Privacy Policy

1. Introduction

This Privacy Policy explains how MyPrimePG ("we", "us", "our") collects, uses, processes, and protects personal data in connection with our platform and services. MyPrimePG is a SaaS platform that provides digital tools for Pg Owners to manage their operations and tenant relationships, including booking, communications, invoicing, and administration. By using our services or accessing our website, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

MyPrimePG is operated by NexlyHub LLP, registered under the laws of India. Depending on the context, we act in two distinct legal capacities:

• Data Controller (Data Fiduciary): We act as the Data Controller (or "Data Fiduciary" under the India DPDP Act) for information collected to manage your account registration, handle billing and SaaS subscription administration, and address customer support and communication requests.
• Data Processor: We act as a Data Processor for all data entered or uploaded by PG Owners regarding their tenants and guests, including tenancy records, occupancy details, rent transaction logs, and uploaded identification or verification documents. PG Owners remain the primary Data Controllers (Data Fiduciaries) for this tenant and guest data.

If you are a Tenant or Guest and your personal data is processed on the MyPrimePG platform, please contact your PG Owner or accommodation provider directly to exercise your data protection rights.

3. Types of Data We Collect

MyPrimePG is firmly committed to the principles of data minimization and purpose limitation. We collect and process only the personal data that is necessary to deliver, secure, and support our services. We do not collect excessive or unrelated information.

3.1 Data We Collect From PG Owners (Our Direct Customers)

To register and manage your account, ensure platform functionality, and provide support, we collect:

• Full name and account profile credentials
• Business details and property contact information
• User roles and permission settings
• Billing, subscription tier, and usage metrics

3.2 Data We Process on Behalf of PG Owners (Tenant/Guest Data)

We process only the personal data explicitly entered, uploaded, or managed by the PG Owner, which may include:

• Tenant names, email addresses, phone numbers, and contact profiles
• Invoices, rental payments, billing transactions, and receipt records
• Facility allocations, occupancy status, and room details
• Uploaded lease agreements, identity verifications, or other tenant-related documents

We do not independently collect, enrich, or cross-reference tenant or guest data from third parties.

3.3 Tenant and Guest Data Responsibility

PG Owners are solely responsible for ensuring that they have the legal right, appropriate consent, or lawful basis to collect, upload, and process tenant and guest data. MyPrimePG does not independently verify the legality, accuracy, or authorization of data uploaded by PG Owners. The legal responsibility for compliance with local data protection regulations regarding tenant data remains exclusively with the PG Owner.

3.4 Children's Privacy

Personal data of children may have different age thresholds under applicable laws (e.g., under 18 under India's DPDP Act, under 13 under GDPR and COPPA). We do not knowingly collect or process personal data from children without verifiable parental or guardian consent. PG Owners are strictly responsible for obtaining all necessary legal consents before uploading any records relating to minors. Uploading children's data without authorized consent is a direct violation of our Terms of Service.

4. How We Use Your Data

We process personal data for the following purposes:

• To provide and maintain the platform
• To enable pg users to manage tenants/guests, invoices, bookings, and communications
• To ensure system security and prevent fraud
• To respond to support requests and inquiries
• To analyze platform usage and improve our services (aggregated/anonymous data only)
• To send service-related notifications

5. Legal Basis for Processing

Where applicable under the data privacy laws and regulations, we rely on the following legal bases:

• Performance of a contract (e.g., providing the service)
• Legitimate interest (e.g., system security, troubleshooting)
• Compliance with legal obligations
• Consent (for specific optional features, marketing communications)

6. Sharing and Disclosure

We do not share personal data with third parties except in the following limited circumstances:

• Third-Party Subprocessors: We engage trusted service providers to assist in delivering the platform's core infrastructure and extensions. These subprocessors include cloud hosting providers, analytics services, subscription billing and payment gateways (to process transactional payments securely), and communication services (used for sending automated transactional emails, SMS alerts, and WhatsApp notifications on behalf of PG Owners).
• Legal Requirements: When required to disclose personal data by lawful authorities or to comply with statutory obligations under the jurisdiction of Ahmedabad, Gujarat, or India.
• Protection of Rights: If necessary to enforce our Terms of Service, defend against liability, or prevent fraud and security issues.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business, subject to confidentiality agreements and notice to users.

All subprocessors are bound by data processing agreements to ensure they maintain data protection standards aligned with our privacy policies.

7. Data Retention

We retain personal data only as long as necessary for the purposes outlined above or as required by law. Upon account termination or request, data may be deleted, anonymized, or archived as appropriate.

Tenant/Guest should direct deletion requests to their PG owner.

8. Your Rights

Depending on your jurisdiction (GDPR, CCPA, LGPD, etc.), you may have rights to:

• Access your personal data
• Correct or update inaccurate information
• Request deletion ("right to be forgotten")
• Object to processing or withdraw consent
• Data portability
• Lodge a complaint with a supervisory authority

9. Data Security

We implement appropriate technical and organizational measures designed to secure your personal data from accidental loss, unauthorized access, alteration, or disclosure. These measures include administrative controls, restricted access permissions, and industry-standard encryption technologies.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal data, we cannot guarantee its absolute security.

9.1 Data Breach Notification

In the event of a confirmed security incident or data breach that affects your personal data, we will conduct a prompt investigation. We will notify relevant regulatory authorities and affected users when and as required by applicable laws, including India's DPDP Act and GDPR. Such notifications will describe the nature of the breach, the measures taken to mitigate its impact, and the recommended actions for affected parties.

10. Cookies and Tracking

We use essential cookies for platform functionality. We may also use optional cookies (analytics, preferences) with user consent.

For more details, refer to our Cookie Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification.

12. Contact Us and Grievance Redressal

For any privacy-related questions, data rights requests (access, deletion, portability), or concerns, you can contact our Data Protection representative:

Data Protection Contact
Email: [email protected]

12.1 Grievance Redressal Officer (DPDP Act Compliance)

In accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act), we have appointed a Grievance Redressal Officer to handle data-related complaints and queries from individuals located in India. The Grievance Officer will investigate and respond to all complaints within the timelines stipulated under the law.

Grievance Officer: Legal & Compliance Officer
Company: NexlyHub LLP
Email: [email protected]