Privacy Policy

“warden”, and/or “wardenera” is a product of lagom innovations private limited (“us”, “we”, “company” or “our”) owns, operates, and manages a mobile application under the name and style of “[●]” (“platform”). The company operates the platform which: (i) enables property owners (“users”, “you” or “your”) to list and offer their property/house/living space (“property”) on a rental basis to the tenants (“rental services”); and (ii) provides online property management services to the users (“property management services”). For the purpose of this privacy policy, the services offered through the platform, i.e., the rental services and the property management services are collectively referred to as “services”. The services can be accessed, used, and availed through the platform in accordance with our terms of use available at [●] (“operator terms”).

This privacy policy, inter alia, states the following: the type of information collected from the users, including personal information (as defined below) and sensitive personal data or information (as defined below) relating to an individual; the purpose, means, and modes of collection, usage, processing, retention, and destruction of such information; and how and to whom we will disclose such information. This privacy policy shall apply to any person who visits, browses, uses, or accesses the platform or use any services on the platform. This privacy policy is an electronic record in terms of the information technology act, 2000, and rules and regulations made thereunder. Further, this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to our current service at any point in the future shall also be subject to the terms set out in this policy. “personal information” is defined under the information technology (reasonable security practices and procedures and sensitive personal information) rules, 2011 (the “spi rules”) and means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The spi rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to: (i) passwords; (ii) financial information such as bank accounts, credit, and debit card details, or other payment instrument details; (iii) information received by body corporate under lawful contract or otherwise; (iv) visitor details as provided at the time of registration or thereafter; and (v) call data records. Please note that the information collected by us from you may constitute ‘personal information’ or ‘sensitive personal data or information’ under the spi rules. In order to have access to all the features, benefits, or services on our platform, a user must first create an account on our platform. To create an account and avail of all the features, benefits, or services on our platform, a user is required to provide the following information, which such user recognises and expressly acknowledges is personal information allowing others, including us, to identify the user: name, user id, email address, gender, country, zip/postal code, age, phone number, proof of identity and address documents such as aadhar number, etc., password chosen by the user. In addition, at the time of a registered user availing the services, the user is required to provide certain sensitive personal information which includes its bank account or card details for undertaking transactions on the platform for availing features and benefits on the platform and the services through the platform. Other information requested on the account registration page, including the ability to receive promotional offers from us, is optional. We may, in the future, include other optional requests for information from the user to help us to customize the platform to deliver personalised information to the user.

By using and accessing the platform and by availing the services or by otherwise giving us your information, you will be deemed to have read, understood, and agreed to the practices and policies outlined in this privacy policy and agree to be bound by the privacy policy. You hereby consent to our collection, use, and sharing, disclosure of your information as described in this privacy policy. We reserve the right to change, modify, add, or delete portions of the terms of this privacy policy, at our sole discretion, at any time. If you do not agree with this privacy policy at any time, do not use any of the services or give us any of your information. If you use the services on behalf of or for the benefit of someone else, you represent that you are authorised by such individual to (i) accept this privacy policy on such individual’s behalf, and (ii) consent on behalf of such individual to our collection, use and disclosure of such individual’s information. You may note that this privacy policy is based on the applicable laws of India and good data privacy practices adopted by the company in India and may be found deficient with respect to certain privacy laws of some other countries. By visiting the platform you agree to be bound by the terms and conditions of this privacy policy. If you do not agree with the terms contained herein, please do not use or access our platform or avail of any services on the platform. By mere use of the platform, you expressly consent to our use and disclosure of your personal information in accordance with this privacy policy.

We respect your need to understand how and why information is being collected, used, disclosed, transferred, and stored. Thus, we have developed this policy to familiarise you with our practices and demonstrate our commitment to the protection of your privacy and your personal information. This privacy policy sets out the way in which we process your information when you visit the platform or use the services in accordance with applicable data protection laws. By accessing our platform or availing the services, you agree to be bound by the terms of this policy. It is important that you read this policy together with any other policies that we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This policy supplements the other notices and is not intended to override them. The information contained on this platform and the personal information collected by using/ logging in and or accessing this platform is stored at a secured server. It is stated by the server service provider that they have all the best security practices required for the server. The platform is owned by us and is located in India. Hence, we are bound by duty to abide by the laws, including but not limited to, regulations, rules, circulars, and notifications governing privacy in India.

We provide this privacy policy to inform you of our policies and procedures regarding the collection, storage, processing, and sharing of personal data that we receive from users of the platform or those which are stored or accessed by us at the time of availing the services or making transactions on the platform. With regard to this privacy policy, the terms “using" and "processing" information include, without limitation, the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modification, and use of personal data. This privacy policy applies only to personal data that you provide us via the platform. We reserve the right to update this privacy policy from time to time to reflect any changes to our services. We will do this by amending the privacy policy on the platform. The changes will take effect automatically, as soon as they are posted on the platform. This privacy policy is applicable to all users of this platform. By using the services, registering with us, or by otherwise giving us your information, you will be deemed to have read, understood, and agreed to the practices and policies outlined in this privacy policy and agree to be bound by the terms hereof. You hereby consent to us collecting, using and sharing, and disclosing your information as described in this privacy policy. We reserve the right to change, modify, add, or delete portions of the terms of this privacy policy, at our sole discretion, at any time. If you do not agree with this privacy policy at any time, do not use any of the services, use or access the platform or give us any of your information. Any user that does not agree with any provisions of the privacy policy has the option to discontinue the services provided by us immediately.

We may process your personal data for, including without limitation, the following purposes: providing our services: the user might be required to upload or post pictures of the property(ies), details of the property(ies), or any other relevant document in relation to the property(ies) among other things., on the platform (“user content”) in order to avail certain features or service offering on the platform or as part of the service itself and we might process your personal data and user content to provide services so as to facilitate the interaction and transaction of the users. For example, personal data is processed in order to set up your account and allow you to avail of the services. We process the following personal data: (i) name; (ii) phone number; (iii) email address; (iv) home address; (v) ip address; (vi) location; (vii) user account profile data. Customer service: we need to process personal data for this purpose because it enables us to adequately respond to users’ questions/ concerns and verify the correctness of the property(ies) listed on the platform and ensure the overall quality of the services availed by a user on the platform. Marketing: we process users’ data for marketing purposes. This means that we can contact customers to draw attention to our services. For this purpose, we process the following personal data: (i) website behaviour; (ii) ip address;(iii) email address; (iv) postal address; (v) phone number (vi) online identifiers; (vii) order information; (viii) location; (ix) and account information. Commercial use: all the information provided to us by a user, including personal information or any sensitive personal data or information, is provided voluntarily. You understand that we may use certain information provided by you, which may include your personal information or sensitive personal data or information for (i) the purpose of providing the services to you; (ii) in an aggregated and anonymised form for research, statistical analysis and/or business intelligence purposes; (iii) sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates; (iv) communication purposes to enhance your experience and obtaining feedback in relation to the services; (v) customer support related issues; (vi) and enabling you to complete any transaction through the platform. In addition to the above, we may also use your personal data for several reasons, including but not limited to; (i) keep you informed of the booking status of the property(ies); (ii) send you communication in relation to availing of the services via sms or any other messaging service; (iii) allow our customer service to contact you, if necessary; (v) request you for reviews of the services; (vi) send you verification message(s) or email(s); (vii) validate/authenticate your account and to prevent any misuse or abuse; (viii) send you important notices and communications regarding our services availed or changes to the terms and conditions and/or policies; (ix) to send you marketing related communications; (x) to deal with enquiries and complaints raised by you and to troubleshoot problems; (xi) ensure compliance with all applicable laws and to ensure safety of the platform and all users; (xii) to prevent fraud, errors and/or any illegal activity on the platform; (xiii) to send invoices, statements, agreements and/or to collect payment from you.

It may be necessary for us to disclose your personal data whether by law, legal process, and/or by request from public and/or governmental authorities within or outside of your country of residence. We may also disclose your personal information if we determine that disclosure is necessary or appropriate for the purposes of law enforcement, and national security or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, or legally actionable. Some sections on the platform are freely accessible by all users and visitors and require no prior registration. Further, certain sections on the platform are accessible by users only after entering their details, username, and password. Therefore, we request you use a safe and secure server to access the platform to ensure the safety of your username, password, and other information. We do not guarantee the security and/or privacy of any information, which may be available to all users and visitors of the platform publicly. We automatically receive the url of the site from which anyone visits. We also receive the internet protocol (ip) address of each user’s computer (or the proxy server a user used to access the world wide web), the user’s computer operating system and type of web browser the user is using, email patterns, as well as the name of user’s isp. This information is used to analyze overall trends to help us improve our services. The linkage between user’s ip address and user’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, we may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow our business. Note that we maintain a strict no-spam policy and do not rent, sell, disclose, or share personal information belonging to you with other people or non-affiliated companies without your consent, except to provide promotions or otherwise as specifically provided for in this privacy policy. You agree that in addition to as may be provided in this policy, we may also disclose your personal information under the following circumstances: third-party service professionals and/or providers: we engage, retain, or might, as per the requirement and business needs of the company, employ, engage, and contract with third-party service professionals/providers to work on behalf of or with us, under agreements containing confidentiality obligations and in accordance with the law, in relation to the services provided by us on the platform. These third-party service providers may use your personal information in assisting us to communicate with you about our offers, feedback on services, assisting with payment facilities, provide customer support, assisting in advertising on the platform, provide teaching services, etc. We may employ third-party companies and/or individuals to help improve or facilitate our service, to provide the service on our behalf, and to perform platform-related services, including but not limited to payment processing, maintenance services, fraud detection services, database management, web analytics, monitoring, and evaluation services. In this event, your information may be shared with such third-party companies and/or individuals; compliance with laws and protection of users: we may release your personal information when the same is required in order to comply with the law, in response to court orders, court summons, judgments, decrees, injunctions, arbitral awards, administrative orders, governmental investigation or orders of any government authority or any other legal process, to establish/exercise our legal rights or defend against legal claims or in the event we reasonably believe that doing so is legally required or is in your interest to protect your property or other legal rights or property or rights of others. We may also share your personal information in order to enforce and fully comply with our terms of service and other company policies; business transfer and mergers: we may transfer your personal information if the company, is acquired by or merged with another company, to the extent permitted by applicable law and/or required under the scheme/arrangement of a merger, etc. In such an event we will notify you before your personal information is transferred/shared with the other entity and hence becomes subject to a different privacy policy; with your consent: in addition to the aforementioned circumstances, we may share your personal information with third parties with your prior consent and/or at your request.

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on our platform. This aggregated information shall be used by us in research, and analysis, to improve and monitor our services and for various promotional schemes. Such non-personal data may be shared in aggregated, non-personal form with a third party to enhance customer experience, offerings, or services.

We respect the exercise of the rights you have in relation to the personal data we process or use. You can request access to or a copy of your personal data collected and processed by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their "account" on the platform and changing the account settings. If you have an objection to the use of your data under this policy, please write to our privacy team at legal@wardenera.com. To prevent misuse, we will ask you to identify yourself.

We do not control or endorse the content, messages, or information placed on the platform by any user or third party and, therefore, we specifically disclaim any liability with regard to such information and your participation/ engagement with such users, third-party service providers and services offered by them and you agree that you waive any claims against us relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against us relating to the same. You are responsible for maintaining the accuracy, truthfulness, correctness, and completeness of the information you submit or provide to us, on the platform; and shall hold harmless and indemnify the company from and against all claims arising out of or in relation to the wrongful information posted, provided by you to us, on the platform. If your personal information changes, you may correct, delete inaccuracies, or amend information by contacting us at legal@wardenera.com. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at legal@wardenera.com.

We understand the serious implications of data security and take extensive measures to ensure your data and information are secured. We take extensive technical, and legal measures to safeguard your personal data. The platform uses a reliable ssl certificate to ensure your personal data is not misused in any manner whatsoever. We use ssl encryption when transmitting certain kinds of information, such as financial services information or payment information. An icon resembling a padlock is displayed on the bottom of most browser windows during ssl transactions that involve debit/credit cards and other forms of payment. In case we ask you for your debit/credit card number for payment or for verification purposes, the same will be ssl encrypted. The information you provide will be stored securely on our servers. Once you choose to store or enter your debit/credit card number, it will not be displayed back to you in its entirety when you retrieve or edit it in the future. Instead of the entire number, you will only see asterisks and either the first four digits or the last four digits of your debit/credit card number. Our employees and data processors, who have access to and are associated with processing sensitive personal data or information, are obliged to respect the confidentiality of every user’s personal information or sensitive personal data and information. We have put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain the security of all personal data from the point of collection to the point of destruction. No administrator of the platform will have knowledge of your password. It is important for you to protect against unauthorised access to your password, your computer, and your mobile phone. Ensure you log off from the platform when finished. We do not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorised use of your account, you must immediately notify us by sending an email to legal@wardenera.com. You shall be liable to indemnify us due to any loss suffered by us due to such unauthorised use of your account and password. Please note that we make all user information accessible to our employees, agents or partners, and third parties only on a need-to-know basis. However, we are not responsible for the confidentiality, security, or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. In case there is any breach of security, we will make all legally required disclosures concerning the breach and the confidentiality, or integrity of your unencrypted electronically stored "personal data" to you via email or by posting it on platform without unreasonable delay, in as far as is consistent with any legitimate needs of law enforcement and any measures required to determine the scope of the breach and to safeguard the integrity of data.

We ensure that your data and information shall be protected under the provisions of the general data protection regulation, information technology act, 2000, information technology (intermediary guidelines and digital media ethics code) rules, 2021, and information technology (reasonable security practices and procedures and sensitive personal data or information) rules, 2011 along with any amendments made to these acts, rules, and regulations.

We do not keep your personal data longer than necessary for the purpose of processing. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you have any questions or complaints about the processing of your personal data, write to us at legal@wardenera.com. Our team will be happy to assist you.