This Privacy Policy applies to all services provided by Hall Mark Realtors through our website, mobile applications, and in-person consultations. By engaging our services, you agree to the terms described herein.
Introduction
Hall Mark Realtors ("we," "us," or "our") is committed to protecting the privacy and personal information of every client, prospect, and visitor who engages with our services. This Privacy Policy outlines the types of personal data we collect, how we use it, and the rigorous safeguards we have in place to ensure it remains confidential, secure, and used exclusively for the purposes for which it was provided.
As a RERA-registered brokerage operating under MahaRERA Registration No. A518000XXXXX, we are bound by the Real Estate (Regulation and Development) Act, 2016, in addition to applicable provisions of the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023 (DPDPA). Our practices are also aligned with global best practices including GDPR principles.
We believe that transparency is not merely a legal obligation — it is the foundation of every client relationship we build. Our flat 1% brokerage model itself is a testament to this conviction.
Information We Collect
We collect only the personal information necessary to deliver our brokerage services effectively. The categories of data we may collect include:
Personal Identification Data
- Full name, as provided via lead capture forms, site visit bookings, or in-person consultation
- Phone number and email address for direct advisory communication
- Government-issued ID documents (Aadhaar, PAN) collected only when legally required for transaction processing
Property & Financial Preferences
- Desired property type (residential, commercial, luxury rental, investment)
- Budget range and preferred micro-markets within Mumbai
- Timeline for purchase or rental decision-making
- Financing preferences (self-funded, home loan, NRI remittance)
Technical & Behavioural Data
- Device type, browser version, and approximate geographic location (city level)
- Pages visited, time spent on property listings, and search filter preferences
- IP address for security and fraud prevention purposes
We do not collect biometric data, caste, religion, political affiliation, or any other sensitive personal data as defined under the DPDPA 2023.
How We Use Your Data
All data collected by Hall Mark Realtors is used solely for the purpose of delivering a high-quality, transparent brokerage experience. Specific uses include:
- Scheduling and confirming property site visits at your convenience
- Providing personalised consultation on our flat 1% brokerage model and what it means for your transaction savings
- Sending RERA-compliant updates on project status, possession timelines, and regulatory changes relevant to your enquiry
- Connecting you with pre-vetted developers, project teams, or home loan advisors strictly upon your explicit request
- Improving our internal CRM to provide faster, more accurate service over time
- Legal compliance including maintaining transaction records as mandated by MahaRERA
We do not use your data to build marketing profiles for third-party advertisers, and we do not engage in automated decision-making or profiling that produces legal or similarly significant effects.
Legal Basis for Processing
Consent
Lead forms and newsletter subscriptions
Contractual
Processing your property transaction
Legal Obligation
RERA & MahaRERA compliance
Legitimate Interest
Service improvement and fraud prevention
1% Transparency Clause
Special Category: Financial Transaction Data
Any and all financial information shared with Hall Mark Realtors in connection with our flat 1% brokerage fee — including deal values, payment schedules, loan disbursement details, and stamp duty calculations — is treated as strictly confidential financial data and afforded the highest level of protection within our systems.
This data is accessible only to the assigned advisor and senior management on a strict need-to-know basis. It is never shared with marketing teams, third-party analytics platforms, or any external party not directly involved in your transaction.
Our 1% brokerage model is, by design, fully disclosed upfront. There are no additional fees, referral commissions, or builder-side incentives that affect our advice. This financial transparency is reflected equally in how we protect your transactional data: completely, and without exception.
- Brokerage invoices and receipts are generated only in your name and stored in encrypted format
- Deal-specific financial summaries are never aggregated into public or semi-public reporting
- Access logs are maintained for all records accessed by internal staff
- Financial data is deleted or anonymised within 7 years of transaction completion, as required by applicable law
Third-Party Disclosure
Hall Mark Realtors does not sell, lease, rent, or trade your personal data to any third-party marketing companies, data brokers, or external advertising networks — under any circumstances.
Limited disclosures may occur only in the following tightly controlled situations:
- To RERA-registered developers or project teams — only when you have expressly requested an introduction or site visit booking for their specific project
- To home loan advisors or partner banks — only when you have explicitly asked us to initiate a pre-approval or eligibility check on your behalf
- To legal counsel or chartered accountants — only when engaged directly by you to facilitate due diligence on a specific transaction
- To regulatory or law enforcement authorities — only when legally required by a court order, MahaRERA directive, or equivalent legal instrument
In each case, only the minimum necessary information is shared. We require all third parties to sign a data processing agreement confirming they will handle your information with equivalent standards of confidentiality.
Our commitment: You will never receive unsolicited marketing calls from builders, banks, or any third party as a result of an enquiry made through Hall Mark Realtors. Your contact details are not tradeable commodities.
Your Rights
Under the Digital Personal Data Protection Act, 2023 (DPDPA) and aligned international frameworks, you hold the following rights regarding your personal data held by us:
Right of Access
Request a copy of all personal data we hold about you
Right to Correction
Request correction of inaccurate or outdated information
Right to Erasure
Request deletion of your data, subject to legal retention obligations
Right to Portability
Receive your data in a structured, machine-readable format
Right to Withdraw
Withdraw consent at any time without affecting prior processing
Right to Grievance
Lodge a complaint with our DPO or with the Data Protection Board of India
To exercise any of the above rights, contact our Data Protection Officer at legal@hallmarkrealtors.in. We will respond within 30 days of a verified request.
Data Security
We implement a multi-layered security framework to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:
- TLS 1.3 encryption for all data transmitted between your device and our servers
- AES-256 encryption for data stored in our CRM and document management systems
- Role-based access controls limiting staff access to only the data relevant to their function
- Regular third-party security audits and penetration testing
- Two-factor authentication required for all internal system access
- Automated alerts for anomalous data access patterns
In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant regulatory authority within 72 hours of becoming aware of the incident, in accordance with applicable law.
Changes to This Policy
We periodically review and update this Privacy Policy to reflect changes in our services, applicable law, or industry best practices. When we make material changes, we will:
- Update the 'Last Updated' date at the top of this document
- Display a prominent notice on our website homepage for a period of no less than 30 days
- Email registered clients whose data processing is materially affected by the change
We encourage you to review this Policy periodically. Continued use of our services after the effective date of a revised Policy constitutes your acceptance of the updated terms.
Contact Our Data Protection Officer
Effective Date: 15 March 2026 · Version 3.1