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Privacy Policy

FlatMate.in Limited (“FlatMate.in,” “we,” and “us”) respects the privacy of its users (“you”) and has developed this Privacy Policy to demonstrate its commitment to safeguarding your privacy. This Privacy Policy describes the information we collect and process through our mobile apps and website (“our Sites”), how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

We encourage you to read this Privacy Policy carefully when using our Sites or property search or other services (“Services”) or when transacting business with us. By using our Sites or Services you are accepting the practices described in this Privacy Policy.

This Privacy Policy was last updated in December 2021 and may be subject to future revisions.

Our Sites are not intended for children and we do not knowingly collect data relating to children.

Information we Collect About You

In General.

FlatMate.in is the data controller and responsible for our Sites and Services and for your Personal Data.

We have appointed a Privacy Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Privacy Officer: friends@flatmate.in.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links.

Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy notice of every website you visit.

Data we Collect.

Personal data, or personal information (“Personal Data”), means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

By using our Sites or Services, you are authorising us to gather, parse and retain data related to the provision of the Service. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, maiden name, username or similar identifier, employer, title or employee reference, photos or other images.

Contact Data includes address, email address and telephone numbers, and any social media accounts used to contact us or used.

Financial data includes bank account and payment card details.

Transaction data includes details about payments to and from you and other details of products and services purchased from or through us.

Technical Data includes device ID, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Sites and Services.

Profile Data includes any username and password, reservations, purchases or orders made by you, or events attended or in which you participate, your interests, preferences, feedback and survey responses, including any data used to open a FlatMate.in account or to communicate with landlords, agents and letting agencies (FlatMate.in Partners) marketing properties in which you express an interest. This may also include any property preferences you provide, such as location of interest, budget, furnished state, number of bedrooms and move in date.

Usage Data includes information about how you use our Sites or Services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and FlatMate.in Partners marketing properties in which you express an interest, and your communication preferences.

We do not knowingly collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). All the information we took from you are sent to our servers which are located at https://www.flatmate.in.

If You Fail To Provide Personal Data.

Where we need to collect personal data by law, or under the terms of a contract (i.e. User Terms and Conditions) we have with you, or we have legitimate interest in collecting because of a service offered, and you fail to provide that data when requested, we may not be able to perform the contract or service we have or are trying to enter into with you. In this case, we may have to cancel a registration or service you have with us but we will endeavour to notify you if this is the case at the time.

How We Collect Personal Data.

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Profile, Contact, Financial Data and Marketing and Communications Data by using our Sites or Services including by creating a FlatMate.in account, or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

- make an enquiry about our services

- subscribe to or use our Sites

- request marketing to be sent to you

- register your interest in, attend or participate in an event we manage or organise

- enter a competition, promotion or survey

- give us some feedback.

Automated Technologies.

We may use various technologies to collect Identity, Profile, Contact, Financial Data and Technical Data from you when you use our Sites or Services.

Cookies and Use of Cookie Data. When you use our Sites we may assign your device one or more cookies to facilitate access to our Sites and Services and to personalise your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Sites and through our Services, such as the pages you visit, the time and date of your visits and the links you click. We (or third parties including FlatMate.in Partners) that advertise via our Sites or Services may use certain data collected on our Sites and through our Services (such as Profile Data) via cookies to show you specific properties and advertisements. Please see our Cookie Policy for further details.

Google Analytics. We use Google Analytics to collect and store data that enables us to analyse the use of our Service. Google Analytics collects and stores statistical and other information about website use by means of cookies, which are stored on users’ computers. Certain advertising features have been enabled that may collect data via the user of advertising cookies and anonymous identifiers Google Analytics Demographics & Interest Reporting To prevent your data being collected by Google Analytics you may opt-out via Google Analytics’ currently available opt-outs for the web. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Sites and Services and to deliver or communicate with cookies. We also may include web beacons in advertisements or email messages to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the services we offer users, to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

Public Sources.

We may also collect data if you interact with us via social media accounts and via search engines.

Third Parties, Service Providers and FlatMate.in Partners.

Among the third parties we may collect your Personal Data from include:

- FlatMate.in Partners with whom you have engaged, and service providers acting as data processors who provide IT and system administration services, such as Google Play Billing.

- Marketing automation or survey development and distribution platforms, acting as a processor, such as Google Analytics.

- Social media platforms with whom you have an account, such as Facebook, and Google.

How we Use the Information we Collect.

In General.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

- Where we need to perform a contract we are about to enter into or have entered into with you or one of our FlatMate.in Partners or other partners or providers (i.e. Third Parties, Service Providers and FlatMate.in Partners as set out above).

- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

- Where we need to comply with a legal or regulatory obligation.

-We rely on consent as one of the legal bases for processing your personal data where you have expressly given it. In relation to sending third party direct marketing communications to you via email or text message we will only rely on consent. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which we Will Use Your Personal Data.

We have set out below, in a table format, a description of the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or user of our Sites or Services.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you or one of our FlatMate.in Partners or other partners or providers.
To process and deliver our Services, including: (a) To inform you of developments or updates in relation to the Services we provide to you (including our Sites) or provided by a permitted and authorised provider (i.e. FlatMate.in Partner) or professional (b) Connect you to a third party administrative or technology provider (i.e. Google Payment) in order to perform our services (c) Manage payments, fees and charges	(a) Identity (b) Contact (c) Profile (d) Financial (e) Transaction (f) Marketing and Communications	(a) Performance of a contract with you or one of our FlatMate.in Partners or other partners or providers. (b) Necessary for our legitimate interests (i.e. to keep our records updated, to study how customers use our Sites and Services and to comply with our legal and tax obligations)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) If you have some other form of contractual relationship with us	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Special Category	(a) Performance of a contract with you or one of our FlatMate.in Partners or other partners or providers. (b) Necessary to comply with a legal (c) Necessary for our legitimate interests (i.e. to keep our records updated, to study how customers use our Sites and Services and to comply with our legal and tax obligations)
To engage with you via our Sites or to enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you or one of our FlatMate.in Partners or other partners or providers. (b) Necessary for our legitimate interests (i.e. to keep our records updated, to study how customers use our Sites and Services and to comply with our legal and tax obligations)
To administer and protect our business and Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (i.e. to study how customers use our Sites and Services, to develop them, to grow our business and to inform our marketing strategy)
To use our database and data analytics to improve our Sites and Services (including marketing, customer relationships and experiences)	(a) Technical (b) Usage (c) Contact (d) Identity (e) Marketing and Communications (f) Profile	Necessary for our legitimate interests (i.e. to define types of customers for our products and services, to keep our Sites and Services updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that are similar to those already provided or which you have previously taken and which may be of interest (including our email newsletter and social media marketing)	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (i.e. to develop our Sites and Services and grow our business) (b) Consent

Marketing.

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing. We have also established the following Personal Data control mechanisms:

Promotions from us – We may use your Identity, Contact, Technical, Usage, Profile, Marketing and Communication Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us where you have opted to do so or where you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition and, in each case, you have not opted out of receiving that marketing.

Third Party Marketing – We will get your express opt-in consent before we share your personal data with any company outside FlatMate.in for marketing purposes, including our FlatMate.in Partners.

Opting out – You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us at any time.

We will need to maintain a restricted record of Contact and Identity Data where you have opted out of receiving marketing and this is to prevent any future marketing being carried out and, unless otherwise informed, no other processing shall be carried out in relation to this information.

Change of Purpose.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.

With Whom we Share Your Information.

We do not share your personal information with others except as indicated in this Privacy Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:

Third Parties, Service Providers and FlatMate.in Partners. We may share information, including personal information with FlatMate.in Partners (where you agree to this) or third parties that perform certain services on our behalf. These services may include booking viewings, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Sites or Services. These service providers may have access to Personal Data needed to perform their functions but are not permitted to share or use such information for any other purposes.

We require all third parties to commit to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third parties to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions:

Other Situations. We may disclose your information, including personal information:purposes.

- In response to a court order or similar investigative demand, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

- If we are required to do so by law; in connection with any legal proceedings or prospective legal proceedings; to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

-- when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use. or other agreements or policies.

- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Aggregated and/or non-personal information.

We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or Personal Data in hashed, non-human readable form, with third parties, including advisors and investors, for the purpose of conducting general business analysis or other business purposes. For example, we may engage a data provider who may collect web log data from you (including Technical Data and Usage Data), or place or recognise a unique cookie on your device to enable you to receive customised advertisements or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. To opt-out of cookies that may be set by third party data or advertising partners, please go to http:// www.aboutads.info/choices/.

We may use and share non-personal information we collect under any of the above circumstances.

International Transfers.

Using our Sites and Services from outside the India.

If you are using our Sites or Services from outside the India, please be aware that your information may be transferred to, stored, and processed in the India where our servers are located and our central database is operated. By using our Sites and Services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

Data Security and Data Retention.

Data Security.

We have put in place appropriate technical and organisational measures to secure your Personal Data and prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties (including FlatMate.in Partners) who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Please note however that we cannot guarantee the security of third party networks or systems.

We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.

Data Retention.

We will retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Sites and Services or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We have to keep basic information about our customers and employees (including Contact, Identity and any financial data) for six years after they cease being customers or employees for tax and legal liability purpose, but we also keep this information to make it easier for users to process new, follow-on or repeat service requests. Where we rely on consent (i.e. for marketing) we will seek to renew this regularly.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for data analytical purposes in which case we may use this information indefinitely and share it with third parties without further notice to you.

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit your profile page or mail us at: feedback@flatmate.in

Your Choices about Collection and Use of Your Information.

- You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Sites or Service because such information may be required in order for you to register as user; request to book a viewing on a property; participate in a contest, promotion, survey, or sweepstakes.

- Our Sites and Services may also deliver notifications to your phone or mobile device, where you have consented to such communications. You can disable these notifications by changing the settings on your mobile device.

- You can also control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.

- You may instruct us not to process your personal information for marketing purposes (see Opting-out above).

No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

Changes to this Privacy Policy. We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Sites from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

How to Contact us.

If you have any questions about this Privacy Policy, please contact us by email atfriends@flatmate.in

Cookie Policy.

Our Sites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you use our Sites and also allows us to improve our Sites. By continuing to use the Site, and accepting our cookie notifications, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the memory of your computer or device if you agree. Cookies contain information that is transferred to your computer's memory.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas of our Sites.

Analytical/performance cookies. They allow us to recognise and count the number of users and visitors and to see how they move around our Sites when using them. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our Sites. This enables us to personalise our content for you, greet you by name and remember your preferences.

Targeting cookies. These cookies record your visit to our Sites, the pages you have visited and the links you have followed. We will use this information to make our Sites and the content displayed more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.