Privacy Policy

1. Who We Are

Emynence is a real estate Channel Partner (CP) CRM and lead distribution platform operated by mFunnel Technologies Pvt. Ltd. (CIN: U62090MH2025PTC451642, GST: 27AAACM5979P1ZL), with its registered office at 602, Satyadeep, Siddharth Nagar 4, Goregaon West, Mumbai – 400104, India.

For GDPR purposes, mFunnel Technologies Pvt. Ltd. is the Data Controller of personal data collected through the Emynence platform. You may contact our designated Data Protection Officer at privacy@emynence.com.

2. What Personal Data We Collect

We collect the following categories of data:

We do not collect sensitive personal data (health, religion, biometrics, etc.) unless legally required.

3. How We Use Your Data

Your data is used strictly for the purposes listed below:

• To create and manage your Emynence account and team hierarchy.
• To process lead submissions, deduct CPL charges from your wallet, and maintain transaction logs.
• To provide the CRM dashboard — lead pipeline, follow-up scheduling, activity logs.
• To send transactional notifications — lead alerts, wallet alerts, follow-up reminders (no unsolicited marketing unless you opt-in).
• To verify identity, prevent fraud, and enforce our Terms of Service.
• To comply with applicable Indian law, court orders, or regulatory requirements.
• To improve platform performance and debug issues using anonymised usage analytics.

We will never sell your personal data or use it for third-party advertising without your explicit consent.

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) or the United Kingdom, we process your data on the following legal grounds:

• Contract performance – to deliver the services you signed up for (account management, lead CRM, wallet system).
• Legitimate interests – platform security, fraud prevention, internal analytics, product improvement.
• Legal obligation – to comply with applicable laws, tax regulations, and court orders.
• Consent – for optional communications, marketing emails, or cookies that are not strictly necessary. You may withdraw consent at any time.

5. Lead Data Handling – Special Notice

The Emynence platform involves processing personal data of third-party individuals (prospective property buyers) — referred to as "leads." Channel Partners (CPs) who submit leads act as independent data processors in respect of this data. Emynence processes lead data as a sub-processor on behalf of the CP.

CPs are solely responsible for ensuring they have obtained appropriate consent or a valid legal basis from their leads before submitting their data to the Emynence platform. Emynence provides the technical infrastructure to store and display this data within the CRM but does not independently contact or market to leads.

Lead data is stored securely within India (or in EU-standard-compliant data centres) and is accessible only to the submitting CP and their authorised team members.

6. Data Sharing & Third Parties

We share your data only in the following circumstances:

• Within your team: Team members you invite (managers, agents) can see leads assigned to them within the CRM. Super admins can see all data.
• Payment processors: We share necessary transaction data with payment gateways (e.g., Razorpay) to process wallet top-ups. We do not store full card details.
• Cloud infrastructure: Data is hosted on Railway (cloud infrastructure). All providers are contractually obligated to protect your data.
• Legal requirements: We may disclose data if required by Indian courts, regulators, or law enforcement authorities.
• Business transfers: In the event of a merger or acquisition, data may be transferred to the successor entity subject to equivalent protections.

We do not share your data with advertisers, data brokers, or any third parties for commercial purposes.

7. Data Retention

After the applicable retention period, data is permanently deleted or fully anonymised so it can no longer identify any individual.

8. Your Rights

Depending on your jurisdiction, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to Be Forgotten"): Request deletion of your data, subject to legal retention obligations.
• Right to Restriction: Request that we limit processing of your data in certain circumstances.
• Right to Data Portability: Receive your data in a machine-readable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior lawful processing.
• Right not to be subject to automated decisions: We do not use purely automated decision-making that significantly affects you.

To exercise any of these rights, email us at privacy@emynence.com. We will respond within 30 days. If you are in the EEA, you also have the right to lodge a complaint with your local Data Protection Authority.

9. Cookies & Tracking

We use the following types of cookies:

• Strictly necessary cookies: Required for authentication (JWT session tokens stored in localStorage) and platform functionality. Cannot be disabled.
• Analytics cookies: Used to understand how the platform is used (e.g., page views, feature usage). These are anonymised and aggregated. You may opt out.
• Preference cookies: Remember your settings (e.g., selected city filters, dashboard preferences).

We do not use advertising cookies or cross-site tracking. You can manage cookie preferences in your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in.

10. Data Security

We implement industry-standard security measures to protect your data:

• All data transmitted between your browser and our servers is encrypted using TLS (HTTPS).
• Passwords are stored using bcrypt hashing – we never store plain-text passwords.
• Access to production databases is restricted to authorised personnel only, with audit logging.
• JWT authentication tokens expire after a defined period and must be refreshed.
• Wallet transactions are processed within database-level ACID transactions with automatic rollback on failure.
• We conduct periodic security reviews of our infrastructure and code.

In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware, as required by GDPR Article 33.

11. International Data Transfers

Emynence is headquartered in India. Your data is primarily processed and stored within India. Where our infrastructure providers are located outside India (e.g., EU-based data centres), we ensure that transfers are made in accordance with GDPR Chapter V requirements — including the use of Standard Contractual Clauses (SCCs) where applicable.

12. Children's Privacy

The Emynence platform is intended for use by real estate professionals aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at privacy@emynence.com and we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify registered users by email and/or by displaying a prominent notice on the platform at least 14 days before the changes take effect. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Continued use of the platform after changes take effect constitutes acceptance of the updated policy.

14. Contact Us

For any privacy-related questions, data requests, or complaints: