Privacy Notice

1. Introduction

This Property.new Buyer Privacy Notice ("Privacy Notice") explains how Cladbe Platforms LLP ("Cladbe", "we", "us", or "our") collects, uses, shares, retains, and protects your personal data when you use Property.new — our buyer-facing real estate marketplace. This Privacy Notice is published in compliance with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 ("DPDP Act and Rules"), the Information Technology Act, 2000, and other applicable Indian law.

This Privacy Notice applies to your use of Property.new as a Buyer. Cladbe operates other surfaces — the Cladbe Operating System for Builders and Channel Partners, the Studio engagement services, and the Stage distribution network. Your use of those surfaces, where applicable, is governed by the Master Privacy Policy at cladbe.com/privacy. This buyer-focused Privacy Notice should be read alongside the Property.new Buyer Terms, the Buyer Cookie Notice, the Buyer Refund & Cancellation Policy, and the Master Privacy Policy.

2. Who We Are

Cladbe Platforms LLP is a limited liability partnership incorporated under the Limited Liability Partnership Act, 2008, with its registered office at Tulsi Nagar, Bareilly, Uttar Pradesh – 243006, India. For your personal data processed through Property.new, Cladbe is the "Data Fiduciary" within the meaning of Section 2(i) of the DPDP Act — the entity that decides the purpose and means of processing your data.

Cladbe plans and operates as if it qualifies as a Significant Data Fiduciary under the DPDP Act. Whether or not Cladbe is formally designated as a Significant Data Fiduciary by the Data Protection Board of India, Cladbe applies the controls, resourcing, and grievance handling appropriate to that classification.

3. What Personal Data We Collect

We collect your personal data in stages, only as required for the next step you choose to take on Property.new. The table below itemises each category, as required under Rule 3 of the DPDP Rules, 2025.

3.1 Information We Collect at Sign-In

3.2 Information We Collect at EOI Submission

3.3 Information We Collect at Token Money Payment

3.4 Information We Collect Automatically

3.5 Information We May Collect from Third Parties

4. Why We Process Your Data

We process your personal data for the following specific purposes:

• To create and operate your account, authenticate you at sign-in, and respond to your service requests;
• To route your enquiry/Expression of Interest to the fulfillment channel best placed to help you — the Builder, an authorised Channel Partner, and/or the Cladbe Experience Centre team — for the project you enquired on and comparable alternatives, and to enable the party handling your booking to assess and process it;
• To process Token Money payments through RBI-licensed Payment Aggregators and to manage refunds where applicable;
• To send you transactional communications (OTPs, EOI confirmations, receipts, refund updates, grievance acknowledgements);
• To send you marketing communications about projects, launches, Flash Sales, and offers, on the basis of consent captured during account creation through a prominently displayed marketing preference (defaulted to ON, which you may disable at any time during sign-up or thereafter in account settings — see Section 12.3 of the Property.new Buyer Terms);
• To promote projects and the Property.new platform — including measuring the effectiveness of on-platform promoted/featured listings and of advertising we run on third-party channels (such as Google, Meta, and LinkedIn), and building and measuring advertising audiences — using cookies and similar technologies subject to your consent, as explained in the Property.new Buyer Cookie Notice;
• To run the Mortgage Buyability Calculator and route indicative pre-approval requests to partner lenders, where you choose to use that feature;
• To detect, investigate, and prevent fraud, abuse, and security incidents on the Service;
• To comply with our statutory and regulatory obligations under RERA, the DPDP Act, the Consumer Protection Act, the Income Tax Act, the Prevention of Money Laundering Act, and other applicable Indian law;
• To operate and improve algorithmic features of the Service — including lead-routing to Builders and Channel Partners, search ranking, Trust Score computation on Cladbe Verified listings, and fraud-detection scoring — using your activity data combined with aggregated data from other users. Such processing does not result in fully automated decisions that produce legal or similarly significant effects on you. Where any algorithmic output could materially affect a transaction outcome (such as Mortgage Buyability Calculator results), the final decision is made by a partner lender or human reviewer, not by an algorithm in isolation;
• To generate aggregated, anonymised analytics for service improvement and market intelligence (no individual buyer is identifiable in such analytics);
• To respond to lawful requests from courts, regulators, and law enforcement agencies.

5. Who We Share Your Data With

Your personal data is shared only with the entities listed below, and only for the purposes set out. We do not sell your personal data.

When you submit an enquiry or Expression of Interest on Property.new, you are making a request to Cladbe to help you find and buy property. On receiving your request, Cladbe routes your details to whichever fulfillment channel — the Builder, an authorised Channel Partner, the Cladbe Experience Centre team, or a combination of these — is best positioned to assist you. This routing is not limited by the claim status of the listing you enquired on, and the party that assists you may help you with the project you enquired on and with comparable or alternative projects that match your requirement.

5.1 Builders

Where Cladbe routes your request to a Builder, the Builder receives your enquiry details — your name, phone number, email address, the unit or configuration you enquired about, the EOI value where applicable, attribution timestamp, and any preferences you shared — so they can assist you and progress the transaction. Where you proceed toward booking or Token Money payment, the Builder additionally receives the KYC documentation required for booking and Builder-Buyer Agreement execution. From the Builder-Buyer Agreement stage onward, the Builder is an independent Data Fiduciary for your data in their own systems, and the Builder's own privacy policy applies.

5.2 Authorised Channel Partners

Where Cladbe routes your request to an authorised Channel Partner — regardless of whether the listing you enquired on is claimed or unclaimed — the Channel Partner receives your enquiry details (name, phone number, email, requirement, budget, source listing, and EOI value) so they can assist you with site visits, project information, comparable options, and the purchase process.

Where a Channel Partner is the party assisting you with a booking, they additionally receive the KYC documentation (such as PAN and Aadhaar) necessary to assess and process that booking — because the party handling your booking must verify your documents to determine whether the booking can proceed. Channel Partners are bound by contractual confidentiality and data-protection obligations consistent with the DPDP Act, and may use your data only to assist you with your property requirement.

5.3 Cladbe Experience Centre Team

Where Cladbe routes your request to the Cladbe Experience Centre team — an internal Cladbe team operating in select locations as part of our distribution network — they receive your enquiry details to assist you with site visits, project walkthroughs, comparable options, and the purchase process. Where the Experience Centre team is the party assisting you with a booking, they additionally receive the KYC documentation necessary to assess and process that booking, for the same reason set out in Section 5.2. The Experience Centre team is bound by Cladbe's data handling commitments.

5.4 RBI-Licensed Payment Aggregators

All payments you make through Property.new — Token Money, booking amounts, Convenience Fees, and other amounts — are processed by RBI-licensed Payment Aggregators (Cladbe operates as a sub-merchant within the Payment Aggregator framework, under the RBI Regulation of Payment Aggregators Directions, 2025). To enable payment processing, your name, phone, email, payment amount, and payment instrument details are shared with the Payment Aggregator. The Payment Aggregator processes this data as an independent Data Fiduciary, under its own privacy policy.

5.5 Partner Lenders (for Mortgage Buyability Calculator)

Where you choose to use the Mortgage Buyability Calculator on Property.new, basic affordability information you provide — income range, loan amount sought, tenure preference, employment type — is shared with one or more partner lenders to generate an indicative pre-approval. Cladbe operates strictly as a Direct Selling Agent in this flow, under the RBI Digital Lending Directions, 2025. The partner lender is the loan provider; your formal loan application is made to the lender directly on the lender's own interface.

5.6 Service Providers (Sub-Processors)

Cladbe engages third-party service providers to deliver the Service — including cloud hosting, communication delivery (SMS, email, WhatsApp), analytics, customer support, AI Assistant infrastructure, and security monitoring. These service providers are Data Processors acting on Cladbe's instructions, bound by contractual data-protection commitments consistent with the DPDP Act. The current list of principal sub-processors is available on written request to grievance@property.new.

5.7 Statutory and Law Enforcement Disclosures

Cladbe may disclose your personal data where required by law, court order, or lawful instruction from a competent authority, including under the IT Act, the DPDP Act, the Income Tax Act, RERA, the Consumer Protection Act, the Code of Criminal Procedure, and similar statutes. Where the disclosure is not legally restricted from being shared with you, we will inform you of the disclosure within a reasonable timeframe.

5.8 Aggregated and Anonymised Sharing

Cladbe may share aggregated, anonymised, and statistical data — from which no individual buyer is identifiable — with Builders, market research firms, and other parties for market intelligence, industry benchmarking, and policy advocacy. Such aggregated data does not constitute personal data under the DPDP Act.

6. How Long We Keep Your Data

Cladbe retains your personal data only for as long as necessary for the purpose for which it was collected, or as required under applicable law, whichever is longer. Specific retention periods are:

Where you request account deletion or exercise your right to erasure under the DPDP Act, Cladbe will close your account access, stop marketing communications, and remove your profile from active systems. Transactional records (EOI history, payment records, KYC documents, audit trails) cannot be permanently deleted ahead of the statutory minimum retention period, as they are mandated to be retained under tax, AML, IT Act, and RERA law. Such records are protected by access controls and are deleted or anonymised at the point their statutory retention obligation expires.

7. Your Rights Under the DPDP Act

As a Data Principal under the DPDP Act, you have the following rights with respect to your personal data held by Cladbe:

To exercise any of these rights, write to grievance@property.new with the subject line "DPDP Rights Request — [Name of Right]", the phone number registered on your account, and the specific data or processing activity to which your request relates. Cladbe will acknowledge your request within 72 hours of receipt and respond substantively within the timelines prescribed under the DPDP Rules — typically within 30 days of receipt of a verifiable request.

8. Cross-Border Data Transfers

Cladbe's primary data processing infrastructure is hosted in India. However, certain service providers we engage (for cloud hosting, communications delivery, analytics, AI Assistant model serving, customer support tooling) may process data outside India, in jurisdictions including the United States, the European Union, the United Kingdom, and Singapore. Where this is the case, the cross-border transfer is governed by Section 16 of the DPDP Act and Rule 14 of the DPDP Rules, 2025, including any restrictions notified by the Central Government in respect of categories of personal data or destination jurisdictions.

Cladbe maintains contractual data-protection commitments with each cross-border service provider, consistent with the requirements of the DPDP Act and Rules. The current list of principal cross-border service providers is available on written request to grievance@property.new.

9. Children's Data

Property.new is not intended for transactional use by individuals under the age of eighteen (18). Children may browse Property.new and explore project information, but cannot create transactional accounts, submit Expressions of Interest, or make any payments. Where a property is being purchased in the name of a minor, the legal guardian must create the account in the guardian's own name.

Where Cladbe becomes aware that a User is a child within the meaning of the DPDP Act, Cladbe shall (a) cease any processing of the child's personal data that requires consent, except as permitted under Section 9 of the DPDP Act and Rule 10 of the DPDP Rules; (b) seek verifiable parental or guardian consent in accordance with Rule 10 before continuing any processing for which consent is required; and (c) not undertake any processing of the child's personal data that is likely to cause a detrimental effect on the well-being of the child, in line with Section 9(3) of the DPDP Act.

10. Security

Cladbe deploys technical and organisational security measures consistent with the requirements of Section 8(5) of the DPDP Act and Rule 6 of the DPDP Rules. These include:

• Encryption of personal data in transit (TLS 1.2 or higher) and at rest (industry-standard encryption);
• Role-based access controls with the principle of least privilege;
• Multi-factor authentication for internal access to systems holding personal data;
• Continuous monitoring, intrusion detection, and security event logging;
• Network segmentation between data planes;
• Periodic vulnerability assessments and penetration testing;
• Vendor due diligence and contractual data-protection commitments with all sub-processors;
• Incident response procedures with defined breach-notification protocols.

No security control is absolute. Where a personal data breach is detected, Cladbe will notify the Data Protection Board of India within 72 hours of awareness as required under Rule 7 of the DPDP Rules, and will notify affected Data Principals where the breach is likely to result in significant risk.

11. Grievance Officer and Contact

Cladbe has designated a Grievance Officer to address concerns about the handling of your personal data and the operation of Property.new. The Grievance Officer is the same individual designated under the Master Privacy Policy and the Property.new Buyer Terms.

Where you are not satisfied with Cladbe's response to a privacy grievance, you may escalate to the Data Protection Board of India once it becomes operationally functional. As of the date of this Privacy Notice, the Data Protection Board is in the foundational provisions phase under Rule 17–21 of the DPDP Rules, with full operational compliance scheduled from May 2027.

12. Changes to This Privacy Notice

Cladbe may update this Privacy Notice from time to time to reflect changes in the Service, applicable law, or our data handling practices. Where material changes are made — such as new categories of data collected, new sharing recipients, new purposes of processing, or material changes to your DPDP rights process — Cladbe will notify you through a prominent notice on Property.new and through your registered email and phone, and will seek your renewed consent where required under the DPDP Act.

The Effective Date and Last Reviewed date on the cover page indicate when this Privacy Notice was last updated. The Master Privacy Policy at cladbe.com/privacy is the authoritative document for the full Cladbe ecosystem; this Privacy Notice is a buyer-focused presentation of how the Master Privacy Policy applies to your use of Property.new.