Privacy Policy

Effective Date: April 1, 2026 | Last Updated: May 18, 2025 | Version 1.0

YOUR PRIVACY MATTERS TO US. This Privacy Policy explains how Hutweo Solutions (“Hutweo”, “We”, “Us”,”Our”) collects, uses, stores, shares, and protects your personal information when you access or use the Hutweo platform (“Platform”). Please read this Policy carefully before using our services. By using the Platform, you acknowledge that you have read and agreed to the practices described herein.

1. INTRODUCTION AND SCOPE

This Privacy Policy (“Policy”) is published and maintained by Hutweo Solutions (“Hutweo”, “We”, “Us”, “Our”) in accordance with:

The Information Technology Act, 2000 and its amendments;
The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);
The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
The Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the rules framed thereunder, to the extent applicable and in force.

This Policy applies to all individuals who access or use the Hutweo Platform, including property Listers, property Seekers, registered users, and visitors (collectively “Users”, “You”, “Your”). This Policy governs the collection, storage, use, disclosure, and protection of personal data processed by Hutweo in connection with the Platform and its services.

This Policy should be read alongside our Terms & Conditions, Refund Policy, and any other supplementary policies published on the Platform. In the event of a conflict between this Policy and any other policy, this Policy shall prevail with respect to personal data matters.

2. DEFINITIONS

For the purposes of this Policy, the following terms shall have the meanings assigned to them below:

Term	Definition
“Personal Data”	Any data about an individual who is identifiable by or in relation to such data, including name, phone number, email address, and location.
“Sensitive Personal Data”	Data relating to passwords, financial information, health data, biometric information, or any other category designated under the SPDI Rules or the DPDP Act.
“Data Principal”	The individual to whom Personal Data relates — i.e., the User.
“Data Fiduciary”	Hutweo Solutions, which determines the purposes and means of processing Personal Data.
“Processing”	Any operation performed on Personal Data, including collection, storage, use, sharing, disclosure, or deletion.
“Consent”	A free, specific, informed, unconditional, and unambiguous indication of the Data Principal’s agreement to the processing of their Personal Data.
“Platform”	The Hutweo website, mobile application, and all related digital services operated by Hutweo Solutions.
“Third Party”	Any entity other than Hutweo and the User, including payment gateways, analytics providers, and legal authorities.

3. PERSONAL DATA WE COLLECT

3.1 Categories of Data Collected

Hutweo collects personal data across the following categories, depending on the nature of your interaction with the Platform:

Category	Specific Data Points	Collection Method
Identity Data	Full name, username, gender (optional)	Registration form, profile setup
Contact Data	Phone number, email address, WhatsApp number	Registration, profile, listing form
Location Data	City, locality, PIN code, property address	Search filters, listing form, GPS (with permission)
Property Data	Property type, size, rent’, amenities, floor, availability	Listing creation by Lister
Media Data	Photographs, videos of listed properties	Uploaded by Lister during listing creation
Financial Data	Transaction ID, subscription plan, payment status (NOT card/bank details)	Payment gateway callback
Technical Data	IP address, browser type, device ID, operating system, session data	Automatic collection via cookies and logs
Usage Data	Pages visited, features used, search queries, contact unlocks performed	Analytics tools, server logs
Communication Data	Support emails, grievance submissions, feedback messages	Direct communication with Hutweo
Verification Data	Government ID documents, ownership proof (when submitted)	Voluntary upload during listing verification

3.2 Data We Do NOT Collect

Hutweo expressly does NOT collect or store:

Complete payment card numbers, CVV, or bank account details (handled exclusively by Payment Processors);
Biometric data (fingerprints, facial recognition, iris scans);
Medical or health information;
Political opinions, religious beliefs, or caste information;
Data from users under the age of 18.

3.3 Data Collected from Minors

The Platform is not directed at individuals under 18 years of age. Hutweo does not knowingly collect personal data from minors. If we become aware that personal data of a minor has been collected without appropriate consent, we will delete such data promptly. If you are a parent or guardian and believe your child has provided personal data to us, please contact hutweo@gmail.com immediately.

4. HOW WE COLLECT YOUR DATA

4.1 Data Provided Directly by You

We collect data that you provide directly to us, including when you:

Register for an account on the Platform;
Create or update a property Listing;
Subscribe to a paid plan and make a payment;
Unlock a Lister’s contact details;
Submit a support request, grievance, or feedback;
Participate in surveys, contests, or promotional activities organised by Hutweo.

4.2 Data Collected Automatically

When you access or interact with the Platform, we automatically collect certain technical and usage data through:

Cookies and similar tracking technologies (see Section 6 for details);
Server logs that record IP addresses, access times, and pages visited;
Analytics tools that measure user behaviour, feature usage, and navigation patterns;
Device information, including browser type, operating system, and screen resolution

4.3 Data from Third Parties

In certain circumstances, we may receive data about you from third parties, including:

Payment Processors: Transaction confirmation, payment status, and fraud risk signals;
Analytics Providers: Aggregated behavioural insights about Platform usage;
Verification Partners: Results of document or identity checks (where applicable).

5. PURPOSES FOR WHICH WE PROCESS YOUR DATA

Hutweo processes your personal data only for specified, lawful, and legitimate purposes. The following table sets out the purposes for which we use your data and the legal basis for such processing:

Purpose	Description	Legal Basis
Account Creation & Management	Creating and maintaining your registered user account, authenticating identity, and managing profile settings.	Consent / Contractual necessity
Service Delivery	Enabling the Contact Unlock Service, publishing Listings, and providing subscription plan functionality.	Contractual necessity
Payment Processing	Facilitating subscription purchases and verifying payment status via third-party gateways.	Contractual necessity / Legal obligation
Fraud Prevention & Security	Detecting and preventing fraudulent listings, fake accounts, unauthorized access, and abuse of the Platform.	Legitimate interest / Legal obligation
Platform Improvement	Analyzing usage data to improve Platform features, performance, and user experience.	Legitimate interest (with anonymization where possible)
Legal Compliance	Complying with applicable laws, court orders, regulatory obligations, and responding to lawful government requests.	Legal obligation
Marketing & Communication	Sending service updates, Platform notifications, and (with your consent) promotional offers.	Consent
Grievance Redressal	Processing and responding to User complaints, support requests, and dispute submissions.	Legal obligation / Contractual necessity
Analytics & Research	Conducting market research and generating aggregated, anonymized insights about Platform usage.	Legitimate interest

Hutweo does not process your personal data for any purpose other than those listed above without obtaining your prior consent or as required by law

6. COOKIES AND TRACKING TECHNOLOGIES

6.1 What Are Cookies

Cookies are small text files placed on your device when you visit the Platform. They help us recognize your device, remember your preferences, and analyze how the Platform is used. We also use similar technologies such as web beacons, pixel tags, and local storage.

6.2 Types of Cookies We Use

Cookie Type	Purpose	Retention
Strictly Necessary	Enable core Platform functionality: login sessions, security tokens, page navigation.	Session / Until logout
Performance	Measure page load times, error rates, and feature usage to improve Platform performance.	Up to 12 months
Functional	Remember your preferences such as language, location filters, and saved searches.	Up to 12 months
Analytics	Collect aggregated usage data via tools like Google Analytics to understand user behavior.	Up to 24 months
Marketing / Targeting	Track your interaction with Platform features for retargeting (only with explicit consent).	Up to 6 months

6.3 Managing Cookies

You may control and manage cookie preferences through:

Your browser settings — most browsers allow you to block or delete cookies;
Our cookie preference centre (where available on the Platform);
Opting out of Google Analytics via the Google Analytics Opt-Out Browser Add-on.

Please note that disabling strictly necessary cookies may impair certain Platform functions, including login and payment processing.

7. DATA SHARING AND DISCLOSURE

7.1 Our Commitment

Hutweo does NOT sell, rent, trade, or commercially exploit your personal data to any third party. Your data is shared only as described in this Policy and strictly on a need-to-know basis.

7.2 Categories of Third Parties with Whom We Share Data

Recipient	Purpose of Sharing	Safeguards
Payment Processors (e.g., Razorpay, PayU)	Processing subscription payments and refunds.	PCI-DSS compliant; Hutweo does not access card/bank details.
Cloud Infrastructure Providers	Hosting Platform data on secure servers.	Data Processing Agreements (DPAs) in place; encryption at rest.
Analytics Providers (e.g., Google Analytics, Meta Pixel)	Understanding Platform usage patterns (aggregated/anonymized where possible).	Data shared in pseudonymized/aggregated form; subject to providers’ privacy policies.
Communication Service Providers	Sending transactional emails, OTPs, and Platform notifications.	Limited to contact data required for communication delivery only.
Legal and Regulatory Authorities	Complying with court orders, law enforcement requests, or government directives.	Disclosed only as required by law; minimum data disclosed.
Fraud Prevention Partners	Detecting and preventing fraudulent activity on the Platform.	Anonymized risk signals only; no bulk data sharing.
Business Successors	In the event of a merger, acquisition, or sale of Hutweo or its assets.	Users will be notified; transferred data subject to equivalent privacy protections.

7.3 Lister Contact Data

When a Seeker performs a Contact Unlock, the Lister’s contact details (phone number, email, and/or WhatsApp) are revealed to that specific Seeker. This constitutes a core function of the Platform and is disclosed with the Lister’s implicit consent at the time of Listing creation. By publishing a Listing, the Lister acknowledges and consents to their contact data being shared with Seekers who perform a Contact Unlock

7.4 Cross-Border Data Transfers

Where your data is processed or stored by third-party service providers (such as cloud infrastructure or analytics providers) whose servers may be located outside India, Hutweo ensures that such transfers are governed by appropriate data transfer mechanisms, including standard contractual clauses or equivalent protections as required under applicable Indian law.

8. DATA STORAGE, SECURITY, AND RETENTION

8.1 Storage Location

Your personal data is stored on secure servers, which may be operated by Hutweo directly or by trusted cloud infrastructure partners. Hutweo maintains Data Processing Agreements with all infrastructure providers to ensure equivalent standards of data protection.

8.2 Security Measures

Hutweo implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

Encryption of personal data in transit using TLS/SSL protocols;
Encryption of sensitive data at rest using AES-256 or equivalent standards;
Role-based access control, ensuring that only authorised personnel can access personal data;
Regular security audits, vulnerability assessments, and penetration testing;
Two-factor authentication for administrative access to data systems;
Incident response procedures for detecting and addressing data breaches.

SECURITY DISCLAIMER: While Hutweo takes all reasonable and industry-standard measures to protect your data, no digital system or transmission over the internet can be guaranteed to be 100% secure. In the event of a data breach that affects your rights or interests, Hutweo will notify you and the relevant authorities in accordance with applicable law.

8.3 Data Retention Schedule

Hutweo retains your personal data only for as long as necessary to fulfill the purposes set out in this Policy, or as required by law. The following retention schedule applies:

Data Category	Retention Period	Reason for Retention
Account & Identity Data	Duration of account + 2 years after deletion	Legal compliance, dispute resolution
Property Listing Data	Duration of listing + 1 year after removal	Fraud investigation, audit trail
Financial & Transaction Data	7 years from transaction date	Indian tax and accounting law requirements
Contact Unlock Logs	2 years from date of unlock	Dispute resolution, fraud prevention
Technical & Usage Data	Up to 12 months on a rolling basis	Security monitoring, performance analytics
Backup Copies	Up to 180 days from account deletion	Disaster recovery and system integrity
Communication/Support Data	3 years from date of communication	Legal claims and grievance records
Verification Documents	2 years from submission or account deletion	Fraud prevention, regulatory compliance

After the applicable retention period, personal data will be securely deleted, anonymised, or archived in a non-identifiable format. Anonymised and aggregated data may be retained indefinitely for analytical purposes.

9. CONSENT AND LEGAL BASIS FOR PROCESSING

9.1 How We Obtain Consent

Where Hutweo relies on your consent as the legal basis for processing personal data, we obtain such consent through:

Registration and account creation: By creating an account and accepting these Terms and this Policy, you consent to the collection and use of your personal data as described herein;
Listing creation: By submitting a property Listing, Listers consent to their contact data being made accessible to Seekers via the Contact Unlock mechanism;
Subscription purchase: By subscribing to a paid plan, you consent to the processing of your transaction and identity data for payment and service delivery;
Opt-in communications: We obtain separate, specific consent before sending marketing communications or promotional material.

9.2 Withdrawing Consent

You have the right to withdraw your consent to the processing of your personal data at any time. Withdrawal of consent may be exercised by:

Submitting a written request to hutweo@gmail.com with the subject line “Consent Withdrawal Request”;
Deactivating your account through the Platform’s account settings (where available);
Unsubscribing from marketing communications via the unsubscribe link in any email.

Please note that withdrawal of consent:

Does not affect the lawfulness of processing carried out prior to the withdrawal;
May limit or prevent your ability to use certain features of the Platform;
Does not override Hutweo’s right to retain data as required by applicable law.

9.3 Consent for Sensitive Personal Data

Where Hutweo processes sensitive personal data (such as government identification documents submitted for verification purposes), we will obtain your explicit, informed consent prior to such processing. Such data will be used exclusively for the stated purpose (identity/ownership verification) and will not be shared with any third party except as required by law.

10. FUTURE DATA COLLECTION — GOVERNMENT IDENTIFICATION

10.1 Introduction of KYC-Type Verification in future phases

Hutweo may, in future phases of its operations, introduce a mandatory or optional verification process requiring Users (particularly Listers) to submit government-issued identification such as Aadhaar, PAN Card, or other official documents to establish identity and property ownership.

ADVANCE NOTICE: If and when Aadhaar, PAN, or other government-issued ID for identification is introduced, Hutweo will:

Issue a minimum of 30 days’ advance notice to all registered Users via email and Platform notification;
Obtain fresh, explicit, and affirmative consent from each User before collecting such data;
Update this Policy to reflect the new data collection practices;
Provide Users the option to opt out, with clear information about the consequences of doing so.

10.2 Safeguards for Government ID Data

When government ID data for identification is introduced, Hutweo commits to the following safeguards:

Explicit Consent: Individual, affirmative consent will be obtained from each User before government ID data is collected — pre-ticked boxes or blanket acceptance will not suffice;
Purpose Limitation: Government ID data will be used exclusively for identity verification and fraud prevention purposes. It will not be used for marketing, profiling, or any other purpose.
Minimal Collection: Only the minimum necessary data required for the stated verification purpose will be collected;
Secure Storage: Government ID data will be stored in a separately secured, access-controlled database with enhanced encryption;
Limited Retention: Government ID data will be retained only for the period required for verification and for mandatory legal compliance, after which it will be securely deleted.
No Third-Party Sharing: Government ID data will not be shared with any third party except where mandated by law or a court order.

10.3 Compliance with Aadhaar Regulations

If Aadhaar-based verification is introduced, Hutweo will comply with all applicable provisions of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016, the Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2020, and any guidelines or circulars issued by UIDAI, and will use only UIDAI-approved authentication mechanisms.

11. YOUR RIGHTS AS A DATA PRINCIPAL

Under the Digital Personal Data Protection Act, 2023 and applicable Indian data protection laws, you have the following rights with respect to your personal data. These rights may be exercised by submitting a written request to hutweo@gmail.com.

Your Right	What It Means	How to Exercise
Right to Access	Request a copy of all personal data held by Hutweo about you, including the categories processed and the purposes for which it is used.	Email request to hutweo@gmail.com
Right to Correction	Request correction of any inaccurate, incomplete, or outdated personal data held by Hutweo.	Email request or self-service via account settings
Right to Erasure	Request deletion of your personal data, subject to our legal retention obligations and legitimate interests.	Email request; data deleted within 30 days of verification
Right to Withdraw Consent	Withdraw consent to processing at any time, without affecting the lawfulness of prior processing.	Email request or unsubscribe link
Right to Restrict Processing	Request that Hutweo restricts the processing of your data in certain circumstances (e.g., while a correction request is being verified).	Email request to hutweo@gmail.com
Right to Data Portability	Request a copy of your personal data in a machine-readable, structured format.	Email request; fulfilled within 30 days
Right to Grievance Redressal	File a complaint with Hutweo’s Grievance Officer and receive acknowledgement within 48 hours and resolution within 15 days.	Email to hutweo@gmail.com
Right to Nominate	Nominate another individual to exercise your data rights in the event of your death or incapacity (as provided under DPDP Act).	Written nomination form — contact us for the form

11.1 Exercising Your Rights — Process

To exercise any of the rights listed above:

Send a written request to hutweo@gmail.com with the subject line: “Data Rights Request — [Type of Request]”;
Include your registered email address, full name, and a description of the right you wish to exercise;
We may ask you to verify your identity before processing your request.
We will acknowledge your request within 48 hours and respond substantively within 30 days.

Hutweo may decline requests to delete or restrict data where retention is required by law, for fraud prevention, or for the establishment, exercise, or defence of legal claims.

11.2 Right to Lodge a Complaint

If you believe that Hutweo has violated your data privacy rights, you may:

First, contact our Grievance Officer at hutweo@gmail.com;
If your complaint is not resolved satisfactorily, escalate to the Data Protection Board of India (once constituted and operational under the DPDP Act);
Seek legal remedies before a court of competent jurisdiction as provided under applicable law.

12. CHILDREN’S PRIVACY

The Hutweo Platform is strictly intended for individuals who are 18 years of age or older. Hutweo does not knowingly collect, solicit, or process personal data from individuals under the age of 18 (“minors”).

If you are a parent or legal guardian and believe that your minor child has provided personal data to Hutweo without your consent, please contact us immediately at hutweo@gmail.com. Upon verification, Hutweo will:

Promptly delete the personal data of the minor from our systems;
Terminate the minor’s account, if applicable;
Investigate how the data was collected and take corrective action to prevent recurrence.

By using the Platform, you represent and warrant that you are at least 18 years of age. If Hutweo discovers that a User is a minor, their account will be suspended and their data will be deleted without notice.

13. THIRD-PARTY PLATFORMS AND EXTERNAL LINKS

13.1 Links to Third-Party Platforms

The Platform may contain links to external websites, applications, or third-party services (including social media platforms, payment gateways, and mapping tools). These links are provided for your convenience and do not constitute an endorsement by Hutweo.

Hutweo has no control over and assumes no responsibility for the content, privacy practices, or data handling of any third-party platform. When you navigate to a third-party platform, you are subject to that platform’s privacy policy and terms of use, not this Policy. We strongly encourage you to review the privacy policies of any third-party platform you visit.

13.2 Third-Party SDKs and Integrations

The Platform may integrate third-party software development kits (SDKs) and tools — such as Google Analytics, Meta Pixel, Firebase, or Razorpay — which may independently collect certain data from your device or browser in accordance with their own privacy policies. Hutweo endeavors to use only reputable, privacy-conscious third-party integrations and contractually restricts their use of your data.

14. PLATFORM COMMUNICATIONS AND MARKETING

14.1 Transactional Communications

Hutweo may send you transactional communications that are necessary for the operation of your account and the delivery of our services. These include:

Account registration and verification emails / OTPs;
Subscription confirmation, invoice, and payment receipt notifications;
Contact Unlock confirmation messages;
Important Platform updates, policy changes, or security alerts.

Transactional communications are service communications and cannot be opted out of while your account is active, as they are necessary for service delivery.

14.2 Marketing and Promotional Communications

Hutweo may, with your separate and explicit consent, send you marketing communications such as:

Promotional offers, discounts, or new subscription plan announcements;
Platform tips, feature highlights, and user guides;
Market reports or property trend updates.

You may opt out of marketing communications at any time by clicking the “Unsubscribe” link in any marketing email, or by submitting a request to hutweo@gmail.com. Opting out of marketing communications does not affect your receipt of transactional communications.

15. GRIEVANCE REDRESSAL MECHANISM

15.1 Designated Grievance Officer

In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the DPDP Act, Hutweo has designated a Grievance Officer responsible for addressing User complaints related to personal data and Platform conduct.

GRIEVANCE OFFICER — HUTWEO SOLUTIONS

Name: [To be updated upon appointment]

Designation: Grievance Officer & Data Protection Officer

Organisation: Hutweo Solutions Email: hutweo@gmail.com

Subject Line: ‘Privacy Grievance — [Nature of Complaint]’

Acknowledgement: Within 48 hours of receipt

Resolution Target: Within 15 days of acknowledgement

Escalation: Data Protection Board of India (once operational)

15.2 Grievance Filing Process

To file a grievance related to this Privacy Policy:

Send an email to hutweo@gmail.com with the subject line: “Privacy Grievance — [Brief Description]”;
Include your full name, registered email, the nature of the grievance, relevant dates, and any supporting evidence;
Hutweo will acknowledge your grievance within 48 hours.
Hutweo will resolve your grievance and communicate the outcome within 15 days of acknowledgement.
If dissatisfied with the resolution, you may escalate to the Data Protection Board of India or seek applicable legal remedies.

16. UPDATES AND AMENDMENTS TO THIS POLICY

16.1 Right to Amend

Hutweo reserves the right to amend, revise, or replace this Privacy Policy at any time to reflect changes in applicable law, our data practices, or the features of the Platform. All changes will be published on the Platform with an updated “Last Updated” date at the top of this Policy.

16.2 Notification of Material Changes

For material changes — changes that significantly affect your rights or Hutweo’s data practices — we will provide advance notice of at least 30 days through one or more of the following:

Email notification to your registered email address;
A prominent banner or pop-up notification on the Platform;
A separate announcement in the Platform’s notification centre.

16.3 Continued Use Equals Acceptance

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request deletion of your account and personal data in accordance with Section 11.

16.4 Policy Archive

Hutweo maintains an archive of previous versions of this Policy. If you wish to review a prior version of this Policy, please contact us at hutweo@gmail.com.

17. CONTACT US

If you have any questions, concerns, or requests related to this Privacy Policy or Hutweo’s data practices, please contact us through any of the following channels:

Hutweo Solutions — Privacy Team

Email: hutweo@gmail.com

Subject Line: ‘Privacy Query — [Your Name]’

Platform: www.hutweo.com

For urgent data breach concerns, please use the subject line: ‘URGENT — Data Breach / Security Concern’

Operating Hours: Monday to Friday, 10:00 AM to 6:00 PM IST

We endeavour to respond to all privacy-related queries within 3 business days

YOUR ACKNOWLEDGEMENT

By accessing or using the Hutweo Platform, you acknowledge that:

You have read this Privacy Policy in its entirety;
You understand how your personal data is collected, used, stored, and shared;
You consent to the data practices described herein;
You are aware of your rights as a Data Principal and how to exercise them;
You are at least 18 years of age and legally competent to consent to the processing of your data.

If you do not agree with any provision of this Privacy Policy, please discontinue use of the Platform immediately.

— End of Terms & Conditions —

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