Legal

Privacy Policy

Effective 27 October 2026 · Last updated 27 October 2026 · BedR Realcon Private Limited

This Privacy Policy (“Privacy Policy”) describes how BedR Realcon Private Limited, having its registered office at E-1/79, Arera Colony, R.S. Nagar, Huzur, Bhopal, R.S.Nagar, Huzur, Bhopal-462016, Madhya Pradesh (“Company”, “ClosR”, “we”, “us” or “our”), collects, receives, records, stores, organises, structures, uses, analyses, shares, transfers, discloses, protects and otherwise processes personal data in connection with ClosR.

ClosR is a technology platform intended primarily for real-estate brokers, agents, consultants and property professionals. ClosR may operate in conjunction with other products and services operated by or associated with BedR Realcon Private Limited, including BedR and ManagR.

This Privacy Policy applies to the ClosR website, ClosR accounts, property inventory, lead services, customer-matching functionality, broker-to-broker functionality, communications, artificial-intelligence systems, telephone calls, WhatsApp interactions, support services and other functionality made available through ClosR.

By creating or using a ClosR account, accessing the website, uploading information, purchasing lead credits, unlocking a customer, submitting a client requirement, communicating with ClosR or otherwise using the service, you acknowledge the data practices described in this Privacy Policy.

Where applicable law requires affirmative consent for a particular processing activity, ClosR will seek such consent through an appropriate mechanism.

1

Data Fiduciary and Contact Information

For the purposes of applicable Indian data-protection law, BedR Realcon Private Limited may act as the entity determining the purposes and means for which personal data is processed in connection with ClosR.

The Company’s registered office is E-1/79, Arera Colony, R.S. Nagar, Huzur, Bhopal, R.S.Nagar, Huzur, Bhopal-462016, Madhya Pradesh.

Privacy questions, requests and grievances may be sent to contact@bedrindia.com.

The designated Grievance Officer for ClosR is Shlok Mittal, who may be contacted at contact@bedrindia.com.

2

Scope of This Privacy Policy

This Policy applies to personal data processed through or in connection with ClosR.

It may apply to brokers, brokerage employees, brokerage owners, real-estate agents, consultants, channel partners, customers, prospective tenants, prospective buyers, property owners, business representatives, website visitors and other persons whose information enters the ClosR ecosystem.

Information may originate directly from ClosR or may originate from BedR, ManagR, a Company advertising campaign, a communication provider, another User, a public source or another lawful source.

Where personal data was originally collected through another Company service, the privacy notice applicable at the time of original collection may also apply to that initial collection.

3

Meaning of Personal Data

For purposes of this Privacy Policy, “personal data” means information relating to an identifiable individual to the extent recognised under applicable law.

Personal data may include information expressly provided by an individual, information received from another lawful source, technical information associated with an individual and information generated, inferred or derived from the person’s interactions with the Company’s products.

4

Broker Account Information

When a broker or property professional registers with ClosR, we may process information necessary to establish and administer the account.

This may include the User’s name, mobile number, WhatsApp number, email address, business or agency name, professional role, photograph, business address, localities of operation, property categories, brokerage information, team information and other profile details.

We may also record account status, verification status, account creation date, last-login information, lead-credit balance, subscription or package information and account restrictions.

5

Identity and Business Verification

ClosR may request information to verify a User’s identity, business or professional status.

Depending on the service and risk level, this information may include PAN information, government identification, RERA registration, agency documentation, business-address information, bank verification, professional information, business references or other documentation.

Verification may be performed by ClosR personnel, automated systems or authorised third-party verification providers.

The precise verification process may differ between Users.

6

Property Inventory Data

ClosR may collect and process information relating to property inventory uploaded, imported, submitted or otherwise made available by brokers.

This information may include the building or society name, locality, address, unit identifier, property type, configuration, rent, expected price, deposit, maintenance charges, brokerage, furnishing, amenities, availability, property photographs, videos, floor plans, visit availability and other property characteristics.

Property information may be combined with other information for duplicate detection, matching and marketplace operations.

7

Property Owner Information

A broker may possess confidential information relating to a property owner.

ClosR does not require a broker to provide an owner’s contact details merely for every property upload unless the relevant product flow expressly requires such information.

Where owner information is submitted to ClosR, we may process that information for the specific purpose for which it was provided, including verification, property management, customer connection, dispute handling, fraud prevention or another disclosed operational purpose.

Private owner contact information is not intended to be automatically exposed to other brokers merely because a property exists on ClosR.

8

Information About Broker-Owned Customers

ClosR may allow a broker to post a requirement for a customer independently represented by that broker.

The broker should provide only information reasonably necessary for matching.

A broker-owned client requirement may therefore include a desired locality, budget, property type, configuration, move-in date, furnishing preference or other property criteria without necessarily including the customer’s name or telephone number.

Where the broker chooses or is required to provide personal customer information, the broker represents that the broker has an appropriate lawful basis and any necessary permission to provide that information to ClosR.

9

BedR Customer Information

ClosR may receive information relating to customers who use BedR.

Such information may include the customer’s name, telephone number, WhatsApp number, email address, account information, search preferences, selected areas, budget, property type, configuration, move-in date, furnishing preferences, tenant profile, properties viewed, properties saved, enquiries submitted, cart activity, purchases, contact unlocks and other interactions relevant to the customer’s property search.

Such information may be used within ClosR where necessary to facilitate customer-property matching, broker matching, enquiries, lead services or other connected functionality and where permitted by applicable law and the relevant customer notice or consent.

10

Customer Active Search Profiles

The Company may maintain a structured profile of a customer’s current property search.

This may be referred to internally or within the product as an “active search”, requirement profile or similar concept.

An active search may combine information expressly supplied by the customer with information obtained through qualification and information derived from behaviour on BedR.

For example, the active search may reflect areas searched, configurations selected, approximate budget, move-in timing, properties viewed, properties saved and properties on which the customer has taken an explicit action.

The purpose of such a profile is to improve matching and avoid unnecessarily asking customers to repeatedly provide the same information.

11

Customer Enquiry Data

Where a BedR customer makes an enquiry on a property associated with a ClosR broker, ClosR may create an opportunity relating to that customer.

Before a broker successfully unlocks the customer, ClosR may restrict or anonymise personal contact details.

The broker may instead see limited information relevant to assessing the opportunity.

Once the applicable unlock process has been completed, ClosR may disclose the customer information reasonably necessary for the broker to contact and service that customer.

12

General Matching of Customers to Brokers

ClosR may identify customers whose requirements appear relevant to brokers operating in particular areas or markets.

Such matching may use information including broker inventory, broker-selected localities, customer search preferences, customer property type, search history and other marketplace information.

A matching broker may initially receive limited or anonymised information.

Customer contact information may be disclosed only after the applicable ClosR flow has been completed.

13

Telephone Number Verification

The Company may verify telephone numbers through OTP, call verification or another authentication mechanism.

A verified telephone number means only that the applicable verification process was completed.

It does not guarantee the identity, financial capacity or future intentions of the individual associated with that number.

14

AI Qualification Calls

BedR and ClosR may use artificial-intelligence voice agents to call customers.

Such calls may be used to confirm whether a customer is still actively searching, confirm or update areas of interest, property type, configuration, budget, move-in timing and other preferences, determine whether a customer consents or agrees to being contacted by relevant marketplace participants, provide customer support or carry out other property-search functions.

Where existing information is already available, the AI system may use that information to avoid unnecessarily asking the customer to repeat it.

15

Human Telephone Calls

The Company may also use employees, contractors, sales representatives, customer-support personnel or other authorised persons to communicate with brokers and customers by telephone.

Such calls may relate to onboarding, verification, qualification, customer support, sales, disputes, platform use, property information or other relevant services.

16

Storage of Call Recordings

ClosR and related Company services may store call recordings.

Where permitted by applicable law and subject to appropriate notice or consent where required, calls involving customers, brokers, Company representatives or artificial-intelligence agents may be recorded and retained.

Recordings may be used to confirm customer requirements, review what was communicated during a transaction, investigate complaints, assess disputes concerning Leads, detect abuse or fraud, improve customer support, monitor service quality, improve AI systems, train authorised personnel and maintain appropriate business records.

Call recordings may contain the voice of the individual, statements made during the call, telephone number, call time, duration and related metadata.

17

Call Transcripts and Summaries

Stored recordings may be converted into text transcripts.

Artificial-intelligence or other automated systems may generate call summaries and extract structured information from a conversation.

For example, a system may extract a customer’s stated budget, property type or preferred area from a call.

Automated transcription and summarisation can contain errors.

ClosR does not represent that every transcript or automated summary is a word-for-word or error-free representation of the underlying call.

The stored audio recording may be used where it is necessary to investigate a material discrepancy.

18

Call Metadata

Even where the contents of a call are not necessary for a particular purpose, the Company may process metadata including telephone numbers, call time, duration, call status, answer status, call attempts and technical routing information.

Such information may be used for qualification workflows, customer support, fraud prevention, system monitoring and analytics.

19

WhatsApp Information

ClosR may communicate with brokers and customers through WhatsApp.

WhatsApp communications may include OTP-related information where supported, account information, property approvals, property rejection notices, BedR enquiry notifications, daily matched-lead summaries, property-availability reminders, lead-balance reminders, purchase confirmations, customer updates, broker-matching communications, reactivation marketing and customer support.

ClosR may process the telephone number used for WhatsApp, message content, delivery status, response information, timestamps and other information required to provide the communication.

20

WhatsApp Service Providers

ClosR may use WhatsApp Business Platform infrastructure, Meta services and/or authorised WhatsApp Business Solution Providers.

Information transmitted through WhatsApp may therefore also be processed by those providers in accordance with their applicable terms and privacy practices.

ClosR does not control the independent processing carried out by Meta or other third-party communication providers.

21

Marketing and Reactivation Messages

Subject to applicable law and any applicable consent or preference requirements, ClosR may send communications intended to encourage a User to return to the platform.

Such communications may relate to new BedR leads, matched customer counts, available inventory, inactive properties, unused lead balances, new features, promotions, lead packs or marketplace opportunities.

Where legally required, ClosR will provide an appropriate means to opt out of promotional communications.

Opting out of promotional communication does not necessarily prevent ClosR from sending essential transactional, security, payment or account communications.

22

Email Information

ClosR may use email for support, account administration, invoices, receipts, payment notices, privacy or Terms updates, grievance communication, marketing and other purposes.

Email delivery information, opens or clicks may be measured where supported by the relevant email service.

23

SMS Information

SMS may be used for authentication, OTPs, account security, transactional notices or other permitted purposes.

The relevant mobile number, message status and technical delivery information may be processed by ClosR and its service providers.

24

Payment and Transaction Information

When a User purchases lead credits or another paid product, ClosR may process information relating to the transaction.

This may include the package purchased, number of credits, amount paid, taxes, date, payment status, transaction reference, invoice information, GST details and any associated refund, reversal or dispute information.

Payment processing may be performed by third-party payment providers.

ClosR may not directly receive or store full card credentials where those credentials are handled directly by the relevant payment provider.

25

Website and Device Information

When a User accesses ClosR, the Company may automatically process technical information.

This may include IP address, device type, browser type, operating system, screen or device information, language settings, session information, referring URL, timestamps and error logs.

Such information may be used to operate and secure the website and understand how the service performs.

26

Platform Usage Information

ClosR may record how Users interact with the service.

This may include properties created, viewed, edited or reconfirmed; Leads viewed or unlocked; searches performed; filters selected; client requirements posted; property matches opened; pages viewed; buttons clicked; lead packs purchased; account balances; time spent; and other product interactions.

This information may be used for platform operation, support, analytics, security and product improvement.

27

Cookies and Similar Technologies

ClosR may use cookies, pixels, local storage, tags, browser technologies, analytics scripts and similar technologies.

These technologies may be used to maintain sessions, authenticate Users, remember settings, secure the platform, prevent abuse, analyse traffic, understand usage, measure advertising and improve functionality.

Where applicable law requires consent for non-essential cookies or similar technologies, ClosR may provide an appropriate consent mechanism.

Users may also be able to control certain technologies through their browser.

Blocking necessary cookies may interfere with website functionality.

28

Advertising Attribution

ClosR may advertise through Meta, Google, LinkedIn or other advertising platforms.

Where permitted by law, ClosR may process or share limited identifiers and event information for purposes such as measuring whether an advertisement resulted in a signup, understanding advertising effectiveness, creating campaign audiences, preventing fraud and optimising campaigns.

Advertising providers may independently process information under their own privacy policies.

29

Meta Lead Forms and Other Advertising Leads

Prospective brokers may provide information through Meta lead forms or other advertising forms relating to ClosR, ManagR, BedR or related Company products.

The Company may process such information to contact the prospective User, understand their business, determine whether a Company product may be relevant, conduct onboarding or sales conversations and measure campaign effectiveness.

Where legally permitted and reasonably connected with the original interaction, information previously submitted regarding ManagR or another Company service may be used to introduce the User to ClosR where ClosR is relevant to the person’s stated activity as a real-estate broker or professional.

30

Publicly Available Business Information

ClosR may obtain professional or business information from lawful public sources.

This may include business websites, professional directories, publicly accessible RERA information, Google Business profiles or other public sources.

The mere public availability of information does not remove ClosR’s obligation to process personal data in accordance with applicable law.

31

Information Received From Other Users

A broker, customer, property owner or another User may provide information concerning another person.

For example, a broker may provide limited information concerning a customer requirement or property owner.

Users who provide information concerning another person are responsible for ensuring that they are lawfully entitled to provide that information.

32

Information Received From Service Providers

The Company may receive information from identity-verification services, payment processors, communication providers, fraud-prevention providers, analytics providers and other vendors used in operating ClosR.

Such information may be combined with information already held by the Company where reasonably necessary for the relevant purpose.

33

Purposes for Which We Process Data

ClosR processes personal data to provide, administer, secure and improve the service.

This includes creating accounts, authenticating Users, verifying identities, managing property inventory, delivering enquiries, enabling lead unlocks, matching customers to brokers, matching broker client requirements to properties, processing payments, sending communications, providing support and operating the marketplace.

Personal data may also be processed for fraud prevention, dispute handling, compliance, safety, analytics and product development.

34

Customer Qualification

The Company may process customer data to determine whether a customer appears to remain actively interested in a property search.

Qualification may use customer statements, website activity, telephone calls, artificial-intelligence interactions, WhatsApp responses or other relevant information.

The purpose of qualification is to improve marketplace relevance and does not constitute a guarantee of future behaviour.

35

Lead Matching

ClosR may process customer and broker information in order to identify potentially relevant matches.

Matching may consider location, property type, configuration, budget, broker markets, property inventory, customer activity and other factors.

A match indicates potential relevance only.

It is not a guarantee of transaction compatibility.

36

Property Matching

Where a broker has posted a requirement for the broker’s own client, ClosR may compare that requirement against property inventory submitted by other brokers.

Information regarding matching properties may then be made available to the broker who posted the requirement.

37

Duplicate Property Detection

ClosR may analyse property addresses, building names, unit numbers, photographs, location information, property characteristics and other data in an attempt to identify multiple representations of the same physical property.

Such processing helps reduce duplicate customer listings and may enable multiple broker representations to be associated with one property record.

Duplicate-detection systems may use automated technology and may not always be perfect.

38

Duplicate Customer Detection

ClosR may process telephone numbers, account identifiers, enquiry history, active-search information and other signals in order to identify whether a broker has previously unlocked the same customer.

This may be used to prevent inappropriate duplicate charging or to associate later customer activity with an existing broker relationship.

39

Fraud Prevention and Platform Security

ClosR may analyse account, transaction, property, lead and device information to identify fraud, misuse or suspicious behaviour.

This may include detection of fake properties, fake accounts, multiple accounts created to evade restrictions, payment abuse, lead-refund abuse, data scraping, automated attacks, impersonation, unauthorised account access or misuse of customer information.

ClosR may retain information reasonably necessary to investigate and prevent such conduct.

40

Customer Safety

The Company may use complaint data, communication records and account activity to investigate allegations of harassment, fraud, misrepresentation, inappropriate contact or misuse of customer information.

Where necessary, ClosR may restrict a broker’s access to customer information or suspend the broker’s account.

41

Customer Support

Where an individual contacts ClosR support, the Company may process account information, correspondence, screenshots, documents, transaction details, recordings, lead information and other material necessary to investigate and resolve the request.

Support interactions may be retained for quality assurance, dispute resolution and future support.

42

Dispute Resolution

ClosR may use personal data to investigate disputes between Users or disputes involving payments or Leads.

Relevant evidence may include call recordings, transcripts, qualification records, WhatsApp interactions, lead unlock timestamps, payment information, customer activity, property data and system logs.

43

Legal Compliance

The Company may process personal data to comply with applicable legal, regulatory, tax, accounting or governmental requirements.

This may include responding to lawful requests from courts, regulators, law-enforcement authorities or other authorised governmental bodies.

44

Legal Claims

ClosR may retain and use information where reasonably necessary to establish, exercise or defend legal claims, enforce contracts, investigate wrongdoing or protect the legal rights of the Company, Users or third parties.

45

Product Development

The Company may analyse platform activity in order to understand product performance, identify bugs, improve workflows, develop new functionality, improve qualification systems and enhance the ClosR marketplace.

Where practical and appropriate, such analysis may use aggregated or de-identified information.

46

AI and Machine Learning

ClosR and related Company products may use artificial intelligence and machine-learning systems.

These systems may be used for voice calls, call transcription, call summarisation, extracting customer requirements, property-data extraction, duplicate detection, matching, fraud detection, customer support, categorisation and other features.

Automated systems may produce inaccurate results.

Users should independently verify information that is material to a transaction.

47

Improvement of AI Systems

Subject to applicable law and relevant notices or permissions, the Company may use stored interactions, call recordings, transcripts, corrections, outcomes and feedback to evaluate and improve artificial-intelligence systems used by ClosR or related Company services.

Where appropriate, data may be anonymised, de-identified or aggregated for model evaluation or system improvement.

48

Automated Decision-Making and Recommendations

Certain platform decisions or recommendations may be made or assisted by automated systems.

For example, an automated system may determine that a property appears to match a customer requirement or that two property listings appear to represent the same physical unit.

Automated decisions are intended to support platform operation and do not constitute guarantees of accuracy.

Where applicable law establishes rights relating to automated processing, ClosR will implement the applicable safeguards when those requirements apply.

49

Sharing Customer Information With Brokers

Where an eligible broker successfully unlocks a customer through ClosR, the Company may disclose appropriate customer information to that broker.

This may include the customer’s name, telephone number, relevant requirement information, property interest, qualification information or other data reasonably necessary for the broker to contact and assist the customer.

ClosR may restrict information that is not reasonably necessary for the broker’s purpose.

50

Broker Responsibilities After Unlocking a Customer

Once customer information is disclosed to a broker, that broker becomes responsible for the broker’s subsequent use of that information.

The broker must use the customer information only for legitimate real-estate purposes connected to the customer’s property search.

The broker must not sell, publicly publish, resell, trade, scrape, distribute or contribute customer information to an unrelated third-party lead database.

The broker must not use customer information for unrelated commercial marketing without an appropriate legal basis.

The broker must respect a customer’s request to stop being contacted.

51

Sharing Customer Information With Property Owners

Where BedR or ClosR offers functionality under which property owners can connect with customers, appropriate customer information may be disclosed to eligible property owners after completion of the relevant product flow.

The extent of information disclosed may depend upon the type of enquiry, the applicable customer interaction and the Company’s then-current product rules.

52

Broker-to-Broker Connections

Where one broker has submitted a client requirement and another broker has matching property inventory, ClosR may facilitate communication between the brokers.

ClosR may intentionally limit the personal information disclosed between the brokers until the relevant connection process is completed.

The Company’s objective is that a broker’s private customer relationship and another broker’s private owner relationship should not automatically be exposed merely because a property match exists.

53

Service Providers

ClosR may disclose personal data to third-party service providers that perform functions on behalf of the Company.

These may include cloud and hosting providers, database services, telephony providers, WhatsApp service providers, email providers, SMS providers, payment gateways, identity-verification services, customer-support software, analytics companies, cybersecurity providers, accounting providers and professional advisers.

The information provided to a service provider may depend on the service being performed.

54

Company Affiliates and Connected Services

Information may be shared between ClosR, BedR, ManagR and other services operated by BedR Realcon Private Limited where reasonably necessary to provide connected functionality, maintain account integrity, qualify customers, match demand and inventory, provide support, prevent fraud or improve Company products.

Such sharing does not mean that every employee or product receives unrestricted access to every category of data.

Access may be limited based on business need and role.

55

Legal and Regulatory Disclosures

The Company may disclose personal data where required by a valid court order, legal process, regulatory instruction, law-enforcement request or other applicable legal requirement.

The Company may also disclose information where reasonably necessary to investigate suspected fraud, protect safety, enforce its agreements or defend legal rights.

56

Business Transfers

If BedR Realcon Private Limited or ClosR participates in a merger, acquisition, financing, restructuring, investment transaction, insolvency process, transfer of business, sale of assets or similar corporate event, personal data may be shared with prospective or actual investors, purchasers, advisers, counterparties or successor organisations subject to applicable law.

A successor organisation may continue processing relevant data in accordance with applicable law and any privacy notice then in force.

57

No Authorised Sale of Customer Databases

ClosR does not authorise brokers to purchase customer information for the purpose of creating a separate resale database.

Payment of a lead credit is consideration for access to a customer opportunity within the ClosR marketplace.

It does not grant a broker the right to resell the customer’s personal information.

58

Internal Access

Personal data may be accessible to Company employees, contractors and authorised personnel who require access for legitimate business functions.

Access may differ by team and responsibility.

Personnel involved in support may require account and interaction information. Personnel handling payments may require transaction information. Personnel responsible for marketplace integrity may require property and customer activity information.

59

Confidentiality and Personnel Controls

The Company may require personnel and contractors with access to personal data to comply with confidentiality, information-security and acceptable-use obligations.

Access may be withdrawn when the person no longer requires the information for their role.

60

Data Retention

ClosR retains information for periods reasonably necessary to fulfil the purposes described in this Policy, comply with legal obligations, maintain business records, prevent fraud, resolve disputes, secure the platform and establish or defend legal claims.

Different categories of data may therefore be retained for different periods.

The fact that an account or customer search has ended does not necessarily mean that every associated record is immediately deleted.

61

Retention of Call Recordings

Call recordings are stored and may be retained for as long as reasonably necessary for qualification records, quality assurance, support, dispute handling, fraud prevention, compliance, service improvement, AI-system improvement and legal purposes.

The Company may apply different retention periods depending upon the nature of the call, the purpose for which it is retained and applicable law.

Where a recording is subject to an active complaint, investigation, dispute or legal requirement, ClosR may retain the recording for as long as reasonably necessary to resolve that matter.

62

Retention of Transcripts and Summaries

Call transcripts and summaries may be stored separately from the underlying audio recording.

They may be retained where reasonably necessary for customer qualification, support, marketplace history, dispute resolution, analytics or other legitimate purposes described in this Policy.

63

Retention of Lead Records

ClosR may maintain records of Leads even after a customer stops searching.

This may be necessary to determine whether a broker has previously unlocked the same customer, resolve disputes, investigate customer complaints, prevent duplicate charging, understand marketplace performance or maintain appropriate business records.

Older information may be archived, restricted, aggregated or de-identified where appropriate.

64

Retention of Property Records

ClosR may retain historical property records after a listing is rented, withdrawn, paused or removed from public visibility.

Historical information may assist with duplicate detection, building records, dispute resolution, fraud prevention, analytics and future property updates.

The fact that a property is no longer publicly visible does not necessarily mean that every internal record concerning the property has been deleted.

65

Retention of Payment Records

Transaction and invoice information may be retained for the period required by tax, accounting, corporate and other applicable legal obligations.

Deletion of a ClosR account does not require ClosR to delete financial records that the Company is legally required or reasonably entitled to retain.

66

Security Logs

ClosR may retain technical security information including login records, IP information, device information and activity logs for periods reasonably necessary to protect accounts, investigate misuse and maintain platform security.

67

Data Minimisation

ClosR seeks to collect information reasonably connected with the relevant product or service.

Users should avoid placing sensitive, confidential or unnecessary personal information into fields that are intended solely for property or requirement matching.

68

Data Accuracy

ClosR may rely upon customers, brokers, property owners and other parties to provide accurate information.

Users are responsible for maintaining accurate account and business information.

Individuals may contact ClosR to request correction of inaccurate personal data where appropriate and permitted by law.

69

Security Measures

The Company uses reasonable technical and organisational safeguards intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Measures may include authentication, access controls, encryption where appropriate, secure transmission, logging, monitoring, cloud-security controls, backups, vendor controls and internal processes.

The specific safeguards used may evolve as the platform and technological risks change.

70

No Absolute Security Guarantee

No online platform, telecommunications network, cloud provider, messaging service or data-storage system can be guaranteed to be completely secure.

Accordingly, while ClosR takes reasonable measures to protect information, it cannot guarantee absolute security.

Users are responsible for protecting their own devices, accounts and authentication credentials.

71

Data Breaches and Security Incidents

Where ClosR becomes aware of a personal-data breach or other security incident, the Company may investigate the incident, contain the issue, preserve relevant evidence, engage affected service providers and take remedial action.

Where applicable law requires notification to affected individuals, authorities or other persons, ClosR will provide the required notification in accordance with applicable legal requirements.

72

Account Credentials and OTP Security

Users must maintain control over their account credentials and OTPs.

Users should not permit unauthorised persons to use their ClosR accounts.

A User who believes their account has been compromised should contact contact@bedrindia.com promptly.

73

International Processing

Some technology or infrastructure providers used by ClosR may operate servers or personnel outside India.

Where personal data is transferred or processed outside India, ClosR will comply with applicable restrictions or requirements imposed under Indian law.

74

Marketing Preferences

Users may be able to opt out of non-essential promotional communications using the controls provided in the relevant message or by contacting ClosR.

A marketing opt-out does not necessarily stop operational communications.

ClosR may continue sending communications that are necessary for account administration, security, payment confirmation, service delivery, policy changes or other non-marketing purposes.

75

Withdrawal of Consent

Where a particular processing activity relies on consent, an individual may withdraw that consent using an appropriate mechanism made available by ClosR or by contacting contact@bedrindia.com.

Withdrawal will ordinarily operate prospectively.

It does not invalidate processing that was lawfully carried out before withdrawal.

Where the relevant personal data is necessary to provide a requested service, withdrawal may result in that service becoming unavailable.

76

Access to Personal Data

To the extent provided under applicable law, an individual may request information concerning personal data processed by ClosR.

ClosR may require reasonable information to verify the identity of the requester and prevent unauthorised disclosure.

The scope of a response may be subject to exceptions, restrictions and retention obligations under applicable law.

77

Correction and Updating

Individuals may request correction or updating of personal data that is inaccurate or incomplete, subject to appropriate verification.

Where the relevant information can be edited directly through a ClosR account, the User may be asked to update the information using the account interface.

78

Erasure

Where applicable law gives an individual a right to request erasure, the individual may request deletion of personal data that is no longer required for the relevant purpose.

Such requests are subject to lawful retention requirements.

ClosR may retain information notwithstanding an erasure request where retention is required or permitted for legal compliance, accounting, fraud prevention, security, dispute resolution, exercise or defence of legal claims or another lawful purpose.

79

Account Deletion

Closure or deletion of a ClosR account does not necessarily result in immediate deletion of all historical information.

The Company may retain transaction information, support records, lead history, call recordings, security logs or other records where continued retention is reasonably necessary or legally required.

80

Grievance Redressal

Individuals may raise privacy grievances by contacting the ClosR Grievance Officer.

Grievance Officer: Shlok Mittal
Email: contact@bedrindia.com

ClosR may request information necessary to identify the individual, understand the complaint and verify the relevant account or interaction.

Grievances will be handled in accordance with applicable law.

81

Data Principal Rights Under Applicable Indian Law

As the relevant provisions of India’s Digital Personal Data Protection framework become applicable, ClosR intends to provide the rights and mechanisms required by law.

These may include rights relating to access to information about processing, correction, updating, erasure, grievance redressal, withdrawal of consent and nomination, subject to the conditions, exceptions and commencement provisions prescribed by applicable law.

Nothing in this Privacy Policy is intended to reduce a statutory right that cannot lawfully be waived.

82

Data Protection Requests

Privacy or data-protection requests should be sent to contact@bedrindia.com.

The requester should provide sufficient information for ClosR to identify the relevant records.

ClosR may ask the requester to verify their identity before providing access to, correcting or deleting information.

This verification is intended to protect personal data against disclosure to unauthorised persons.

83

Children

ClosR broker accounts are intended for persons who are legally capable of conducting the relevant professional or commercial activity and are ordinarily at least eighteen years of age.

ClosR does not knowingly permit minors to create professional broker accounts.

If ClosR learns that personal data of a child has been improperly submitted through a broker account, the Company may take appropriate action subject to applicable legal obligations.

84

Third-Party Websites

ClosR may contain links to websites or services operated by third parties.

This Privacy Policy does not govern the independent data-processing practices of a third party after the User leaves ClosR or directly interacts with that third party.

Users should review the applicable third party’s privacy information.

85

Third-Party Embedded Technology

ClosR may incorporate third-party payment interfaces, maps, analytics, authentication tools, communication tools or other embedded functionality.

The provider of such functionality may receive technical or transactional information necessary to operate the feature.

86

Aggregated Information

The Company may combine information from multiple Users or customers to generate aggregated analytics.

Such analytics may be used to understand customer demand, property supply, broker activity, locality trends, marketplace liquidity, conversion behaviour and platform performance.

Where information has been genuinely anonymised so that it no longer identifies an individual, it may be used for statistical, research, business and product-development purposes.

87

Market Intelligence

ClosR may produce marketplace insights from aggregated or de-identified data.

For example, ClosR may analyse customer demand by locality, approximate budgets, popular property types, inventory availability or enquiry volumes.

Market-level insights are intended to describe broader marketplace patterns and not expose the identity of a particular customer.

88

Statistical and Business Analysis

The Company may use information to prepare internal forecasts, financial models, investor reporting, operational metrics, sales analysis, demand analysis and other business intelligence.

Where practical, such reporting may use aggregated rather than individually identifiable information.

89

Changes in Processing Purposes

If ClosR proposes to process personal data for a materially different purpose that requires additional notice or consent under applicable law, ClosR will provide such notice or seek the required consent before carrying out that processing.

90

Changes to This Privacy Policy

ClosR may update this Privacy Policy to reflect changes to the platform, technology, data practices, vendors, legal requirements or Company structure.

The updated Policy will be published on the ClosR website.

The date shown under “Last Updated” will indicate when the Policy was most recently revised.

Where applicable law requires additional notice or renewed consent for a material change, ClosR will provide such notice or obtain such consent.

91

Governing Privacy Framework

This Privacy Policy is intended to operate consistently with applicable Indian data-protection, information-technology and privacy law, including the Digital Personal Data Protection Act, 2023 and rules made under that legislation as and when the relevant provisions are applicable.

Nothing in this Privacy Policy is intended to exclude or restrict a statutory privacy right that cannot legally be excluded or restricted.

92

Contact Details

All privacy requests, questions and grievances concerning ClosR may be directed to:

BedR Realcon Private Limited
Grievance Officer: Shlok Mittal
Privacy and Support Email: contact@bedrindia.com
Registered Office: E-1/79, Arera Colony, R.S. Nagar, Huzur, Bhopal, R.S.Nagar, Huzur, Bhopal-462016, Madhya Pradesh

93

Acknowledgment

By using ClosR, you acknowledge that personal data may be processed as described in this Privacy Policy.

Where a particular processing activity requires affirmative consent under applicable law, the Company will rely on an appropriate consent mechanism rather than treating general use of the website as consent for that activity.

The Company may maintain electronic records of notices, consent, consent withdrawal, customer interactions, account activity and other platform events where reasonably necessary to demonstrate and administer compliance.

Questions about this policy?
Write to our Grievance Officer, Shlok Mittal, at contact@bedrindia.com.
Email us