This document is a draft pending legal review and may change before it is finalised.
Your trust matters to us. This policy explains, in plain language, what personal data we collect, why, and the choices you have.
1. Who this policy covers
This policy explains how Veneraa (“Veneraa”, “we”, “us”) handles personal data about visitors, registered users, investors, partners and anyone who contacts us through veneraa.in (the “Platform”).
We act as the data fiduciary for this data under the Digital Personal Data Protection Act, 2023 (“DPDP Act”), and we follow the Information Technology Act, 2000 and the rules made under it. This policy forms part of our Terms of Use.
2. What we collect
- Contact details: name, email, phone number, city and company, when you enquire, register or book a meeting.
- Identity and KYC data: PAN, Aadhaar (masked or offline verification only), photograph, signature, address proof, and video-KYC recordings, as required to verify you before you invest.
- Financial data: bank account details, payment references, and records of your holdings, distributions and resale listings. We do not store card numbers or UPI PINs.
- Partner data: details of projects, land or inventory that developers, landowners and advisors share with us.
- Technical data: IP address, device and browser type, pages viewed and similar usage information, collected automatically when you use the Platform.
3. How we collect it
- Directly from you, through forms, account registration, KYC, emails, calls and meetings.
- From KYC and verification providers, banks, escrow agents and public registries, when we verify you or complete a transaction.
- From channel partners or advisors who introduce you to us with your knowledge.
- Automatically, through cookies and similar technologies (see section 6).
4. How we use it
We use personal data only for clear purposes:
- to respond to enquiries, arrange meetings and provide the services you ask for;
- to verify your identity and meet our obligations under anti-money-laundering, tax and company law;
- to process investments, maintain SPV shareholder records, issue co-ownership certificates and pay distributions;
- to run the resale board and our transaction and leasing services;
- to send service messages such as confirmations, statements and important notices;
- to send marketing updates, only where you have agreed, with an easy way to opt out; and
- to keep the Platform secure, prevent fraud and improve how it works.
We process data on the basis of your consent, or where the DPDP Act permits processing without consent, for example to meet a legal obligation or for a purpose you have voluntarily provided the data for.
7. Storage and security
We use reasonable security practices, including encryption in transit, access controls and limited staff access, to protect personal data against loss and misuse. No system is completely secure, so we cannot guarantee absolute security.
Some of our service providers may store or process data outside India. Where they do, we transfer data only to countries not restricted by the Government of India under the DPDP Act, and under safeguards that keep it protected.
If a personal data breach occurs, we will notify affected users and the Data Protection Board of India as the law requires.
8. How long we keep it
- KYC and transaction records: for as long as you hold an investment, and at least five years after, as required by anti-money-laundering law.
- SPV shareholder records: for as long as company law requires.
- Enquiries from people who do not go on to invest: up to 24 months after our last contact, unless you ask us to delete them sooner.
9. Your rights
Under the DPDP Act you can:
- ask for a summary of the personal data we hold about you and how we use it;
- ask us to correct, complete or update it;
- ask us to erase it, unless we must keep it by law;
- withdraw consent at any time, without affecting processing already carried out;
- nominate someone to exercise these rights if you die or become incapacitated; and
- raise a grievance with us, and then with the Data Protection Board of India if you are not satisfied.
To use any of these rights, contact us through the contact details listed in the footer of this website. We may need to verify your identity first.
10. Children
The Platform is meant for adults. We do not knowingly collect personal data from anyone under 18.
11. Your part
Keep your login details private and sign out on shared devices. If you share someone else's details with us, for example as a nominee or joint holder, make sure they know and agree.
12. Changes to this policy
We may update this policy as our services or the law change. The “Last updated” date shows when it last changed, and we will tell you about material changes on the Platform or by email.
13. Contact and grievance officer
For questions or complaints about your personal data, contact our Grievance Officer through the contact details listed in the footer of this website. We will acknowledge your request within 24 hours and aim to resolve it within 15 days.