Privacy Policy

Any information provided by you while accessing or using the website (“Site”), shall be handled as per the privacy policy outlined further (“Privacy Policy”). For the purpose of this document, all other capitalized or uncapitalized terms used herein and not specifically defined herein, shall have the meaning assigned to them under our ‘Terms and Conditions’.

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1. Introduction‍
   1. Strata Capital Management Private Limited (“Strata Capital”, or “we“, or “us“, and “our“) respect your privacy and is committed to protecting the privacy and security of the information that you share with us.
   2. We, thus, intend to keep up this commitment by making sure that you understand the information we collect, how we use it, and the choices that you are entitled to concerning your information, through this privacy policy.
   3. This privacy policy (“Policy”) describes the policies and procedures on the collection, usage, and disclosure of your information when you use the Site on a mobile, tablet, smart device, etc. made available by Strata Capital having its registered office at No. 6/1-1, Museum Road, Mahatma Gandhi Road, Richmond Town, Bangalore, Karnataka, 560001.
   4. Kindly note that the terms “you” and “your” refer to the user of the Site and the term “Services” refers to any of the services offered on the Site.
   5. Please read this Privacy Policy before using the Site, or before submitting any information on the said Site.

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2. Applicability & Type of Information Collected

We are committed to safeguarding your Information (as defined hereinafter), however, please read and understand the Privacy Policy carefully. If you do not agree with our policies and our practices in the way we treat your information (“Information” which may include your name, nationality, date of birth, telephone number, email address, IP address, physical address, financial information, or any other information and/or documents submitted by you), you should immediately stop accessing the Site. Your continued use or access of the Site shall constitute your agreement to this Privacy Policy. The policy does not apply to, nor does Strata Capital take any responsibility for, any information that is collected by any third-party either using the Site or through any links on the Site or through any advertisements on the Site.

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3. Your Consent

By using the Site and the Services, you agree and consent to the collection, usage, transfer, storage, disclosure and sharing of your Information and other information as described and collected by us per this Privacy Policy to the extent permitted under applicable laws.

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4. Nature and Manner of Collecting Information

Information required for the use of the Site:

The following information is required to be provided to us for the adequate performance of the contractual obligations between you and us:

1. Account Information. When you sign up for an account, we require certain information such as your first name, last name, mobile number and e-mail id.
2. Profile Information. To use certain features of the Site, we may ask you to provide additional information, which may include your name, email, phone number, company name, etc.
3. Information you provide to us: The information we collect on, or through our Services on the Site may include:
   1. Search results and other activities: We may collect information on your search activities and search results on the Site.
   2. Browsing information: We may collect information on the usage of our Services, usage of features on the Site.

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4. Information collected through automated data technologies. We may also automatically collect certain information about the devices (mobile devices/ tablets) used by you to access the Site:
   1. Service Usage information: We may track the details of your activity on the Site, and the usage of the Services, including traffic data, location data, logs and other communication data and the resources that you access and use on, or through the Services.
   2. Location information: We may collect real-time information about the location of your device, as may be permitted by you.
   3. Mobile device IDs: We may use mobile device IDs (the unique identifier assigned to a device by the manufacturer), to recognise you. Kindly note that analytics companies may also use mobile device IDs to track your usage of the Site.
   4. Device status: We may also track the status (online or offline) of the Site on your device.

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5. Purpose and Use of Information Collected

The Information and other information collected from you may be used for several purposes, including, but not limited to:

1. Understand our users, improve the content and feature of our Services, process and complete your transactions and respond to your queries;
2. Administer our Services and diagnose technical problems;
3. Create and maintain a trusted and safer Site;
4. Generate and review reports and data, and to conduct research on our user base and Service usage patterns;
5. Administer polls and other interactive features of our Services, if any;
6. Provide you with customer support and policies about your account;
7. Carry out our obligations concerning contracts entered into between you and us;
8. Notify you about changes to our Services;
9. Allow you to participate in interactive features offered through our Services; and
10. For any other purpose with your consent
11. Any information shared on the Site will be used for purposes based on legitimate interests, fulfilment of any contractual obligations with you, compliance with applicable laws, and/or your consent. An indicative list of such purposes is set out below:
    1. Verifying your identity;
    2. Creation of user account(s), if applicable; 
    3. Sending administrative information to you; 
    4. Providing any Services to you as highlighted in the Terms and Conditions;
    5. Reasons ancillary to the above purposes

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If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by writing to us at the contact details mentioned below. However, please note that this will not affect the lawfulness of any data accessed/processed before such withdrawal of consent and might affect our ability to facilitate your access to our Site or our Services.

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6. Disclosure of Information

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1. We may share the information collected under Clause 4:
   1. to contractors, service providers and other third-parties whose services are required to ensure the adequate performance of the contractual obligations between you and us, and who are bound by contractual obligations to maintain the confidentiality of the information transferred;
   2. for any other purpose disclosed by us when you provide the information.

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2. We may share your information with outside vendors that we use to send push notifications to your device on our behalf to analyse our Services. We may employ vendors for conducting surveys or organising polls for us.
3. If Strata Capital undertakes, or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
4. We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymised information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes. 
5. We may disclose your Information and other information to law enforcement agencies, governmental authorities, or any other authorized third parties, if and to the extent such disclosure is reasonably necessary: (i) to comply with our legal obligations including defending claims asserted against Strata Capital or its holding company or affiliates; (ii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability; or (iii) to protect the rights, property or personal safety of Strata Capital, or its holding company or affiliates its employees, or members of the public.
6. Except as otherwise provided herein, no personally identifiable information will be disclosed or shared with any third-party without your express consent. Strata Capital may use the information you provide for Know Your Customer (KYC) verification or other similar processes as required under applicable laws, which may include sharing your information with regulatory bodies.

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7. Your Rights

You are entitled to the following rights:

1. Right to review and manage your information:
   You have the right to access, review and update the information provided by you through your account settings. If you have connected your account to a third-party application, you can change your account settings and remove permission for the concerned application.

2. Right to rectify inaccurate/ incomplete information:
   You have the right to request the correction of inaccurate or deficient personal information about you, and such inaccurate/deficient personal information shall be corrected or amended by us as feasible (and which cannot be self -updated through your account.)

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3. Right to withdraw consent:
   1. Since we process your information based on your consent, you may choose to withdraw your consent at any time by sending a written communication to your Compliance Officer. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
   2. Additionally, kindly note that, once we process your withdrawal of consent, your account shall automatically stand deleted and you will no longer be entitled to access the Services provided through the Site.
   3. Notwithstanding anything contained in clauses 7(a) , 7(b), and 7(c) above, your right to review, update, correct and delete your information may be limited by the following, subject to the laws of India :
      1. requests being abusive or unreasonably excessive;
      2. requests that encroach upon the safety and privacy of another person;
      3. requests that relate to existing or anticipated legal proceedings between you and us, or where providing access to you would prejudice an investigation of possible unlawful activity.
         
         Your right to review, update, correct, and delete your information is subject to our records retention policies and applicable law, including any statutory retention requirements.
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4. Right to lodge complaints :
   You also have the right to lodge complaints about our data processing activities or any discrepancies or violations of this Privacy Policy by filing a complaint with our Compliance Officer who can be reached by the e-mail address provided. 
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5. Any other applicable rights provided under the Securities and Exchange Board of India (Real Estate Investment Trusts) Regulations, 2014 as amended from time to time.

Please note that you may be asked to verify your identity before we take further action on your request.

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8. Changes To Policy

Strata Capital reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we shall notify you by way of a pop up / notification on the Site. If you disagree with the revised Privacy Policy, you may cancel your account and cease to use the Site. If you do not cancel your account within seven (7) days from the effective date of the revised Privacy Policy, your continued access to, or use of the Site will be considered to be a deemed acceptance of the revised Privacy Policy and your continued use, or access to the Site will be subject to the revised Privacy Policy.

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9. Data Security & Data Retention
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   1. We would follow industry standards to the best of our knowledge, to protect the information submitted by you to maintain data security and to prevent any unauthorised access to your personal information. We also have in place adequate security practices and procedures as may be amended from time to time, to safeguard and protect your personal information. 
   2. However, notwithstanding anything contained hereinabove; we assume no liability or responsibility for disclosure of your information due to unauthorised third-party access, loss in transmission, or other causes beyond our control. Kindly note that you play an integral role in keeping your personal information secure. You should ensure that you do not share your user name, password, or other security information for your account with anyone. If we receive instructions using your user name and password, we will consider such instructions as being authorised by you.
   3. We may transfer, store, and process your Information in countries other than your own in compliance with applicable laws. While we will use all reasonable efforts to ensure that the Information and other information submitted by you is safe and secure, we offer no representation, warranties, or other assurances that the security measures taken by us are adequate, safe, or impenetrable. 
   4. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law.

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10. Contact Us‍

If you have any queries regarding the usage/ processing of your personal information or concerning this Privacy Policy, you may send an e-mail at info@stratasmreit.com.

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