Privacy Policy

1. Who we are

GAP Group and its affiliates (collectively, “GAP Group”, “we”, “us” or “our”) respect your privacy and are committed to protecting your data. For the data you provide through our Website, GAP Group determines the purposes for which and the manner in which such information is processed and therefore acts as the Data Fiduciary, as defined under the Digital Personal Data Protection Act, 2023, wherever applicable.

GAP Group is engaged in the business of real estate development and related activities, including the development, promotion, sale, lease and management of residential and commercial properties.

This Privacy Policy (“Policy”) outlines our practices regarding the collection, receipt, storage, use, processing, disclosure and protection of data that you provide to us or that we collect when you access or use our website, https://gapgroup.in (“Website”), submit an enquiry, express interest in our projects or properties, request project details or brochures, enquire about purchasing or leasing a property, schedule a site visit, communicate with us, engage as a channel partner or broker, apply for a career opportunity, or otherwise interact with us through our Website or other communication channels (collectively, the “Services”).

Please read this Policy together with our Terms of Use. By using our Services, you confirm that you have read and understood this Policy. We will obtain your consent wherever required by law.

2. Definitions and key concepts

• “Personal Information / Data” means personal information, including sensitive personal information and special category personal data (as defined under applicable Data Protection Laws) about you, which we collect, receive or otherwise process in connection with your access to or use of our Website and Services.
• “User” or “you” means any person who visits or uses our Website or Services.
• “Website” means GAP Group’s website, https://gapgroup.in.
• “Cookies” means small files stored on your device when you visit our Website. These help the Website remember your preferences and improve your browsing experience.
• “Data Protection Laws” means any applicable law for the time being in force relating to the processing of data.
• “Partners” means third parties, including business associates, channel partners and brokers, with whom GAP Group works in connection with its business.
• “Service Providers” means third parties engaged by GAP Group to provide services such as website hosting, technology, communication, marketing and data management.
• “Data Fiduciary” means any person who alone or in conjunction with other person(s) determines the purpose and means of processing of personal data.
• “GAP Group” means GAP Group and its relevant affiliates and entities involved in its real estate and related business activities.

Our role as Data Controller or Data Processor: depending on the purpose of processing, GAP Group may act as a “Data Controller” when we decide how and why your data is used, or as a “Data Processor” when we process your data on behalf of another group entity or third party and follow their instructions.

3. What we collect

We collect data that you provide to us or that is generated when you use our Website and Services. Depending on your interaction with us, this information may include, but is not limited to, the following:

Not all categories apply to every user. Financial and transaction information may be collected separately where relevant to a property transaction or service. GAP Group does not store credit or debit card details on its Website.

4. How we collect data

• Information you provide to us: we collect and store information that you submit through our Website, forms and career applications, or provide to us through other communication channels.
• Automatic information we collect: we may automatically collect certain technical information when you visit or use our Website. We use cookies and similar technologies to collect and store information about your Website activity. See Cookies, analytics and advertising.
• Customer support: we collect and store information you provide when contacting our team with enquiries, requests or concerns through our available communication channels.
• Information collected through third-party content: when you access maps or videos embedded on our Website, third-party providers such as Google Maps, YouTube and OpenStreetMap/Carto may automatically receive technical information, including your IP address and browser details.
• Information from other sources: where applicable, we may receive your data from other GAP Group entities, channel partners, brokers or business associates in connection with enquiries, referrals or business relationships.
• Information previously shared with GAP Group entities: where you have previously provided your data to any entity within GAP Group, that entity may share relevant information with us, where permitted under applicable law and where necessary for the purposes described in this Policy. Where your consent is required for such sharing, the information will be shared only after obtaining your consent. We will process the information received in accordance with this Policy and applicable Data Protection Laws.
• Use of feedback: by using our Website, you acknowledge and agree that GAP Group may use and display feedback, reviews or opinions shared by you on its Website and in its marketing and promotional materials.

5. Sharing of data

We may share your data in the following circumstances:

Within GAP Group: we may share your data with the relevant teams or departments within GAP Group to handle your requests and provide the required assistance.

Service Providers: we engage third-party service providers to support the operation, maintenance, security and functionality of our Website. These providers may access or process data only as necessary to perform their services for us.

Other third parties: we may share your data with relevant third parties, where necessary, to fulfil your requests, provide our services, complete transactions or support our business operations, in accordance with applicable laws.

Third-party websites: our Website may contain links to or content from third-party websites and services. When you access such content, the relevant third party may collect information in accordance with its own privacy policy. GAP Group is not responsible for the privacy practices of independent third-party websites.

Legal disclosure: we may disclose your data where required or permitted under applicable law, including in response to a court order or a request from a government or regulatory authority.

Marketing within GAP Group: we reserve our right to share the information collected within the GAP Group entities and internal departments for promotional and marketing activities and communications.

Outside India: some of our service providers may store or process your data outside India, depending on the location of their servers and infrastructure. Any such transfer will be carried out in accordance with applicable data protection laws, including relevant requirements under the Digital Personal Data Protection Act, 2023, and applicable rules.

6. How we use data and consent

We use your data for the purposes described in this Policy. Where processing is based on your consent, we obtain it through the relevant form or consent mechanism. Depending on the form or service you use, the following consent notices may be displayed:

• Website Terms and Privacy Policy, Agree button: “By clicking ‘Agree’, you confirm that you have read and agree to GAP Group’s Terms of Use and Privacy Policy.”
• Enquiry forms, submission consent: “By sending, you agree GAP Group may contact you about this enquiry.”
• Career applications, consent tick box: “I agree that GAP Group may use my details and CV to consider my application and contact me about it.”

Where a consent notice is displayed, the relevant notice may include a link to this Policy. By clicking the “Agree” button, submitting the relevant enquiry form or selecting the career application consent checkbox, as applicable, you provide your agreement or consent for the purpose stated in that notice.

You may withdraw your consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing carried out before such withdrawal. Once your consent is withdrawn, we will stop processing your data for the relevant purposes, unless continued processing is permitted or required under applicable law.

7. Data security

We take reasonable technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, loss or misuse. Our Website uses HTTPS encryption, and information submitted through our forms is stored in restricted-access systems accessible only to authorized GAP Group personnel and relevant service providers where necessary.

We regularly take appropriate measures to maintain the security of our Website and protect the information entrusted to us. However, no method of electronic storage or transmission over the internet is completely secure, and we cannot guarantee absolute security.

If you suspect any misuse, loss or unauthorized access to your data, please notify us immediately at marketing@gapgroup.in. We will take appropriate steps to investigate and address the matter in accordance with applicable laws.

8. Permissible age

Our Website and Services are not intended for individuals under the age of 18. We do not knowingly collect or solicit data from children under the age of 18 without the consent of their parent or legal guardian, wherever required under applicable laws.

If we become aware that data has been collected from a child without the required parental or guardian consent, we will take appropriate steps to delete such information in accordance with applicable laws.

If you believe that a child has provided us with personal information, please contact us at marketing@gapgroup.in.

9. Cookies, analytics and advertising

Cookies are small text files stored in your browser when you visit our Website. We also use similar technologies, such as session storage, to remember your preferences and improve your browsing experience. We use the following categories of cookies and similar technologies:

• Strictly necessary cookies: these cookies are required for the proper functioning of our Website and to remember your cookie preferences. They do not require your consent.
• Analytics cookies: we may use Google Analytics to understand how visitors use our Website, including pages viewed, clicks and browsing activity. These cookies remain disabled until you provide your consent.
• Advertising cookies and technologies: Google Ads and the Google Analytics Advertising Features we may use: Google signals, remarketing, conversion measurement, and demographics and interests reports. These stay off until you press Accept. They let us show our ads to people who have visited the Website, count ad clicks that lead to an action here, and see grouped reports about our audience. We and Google use first-party cookies, such as the Google Analytics cookie, together with third-party cookies and identifiers, such as Google’s advertising cookie, for this. Accept covers both analytics and advertising.
• Embedded content: our Website may include content from third-party services, such as Google Maps, YouTube and OpenStreetMap/Carto. When you access maps or play embedded videos, these third-party providers may collect technical information, including your IP address and browser details, in accordance with their respective privacy policies.
• Third-party cookies: certain third-party providers, including Google, may place cookies or use similar technologies when you interact with their services on our Website. Their use of such information is governed by their own privacy policies.

The following table provides details of certain cookies and technologies that may be used on our Website:

You may change or withdraw your cookie preferences at any time with the button below. It will reset your previous cookie selection, remove applicable analytics and advertising cookies set through our Website, where technically possible, and display the cookie consent option again so that you can make a new selection.

You may also block or delete cookies through your browser settings. However, blocking strictly necessary cookies may affect certain Website features and functionality, and your cookie preferences may not be remembered.

Google also provides a browser add-on that allows you to opt out of Google Analytics measurement across websites.

You may manage your personalized advertising preferences through Google My Ad Center. You may also opt out of certain online advertising practices through the Network Advertising Initiative.

For more information about how Google uses information collected through websites and applications that use its services, please refer to Google’s Privacy Information.

10. Retention of data

We retain your data only for as long as necessary to fulfil the purposes for which it was collected, provide our services, comply with applicable legal and regulatory requirements, resolve disputes and protect our legitimate business interests. Retention periods may vary depending on the type of information and purpose of processing.

Because these needs can vary for different data types and purposes, actual retention periods can vary significantly. Even if we delete your data, including on account of an exercise of your rights described below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

11. Where we store data

Your data may be stored or processed in India or in other countries where our third-party service providers maintain their servers and infrastructure. Accordingly, your information may be transferred outside the country in which it was originally collected. We take reasonable steps to ensure that such transfers are carried out in accordance with applicable Data Protection Laws and that appropriate security and data-protection safeguards are maintained.

If the GDPR or UK GDPR applies to our processing of your data, we will process or transfer your data outside the European Economic Area or the United Kingdom only where the transfer complies with applicable Data Protection Laws and appropriate safeguards are in place to protect your data. Such transfers may take place:

• under a data transfer agreement incorporating the applicable Standard Contractual Clauses approved for use in the European Economic Area or the United Kingdom;
• to a country recognized by the European Commission or the relevant UK authority as providing an adequate level of data protection; or
• where the transfer is necessary for entering into or performing a contract between us and a third party, and the transfer is in your interest in connection with that contract.

12. Your rights and choices

Subject to applicable Data Protection Laws, you have certain rights regarding your data collected and processed by GAP Group. You may exercise these rights by contacting us using the details under How to contact us. We may request reasonable information to verify your identity before processing your request.

Under the Digital Personal Data Protection Act, 2023, where applicable, you have the following rights:

• Right to access: you may ask us to confirm whether we hold your data and request a copy of it. You may also ask us to correct, update or delete your information, subject to applicable laws.
• Right to rectification: you may request us to correct or complete any inaccurate or incomplete data we hold about you.
• Right to erasure: you may request us to delete your data, subject to applicable legal requirements.
• Right to withdraw consent: you may withdraw your consent to the processing of your data at any time, where the processing is based on consent.
• Right to grievance redressal: you may raise a complaint with us if you have any concerns about how we handle your data.
• Right to file a complaint: you may raise a complaint with GAP Group regarding the handling of your data and, where applicable, approach the relevant authority under applicable Data Protection Laws.
• Right to nominate: you may nominate another person to exercise your rights if you die or become unable to for any other reason.

To exercise these rights or ask questions about your data and promotional communications, please contact us using the details under How to contact us.

Please ensure that the data you provide to us is accurate and up to date. If any of your information changes, kindly inform us so that we can update our records.

13. Processing of data

We take appropriate steps to ensure that your data is processed in accordance with this Policy and applicable laws.

14. Severability

If any provision of this Policy is found to be invalid or unenforceable by a court or competent authority, the remaining provisions will continue to remain valid and effective.

15. Links to third-party websites

Our Website may contain links to third-party websites or services. When you visit these websites, their own privacy policies and terms will apply. GAP Group is not responsible for how these third parties collect, use or protect your data. We encourage you to review their privacy policies before sharing any data or using their services.

16. Changes to this Policy

We may update this Policy from time to time. Any changes will be posted on our Website along with the revised “Last updated” date. Your continued use of our Website after the updated Policy is published will be subject to the revised Policy.

If we intend to use your data for a new purpose that is different from the purpose for which it was originally collected, we will inform you and obtain your consent wherever required under applicable laws.

17. How to contact us

To request access to, correction of, or deletion of your data, withdraw your consent, raise a grievance or ask any questions about this Policy, you may contact us at:

Email: marketing@gapgroup.in
Head Office: 1103, Palak Prime, Opposite DoubleTree by Hilton, Iscon Ambli Road, Ahmedabad, Gujarat 380058.

We will review and respond to your request within the time prescribed under applicable laws.

18. Grievance Officer

For any complaints or grievances relating to this Policy or the processing of your data, you may contact our Grievance Officer at the details below:

Name: Hinal Patel
Email: marketing@gapgroup.in

The Grievance Officer will address complaints and grievances in accordance with applicable laws, including the Information Technology Act, 2000, the Consumer Protection Act, 2019, and the rules made under them, wherever applicable.