PRIVACY POLICY

1. About Us

LemonTalks Media & Entertainment Pvt. Ltd. is a performance marketing and digital agency specialising in the real estate sector. We operate from offices in Gurugram, India and Dubai, UAE, serving real estate developers across both markets.

2. Information We Collect

2.1 Information You Provide

When you submit an enquiry, contact, or lead form on our website, we collect:

• Full name
• Mobile number / phone number (including country code for UAE enquiries)
• Email address
• City, country, or location
• Budget range, project type, or service interest
• Any other information you voluntarily provide in form fields or messages

2.2 Information Collected Automatically

When you visit our website, we automatically collect:

• IP address and approximate geolocation
• Browser type, version, and device type
• Pages visited, time spent, and click behaviour
• Referring URL and UTM parameters
• Cookie identifiers and advertising IDs

2.3 Information from Ad Platforms

If you interact with our advertisements on Google, Facebook, or Instagram, those platforms may share limited data (such as lead form submissions) with us in accordance with their own privacy policies. We handle such data only for the purpose of client lead generation and follow-up.

3. Legal Framework — India

For users and clients based in India, our collection and processing of personal data is governed by:

• The Information Technology Act, 2000 and the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• The Digital Personal Data Protection Act, 2023 (DPDPA), as and when operative and notified
• Applicable rules and regulations issued by the Ministry of Electronics and Information Technology (MeitY)

4. How We Use Your Information — India

• To respond to your service enquiry and follow up with relevant information about LemonTalks' services.
• To onboard and manage client engagements for real estate marketing in Indian markets (Delhi NCR, Mumbai, Bengaluru, etc.).
• To send you service-related communications including reports, campaign updates, and invoices.
• To run retargeting campaigns using Meta Pixel and Google Ads conversion tracking on Indian audiences.
• To comply with applicable Indian tax, regulatory, and legal requirements.

5. Your Rights — India

Under the Digital Personal Data Protection Act, 2023 and existing IT rules, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete personal data.
• Erase your personal data, subject to legal retention requirements.
• Withdraw consent at any time by writing to us — withdrawal does not affect prior processing.
• Raise a grievance with our Grievance Officer (details in Section 11).

6. Data Retention — India

• Lead enquiry data: retained for up to 2 years from date of submission.
• Client account data: retained for 5 years after end of engagement, as required for GST and income tax compliance under Indian law.
• Website analytics data: retained as per Google Analytics 4 default settings (maximum 14 months for user-level data).

7. Legal Framework — UAE

For users and clients based in the United Arab Emirates, our collection and processing of personal data is governed by:

• The UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) and its Executive Regulations
• Regulations issued by the UAE Data Office
• Applicable sector-specific regulations issued by the Dubai Land Department (DLD) and Real Estate Regulatory Agency (RERA Dubai) for real estate-related processing

Where our UAE operations process data of residents in the Emirate of Dubai, we operate in compliance with the above framework. Data collected from UAE users may be transferred to and processed in India, where LemonTalks' registered office is located. Such transfers are made with appropriate safeguards in place, including data processing agreements with service providers.

8. How We Use Your Information — UAE

• To respond to enquiries about real estate marketing services for Dubai, Abu Dhabi, Ras Al Khaimah, and other UAE markets.
• To onboard and manage client engagements for UAE real estate developers, off-plan project marketing, and international buyer lead generation.
• To run multi-country digital advertising campaigns on Google and Meta targeting buyers from India, UK, Russia, GCC, and other markets for UAE real estate projects.
• To send service-related communications and reports related to UAE campaign performance.
• To comply with UAE federal and emirate-level regulatory requirements.

9. Your Rights — UAE

Under the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, you have the right to:

• Access your personal data held by us.
• Correct inaccurate personal data.
• Erase your personal data where no legal basis for retention exists.
• Object to processing for direct marketing purposes.
• Restrict processing in certain circumstances.
• Data portability — receive your data in a structured, commonly used format.
• Withdraw consent at any time for processing based on consent.

To exercise these rights, please write to hello@lemontalks.in. We will respond within 30 days.

10. Data Retention — UAE

• Lead and client data for UAE engagements: retained for 5 years in accordance with UAE commercial and tax regulations.
• Financial and contractual records: retained for the period required under UAE Federal Law No. 2 of 2015 (Commercial Companies Law) and applicable VAT regulations.

11. Cookies and Tracking

Our website uses cookies including essential cookies for website functionality, Google Analytics 4 for traffic analysis, and Google Ads and Meta Pixel for conversion tracking and retargeting. You may disable cookies through your browser settings, which may affect website functionality. For UAE users, we honour cookie preference signals where technically supported.

12. Data Sharing

We do not sell your personal data. We may share data with:

• Service providers: Google Workspace, WhatsApp Business API, Google Analytics, Meta Business Suite, and CRM platforms — who process data only on our behalf.
• Our real estate clients: If you submit a lead form relating to a developer's project, your contact data is shared with that developer for follow-up.
• Legal authorities: Where required by Indian or UAE law, court order, or regulatory requirement.

13. Data Security

We implement SSL/TLS encryption, access controls, and industry-standard security practices to protect your data. No internet transmission is 100% secure; we cannot guarantee absolute security but are committed to best-practice data protection.

14. Grievance Officer (India)

As required under the Information Technology Act, 2000:

15. Changes to This Policy

We may update this Privacy Policy periodically. The effective date at the top of the page will reflect the latest revision. Continued use of our website or services after updates constitutes acceptance of the revised policy.