Privacy Policy

CoHold (“CoHold”, “we”, “us” or “our”) respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how information may be collected, used, stored, shared and protected when you use the CoHold website, mobile application and related services (together, the “Platform”). It also explains the choices and rights available to you regarding your personal information.

By submitting information through the Platform, you acknowledge that you have read this Privacy Policy. Where consent is required by applicable law, CoHold will request appropriate consent before processing your personal data.

CoHold does not currently offer user accounts, and does not currently collect KYC documents, payment details or bank account information. The Platform today lets you browse property opportunities and register your interest in them. Sections below describe only what the Platform actually does at the effective date shown above.

A. Information you provide

When you submit a registration of interest, or contact us, we collect the information you enter in the form:

• your name;
• your mobile number;
• your email address;
• your location as shown or edited in the form (city, state and country);
• the expected investment range you select, if any;
• the property categories you indicate an interest in, if any;
• the specific property your registration relates to, where applicable;
• whether you opt in to receiving updates on WhatsApp;
• the fact that you gave consent, and the date and time you gave it; and
• any message or enquiry you send to us.

If services such as identity verification (e-KYC), payments or formal investment onboarding are introduced in future, additional information would be collected and appropriate disclosures would be provided before that collection begins.

B. Location and network information

CoHold uses your Internet Protocol (IP) address to determine an approximate location — city, region or country — to pre-fill the location field on registration forms and to help us understand where interest is coming from. This lookup is performed on our servers using a third-party IP geolocation provider (currently ipapi.co). Your IP address is recorded alongside a registration of interest.

CoHold does not collect precise or device location. The CoHold mobile application does not request Android or iOS location permission and does not access GPS or similar device sensors. You can correct or overwrite the pre-filled location before submitting a form.

C. Device and usage information

When you use the website, limited technical information is collected automatically by our hosting provider and by website analytics, including IP address, browser type, operating system, device type, pages viewed, date and time of access, and referral information where available.

The mobile application does not currently include any analytics, advertising, crash-reporting or push-notification software development kit, and does not generate an advertising identifier. Screens within the app that display long-form information (How It Works, Shariah Approach, Risk Disclosure and FAQs) are rendered by loading the corresponding pages of our website inside the app, so website analytics described below apply to those screens.

D. Cookies and similar technologies

The website uses Google Analytics, which sets cookies and similar identifiers to measure how the site is used. Essential cookies may also be used to keep the site working correctly and securely.

The mobile application stores a list of the properties you save to your watchlist in local storage on your own device. That list contains property identifiers only, stays on your device, and is not transmitted to us.

Where required by applicable law, appropriate consent controls will be provided for non-essential technologies.

CoHold may use the information described above to:

• record and manage your registration of interest;
• contact you about your registration or enquiry;
• provide information you have requested about property opportunities;
• operate, maintain and improve the Platform;
• pre-fill and simplify forms using approximate location;
• provide customer support;
• verify submitted information where appropriate;
• detect and prevent fraud, abuse and security incidents, including rate limiting;
• measure service performance and understand how the Platform is used;
• comply with applicable legal and regulatory requirements;
• establish, exercise or defend legal claims; and
• tell you about important changes to the Platform or to these policies.

We will not use personal data for materially incompatible purposes without appropriate notice, or consent where that is required.

Submitting a registration of interest does not, by itself:

• constitute an investment;
• create ownership in a property;
• guarantee an allotment;
• reserve a fractional interest;
• create an LLP or SPV ownership interest;
• guarantee acceptance into an investment opportunity; or
• create a binding purchase obligation, unless expressly stated in separate transaction documents.

Information submitted through a registration-of-interest form may be used to contact you about the relevant opportunity and related Platform services.

CoHold does not sell personal information. Information is shared only where reasonably necessary, with the following categories of recipients. The named providers are those actually used at the effective date shown above.

• Website and application hosting — Vercel Inc., which hosts the website and its server-side functions and processes request metadata including IP address.
• Database hosting — Supabase, which hosts the database holding registration records. The database is provisioned in an India (Mumbai) region.
• IP geolocation — ipapi.co, which receives an IP address in order to return an approximate city, region and country.
• Website analytics — Google Analytics, which receives website usage and device information as described above.
• Image delivery — third-party image content delivery networks used to display property imagery, which receive your IP address as part of serving those images.
• Professional advisers such as lawyers, accountants and auditors, where reasonably required.
• Government authorities, courts or regulators, where legally required.

Third parties that process data on our behalf receive only the information reasonably necessary to perform their service. If communications, payment, escrow, banking or identity-verification providers are engaged in future, this section will be updated before those services go live.

At the effective date shown above, CoHold does not collect KYC documents, Aadhaar details, PAN details, bank account information or payment-card information through the Platform. References elsewhere on the Platform to a future e-KYC step describe functionality that is not yet available.

If payment or identity-verification functionality is introduced, you will receive disclosures before collection describing what is collected, why, which service providers are involved, how long it is retained and how it is protected. Where payments are processed by authorised third-party providers, their own terms and privacy practices may apply.

CoHold uses reasonable technical and organisational safeguards designed to protect personal information from unauthorised access, loss, misuse, alteration or disclosure. These currently include encrypted HTTPS connections enforced across the site, access restrictions and authentication on administrative interfaces, managed and access-controlled hosting infrastructure, rate limiting on public submission endpoints, and collecting only the information we need.

No internet-based service or electronic storage system can be guaranteed to be completely secure, and we do not claim otherwise. If you believe your information has been compromised, please contact us using the details in the contact section below.

CoHold retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing services you have requested, maintaining legitimate business and transaction records, preventing fraud or abuse, resolving disputes, and satisfying applicable legal, accounting or regulatory requirements.

Registration-of-interest records are not retained indefinitely without a valid purpose. When personal data is no longer required, it is securely deleted or anonymised, subject to any legal retention obligations.

Subject to applicable law, you may contact us to request:

• access to the information associated with you;
• correction of inaccurate information;
• updating of incomplete information;
• deletion or erasure of your personal information;
• withdrawal of consent, where processing is based on consent;
• information about how your personal information is handled; and
• resolution of a grievance relating to personal-data processing.

Some information may need to be retained where required by law or where necessary for legitimate legal or security purposes. Withdrawing consent does not affect processing lawfully carried out before the withdrawal.

You may request deletion of the personal information associated with your registration at any time. Full instructions, including how we verify a request and what we may be required to retain, are on our Delete My Data page.

Because CoHold does not currently offer user accounts, there is no in-app account to delete. Deletion requests apply to registration-of-interest records and any related correspondence.

If you register interest, we may contact you about that registration, about the relevant property information, about service updates, and to provide follow-up you have asked for. If you opt in to WhatsApp updates, we may contact you on that channel as well.

Promotional communications are sent only in accordance with applicable requirements, and you will be given a reasonable way to opt out of them. Transactional or legally required communications may still be sent where necessary.

The Platform is intended for people who are at least 18 years old, and CoHold does not knowingly solicit investment registrations from children. If we become aware that personal information has been collected from a child in circumstances where it should not have been, we will take appropriate steps in accordance with applicable law.

The Platform may link to third-party websites or services, including WhatsApp and mapping providers. CoHold does not control the privacy practices of independent third parties. Please review their privacy policies before submitting personal information to them.

The database holding registration records is provisioned in an India (Mumbai) region. However, some of the technology and cloud service providers we use — including our hosting, analytics and IP geolocation providers — may process information from, or route it through, locations outside India.

Where cross-border processing occurs, CoHold will handle that processing in accordance with applicable data-protection requirements.

CoHold may update this Privacy Policy when Platform functionality changes, when our data practices or service providers change, or when legal or regulatory requirements change. The latest version is always published at https://cohold.in/privacy.

The effective date shown at the top of this page is updated whenever material changes are made.

CoHold intends to handle personal information in accordance with applicable Indian privacy and data-protection requirements, including the Digital Personal Data Protection Act, 2023 and the rules and requirements brought into force under it from time to time, to the extent applicable and in force, together with other applicable laws.

For privacy questions, correction requests, deletion requests or grievances relating to personal data, please contact us:

• CoHold, operated by CoHold Digitals Private Limited
• Email: support@fracsquare.com
• Phone: +91 88702 42601
• Website: https://cohold.in

We aim to acknowledge privacy requests promptly and to respond within the timeframes required by applicable law.