keep it
We retain enquiry data for as long as is necessary to respond to you and to pursue your interest in the Project, and thereafter for as long as required for our legitimate business records, tax and regulatory obligations, or the limitation period for legal claims.
Where you ask us to erase your data and we are not required to keep it, we will delete it or irreversibly anonymise it.
8. Security
We maintain reasonable security practices and procedures designed to protect the personal data we hold from unauthorised access, disclosure, alteration and destruction, including access controls and transmission of the Site over HTTPS.
No method of transmission over the internet is completely secure, and we cannot guarantee absolute security. You share information with us at your own discretion.
9. Your rights
Subject to applicable law, you may:
- Access a summary of the personal data we hold about you and how we process it
- Correct or complete data that is inaccurate, misleading or incomplete
- Erase your personal data where we are not required to retain it
- Withdraw your consent to being contacted, at any time
- Nominate another individual to exercise these rights in the event of your death or incapacity
- Complain to us, and thereafter to the Data Protection Board of India
To exercise any of these, write to [privacy@yourdomain.com] from the email address you registered with, or call +91 9011 09 4545. You may simply reply STOP to any message from us to stop further marketing contact. We will act on your request within the timelines prescribed by law.
10. Children
The Site is intended for persons aged 18 and above and is not directed at children. We do not knowingly collect personal data of a child. If you believe a child has provided us personal data, please contact us and we will delete it.
11. Third-party links
The Site may link to third-party services such as WhatsApp, mapping services or social media. We are not responsible for the content or privacy practices of those services, and this Policy does not apply to them.
12. Changes to this Policy
We may update this Policy from time to time. The revised version takes effect when it is published on this page, and the “Last updated” date above will change. Please review this page periodically.
13. Contact us and grievance redressal
For any question, request or complaint about this Policy or about how your personal data is handled, please contact:
Grievance Officer: [Grievance Officer Name]
Entity: [Developer Legal Name]
Address: [Registered Office Address]
Email: [grievance@yourdomain.com]
Telephone: +91 9011 09 4545
We will acknowledge your complaint and endeavour to resolve it within the period prescribed under applicable law. If you remain dissatisfied, you may escalate the matter to the Data Protection Board of India.