Privacy policy v 1.02

Last updated: March 03, 2023

BY ACCESSING OR USING THE PLATFORM OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU CONFIRM THAT YOU HAVE THE CAPACITY TO ENTER INTO A LEGALLY BINDING CONTRACT UNDER INDIAN LAW, IN PARTICULAR, THE INDIAN CONTRACT ACT, 1872 ANDYOU 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 EXPRESSLY CONSENT TO OUR COLLECTION, USE, SHARING, PROCESSING AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THI\S PRIVACY POLICY.

THIS PRIVACY POLICY IS INCORPORATED INTO, AND SUBJECT TO, THE TERMS OF USE. CAPITALISED TERMS USED IN THIS PRIVACY POLICY BUT NOT SPECIFICALLY DEFINED HEREIN SHALL HAVE THE MEANINGS ASCRIBED TO SUCH TERMS IN THE TERMS OF USE.

The “Platform” shall mean this internet-based ecommerce services platform and/or an application, website and/or web-page (including but not limited to any web app, marketing landing page(s), and/or iOS/Android app or any other app that the buyer may be using to access/communicate with MMM One) (“Platform”), owned and/or operated, directly or indirectly, by MMM One Platforms Limited (referred collectively as “We”/ “Us”/ “Our”), that enables individual home builders, customers and service providers to interact, engage and independently contract for construction of residential properties and to continually monitor progress of construction (“Services”).

This Privacy Policy governs the usage of information and the ways in which all the users and visitors of the Platform (referred collectively as “You”, “Your” or “User”) can protect their privacy. This Privacy Policy is published in pursuant to inter-alia:

Section 43A of the Information Technology Act, 2000;

Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2021; and

Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDIRules”).

1. General

1.1. A condition of each User’s use of and access to the Platform, is his/her/its acceptance of the terms of use (“Terms of Use”), which also involves acceptance of the terms of this Privacy Policy. Any User who does not agree with any provisions of the Terms of Use or this Privacy Policy is advised not to accept the Terms of Use and not use the Platform.

Our Privacy Policy explains: (a) what information We receive from You; (b) how We collect and use that information; (c) how You can provide information selectively, access and update the information; and (d) how We process, share and protect Your information.

1.2. The User’s visit to and/or use of the Platform and any dispute over privacy is subject to this Privacy Policy and the Terms of Use. We may update this Privacy Policy at any time, with or without advance notice. We shall not be required to notify the Users of any changes made to this Privacy Policy. It is Your responsibility, in such cases, to review the terms of this Privacy Policy from time to time.

In the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your Information including Personal Information to the fullest extent permitted under such applicable law. We may reach out to You for obtaining additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue your access to the Platform.

1.3. If You use the Platform on behalf of someone else (such as Your company, partnership or trust), You represent that You are authorised by such entity to accept this Privacy Policy on such entity’s behalf, and consent on behalf of such entity to Our collection, use, sharing, processing and disclosure of such entity’s information as described in this Privacy Policy.

All the Information and User Information provided to Us by a User is voluntary. The User has the right to request the withdrawal of his/her/its consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use. It is the User’s duty to ensure strict caution while giving out any Information about himself/herself/itself or his/her family members in use of any of the Services. We do not endorse the content, messages or information found in any Services and therefore, We specifically disclaim any liability with regard to the Services and any actions resulting from the User’s participation in any Services. As a condition to use the Services, You as a User agree to waive any claims against Us relating to the same, and to the extent such waiver may be ineffective, You agree to release any claims against Us relating to the same.

1.4. Collection, use and disclosure of Personal Information and SPDI requires Your express consent. You are providing Us with Your consent to Our use, collection and disclosure of the Personal Information and SPDI. You may choose to not provide Us with Personal Information and SPDI, but in the event that You do so, We will be unable to provide You access to Our Platform or Services.

2. Information Collected and Means of Collection

2.1. We collect the following types of information about You when You use the Platform: User and Account Information, Demographic Information, Homebuyer Preferences, Financial Information, Behavioural Information, Indirect Information, Personal Information and SPDI (collectively, “Information”).

User and Account Information: In order to use the Platform, You are required to provide Us with Your details including but not limited to Your name, address, financial details such as bank account information or credit card or debit card or other payment instrument details, third party sign-in information shared on the other website (such as Facebook, Google, Twitter or Pinterest), contact number and email address, relevant identity documents and email communication by/with Us such as enquiry, order and transaction related information, disputes or complaints.

2.2. Demographic Information: We may collect from You, information that is not unique to You, in the sense that it refers to selected population characteristics, such as Your postal code, physical location, location of the land parcel where you require construction related services, IP location, URL and occupation.

Financial Information: For the use of the Services, You may be required to pay with a credit card, electronic-transfer, debit card or other applicable modes of payments through a third-party payment gateway provider. For availing of financing options on the platform You may be able to apply to potential financiers on the Platform. Such third party payment gateway providers and financiers may be required to collect certain financial information from You including, but not restricted to, Your credit / debit card number or Your bank account details, bank statements, annual reports, GST data. All Financial Information collected from the Users by Our third-party payment gateway providers and financiers will be used for billing and payment processes and evaluate and provide financing options. The verification of the Financial Information shall be accomplished only by the User through a process of authentication in which We shall have no role.

2.3. Homebuyer preferences: We will also collect details about services facilitated on the Platform including but not limited to Your design preferences for the project, expectations of the budget for the project, details of Your family members, government documentation and approvals in relation to the site of the project, etc.

Behavioural Information: We also collect information regarding how You use the Platform. This includes the areas of the Platform that You visit, and information about Your computer hardware and software including Your IP address, browser and operating system type, IMEI number and MAC address of the computer/device from where the Platform was accessed, domain names, access times, locations which may also include global positioning system coordinates or similar information regarding the location of the device using which the User has visited or used the Platform, Your previous orders and transactions including transaction information and payment and browsing history.

2.4. Indirect Information: Your use of certain third-party services on the Platform, such as interaction with franchisees or contractors or banking partners you deal with on the Platform, may require Us to collect such information as is considered necessary for facilitating the Services.

User Information: We also collect your details including but not limited to information regarding your transactions you undertake through the Platform (including purchase history). We also collect details including Your information such as passwords, financial information such as bank account information or credit card or debit card or other payment instrument details, any other items of “sensitive personal data or information” as such term is defined under the SPDI Rules; identification code of your communication device which You use to access the Platform or otherwise deal with any JSW One entity, any other Information that You provide during Your registration process, if any, on the Platform and any other information that You voluntarily choose to provide to us.

2.5. Personal Information: We also collect information that relates to You, which, either directly or indirectly, in combination with other information available or likely to be available to Us, is capable of identifying You. Should any of the information defined above be classified as Personal Information, You hereby agree that We may collect, use, share, process and/or disclose the Personal Information for the purposes as set out in this Privacy Policy.

The SPDI Rules further define “Sensitive Personal Data or Information” or “SPDI” of a person as Personal Information about that person relating to:

(a) Passwords;

Financial information such as bank accounts, credit and debit card details or other payment instrument details;

(b) Physical, physiological and mental health condition;

Sexual orientation;

Biometric information; and

(d) Information received by body corporates under lawful contract or otherwise.

It may be noted that any information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be regarded as sensitive personal data or information, or as personally identifiable information.

2.6. We may keep records of telephone calls received from and made to Users for the purpose of administration of Services, research and development, training, business intelligence, business development, or for User administration. We may share the telephone records with third parties when required by law or when required to provide or facilitate the User with the Services.

We may choose to conduct contests and surveys to collect relevant information about the Users’ preferences. These surveys and contests are optional and if the User chooses to respond, his/her/its responses will be kept anonymous. The demographic information that the User provides while availing or signing-up for the Services and through any surveys or contests is used to help Us improve Our services to meet the needs and preferences of Users.

3. Use of information

3.1. We may use Your Information for the following purposes:

(a) To facilitate Your use of the Platform or other Services;

To respond to Your inquiries or fulfil Your requests for information about the various Services offered on the Platform, including resolution of any dispute;

(b) To send You important information regarding the Platform, changes in Terms of Use, Agreements and policies and/or other administrative information;

To send You surveys and marketing communications, promotional offers that We believe may be of interest to You or tailored to Your preferences;

(c) To meet legal and regulatory requirements;

To aid Us in collecting and/or paying monies from / to Users for transactions carried out on the Platform;

(d) To facilitate financing;

To analyse data, track trends, build algorithms, create databases for rating systems, recommendations engines, etc.;

(e) For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research or service enhancement purposes;

To protect the integrity of the Platform, resolve technical issues and troubleshoot problems including to undertake forensics of the concerned computer resource as a part of investigation or internal audit;

(f) To detect and protect Us from error, fraud and other criminal activities;

To implement information security practices and determine any security breaches, computer contaminant or computer virus;

(g) To trace computer resources or any person who may have contravened, or is suspected of having or being likely to contravene, any provision of law including the Information Technology Act, 2000 that is likely to have an adverse impact on the services provided on any Platform or by Us;

To enforce the Terms of Use;

(h) To contact You, by way of SMS, email and phone calls, from time to time to record Your valuable feedback on Our Services, as they currently stand, and/or any potential Services that may be offered in the future; or

Other reasons which, prior to being put into effect, shall be communicated to the Users through an update carried out to this Privacy Policy.

(collectively, the “Purposes”).

3.2. The User consents to Us reproducing / publishing all testimonials and reviews given by the User (whether on the Platform social media platforms, or in any other manner whatsoever) in relation to Us, together with the User’s name and location, on the Platform, on such page and in such position as We may determine in Our sole discretion. The User agrees that We may edit the testimonials and reviews provided by the User and reproduce / publish such edited or paraphrased versions of the testimonials and reviews on the Platform. If the User has any concerns with the reproduction / publication of any testimonial or review provided by the User on the Platform, the User may contact Us at mmmconco.com

Additionally, We use Demographic Information, Behavioural and Indirect Information of the Users collectively, such as what areas Users visit most frequently and what Services Users access the most. Such data is used anonymously and in the aggregate. This information helps Us determine what is most beneficial for the Users.

3.3. The Financial Information collected from the Users is transacted through secure digital platforms of approved payment gateways/financiers which are under encryption, thereby complying with reasonably expected technology standards. While We shall make reasonable endeavours to ensure that the Users’ Personal Information and Financial Information is duly protected by undertaking security measures prescribed under applicable laws, the User is strongly advised to exercise discretion while providing Personal Information or Financial Information while using the Services given that the Internet is susceptible to security breaches.

4. Disclosure of the information

4.1. We disclose Your Information to third parties in the manner specified below, including, but not limited to:

(a) disclosing Your Information to contractors /service providers listed on the Platform and related service providers and logistics partners, for the purposes of servicing and delivering and providing credit period with respect to the orders placed by You on the Platform;

disclosing Your Information to potential financier for availing financing for Your purchases on the Platform;

(b) disclosing Your Information to companies, agencies, individuals and other third parties who are authorised by Us to perform functions on our behalf. We may transfer Information or User Information to a third party (in India or outside India) such as sellers, affiliates, agents, contractors, third party service provides that process or will process Your information or User Information on Our behalf including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres, to improve the Platform;

We may share Your Information with Our partners, affiliates and service providers on the Platform (both for commercial and non-commercial purposes), so that they too may understand the activities of Users and visitors on the Platform and related information, and can contribute in creation of a better overall experience for Users and visitors. We may also share Your information with the partners and affiliates, other Platform visitors, and other third parties so that they can understand the kinds of visitors and how they use the Platform in order to serve advertisements and other kinds of marketing information to You on the Platform;

(c) We may disclose and transfer Your Information or User Information to a third party who acquires the business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of the assets;

We may be required to disclose Your Information or User Information, without Your consent, to governmental institutions or authorities when such disclosure is requisitioned under any law or judicial decree or when We, in Our sole discretion, deem it necessary in order to protect Our rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

4.2. We or Our Affiliates, parent company, group companies, subsidiaries, associates, affiliates, suppliers, vendors, sister concerns, service providers and service partners and other third parties (collectively referred to as “Other Parties”) may merge with or be acquired by another business entity. In such an event, We and the Other Parties may be required to transfer the Personal Information to such merging or acquiring party, as the case may be. While sharing such Personal Information with the acquiring or merging entity, as the case may be, We and the Other Parties shall make reasonable endeavours to ensure that the Users’ Personal Information is duly protected by the acquiring or merging entity, as the case may be, by undertaking security measures prescribed under applicable laws.

Subject to applicable law, We may, at Our sole discretion, transfer Information to any other body corporate (as defined under the Information Technology Act, 2000) that ensures at least the same level of data protection as is provided by Us under the terms hereof, whether located in India or any other country. By using the Platform, You accept the terms hereof and You hereby consent to the storage and processing of information in any of the above locations. We will endeavour to require that the third party or the location to which the SPDI is transferred accords same level of data protection as would be afforded under Indian law.

5. Changes to Your Information

5.1. You may review, correct, update, change or delete Your Account Information or User Information on the Platform. You can delete any part of the Account Information or User Information or request us to delete Your Account Information or User Information, which We would do, unless We must keep certain information for legal purposes.

Should You choose to delete Your Information or modify it in a way that is not verifiable by Us, or leads to such Information being incorrect, We will be unable to provide You with access to Our Platform, as described under the Terms of Use, and such a deletion or modification may be regarded as the User seeking to discontinue his, her or their access to Our Platform.

5.2. We reserve the right to verify and authenticate Your identity and Your User and Account Information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of Your Account Information may be denied or limited by Us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

6. Security of Your Information

6.1. We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect Your Information and User Information against loss, misuse, copying, damage or modification and unauthorised access or disclosure. Some of the security measures adopted by Us are:

(a) We review Our information collection, usage, storage, processing and disclosure practices, including physical security measures, to guard against unauthorised access to systems; and

We restrict access to Your Information to Our employees, agents and partners who need to know that information in order to process it for Us, and who are subject to strict contractual confidentiality obligations, and may be disciplined or whose relationship with Us may terminate if they fail to meet these obligations.

6.2. We have implemented security policies, rules and technical measures, as required under applicable law including firewalls, transport layer security and other physical and electronic security measures to protect the Financial Information and Personal Information that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. It is expressly stated that We shall not be responsible for any breach of security or for any action of any third parties that receive Users’ personal data or events that are beyond Our reasonable control, including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

All Our employees and data processors, who have access to and are associated with the processing of Personal Information or Financial Information provided by Users are obliged to respect the confidentiality of every User’s Personal Information or Financial Information.

6.3. All information collected from the Users by Us is maintained in electronic form on servers and/or cloud systems and shall be accessible by Our certain employees. The User information may also be converted to physical form from time to time. Regardless of the manner of storage, We shall make commercially reasonable endeavours to ensure that the User information is rendered confidential, and will disclose User information only in accordance with the terms of this Privacy Policy.

If You suspect any unauthorised use of Your account, You must immediately notify Us by sending an email to the contact details indicated in the contact section. You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorised use of Your account or password.

7. Retention of Information

7.1. We have measures in place such that Your Information and User Information which is in Our possession or under Our control, is destroyed and/or anonymised as soon as it is reasonable to assume that: (i) the Purposes for which Your User Information has been collected have been fulfilled; and (ii) retention is no longer necessary for any other reason.

Notwithstanding the above, we reserve the right to retain Your Information for such period as is permitted under applicable law.

8. External links on the Platform

8.1. We may allow other companies or entities to serve advertisements, research and news to Users and on the Platform. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research and news firms. We may target some advertisements to Users that fit a certain general profile. We do not use personally identifiable information to target advertisements to specific Users. In the course of serving advertisements or optimising the Services to its Users, We may allow authorised third parties to place or recognise a unique cookie on the User’s browser.

We do not exercise control over the third-party websites displayed as links from within the Platform. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit Personal Information or Financial Information from the Users, for which We shall not be held responsible or liable. We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do We guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Us of such websites, the websites’ provider, or the

information on the website.

9. Opt-Out Policy

9.1. You agree and consent to receive all communications, including but not limited to text messaging services or over-the-top communication services (including inter alia WhatsApp, Facebook Messenger, Telegram, Google, Signal, JioChat), at the mobile number provided by You, or any such number which may be provided to Us from time to time, even if such mobile number is registered under DND/NCPR list under the Telecom Regulatory Authority of India (TRAI) regulations. Notwithstanding Your registration with the National Do Not Call Registry (in the fully or partly blocked category under National Customer Preference Register set up by TRAI), You hereby express Your interest and accord informed consent to receive communications (including commercial communications) in relation to Our services. You further confirm that no communication to You from Us or on behalf of Us shall be construed as “unsolicited commercial communication” under Regulation 2(bw) of the Telecom Commercial Communications Customer Preference Regulations, 2018 and You have specifically opted to receive communications in this regard on the mobile number provided by You or any such number which may be provided to Us from time to time. And for that purpose, You further authorise Us to share/disclose the information to any third party service provider or any of Our affiliates, group companies, authorised agents or third party service providers.

All Users may opt-out of receiving non-essential, promotional, or marketing-related communication from Us. These settings can be found on the Platform. You can alternately address the said opt-out requests to the Grievance Officer. If a User wishes to remove his/her/its contact information from Our call/email lists and newsletters, the User can contact the Grievance Officer in this regard. We however reserve the right to limit accessibility to the Platform and related services provided by it based on availability of information from the Users.

10. Cookies and Other Tracking Technologies

10.1. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Platform. The Platform uses temporary cookies to store certain data. We do not store personally identifiable information in the cookies. Information collected by Us, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilisation described above) is exclusively owned by Us and may be used by Us and third-party service providers for technical administration of the Platform, user administration, research, development, and other purposes. Additionally, We may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to Other Parties.

Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, stream patterns, and dates and times that Our Platform are accessed. Our use of tracking technologies allows Us to improve Our Platform and Your experience.

10.2. A User may set or amend his/her/its web browsers to delete or disable cookies. If a User chooses to disable cookies on his/her/its computer, mobile telecommunication device, or any such device being used to access the Platform, it may impair, degrade or restrict access to certain areas of the Platform. Merely closing the web browser should ordinarily clear all temporary cookies installed by Us. However, Users are encouraged to use the “clear cookies” functionality of their browsers to ensure deletion, as We cannot guarantee, predict or provide for the behaviour of the equipment of all the Users of the Platform.

11. Grievance Officer and Contact information

Users can access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his/her/its decision to become a User. If you believe that your rights are being infringed or you have any grievances, complaints or concerns, including in relation to the information shared by the User with MMM One on the Platform, you may reach out to our grievance officer through telephonic or electronic mode in the following manner:

Name: Sherien Kaul

Address: 6th Floor, Grande Palladium, CST Road, Kalina, Mumbai 400098.

Email: mmmconco.com

Phone Number: +91 22 68542400

We respond expeditiously to rights owners and their agents who communicate their concerns about any alleged infringement in the manner provided under this Privacy Policy.

12. Applicable Law and Dispute Resolution

The Privacy Policy and applicable additional terms/policies shall be governed by and interpreted and construed in accordance with the laws of India. Any disputes pertaining to the Privacy Policy shall be subject to the dispute resolution provisions provided for under the Terms of Use.

13. Miscellaneous

13.1. Disclaimer: We cannot ensure that all of Your Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting Your privacy, We do not promise, and You should not expect, that Your Information or private communications will always remain private. As a User of the Platform, You understand and agree that you assume all responsibility and risk for Your use of the Platform, the internet generally, and the information You post or access and for Your conduct on and off the Platform.

Indemnity: You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through our Platform or otherwise and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information which You may have disclosed to such third parties.

13.2. Severability: Each clause of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other clauses herein except where otherwise expressly indicated or indicated by the context of the Privacy Policy. The decision or declaration that one or more clauses are null and void shall have no effect on remaining clauses of this Privacy Policy.

Interpretation: This Privacy Policy does not create or confer upon any individual any rights, or impose upon Us any obligations outside of, or in addition to, any obligations imposed by the applicable Indian information security laws.If and to the extent that this Privacy Policy is not in accordance with the applicable law, the provisions of applicable law shall be deemed to prevail.