Privacy
Policy
Effective Date: 1 January 2026 · Last Reviewed: 1 May 2026
1. Introduction
Executive Chandigarh is operated by SN Silos Pvt Ltd ("Developer") and marketed by Brillwood Capital Advisory ("Marketing Advisor"). We are committed to protecting the privacy and confidentiality of personal data entrusted to us. This Privacy Policy explains how we collect, use, store, and protect personal data submitted through the Private Inquiry process and any subsequent stewardship relationship.
This Policy is issued in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and the Digital Personal Data Protection Act, 2023 ("DPDP Act").
2. Data We Collect
We collect only the personal data that is strictly necessary for the purposes described in this Policy. This includes:
Identity Data
Full legal name, government-issued identification numbers (PAN, Aadhaar, Passport), nationality and residential address.
Contact Data
Private email address and direct telephone number as provided through the Private Inquiry form.
Financial Data
Source of funds documentation, ITR records, and bank statements collected for AML/KYC compliance purposes.
Preference Data
Estate requirements, unit count, security protocols, and other specific requirements disclosed in the Private Inquiry.
3. Purpose & Legal Basis for Processing
Legal Compliance
Processing of identity and financial data is required for our obligations under PMLA, 2002, RERA, 2016, and the Income Tax Act, 1961. This processing is mandatory and cannot be declined.
Pre-Contractual & Contractual Necessity
Contact and preference data is processed to evaluate your inquiry, conduct vetting, and — where successful — to enter into an Agreement for Sale.
Consent
By submitting the Private Inquiry form, you provide explicit consent to processing of your data for the purposes described. You may withdraw consent at any time by contacting us, subject to our overriding legal obligations.
4. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law:
Data from inquiries that do not proceed to a transaction is deleted within 12 months of the inquiry date, unless retention is required for regulatory purposes.
KYC and financial records are retained for a minimum of 5 years from the date of the transaction in accordance with PMLA Rules, 2005.
Contact and preference data is retained for the duration of the estate ownership and for 3 years following termination of the stewardship relationship.
5. Disclosure & Third Parties
We do not sell, rent, or share your personal data with third parties for marketing purposes. Disclosure is made only in the following limited circumstances:
- chevron_rightRegulatory Authorities: FIU-IND, Income Tax Department, RERA Authority, and other competent authorities as required by law.
- chevron_rightProfessional Advisors: Legal counsel, auditors, and compliance consultants bound by professional secrecy obligations.
- chevron_rightService Providers: IT and CRM service providers who process data on our behalf under strict data processing agreements and are prohibited from using data for any other purpose.
6. Your Rights as a Data Principal
Under the Digital Personal Data Protection Act, 2023, you have the following rights:
Right to Access
Request confirmation of whether we process your data and obtain a summary.
Right to Correction
Request correction of inaccurate or incomplete personal data.
Right to Erasure
Request deletion of data where processing is no longer necessary or lawful.
Right to Nominate
Nominate another individual to exercise your rights in the event of your death or incapacity.
To exercise any of these rights, please contact our Privacy Officer. We will respond within 30 days. Please note that certain rights may be limited by overriding legal obligations (such as PMLA record-keeping requirements).
7. Security
We implement reasonable security practices as required under Rule 8 of the SPDI Rules, 2011, including encryption of data in transit (TLS 1.2+), access controls, audit logging, and periodic security reviews. In the event of a data breach that is likely to cause harm to a Data Principal, we will notify the Data Protection Board of India and affected individuals as required by the DPDP Act, 2023.
8. Contact — Privacy Officer
Grievances will be acknowledged within 48 hours and resolved within 30 days.