Privacy Policy

1. Introduction

Real Galaxy ("we," "us," "our," or "the Company"), operated by EWS Technologies, respects the privacy of our users ("user" or "you"). This Privacy Policy explains how we collect, use, store, process, host, share, disclose, and safeguard your information when you access or use our website, mobile application, and related services (collectively, "the Platform").

This Privacy Policy is published in compliance with the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and any applicable data protection legislation in force in India.

By accessing, browsing, or using the Platform in any manner, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Platform.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, phone number, password, user type (buyer, seller, agent, builder)
• Profile Information: Photograph, company name, RERA registration number, business address, professional credentials
• Property Listing Data: Property descriptions, photographs, videos, floor plans, pricing, area measurements, location details, amenities, and other listing content you submit
• Transaction & Inquiry Data: Property inquiries, site visit requests, offers, communication history with other users
• Identity Verification Data: Government-issued ID documents (Aadhaar, PAN, etc.) submitted for verification purposes
• Payment Information: Billing address, payment method details (processed by third-party payment gateways; we do not store full card details)
• Communications: Messages, feedback, complaints, support requests, and survey responses

2.2 Information Collected Automatically

• Device Information: Device type, operating system, browser type and version, screen resolution, unique device identifiers
• Usage Data: Pages visited, features used, search queries, property views, click patterns, session duration, referral sources
• Location Data: Approximate location based on IP address, and precise location (GPS) if you grant permission for location-based features such as nearby property search
• Log Data: IP address, access times, server logs, error logs, and referring URLs
• Cookies & Tracking: Data collected via cookies, web beacons, local storage, and similar tracking technologies (see Section 8)

2.3 Information from Third Parties

• Social Login Providers: If you sign in via Google or other social platforms, we receive your name, email, and profile picture as authorised by you
• Network Partners: Agents, builders, or developers who submit listings or customer data on your behalf
• Public Sources: Publicly available property records, RERA databases, and government portals

3. How We Use Your Information

We use your information for the following purposes:

• Service Delivery: To operate, maintain, and provide the features and functionality of the Platform, including property search, listing creation, inquiry management, and user communication
• Account Management: To create and manage your account, verify your identity, and authenticate your access
• Transaction Facilitation: To facilitate property inquiries, site visit scheduling, and connections between buyers, sellers, agents, and builders
• Personalisation: To personalise your experience, including property recommendations, search results, and content based on your preferences and behaviour
• Communications: To send transactional notifications (OTPs, booking confirmations, inquiry updates), service alerts, and promotional communications about properties and services
• Analytics & Improvement: To analyse usage patterns, generate aggregate statistics, improve Platform features, and conduct internal research
• Security & Fraud Prevention: To detect, prevent, and investigate fraud, security breaches, and abuse of the Platform
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests
• Business Operations: To process payments, manage billing, conduct audits, and for internal administrative purposes
• Market Intelligence: To create anonymised and aggregated reports on market trends, pricing analytics, and demand patterns

4. Data Sharing & Disclosure

We may share your information with the following categories of recipients:

4.1 Other Platform Users

When you post a property listing, your listing details, name, and contact information may be visible to other users. When you make an inquiry, your name and contact details may be shared with the listing party (owner, agent, or builder). This sharing is essential for the functioning of the Platform and you consent to such disclosure by using the Platform.

4.2 Network Partners

Your information (including contact details, property preferences, and inquiry history) may be shared with Network Partners — real estate agents, brokers, builders, and developers — to facilitate property transactions and provide you with relevant services. Network Partners are independent entities and their use of your data is governed by their own privacy practices.

4.3 Service Providers

We share data with third-party service providers who assist us in operating the Platform, including: cloud hosting and infrastructure providers, payment processors, SMS and email delivery services (MSG91, Brevo), analytics providers, customer support tools, mapping and geolocation services, and content delivery networks. These providers process data on our behalf and are contractually bound to protect your information.

4.4 Legal & Regulatory Authorities

We may disclose your information when required by law, court order, subpoena, or government request; to protect the rights, property, or safety of Real Galaxy, our users, or the public; to enforce our Terms of Use; or to detect, prevent, or investigate fraud, security incidents, or potential illegal activities.

4.5 Business Transfers

In the event of a merger, acquisition, reorganisation, sale of assets, or bankruptcy, your information may be transferred to the successor entity. We will notify you of any such change in ownership or control of your data.

4.6 Aggregated & Anonymised Data

We may share aggregated, anonymised, or de-identified data that does not identify you personally with third parties for analytics, research, business intelligence, and marketing purposes without restriction.

5. Data Storage, Hosting & Retention

Your data is stored and hosted on servers operated by our cloud infrastructure providers, which may be located in India or other jurisdictions. By using the Platform, you consent to the transfer, storage, and processing of your data in these locations.

We retain your personal information for as long as your account is active or as needed to provide you services. After account deletion or deactivation, we may retain certain data for the following periods and purposes:

• Transaction Records: Up to 8 years as required by Indian tax and accounting laws
• Legal Compliance: As long as required by applicable laws, regulations, or legal proceedings
• Dispute Resolution: For the duration of any ongoing or potential legal dispute
• Anonymised Data: Indefinitely, in aggregated or anonymised form for analytics purposes
• Backup Archives: Data may persist in encrypted backup systems for a reasonable period after deletion

6. Data Security

We implement industry-standard administrative, technical, and physical security measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication mechanisms including hashed passwords, JWT tokens, and multi-factor authentication
• Access controls limiting employee and contractor access to personal data on a need-to-know basis
• Regular security assessments and vulnerability monitoring
• Secure cloud infrastructure with compliance certifications

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information using commercially acceptable means, we cannot guarantee absolute security and are not liable for any breach resulting from circumstances beyond our reasonable control.

7. Your Rights & Choices

Subject to applicable Indian law, you have the following rights regarding your personal data:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete data by updating your profile or contacting us
• Withdrawal of Consent: Withdraw your consent to data processing at any time by contacting us or adjusting your account settings. Note: withdrawal of consent may limit your ability to use certain Platform features
• Deletion: Request deletion of your account and personal data, subject to our retention obligations under applicable law
• Opt-Out of Marketing: Unsubscribe from promotional communications at any time via the unsubscribe link in emails, SMS preferences, or account settings. Transactional communications (OTPs, security alerts) cannot be opted out of
• Data Portability: Request your data in a machine-readable format where technically feasible
• Grievance Redressal: File a complaint with our Grievance Officer (details in Section 13) regarding any data handling concerns

To exercise any of these rights, please contact us at privacy@realgalaxy.in. We will respond to your request within 30 days.

8. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Platform:

• Essential Cookies: Required for the Platform to function (authentication, security, session management). Cannot be disabled.
• Functional Cookies: Remember your preferences (language, location, search filters) to improve your experience
• Analytics Cookies: Help us understand how users interact with the Platform, page views, and feature usage to improve our services
• Marketing Cookies: Used to deliver relevant property-related advertisements and track marketing campaign effectiveness

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform. By continuing to use the Platform, you consent to our use of cookies as described herein.

9. Deemed Consent

By accessing, registering on, or using the Platform in any manner, you are deemed to have provided your free, informed, specific, and unambiguous consent to:

• The collection, storage, hosting, processing, use, and disclosure of your personal and non-personal information as described in this Privacy Policy
• The sharing of your contact details and property preferences with Network Partners (agents, builders, developers) for the purpose of facilitating property transactions
• The hosting and processing of your data on servers located in India or other jurisdictions
• The receipt of transactional and service-related communications via SMS, email, WhatsApp, push notifications, and in-app messages
• The creation and use of aggregated, anonymised, or de-identified data derived from your usage for analytics, research, and business purposes
• The retention of your data as described in Section 5, including post-deletion retention for legal compliance

This deemed consent shall remain in effect for the duration of your use of the Platform and for the applicable retention periods thereafter. You may withdraw your consent at any time by contacting us at privacy@realgalaxy.in, subject to any legal obligations requiring continued retention or processing.

If you do not consent to the practices described in this Privacy Policy, you must immediately discontinue use of the Platform and request deletion of your account.

10. Sensitive Personal Data

Under the SPDI Rules, "Sensitive Personal Data or Information" includes financial information (bank account, payment instrument details), passwords, and biometric data. We collect sensitive personal data only when necessary for providing our services and with your explicit consent.

Financial data provided during payment transactions is processed by PCI-DSS compliant third-party payment gateways. Real Galaxy does not store full credit/debit card numbers or CVV codes on its servers. Passwords are stored in hashed format and are never stored or transmitted in plain text.

11. Third-Party Links & Services

Our Platform may contain links to third-party websites, services, or applications including property portals, financial services, mapping services, and social media platforms. We are not responsible for the privacy practices, content, or security of those third-party services. We encourage you to review their privacy policies before providing any personal information.

Any interaction you have with third-party services linked from our Platform, including payment gateways and social login providers, is governed exclusively by the terms and privacy policies of those third parties.

12. Children's Privacy

Real Galaxy is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without verifiable parental consent, we will take steps to delete such information promptly.

13. Grievance Officer

In accordance with the Information Technology Act, 2000 and the SPDI Rules, we have appointed a Grievance Officer to address any concerns or grievances regarding data handling:

If you are not satisfied with our response, you may escalate your complaint to the appropriate regulatory authority in India.

14. Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated version will be indicated by an updated "Last Updated" date at the top of this page.

We will notify you of material changes through Platform notifications, email, or a prominent notice on our website. Your continued use of the Platform after any changes constitutes your deemed acceptance of the revised Privacy Policy. If you do not agree with the updated Privacy Policy, you must discontinue use of the Platform.

15. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us at: