Lovely Home Creators ("we", "us", "our", "Company", or "Data Fiduciary") is committed to protecting the privacy and security of the personal data of the tenants, prospective tenants, joint tenants, guarantors, property owners, vendors and internal staff (collectively, "Users", "Data Principals", or "you") whose information is recorded in the LHC NEST rental and property management platform (the "Application" or "Platform").
This Privacy Policy ("Policy") is issued in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 ("Aadhaar Act") to the extent applicable, and other applicable provisions of Indian law governing the processing of personal data.
This Policy sets forth the manner in which personal data is collected, used, stored, processed, disclosed, retained, and protected by the Company in connection with the Application, which is an internal enterprise system used exclusively to administer residential and commercial rental properties — property and unit records, tenant records, rental agreements, rent receipts and ledgers, deposits and advances, maintenance and expenses, and statutory reporting.
The Application is delivered as a web back office and a companion mobile application for authorised staff of Lovely Home Creators. It is not a consumer application and is not offered to tenants for self-service.
By accessing, downloading, installing, or using the Application, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with any provision of this Policy, you must immediately cease using the Application and notify the Company.
For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them below, in addition to the meanings provided under the DPDP Act, 2023:
This Privacy Policy applies to all personal data collected, processed, stored, and disclosed by Lovely Home Creators through the Application. The scope of this Policy encompasses:
This Policy does not apply to personal data collected offline or through channels other than the Application, unless specifically stated otherwise. This Policy also does not govern the privacy practices of third-party websites, applications, or services that may be linked to or integrated with the Application, and Users are advised to review the privacy policies of such third parties independently.
Access to the Application is restricted to authorised personnel aged eighteen (18) years or above. Tenant records may only be created for individuals of legal contractual capacity.
The Company collects the following categories of personal data through the Application in order to administer tenancies, collect and account for rent, and meet statutory obligations:
The collection and handling of Aadhaar and PAN details is subject to the additional safeguards set out in Section 8 of this Policy.
For the avoidance of doubt, and as a matter of design, the Application does not collect any of the following:
The Company processes personal data collected through the Application solely for the following lawful purposes related to the administration of its rental properties:
The Company shall not use personal data for any purpose beyond those explicitly stated in this Policy without obtaining prior consent from the Data Principal, except where permitted or required by law. Personal data collected through the Application is never used for advertising, profiling for commercial gain, or sale to any third party.
The Company processes personal data in accordance with the DPDP Act, 2023, and other applicable laws. The legal bases for processing personal data through the Application include:
Tenants, joint tenants and prospective tenants provide their personal data and identity documents to the Company voluntarily, for the stated purpose of entering into and administering a tenancy, and consent is obtained at or before the point of collection. Internal staff provide consent through a clear affirmative action at onboarding and first login. Consent may be withdrawn at any time in accordance with Section 17 of this Policy.
Processing of personal data is necessary for the performance of the rental agreement between the tenant and the lessor, and of the employment or engagement arrangements between the Company and its staff. Identity particulars, contact details, occupancy dates and payment records are indispensable to issuing a valid agreement and receipt, and to accounting for rent. Failure to provide such data may result in the Company being unable to execute or continue a tenancy.
The Company processes personal data to comply with statutory obligations under Indian law, including obligations under the Goods and Services Tax laws, the Income-tax Act, 1961 (including tax deduction at source on rent), the registration and stamp duty requirements applicable to rental instruments, state tenancy and rent control legislation and any applicable tenant registration or police verification requirements, and the maintenance of books of account and supporting records.
The Company processes personal data where necessary to pursue legitimate business interests, including protecting property from damage and misuse, preventing rent default and fraud, maintaining the integrity and auditability of financial records, resolving disputes, and improving the Application, provided that such interests do not override the fundamental rights and freedoms of Data Principals.
SDK Infinity Technologies serves as the Data Processor for Lovely Home Creators in relation to personal data processed through the Application. The roles and responsibilities are delineated as follows:
SDK Infinity Technologies processes personal data exclusively on behalf of and in accordance with the documented instructions of Lovely Home Creators as the Data Fiduciary. SDK Infinity Technologies does not determine the purposes or means of processing and acts solely as a technology service provider responsible for the development, hosting, maintenance, and technical support of the Application.
SDK Infinity Technologies has implemented appropriate technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, and destruction. SDK Infinity Technologies shall not use, disclose, or transfer personal data for any purpose other than as instructed by the Data Fiduciary or as required by applicable law.
The relationship between Lovely Home Creators and SDK Infinity Technologies is governed by a formal Data Processing Agreement that stipulates the scope of processing activities, data security obligations, confidentiality requirements, breach notification procedures, and compliance with applicable data protection laws.
SDK Infinity Technologies may engage sub-processors, including cloud hosting providers and infrastructure service providers, to assist in processing personal data. Any such sub-processors are contractually obligated to maintain equivalent security standards and comply with applicable data protection requirements. SDK Infinity Technologies shall ensure that sub-processors process personal data only in accordance with the instructions of the Data Fiduciary.
For inquiries or concerns related to data processing activities performed by SDK Infinity Technologies, Data Principals may contact:
SDK Infinity Technologies
6, 2nd Street, VOC Colony, Kodambakkam
Chennai, Tamil Nadu 600024, India
Email: goalsplanner.sdk@gmail.com
The Application records statutory identifiers and identity documents furnished by tenants for the purpose of verifying identity before a tenancy is granted. Data Principals are hereby informed of the following:
Aadhaar, PAN, GSTIN and uploaded identity or address proof documents are collected and retained solely to:
Furnishing an Aadhaar number is voluntary. Where a tenant declines to furnish Aadhaar, the Company will accept an alternative officially valid document — such as a passport, driving licence, voter identity card, or such other document as the Company may reasonably accept — for the purpose of identity and address verification. No tenancy is refused solely on the ground that Aadhaar was not furnished, where an acceptable alternative is provided.
A Data Principal may at any time request correction of an inaccurate identifier, request that a superseded identity document be removed, or object to the continued retention of a particular document, by contacting the Grievance Officer as set out in Section 16. The Company will act on such requests subject only to its statutory retention obligations.
The Application requests access to the device camera, photo library and file storage for operational purposes related to property documentation and record keeping. Data Principals are informed as follows:
Camera access is used for the following purposes only:
The camera is activated only in response to a deliberate action by the user within the Application. The Application does not access the camera in the background and does not capture images without an explicit user action.
The Application may request access to the device photo library or file storage so that an existing photograph or document can be attached to a tenant, unit, agreement or expense record. Only the files a user explicitly selects are read and uploaded. The Application does not scan, index or transmit the contents of the device photo library or file system.
Uploaded photographs and documents are stored together with the file name, the date of upload and the identity of the staff member who uploaded them. This information constitutes the audit trail that establishes who added a record and when. As stated in Section 4.8, the Application does not collect or attach GPS location metadata.
Users may revoke camera, photo library and storage permissions at any time through device operating system settings. Revoking these permissions does not affect the ability to view existing records, but will prevent the capture of new condition photographs and the upload of new documents from the affected device.
Lovely Home Creators does not sell, rent, trade, or otherwise commercialize personal data collected through the Application. Personal data may be shared or disclosed only under the following circumstances:
Personal data may be accessed by authorised staff of Lovely Home Creators on a need-to-know basis for legitimate operational purposes. Access is governed by role-based permissions. The Application defines two roles: Administrator, which may create, amend and delete records and alone may access agreement templates, billing entity particulars and the statutory reporting registers; and Accountant, which may record day-to-day tenancy and collection activity but may not delete records and has no access to those restricted areas. Records are additionally scoped to the company or billing entity to which a user is assigned, so that a user cannot view records belonging to another entity.
Where a unit is owned by a lessor on whose behalf the Company administers the tenancy, tenancy and collection particulars relating to that lessor's own units — including tenant name, agreement terms, rent received and arrears — are made available to that lessor for the purpose of accounting and statutory reporting. Identity documents are shared with a lessor only where necessary for the execution of the agreement or where required by law.
Personal data is shared with SDK Infinity Technologies in its capacity as Data Processor for the purpose of hosting, maintaining, and providing technical support for the Application. SDK Infinity Technologies processes personal data solely on behalf of Lovely Home Creators and in accordance with documented instructions.
Personal data may be shared with third parties engaged by the Company for specific operational or professional functions, including:
All such third parties are bound by confidentiality obligations, are required to implement appropriate security measures, and may process personal data only for the purposes specified by the Company. They are prohibited from using personal data for their own purposes or disclosing it to unauthorised parties.
Personal data may be disclosed to government authorities, regulatory bodies, law enforcement agencies, courts, or other public authorities where required or permitted by law, including:
In the event of a merger, acquisition, reorganization, transfer of a property portfolio, or other business transfer involving Lovely Home Creators, personal data may be transferred to the successor entity, provided that such entity agrees to honor the terms of this Privacy Policy or provides Data Principals with notice and an opportunity to withdraw consent where required by law.
The Company may share aggregate, anonymized, or de-identified data that does not identify individual Data Principals — such as occupancy rates, collection efficiency or portfolio yield — for business analytics, benchmarking, or other lawful purposes. Such data is processed in a manner that prevents re-identification.
The Company carefully vets any third-party service integrated with the Application to ensure compliance with applicable data protection laws and contractual obligations. The current position is as follows:
The Application and its database are hosted on secure cloud infrastructure provided by reputable service providers that maintain industry-standard security certifications, including ISO 27001, SOC 2, and other relevant compliance frameworks. Data is stored within data centres located in India or in other jurisdictions subject to adequate data protection safeguards.
The Application provides pre-written message templates for common tenant communications, such as rent reminders, receipt intimations and renewal notices. These templates are copied by a staff member and pasted into their own messaging application. The Application does not integrate with the WhatsApp Business API, any SMS gateway, or any other messaging service, and never sends a message automatically. No tenant phone number or message content is transmitted from the Application to any messaging provider.
The Application does not use a push notification service. No device push token is generated, collected or transmitted, and no personal data is routed through a push notification provider.
The Application does not process card payments or collect payment credentials. Rent is paid directly to the lessor's bank account through the tenant's own banking channel; the Application records only the fact, amount, date, mode and receiving bank of a payment for accounting purposes.
Where technical monitoring is used, it is limited to error and crash diagnostics and Application performance measurement, is processed in a manner that minimises the collection of personally identifiable information, and is used solely for operational improvement.
The Application does not integrate third-party advertising networks, tracking pixels, or behavioural advertising technologies. The Application does not track Users across third-party websites, applications, or platforms. Personal data is not used for advertising purposes or shared with advertisers.
Lovely Home Creators retains personal data for the duration necessary to fulfil the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, and maintain accurate business records. Specific retention periods are as follows:
Personal data relating to a current tenant is retained for the duration of the tenancy and of any renewal, and is kept current so that agreements, receipts and ledgers remain accurate.
Following the expiry or termination of a tenancy and the settlement of the deposit, tenancy and financial records may be retained for a period of up to eight (8) years, or such longer period as may be required under applicable law, in order to:
Uploaded identity and address proof documents are retained for the duration of the tenancy and for such period thereafter as is required to defend a claim relating to the identity of the counterparty, and are then deleted. Where a Data Principal requests earlier removal of a superseded document and no legal obligation requires its retention, the Company will act on that request.
Move-in and move-out photographs are retained until the security deposit has been settled and any dispute concerning damage has been concluded, and for a reasonable period thereafter to allow for a claim to be raised. They are then deleted, save where they form part of the record in a pending proceeding.
Where an enquiry or booking does not result in a tenancy, the personal data of the prospective tenant is retained only for so long as is necessary to conclude the enquiry, and in any event for no more than twelve (12) months, after which it is deleted or anonymised.
The audit trail of changes to tenancy and financial records is retained for the same period as the underlying record, because it forms part of that record's integrity. Technical logs, error reports and diagnostic data are retained for a period of up to one (1) year, or such shorter period as is necessary for troubleshooting, security monitoring, and Application improvement.
Upon expiration of the applicable retention period, personal data is securely deleted or anonymised in accordance with industry best practices. Deletion includes removal from active databases, backup systems, and archival storage, subject to technical feasibility and legal constraints. Data Principals may request deletion of their personal data in accordance with Section 18 of this Policy, subject to the Company's legal and contractual obligations.
Lovely Home Creators and SDK Infinity Technologies implement reasonable technical, organizational, and physical security measures to protect personal data against unauthorized access, disclosure, alteration, destruction, loss, or misuse. Security safeguards include, but are not limited to:
In the event of a personal data breach, the Company shall notify the affected Data Principals and the Data Protection Board of India in the manner and within the timelines prescribed under the DPDP Act, 2023 and the rules made thereunder, and shall take prompt remedial action to contain the breach and mitigate harm.
While the Company employs reasonable security measures, no system is entirely immune to security risks. The Company cannot guarantee absolute security of personal data transmitted over the internet or stored in digital systems. Data Principals acknowledge and accept the inherent risks associated with electronic data transmission and storage.
Personal data collected through the Application is primarily processed and stored within the territory of India. However, in certain circumstances, personal data may be transferred to, or accessed from, jurisdictions outside India for the following purposes:
Where personal data is transferred outside India, the Company shall ensure that such transfers comply with applicable legal requirements, including any restriction notified by the Central Government under Section 16 of the DPDP Act, 2023, and that adequate safeguards are in place, including:
Data Principals are informed of, and consent to, cross-border transfers of personal data as described in this section, provided that such transfers are conducted in accordance with applicable law and subject to appropriate safeguards.
Data Principals are entitled to exercise the following rights under the Digital Personal Data Protection Act, 2023, subject to applicable legal limitations and exceptions:
Data Principals have the right to obtain confirmation as to whether personal data concerning them is being processed and, where applicable, to obtain a summary of such personal data, of the processing activities undertaken, and of the identities of the parties with whom it has been shared. A tenant may request a copy of their tenant record, agreement history and ledger. Access requests shall be processed within a reasonable timeframe in accordance with applicable law.
Data Principals have the right to request correction of inaccurate or misleading personal data, completion of incomplete personal data, and updating of outdated personal data — for example, a change of contact number, a corrected spelling of a name, or an updated permanent address. The Company shall verify the corrected information and update its records accordingly.
Data Principals have the right to request erasure of personal data where retention is no longer necessary for the purpose for which it was collected, subject to legal, regulatory, tax, accounting or contractual obligations that require continued retention. Erasure requests are evaluated on a case-by-case basis, and the Company will explain the reason where a request cannot be fully met.
Data Principals have the right to receive personal data concerning them in a structured, commonly used, and machine-readable format and to transmit such data to another data fiduciary, where technically feasible and permitted by law.
Data Principals have the right to file grievances regarding the processing of personal data with the designated Grievance Officer of Lovely Home Creators, and, where the grievance is not satisfactorily resolved, with the Data Protection Board of India, as provided under the DPDP Act.
Data Principals have the right to nominate another individual who may exercise their rights under the DPDP Act on their behalf in the event of death or incapacity.
The exercise of the above rights may be subject to limitations where necessary to comply with legal obligations, protect the rights and freedoms of others, preserve evidence for legal proceedings, prevent or investigate an offence, or fulfil contractual obligations. In particular, financial records underlying issued receipts, tax filings and audited accounts cannot be altered or erased on request, as their integrity is required by law. The Company shall assess each request on a case-by-case basis and provide a reasoned response.
Lovely Home Creators has established a grievance redressal mechanism in accordance with the DPDP Act, 2023, and the IT Act, 2000. Data Principals may submit grievances, complaints, or inquiries regarding the processing of personal data to the designated Grievance Officer.
Name of Grievance Officer: [To be designated]
Organization: Lovely Home Creators
Email: goalsplanner.sdk@gmail.com
Address: 6, 2nd Street, VOC Colony, Kodambakkam, Chennai, Tamil Nadu 600024, India
Grievances may be submitted in writing via email or postal mail to the Grievance Officer. The grievance must include the following information:
The Company shall acknowledge receipt of grievances within forty-eight (48) hours and shall endeavour to resolve grievances within thirty (30) calendar days from the date of receipt, subject to the complexity of the grievance and the need for investigation. Where resolution requires additional time, the Company shall provide periodic updates to the Data Principal.
If a Data Principal is dissatisfied with the resolution provided by the Company, or if the grievance remains unresolved after exhausting the internal grievance mechanism, the Data Principal may escalate the matter to the Data Protection Board of India in accordance with the DPDP Act, 2023.
Data Principals have the right to withdraw consent for the processing of personal data at any time, subject to legal, regulatory, or contractual constraints. Withdrawal of consent may be effected as follows:
To withdraw consent, a Data Principal may submit a written request to the Grievance Officer by email at goalsplanner.sdk@gmail.com or by post to the address in Section 16.1. The request should identify the Data Principal, the tenancy or unit concerned where applicable, and the specific categories of personal data or processing activities for which consent is being withdrawn. Withdrawing consent must be as easy as giving it, and no fee is charged for doing so.
Withdrawal of consent takes effect prospectively and does not affect the lawfulness of processing carried out before withdrawal. Withdrawal may have the following consequences:
Withdrawal of consent does not require the Company to erase personal data where retention is required by law, is necessary for the establishment, exercise, or defence of legal claims, or is essential for the performance of a subsisting contract.
Upon the conclusion of a tenancy, the cessation of employment or engagement, or a request for removal, Data Principals may request account termination and deletion of personal data, subject to the following conditions:
A request may be submitted in writing to the Grievance Officer, identifying the Data Principal and, where applicable, the tenancy or unit concerned, together with confirmation of intent to close the record and delete personal data.
Upon receipt of a valid deletion request, the Company shall:
The Company reserves the right to retain personal data notwithstanding a deletion request where:
In such cases, the Company shall inform the Data Principal of the reasons for continued retention and the expected retention period.
The LHC NEST Application is intended exclusively for use by authorised staff aged eighteen (18) years or above, and tenant records are created only for individuals of legal contractual capacity. The Application is not directed at, intended for, or designed to attract children, and the Company does not knowingly collect, process, or solicit personal data of a child as defined under the DPDP Act, 2023.
Where a minor is recorded incidentally as an occupant of a unit — for example, as a family member named in an agreement — no personal data beyond the name is collected, no behavioural monitoring of any kind is carried out, and no targeted advertising is directed at any individual. Where verifiable parental consent is required by law for any processing of a child's personal data, the Company will obtain it before such processing.
If the Company becomes aware that personal data of a child has been collected without the consent required by law, it shall take immediate steps to delete such data. Parents, guardians, or legal representatives may contact the Grievance Officer to request deletion.
This Application complies with the Google Play User Data Policy. In accordance with Google Play requirements, the Company discloses the following:
The Application collects personal data solely for the administration of rental properties by authorised staff of Lovely Home Creators. Personal data is not collected, used, or disclosed for advertising purposes or shared with third-party advertising networks.
The Application does not request location permission, contacts permission, SMS or call log permission, microphone permission, or any permission designated by Google Play as high risk or sensitive beyond those listed above.
The Application does not track Users across third-party applications or websites for advertising or analytics purposes, and integrates no third-party advertising SDK or tracking technology.
The Company does not sell, rent, trade, or monetise personal data collected through the Application. Personal data is processed exclusively for internal operational purposes and is not disclosed to third parties for commercial gain.
The Application's Google Play Store listing includes a Data Safety section that accurately describes the types of personal data collected, the purposes of collection, data sharing practices, whether data is encrypted in transit, and the mechanism by which deletion may be requested. Users are encouraged to review the Data Safety section for a concise summary of these practices.
Requests for account closure and data deletion may be made in accordance with Section 18 of this Policy, by writing to the Grievance Officer at the address given in Section 16.1.
This Application complies with the Apple App Store Review Guidelines and Apple's privacy requirements. In accordance with those requirements, the Company discloses the following:
The Application's App Store listing includes a privacy nutrition label that discloses the types of personal data collected, whether such data is linked to the User's identity, and whether it is used for tracking. The privacy label accurately reflects the data practices described in this Privacy Policy.
The following categories of personal data are linked to the User's identity:
The Application does not collect location data, contacts, browsing history, search history, sensitive personal information as classified by Apple beyond the identity and financial particulars described above, or any advertising identifier.
Personal data collected through the Application is not used to track Users across applications or websites owned by other companies. The Application does not use the App Tracking Transparency framework because it performs no tracking, and it does not link User data to third-party data for targeted advertising or measurement.
The Application requests access to the camera and photo library only when such access is necessary for a specific user-initiated action, and each request is accompanied by a clear, contextual purpose string explaining why the permission is required.
The Application is an internal business tool. Accounts are provisioned by Lovely Home Creators for its authorised staff; the Application offers no public sign-up, and consequently no third-party or social sign-in service is used. Where an in-app account deletion mechanism is required, account closure requests are handled as set out in Section 18.
Lovely Home Creators reserves the right to amend, modify, or update this Privacy Policy at any time to reflect changes in legal requirements, operational practices, technological advancements, or business needs. Any material changes shall be communicated to Data Principals through one or more of the following means:
The "Last Updated" date at the top of this Privacy Policy indicates the effective date of the most recent revision. Data Principals are encouraged to review this Privacy Policy periodically to remain informed of current data practices.
Continued use of the Application following the publication of changes constitutes acceptance of the revised Privacy Policy. Where required by law, the Company shall obtain fresh consent for material changes that expand the scope of data processing or introduce new processing purposes.
Previous versions of this Privacy Policy may be archived and made available upon request for reference purposes.
For questions, concerns, or inquiries regarding this Privacy Policy or the processing of personal data, Data Principals may contact:
Organization: Lovely Home Creators
Grievance Officer Email: goalsplanner.sdk@gmail.com
Address: 6, 2nd Street, VOC Colony, Kodambakkam, Chennai, Tamil Nadu 600024, India
Website: https://www.lovelyhomecreators.com
Organization: SDK Infinity Technologies
Email: goalsplanner.sdk@gmail.com
Address: 6, 2nd Street, VOC Colony, Kodambakkam, Chennai, Tamil Nadu 600024, India
The Company shall acknowledge receipt of inquiries within forty-eight (48) hours and shall endeavour to provide a substantive response within thirty (30) calendar days, subject to the complexity of the inquiry. Where additional time is required, the Company shall provide interim updates.
Acknowledgment: By accessing, installing, or using the LHC NEST Application, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. You further acknowledge that you have been informed of your rights under applicable data protection laws and of the mechanisms available to exercise them.
Governing Law: This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising out of or relating to this Privacy Policy or the processing of personal data shall be subject to the exclusive jurisdiction of the courts located in Chennai, Tamil Nadu, India.
Severability: If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed, and the remaining provisions shall remain in full force and effect.