Data Deletion Policy
At DLCgroup.in ("we," "us," "our," or "DLC Group"), we respect your right to control your personal information. This Data Deletion Policy explains how you can request deletion of the personal data we hold about you, how we process such requests, the legal grounds on which we may retain certain information, and the timelines and procedures we follow.
This Policy supplements our Privacy Policy and is published in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
By using our website www.dlcgroup.in or our real estate consultancy services, you acknowledge that you have read and understood this Data Deletion Policy.
Purpose and Scope
This Policy governs the deletion of personal data collected by DLC Group through:
- Our website www.dlcgroup.in (forms, inquiries, cookies, and analytics).
- Telephone calls, WhatsApp messages, SMS, and email communications with our consultants.
- Site visits, documentation, and transactions facilitated by DLC Group.
- Third-party lead-generation platforms, developer partners, and advertising networks where you have submitted your interest.
This Policy applies to all data subjects (referred to as "Data Principals" under the DPDP Act) who interact with DLC Group, including prospective buyers, sellers, tenants, landlords, channel partners, and website visitors.
Categories of Data Eligible for Deletion
Upon a valid request, we will delete the following categories of personal data, subject to the exceptions in Section 6:
- Personal Identification Data — full name, email address, mobile/phone number, residential address, date of birth.
- KYC Data — PAN, Aadhaar, Passport, or other government-issued identification (where retained beyond mandatory legal retention).
- Property & Financial Information — property preferences, budget, income range, employment details, loan eligibility data, ownership/rental details.
- Communication Records — call logs, recordings, emails, WhatsApp/SMS chats, feedback, testimonials, and inquiry submissions.
- Technical & Usage Data — IP address, device identifiers, browser fingerprints, cookies, and website behaviour logs associated with your identity.
- Marketing Profiles — lead scores, preference tags, and segmentation data linked to you within our CRM and marketing platforms.
Your Right to Erasure
Under Section 12 of the DPDP Act, 2023, you have the right to request erasure of your personal data where:
- The data is no longer necessary for the purpose it was originally collected.
- You withdraw the consent on which processing is based, and no other legal ground applies.
- You believe the processing is unlawful, inaccurate, or no longer required.
- You wish to terminate your engagement with DLC Group and have no pending transactions or legal obligations with us.
This right is not absolute. Certain data may be retained for the limited purposes set out in Section 6.
How to Submit a Data Deletion Request
You may request deletion of your personal data through any of the following channels:
a. Email
Send your request to info@dlcgroup.in with the subject line: "Data Deletion Request – [Your Full Name]"
b. Postal Mail
Grievance Officer – DLC Group
3rd Floor, 448, Sector 19B, South West Delhi, Delhi – 110075, India
c. Telephone
Call +91 81004 81006 (Monday to Saturday, 10:00 AM – 7:00 PM IST) and request that our representative log a formal deletion request on your behalf.
Information to Include in Your Request
To help us locate your records and verify your identity, please include:
- Full name as previously shared with DLC Group.
- Registered mobile number and email address.
- Approximate date or context of your interaction with us (e.g., property inquired about, name of consultant).
- The specific data you want deleted, or a request for complete deletion of all personal data.
- A clear declaration that you are submitting this request voluntarily and on your own behalf (or as an authorised nominee under Section 14 of the DPDP Act).
Verification Process
To protect your data from unauthorised deletion requests, we will verify your identity before processing the request. Verification may include:
- Matching the request details with information already in our records.
- A confirmation call or email to the registered contact details.
- A request for a self-attested copy of a government-issued ID (which will be used solely for verification and deleted thereafter, unless retention is required by law).
If we are unable to verify your identity within a reasonable period, we may decline the request and will inform you of the reason in writing.
Exceptions — Data We May Retain
In certain circumstances, we may be unable to delete some or all of your personal data. We may continue to retain specific data where:
- Legal & Regulatory Obligations — retention is required under the Income Tax Act, GST laws, Companies Act, RERA, Prevention of Money Laundering Act (PMLA), or any other applicable statute.
- Active Transactions — you have an ongoing property transaction, site visit, booking, loan application, or documentation process with DLC Group, a developer, or a financial institution introduced by us.
- Financial & Audit Records — invoices, brokerage receipts, commission records, and accounting entries must be retained for a minimum of eight (8) years under Indian tax and accounting laws.
- KYC & AML Records — under the Prevention of Money Laundering Act, 2002, KYC documents collected for property transactions may be retained for at least five (5) years after the conclusion of the transaction.
- Legal Claims & Disputes — where the data is required to establish, exercise, or defend a legal claim, respond to a regulatory inquiry, or comply with a court order.
- Fraud Prevention — minimal data may be retained on a suppression list to prevent re-onboarding of fraudulent or blacklisted leads.
- Aggregated or Anonymised Data — data that has been aggregated or irreversibly anonymised, such that it can no longer be linked to you, may be retained indefinitely for analytics and business intelligence purposes.
Where an exception applies, we will inform you in writing of the specific reason for partial deletion or refusal and the legal basis for continued retention.
Timelines for Processing Deletion Requests
We are committed to processing deletion requests promptly and transparently:
| Stage | Timeline |
|---|---|
| Acknowledgement of request | Within 48 hours of receipt |
| Identity verification | Within 7 working days |
| Completion of deletion | Within 30 days of verification |
| Communication of outcome | Within 5 working days of completion |
Complex requests involving multiple systems, third-party developers, or financial partners may take longer. In such cases, we will keep you informed of the status and expected timeline.
Method of Deletion
Once a deletion request is approved, we will:
- Permanently delete the data from our active CRM, email systems, marketing platforms, cloud storage, and internal databases.
- Securely destroy physical records (printed inquiry forms, KYC photocopies, signed documents) through shredding or other irreversible means.
- Anonymise any data that must be retained for analytics or statistical purposes, so it can no longer be linked to you.
- Issue written instructions to our processors and service providers (CRM vendors, marketing platforms, cloud hosting providers) to delete your data from their systems.
Backup copies stored on disaster-recovery systems will be overwritten or deleted in the ordinary course of our backup cycle, typically within 90 days.
Third-Party Data Sharing and Deletion
Where we have shared your data with third parties — including property developers, builders, banks, NBFCs, or lead-generation platforms — we will, upon your request:
- Notify those third parties of your deletion request, where contractually and legally feasible.
- Request that they delete your personal data from their systems.
Please note that DLC Group cannot guarantee deletion by third parties once your data has been lawfully shared with them, particularly developers and financial institutions that have independent legal retention obligations. You may need to contact such third parties directly to exercise your rights against them.
Withdrawal of Marketing Consent (Without Full Deletion)
If you wish to stop receiving promotional communications but do not want full deletion of your records, you may instead:
- Email info@dlcgroup.in with the subject "Unsubscribe – Marketing Communications".
- Click the unsubscribe link in any marketing email from DLC Group.
- Reply STOP to any promotional SMS or WhatsApp message.
Withdrawing marketing consent will not delete your underlying records but will exclude you from future calls, SMS, WhatsApp, and email campaigns.
Confirmation of Deletion
Once your deletion request is fully processed, we will send you a written confirmation (via email or post) stating:
- The categories of data that have been deleted.
- Any categories of data that have been retained, along with the legal basis for retention.
- The date of completion.
This confirmation serves as proof that DLC Group has fulfilled its obligations under the DPDP Act.
Re-Collection of Data
If, after deletion, you re-engage with DLC Group — for example, by submitting a fresh inquiry, requesting a site visit, or contacting a consultant — we will treat you as a new data subject and collect fresh personal information in accordance with our Privacy Policy. Previously deleted data will not be restored.
Deletion of Children's Data
Our Services are not intended for individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a child, we will delete it without requiring a formal request. Parents or guardians may write to info@dlcgroup.in to report such instances.
Refusal of Deletion Requests
We may refuse a deletion request, in whole or in part, where:
- The request is manifestly unfounded, excessive, or repetitive.
- We are unable to verify your identity despite reasonable efforts.
- The data must be retained under applicable law or for active legal proceedings.
- Deletion would adversely affect the rights of other data subjects or third parties.
In every case of refusal, we will provide a written explanation and inform you of your right to escalate the matter to the Grievance Officer or the Data Protection Board of India.
Grievance Redressal
If you are dissatisfied with how your deletion request has been handled, you may escalate the matter to our Grievance Officer:
Grievance Officer — DLC Group
- Address 3rd Floor, 448, Sector 19B, South West Delhi, Delhi – 110075, India
- Phone +91 81004 81006
- Email info@dlcgroup.in
- Website www.dlcgroup.in
We aim to acknowledge grievances within 48 hours and resolve them within 30 days of receipt. If you are not satisfied with the resolution, you may approach the Data Protection Board of India established under the DPDP Act, 2023.
Changes to This Policy
We may update this Data Deletion Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. Any updates will be posted on this page with a revised "Last Updated" date. Material changes will be communicated to active clients via email or SMS where reasonably practicable.
Governing Law and Jurisdiction
This Data Deletion Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising in relation to this Policy shall be subject to the exclusive jurisdiction of the competent courts located in Delhi, India.
By using DLCgroup.in or our services, you acknowledge that you have read, understood, and agree to this Data Deletion Policy.
