Privacy Policy

User privacy is of paramount importance to Justo Realfintech Private Limited and group entities(“Justo”). Justo has developed this “Privacy Policy” which covers how Justo collects, uses, discloses, and stores User information. Users are advised to familiarise themselves with Justo’s privacy practices.

As a result of filling the Customer Information Form, User agrees to be bound by the terms and conditions of this Privacy Policy. Users are advised to refrain from filling the Customer Information Form if they do not agree with the terms and conditions of this Privacy Policy.

This Privacy Policy (as amended, modified, or restated from time to time) read with shall be applicable to the User and constitute a binding arrangement between Justo and the User. If Justo makes significant changes in the way the User’s information is treated, or to the Privacy Policy, Justo will provide notice through the Portal, or by some other means, such as email. User’s continued use of the Services after such notice constitutes User’s consent to the changes. Justo encourages the User to periodically review the Privacy Policy for latest information on Justo’s privacy practices.

For the purpose of this Privacy Policy, where the context so requires, the term:

  1. Applicable Law” shall include all laws, statutes, ordinances, regulations, guidelines, policies and other pronouncements by state, municipality, court, tribunal, government, ministry, department, commission, arbitrator or board or such other body which has the force of law in all or any applicable jurisdictions, including but not limited to the Information Technology Act, 2000 and the rules made thereunder including any statutory modification or re – enactment thereof, to the extent in force, and European Union’s General Data Protection Regulation (“EU GDPR”) wherever applicable. In addition, Users shall also be governed by the applicable laws of User’s country of residence.
  2. Content” shall include, without limitation, data, text, written posts, comments, software scripts, interactive features generated, graphics, images, photos, documents, audio, video, location data, nearby places and all other forms of information or data.
  3. Customer Information Form” means the on boarding form submitted by Users whether in physical form or on the App providing the Personal Information while availing the Services.
  4. Personal Information” shall have the meaning ascribed to it in Sub – Clause 1.3.1 of this Privacy Policy.
  5. Grievance Officer” shall have the meaning as ascribed to it in Clause 19.
  6. Person” shall mean and be deemed to include any individual, firm, company or other corporate body, government authority, joint venture, association, partnership, or other entity (whether or not having separate legal personality).
  7. Portal” shall refer to both the internet portal located at [insert hyperlink] (“Site”) and any computer program created by Justo which is designed to run on smartphones and tablets i.e., a mobile application available for the Android operating system located at Google Play Store and for iOS operating system located at App Store (“App”).
  8. Service Information” means the details of Services available on the Site in different variations for the knowledge of the User.
  9. “Services” means provision of branding, sales and marketing and other services as detailed herein inter alia including advertising properties on behalf of developers and sells units in the properties either directly or through other real estate brokers.

User” means any person who accepts this Privacy Policy

1. Acceptance and Registration
  1. This Privacy Policy will apply to the Customer who walks into any project site where he/she provides the Customer Information Form. User agrees that their Personal Information shall be handled in accordance with this Privacy Policy. Further, User also agrees to Justo’s terms for accessing and correcting information, including but not limited to Personal Information as described in this Privacy Policy.
  2. User’s use of the Portal and filling of Customer Information Form and any dispute over privacy, are governed by this Privacy Policy.
  3. This Privacy Policy (as amended, modified, or restated from time to time) read with Third Party Privacy Policies shall be applicable to the User and constitute a binding arrangement between Justo and the User.
  4. User acknowledges and agrees to the collection, retention, and use of the information that the User discloses in Customer Information Form in accordance with this Privacy Policy, including but not limited to User’s consent for sharing User information as per this Privacy Policy.
  5. This Privacy Policy shall be binding upon and enure to the benefit of the User.
  6. Unless stated otherwise, this Privacy Policy applies to all information that Justo has about the User and User’s disclosure in Customer Information Form.
2. Eligibility
The Portal is only for competent Persons. By using the Portal, the User represents that the User has reached the age of “majority” as per the Applicable Laws of the jurisdiction where the User resides or is not under the age of 18 (Eighteen) years. Persons who are “incompetent to contract” within the meaning of the Indian Contract, 1872 including undischarged insolvents and persons of unsound mind, are not eligible to use the Portal Justo reserves the right to refuse to provide such person with access to the Portal if it is brought to Justo’s notice or if it is discovered that such User is not eligible to use the Portal.
3. Collection and use of Personal Information
  1. Justo may collect and use, through Customer Information Form or such other means as used during the provision of Services or request of Service Information, information that can be used to identify or contact a Person (“Personal Information”), including where permitted by Applicable Law but not limited to Personal Information as enumerated below:
    1. Name
    2. Contact number
    3. Email address
    4. Physical address
    5. Date of birth
    6. Nationality
    7. Occupation and designation
    8. Name of employer
    9. Office address
    10. Annual income
    11. Details related to flat which include configuration desired, budget, expected possession date and purpose of buying.
  2. Information automatically collected: In compliance with Applicable Law in order for the User to access and use the App or visit the Site, information which may be collected by Justo (or third parties acting on its behalf) by automated means includes:
    1. User’s device details
    2. User’s browser type, version, and operating system
    3. Links the User clicks
    4. User’s Internet Protocol (IP) address
    5. The length of time the User visits the Site or uses the Service Information
    6. User’s activities on the Site or use of the Service Information (including User’s movement/ navigation through the Site)
    7. information provided by the User while using the Service Information on the Site or that which is generated in the course of use of the Service Information including timing, frequency, and pattern of use of Service Information such as page views and navigation patterns
    8. internet service provider (ISP)
    9. search terms used by User to reach the Site.
4. Sensitive Personal Information
  1. Sensitive Personal Information” refers to Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health. 
  2. Justo does not require / collect / process Sensitive Personal Information of the User and does not intend to collect, use or in any manner whatsoever, the Sensitive Personal Information of the User.
5. Manner of dealing with Personal Information
  1. Personal Information submitted to the Justo will be used, for the purposes specified in this Privacy Policy.
  2. Justo uses the Personal Information for the following purposes:
    1. improvement of Services;
    2. send email notifications requested by the User;
    3. may use User’s information, such as User’s email address, phone number, or mailing address to contact User with communications Justo thinks will be of interest to the User, including information about products, services, promotions, where permissible and according to Applicable Laws;
    4. provision of add-on and retail assets such as loans, insurance policies and ancillary products where permissible and according to Applicable Laws;
    5. provide third – parties with statistical information about Users (but those third parties will not be able to identify any individual user from that information);
    6. to understand and analyze trends, to administer the Portal, to gather demographic information about the User base as a whole and also towards administering, monitoring, and improving the Portal;
    7. marketing, market research and User profiling; and
    8. Justo may also use Personal Information for internal purposes such as auditing, data analysis, and research to improve the Services.
6. Confidentiality and Disclosure of User’s Personal Information
  1. Justo has adopted reasonable security practices and procedures comprising of managerial, technical, operational, and physical security control measures with a view to ensure confidentiality and prevent unauthorised disclosure of Personal Information.
  2. Justo uses the Personal Information for the purpose for which the same has been furnished.
  3. It may be necessary by Applicable Law, legal process, litigation, and/ or requests from public and government authorities for Justo to disclose User’s Personal Information or User’s “Non-Personal Information”. Justo may also disclose information about the User if it determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. For the purposes of this Privacy Policy, “Non-Personal Information” shall mean the information other than Personal Information.
  4. Justo may share Personal Information with its affiliates and authorised agents, representatives, and advisors to help detect and prevent identity theft, fraud, and other potentially illegal acts and to facilitate joint or co – branded services that the User requests where such services are provided by more than one corporate identity..
  5. In the event of a reorganization, merger, or sale, Justo may transfer any or all Personal Information to the relevant third party with intimation to User.
  6. Justo may share User information with third parties in order to conduct a basic verification of information provided by the User.
  7. Justo may also provide and/or disclose such information to any other trusted businesses or persons for the purpose of processing Personal Information on behalf of Justo.
  8. Justo may disclose the information it collects from Users where Justo believes it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which Justo is involved or protect its operations or Users or in the event Justo has sufficient reason to believe that such Person may by way of application to a court or any other competent governmental authority apply for disclosure of the User’s information and such court or governmental authority, in Justo’s reasonable opinion, is likely to order the disclosure of such User’s information.
  9. Justo may disclose Personal Information if required to do so by law or in good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal or quasi – legal processes. Justo may disclose Personal Information to law enforcement offices, third – party rights’ owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce Justo’s policies; respond to claims that an advertising, posting, or content violates the rights of a third party; or protect rights, property or personal safety of the Users or the general public.
  10. In addition, the Justo may, as permitted or required by Applicable Law and obligations, process Personal Information such as in the circumstances described above; when the privacy interests of others would be jeopardized; or where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy.
7. Protection of Personal Information
  1. Justo has taken adequate measures to protect the security of User’s Personal Information and to ensure that User’s choices for its intended use are honoured. Justo takes precautions and has implemented reasonable physical, technical, and administrative security standards to protect the Personal Information of the User from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
  2. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, Justo has put in place physical, electronic, and managerial procedures to safeguard and secure the information Justo collects through the Portal and the provision of Services and Service Information.
  3. User’s Personal Information is never shared outside Justo without User permission, except under conditions explained under this Privacy Policy.  Personal Information is stored in password-controlled servers with limited access to the members and other personnel or consultants on a need-to-know basis. 
  4. Justo and its agents are contractually bound to maintain the confidentiality of Personal Information and may not use the information for any unauthorized purpose.
  5. The User acknowledges that despite deployment of secure measures for protection of the User’s information on the Customer Information Form, exchange and transmission of information comes with inherent security risks and Justo makes no guarantee with regard to the safety of such transmission of User information.
8. Access and updation of Personal Information

Justo provides Users with the means to ensure that their Personal Information is correct and current. Users may review and update this information and other details related to their profile at any time by contacting Justo.

9. Retention of Personal Information provided by the User

Justo shall retain information about User for the purposes authorised under this Privacy Policy unless prohibited by Applicable Laws.

10. Opt – Out

While collecting any Personal Information, Justo indicates the purpose of collection of such information and obtains consent from the User. Justo provides to the Users the opportunity to exercise an opt – out whenever they wish to by contacting Justo.

11. Limitation of Liability
  1. Justo is not responsible for any breach of security or for any actions of any third parties that receive the User’s Personal Information.
  2. Notwithstanding anything contained in this Privacy Policy or elsewhere, Justo shall not be held responsible for any loss, damage, or misuse of the User’s Personal Information, if such loss, damage, or misuse is attributable to a Force Majeure Event. For the purposes of this Privacy Policy, a “Force Majeure Event” shall mean any event that is beyond the reasonable control of Justo and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, epidemic, pandemic, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of Justo and which Justo is not able to overcome.
12. Deletion / Erasure
In the event that the User, as a data subject, wishes to erase Personal Information concerning the User, Justo will fulfil this request should one of the following grounds apply:
  1. The Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, e.g., the provision of the Services;
  2. Where processing is based solely upon User’s required consent, and User withdraws the consent on which the processing is based;
  3. Where the User objects to the processing, and where there are no overriding legitimate grounds for the processing;
  4. Where the User can demonstrate that the Personal Information has been unlawfully processed;
  5. Where the User provides notice that the Personal Information must be erased for compliance with a legal obligation as contained in a stated Union or Member State law to which the controller is subject; or
  6. Where Justo is unable to demonstrate proper reliance on an exception under Regulation 17(3) of the GDPR.
13. Right to be Forgotten
In the event that Justo has disclosed the User’s Personal Information and where the User has made a valid request to restrict or prevent the continuing disclosure of the User’s Personal Information, Justo will, taking into account the available technology and the cost of implementation, take reasonable steps, including technical measures, to inform any controllers which are processing that Personal Information, or the User’s request for erasure. This option of restricting or preventing the continuing disclosure of the Personal Information by Justo may be exercised by the User by contacting Justo.
14. Grievance Officer
  1. In accordance with Information Technology Act, 2000 and rules made thereunder the contact details and designation of the Grievance Officer are provided below:
    • Designation : Data Grievance Officer
    • Email: grievances : datagreivianceofficer@justo.co.in
    • Contact Number : 7045143573
    • Timings : 10 a.m. to 6 p.m. on all working days.
  2. In the event of any complaint or any issue raised by the User, the same shall be acknowledged and redressed by the Grievance Officer within the timelines specified under Applicable Laws.
  3. All words and expressions used herein and not defined, but defined in the Information Technology Act, 2000 and/or the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 shall have the meanings respectively assigned to them thereunder.