FLENT.IN PRIVACY POLICY

1.1. This privacy policy (this “Privacy Policy”) of the Platform applies to all users and others who access or use the Platform and submit any data (hereinafter referred to as either “You” or “Your”). The Privacy Policy governs the privacy practices regarding the collection, use, disclosure, transfer, retention and safeguard of Your Personal Data by the Platform. It covers Personal Data You give Us on the website, over WhatsApp, email or phone, and when You book, move into and live in a home managed by Us.

1.2. Your clicking of the “I accept” button and submission of Personal Data or if you are a minor, the submission of your Personal Data either by your parents (or your guardian) or by you with the permission of your parents (or guardian) to the Platform will be deemed as your acceptance of this Privacy Policy. Section 14 below explains how We handle the Personal Data of children.

1.3. All capitalized terms that have not been expressly defined herein shall have the meaning ascribed to them under the Terms of Use. This Privacy Policy should be read in conjunction and together with the Terms of Use published on the Platform. For the purposes of this Privacy Policy, ‘Personal Data’ or ‘Data’ shall have the meaning ascribed to it under applicable laws in India, including without limitation The Digital Personal Data Protection Act 2023 (“DPDP Act”) and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“SPDI Rules”), and shall be deemed to include Your Personal Data and Data as well as that of any minor under Your care to whom You have provided access to the Platform.

1.4. This Privacy Policy and Terms of Use are an electronic record in terms of the IT Act 2000 and rules thereunder, and are published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and Rule 4(1) of the SPDI Rules, which mandates for publishing of rules and regulations, privacy policy and terms of use for access or usage of Our Platform. This electronic record is generated by a computer system and does not require any physical or digital signatures.

2.1. You expressly understand, agree and acknowledge that Our collection, disclosure, transfer, storage and processing of Your Personal Data or Data is for a lawful purpose connected with a function or activity of the Platform. You further understand, agree and acknowledge that Your Personal Data or Data is considered necessary for Us to provide various services on the Platform to You and for Your usage of the Platform and other services provided by Us.

2.2. You hereby consent to the collection, storage, use, disclosure, transfer and processing of the Personal Data or Data by Us for the purposes set out herein. By accessing the Platform or by availing the services offered by Us on the Platform, You have deemed to have given consent to collect, store, use, disclose, transfer and process Your Personal Data or Data in accordance with this Privacy Policy. You hereby agree to be bound by Platform and the services provided by Us. You are providing Your Personal Data or Data out of Your free will.

2.3. Some things We only do with a separate, specific consent that You give at the time, and not merely by using the Platform. These are: fetching Your Aadhaar and PAN details through DigiLocker, sharing Your contact details with Your flatmates and the owner of the home, and showing Your profile to prospective flatmates. Section 7 explains each of these. You can withdraw any consent at any time as described in Section 12.

2.4. Information is shared voluntarily. All Personal Data We hold is provided to Us voluntarily, whether by You as a tenant, prospective tenant or lead, or by other parties acting on their own or Your behalf, such as co-tenants, flatmates, referrers, owners, guardians or representatives. No one is obliged to share information with Us; however, if the information needed to verify You or prepare Your agreements is not provided, We may be unable to offer, continue or complete Our services. Whoever provides information to Us is responsible for its accuracy and for having the right to share it, and where You share details of another person (for example a referrer, co-tenant or emergency contact), You confirm that the person has agreed to it. We rely on the information as it is provided to Us.

5.1. We may disclose, share, transfer or part with Your Personal Data to Our consultants, agents, third party service providers, partners, other agencies, investors which may be in other countries and jurisdictions across the world (“Third Parties”). You authorize Us to disclose, share, transfer or part with such Personal Data or Data with such entities. We may disclose, share and/or transfer such Data to Third Parties for the purposes stated in Section 6 below including to provide You with access to the Platform or activity conducted by Us, to provide services and features that You may need on Our Platform, to comply with Our legal obligations, to enforce Our Terms of Use, to facilitate Our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities.

5.2. You hereby provide Your express consent to Us for sharing Your Personal Data with the aforesaid Third Parties for Our legitimate business activities and for the purposes stated in Section 6 below. We may disclose Personal Data to Our affiliates when necessary to perform services on Our behalf or on Your behalf, to provide display advertising and promotional services, providing search results and links (including paid listings and links).

5.3. We shall endeavour that the Third Parties to whom We may provide access to Your Personal Data or Data for the purposes set out herein are under a contractual obligation to protect Your Personal Data or Data in accordance with the same standard that We have agreed to be subjected to under this Privacy Policy.

5.4. In the event of any requirement by court order, government or quasi-government agency to disclose Your Personal Data, We will disclose Data as may be legally required. We may also disclose Your Personal Data if We, in good faith, believe that such disclosure is reasonably necessary to respond to court orders, or other legal process.

5.5. In the event the Platform is merged with, or acquired by, another company or its business or the Platform is transferred/sold to another company, or in case of re-organization or re-structuring of Our business, We and Our affiliates may disclose or transfer Your Personal Data, wholly or in part, to another business entity, and You consent to such disclosure or transfer.

5.6. Service providers who process Data for Us. We use the following kinds of service providers. They process Your Personal Data only to provide their service to Us, and only as much of it as that service needs:

• Cloud hosting and databases: Supabase and Vercel.
• Identity verification: Cashfree Secure ID, which connects to DigiLocker when You choose to verify through DigiLocker.
• Payments (token, security deposit and rent): Cashfree Payments.
• Customer records: Our own customer relationship management (CRM) system, which We host on Google Cloud.
• Documents, email and spreadsheets used by Our team: Google Workspace.
• Messages to You: WhatsApp messages through Superchat and Periskope, and email through Resend.
• Internal communication between Our team members: Slack.
• Error monitoring, so We can find and fix faults in Our systems: Sentry.
• Product analytics: PostHog.
• Electronic signature of Your rental agreements: Zoho Sign.
• Website content management: Webflow.
• AI assistance: AI models, accessed through OpenRouter, that help Our team write internal summaries (for example, a handover note for the colleague preparing Your move-in).

5.7. Other recipients. Depending on the services You use, We also share Personal Data with:

• the owner of the home You rent, and the flatmates You will live with, as described in Section 7.6;
• the outside agency that runs Your background verification, as described in Section 7.4;
• the teams, including service partners, that run and maintain the home You live in; and
• courts, the police, regulators and other authorities, where the law requires it, as described in Section 5.4.

5.8. Processing outside India. Some of Our service providers, for example Sentry, PostHog, Slack, Resend, OpenRouter, Webflow and Zoho, may store or process Personal Data outside India. Any such transfer is made in line with Section 16 of the DPDP Act, and We will not transfer Your Personal Data to any country or territory that the Government of India has restricted.

6.1. We collect the Data directly provided by You (which may include Personal Data) through Your access or usage of the Platform and log data, data collected through cookies and other similar technologies. You agree that We may collect such Personal Data, whenever relevant, including when You access or use Our Platform, use Our services, interact with Us or at the time of Your registration on the Platform.

6.2. We collect Personal Data or Data (a) in order to provide You with a safe, efficient and customized experience while You access or use Platform or avail services offered by Us; (b) to validate and help You to complete any transaction or provide any product/services You have requested or authorized; (c) to provide services, features and products You have requested or to meet Your requirements; (d) to measure Your interest in our services and to inform You about Our offers, products, services, updates or customize Your experience; (e) to detect and protect Us against error, fraud and other criminal activity, enforce our terms and conditions; (f) to promote and market Our products, services and features; and (g) to perform activities such as data analytics to improve Our products and services.

6.3. When You book and live in a home managed by Us, We use Your Personal Data to:

• verify Your identity;
• prepare Your rental agreements, namely the tripartite agreement and the service agreement, and have them signed;
• process Your token, security deposit and rent payments, and settle Your deposit when You move out;
• match You with flatmates;
• run the home You live in, including move-in, maintenance and move-out;
• support You when You contact Us;
• prevent fraud; and
• meet Our legal, tax and regulatory obligations.

6.4. We use Your Personal Data for marketing only as described in clauses 6.2(d) and 6.2(f) above, and You can ask Us to stop at any time as described in Section 12.3.

6.5.1. Personal Data may include details such as Your name, age, gender, contact data, and Your Aadhaar and PAN details. Section 7 explains how We collect and protect identity details. Insofar as sensitive personal data or information is concerned, it will carry the meaning as defined in the SPDI Rules, as amended from time to time.

6.5.2. We may collect Personal Data such as Your name, mobile number, and email, when You use the Platform at the time of Your registration. We may also collect Data such as zip code, age, gender, occupation etc. We will not be liable for any actions, claims, costs, expenses or other liabilities in this respect.

6.5.3. The Platform may include links to other websites/applications from third parties and other content that links to third party websites/applications. Such websites/ applications are governed by their respective privacy policies and terms of use, which are out of the Platform’s control. The collection and use of any Data You provide while using a third party website or Platform through the Platform is governed by the privacy policy of the operator of such website / application You are using or visiting. If You can't find the privacy policy of any of such websites/application via a link on the website’s homepage, You should contact the relevant website / application operator directly for more data in that respect. We are not responsible for third-party websites/application content or their privacy practices, and will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence.

6.5.4. Except as provided herein, We do not solicit any Personal Data about You. The authenticity of the Personal Data or Data provided by You shall not be Our responsibility, and We will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence. Also, if You share any Data with us voluntarily, We will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence of such any unauthorized use or misuse of such Data.

7.1. What We collect to verify You. Before You move into a home, We verify Your identity. For this We ask You to share, voluntarily, Your legal name, date of birth, gender, father’s name, permanent address, PAN, and Aadhaar details. We need these to confirm who You are and to prepare Your rental agreements.

7.2. Two ways to verify. You can choose either of the following. You do not have to use DigiLocker; if You prefer, You can upload Your documents instead.

1. DigiLocker (recommended). We use Our verification partner, Cashfree Secure ID, to connect to DigiLocker. Inside DigiLocker, You decide whether to share Your Aadhaar and PAN with Us. If You agree, We receive Your name, date of birth, address and a masked Aadhaar number that shows only the last 4 digits. We never receive or store Your full Aadhaar number through DigiLocker.
2. Uploading Your documents. You can instead upload images of Your PAN card and Your Aadhaar. Please upload a masked Aadhaar, with the first 8 digits of the Aadhaar number covered, so that only the last 4 digits are visible. You can download a masked Aadhaar from UIDAI, or cover the digits Yourself before uploading. If You choose to upload an Aadhaar that is not masked, You do so of Your own choice; We may mask or delete it, or ask You for a masked copy.

7.3. How We use and protect Your Aadhaar. We use Your Aadhaar only to verify Your identity for Your tenancy and rental agreement. We do not use it to authenticate You with UIDAI. We keep identity documents with restricted access, available to members of Our team, and service providers acting for Us, who need them for Your booking and tenancy. We do not publish Your Aadhaar number.

7.4. Background verification. We verify Your identity, court records and employment through an outside background verification agency, and share with that agency only the details it needs to run these checks. If Your verification fails, Your agreement may be ended, as set out in the key terms of Your agreement.

7.5. Other details We ask for when You move in. To prepare Your agreements, match You with flatmates and run the home, We also ask for:

• Your company, Your role, and Your LinkedIn or X profile;
• Your UAN (Universal Account Number), which is optional;
• Your food, smoking and parking preferences;
• where You are moving from; and
• if someone referred You, the referrer’s name and phone number. Please give Us these only if the person who referred You has agreed to it.

7.6. What Your flatmates and the owner see. With Your consent, given when You onboard, We share Your phone number, email address and LinkedIn profile with Your confirmed flatmates, the owner of the home and the teams that run the home. Separately, and only if You explicitly agree, We show prospective flatmates a masked profile of You. It shows Your work and food preferences, and never Your name. Once details are shared with Your flatmates, the owner or other persons at Your request or with Your consent, their use of those details is their own responsibility, and We are not responsible for it.

8.1. The Data so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all Personal Data may be deleted, however, in a safe and secure mode.

8.2. As a general guide:

• We generally keep Your identity documents and identity details for as long as Your tenancy lasts, and for up to 3 years after it ends, so We can deal with disputes, settle Your security deposit and handle legal claims, after which We delete or anonymise them in the normal course.
• If You do not complete Your booking, We ordinarily delete Your identity documents within about 90 days.
• We keep financial records, such as payments and invoices, for as long as tax law requires, which can be up to 8 years.

8.3. We may keep Data for longer where the law requires or permits it, or where it is needed to establish, exercise or defend legal claims. Copies may also remain for a limited time in backups and in records held by Our service providers until they are deleted in the ordinary course.

9.1. Non-Personal Data (“NPD”) shall mean any data that does not personally identify You and may include unique system or hardware identifiers, system or Platform software, and peripherals.

9.2. Any NPD, when clubbed with Personal Data to personally identify an individual shall be treated as Personal Data.

9.3.1. Collection:
You agree that the Platform may collect diagnostic, technical, usage related data, for the usage purposes described below.

9.3.2. Usage:
The NPD is gathered periodically to provide and improve the Platform and services therein facilitate the provision of software updates, product support and other services to You (if any) and verify compliance with the terms of this Policy.

9.3.3. Sharing:
To enable the Platform partners and third party developers to improve their software, hardware and services designed for use of the Platform, We may also provide any such partner or third party developer with a subset of diagnostic data that is relevant to that partner’s or developer’s software, hardware and/or services, as long as the diagnostic data is in a form that does not personally identify You.

9.3.4. Retention:
The NPD so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all Data may be deleted, however, in a safe and secure mode.

10.1. The Platform, its licensees and agents, may access, collect and analyse Your usage of the Platform and other data related to Your location on a regular basis through Bluetooth and Wi-Fi signals and other technologies and data for the performance of the services provided by the Platform and to help improve the design, functionality, performance, and content of the Platform. In order to collect geo-location data, the location settings must be enabled on Your device. Therefore, in some cases, the Platform may request that You enable the location settings.

10.2. Except in cases where any specific services requested by You require or involve personal identification, the Platform collects location data anonymously and in a form that does not personally identify You. By using the Platform, You agree and consent to transmission, collection, maintenance, processing and use of Your location data and queries to provide and improve such services of the Platform.

11.1. For providing the services on the Platform, We may use technologies such as cookies to provide users with tailored data upon each visit to Our Platform. A ‘cookie’ is a small piece of data stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember Data specific to a given user. We place both permanent and temporary cookies in Your computer’s hard drive. Every time You access Our Platform, Our servers through cookies collect basic technical data such as Your domain name, the address of the last URL visited prior to clicking through to the Platform, and Your browser and operating system, etc. We may collect this data for statistical purposes or otherwise to find out how Our Platform is used and navigated, including the number of hits, the frequency and duration of visits, most popular session times. We may use this data to evaluate and improve Our Platform or services. If You disable all cookies, You may not be able to take advantage of all the features of Our Platform.

11.2. Some cookies and similar technologies hold an identifier that is unique to Your browser or device. These identifiers can be linked to You, so We treat them as Personal Data. We use them for:

• product analytics, through PostHog, to understand how visitors use the website;
• measuring Our advertising, through Google Tag Manager (which loads Google’s advertising tags) and Meta’s pixel and Conversions API, so We can tell which ads lead to enquiries and bookings; and
• remembering which advertisement or link brought You to the website, so We can credit the right campaign.

11.3. You can block or delete cookies in Your browser settings, and You can limit personalised advertising in Your Google and Meta account settings. Doing so will not stop You from browsing the website, though some features may not work as expected.

11.4. We may combine Your Personal Data or Data or other data collected from tracking technologies and aggregate it with data collected from other users using Our services to attempt to provide You with the Services and a better experience on the Platform.

12.1. We strive hard to keep Our records updated and accurate with Your latest Data. You shall be responsible to ensure that the Data You provide from time to time is and shall be correct, current and updated and You have all the rights, permissions and consents to provide such Data.

12.2. Under the DPDP Act, You have the right to:

• ask for a summary of the Personal Data We hold about You and how We process it, and the names of those We have shared it with;
• ask Us to correct, complete or update Your Personal Data;
• ask Us to erase Your Personal Data, except where the law requires Us to keep it (see Section 8);
• have Your grievances heard and redressed (see Section 15);
• nominate another person to exercise these rights for You if You die or become unable to act; and
• withdraw any consent You have given Us.

12.3. To use any of these rights, write to Us at hello@flent.in. Withdrawing consent is as easy as giving it, and does not affect anything We did lawfully before You withdrew. You may note that the withdrawal of consent or deletion of certain Personal Data may lead to cancellation of Your registration with Us and/or Your access to certain features of the services can be restricted and may also lead to complete cessation of Your access to Platform. In particular, if You withdraw consent to the processing We need to verify You and run Your tenancy, We may be unable to continue Your booking, tenancy or services.

12.4. You acknowledge and agree that You may receive certain notifications relating to the Platform and its products and services on Your Device or on Your registered contact. You agree that any communication so received by You from Us will not amount to spam, unsolicited communication or a violation of Your registration on the national do not call registry. At any given point of time, if you decide to not receive notification, you may turn off such notifications by contacting us on our support email.

13.1. The terms shall be governed and construed in accordance with the laws of India.

13.2. We strive to protect Your Personal Data against unauthorized disclosure, misuse, unlawful use, modification, loss or destruction. We take reasonable measures and precautions, in line with standard industry practices, to keep Your Personal Data confidential, and We endeavour to comply with applicable laws.

13.3. We use reasonable administrative, technical, physical and managerial measures to safeguard Your Personal Data against loss, theft and unauthorized access, use and modification as per law. These may include, as appropriate:

• keeping identity documents in private, encrypted storage;
• limiting access by role, so that team members see Your Data only where their work needs it;
• keeping records of access to identity documents where Our systems support it;
• masking Aadhaar numbers where feasible; and
• encrypting Data in transit using TLS.

13.4. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, We cannot guarantee the security of Your Data. By continuing to access the Platform You are aware of such risk.

13.5. Where the law requires, We will notify affected users and the relevant authorities, such as the Data Protection Board of India and CERT-In, of a breach affecting Personal Data.

13.6. To the maximum extent permitted by applicable law, We are not liable for any loss or damage arising from unauthorised access to, or disclosure of, Personal Data that is beyond Our reasonable control, that is caused by third parties (including service providers acting outside Our instructions), or that results from information You or other parties choose to share, including documents that are not masked and details shared with flatmates, owners or other users.

We are committed to protect Your Personal Data collected and processed by Us and look forward to Your continued support for the same. In case of any feedback or concern regarding protection of Your Personal Data, or any privacy-related feedback or concerns, you may contact Our Grievance Officer at the details below.

We will acknowledge Your complaint within a reasonable time and resolve it within 30 days of receiving it, as required by Rule 5(9) of the SPDI Rules. If You are not satisfied with Our response, You may complain to the Data Protection Board of India.