Professional Terms & Professional Code of Conduct

1. Purpose and Scope

• These Professional Terms govern onboarding and use of Investor Setu professional services by approved brokers, property consultants, channel partners, developers, agents, service professionals, organisations, teams, managers and other approved professional categories.
• Investor Setu may provide role-based professional functionality including professional profile management, requirements and property/project information, enquiries, communication, workflow, approvals, reports, analytics and related business services.
• The modules, records, visibility and actions available to a Professional depend on the Professional category, approved role, contractual arrangement, hierarchy and permissions granted by Investor Setu.

2. Definitions

• “Investor Setu” means the Investor Setu platform and its authorised services, websites, applications, systems and related business operations.
• “Professional” means an approved person, organisation, broker, consultant, channel partner, developer, agent, service provider or other professional user authorised to use a professional facility.
• “Professional Data” means information submitted by or relating to the Professional and information the Professional is authorised to submit or manage through the platform.
• “Third-Party Data” means personal, confidential or business information relating to another person or entity that a Professional submits or makes available.
• “Authorised User” means a person who has been validly approved and assigned access by Investor Setu or an authorised professional administrator.

3. Eligibility, Onboarding and Verification

• A Professional must provide accurate, current and complete information reasonably required for onboarding, verification, service delivery, security and legal compliance.
• Investor Setu may verify mobile number, email address, professional identity, business details, registrations, licences, authorisations and other information reasonably necessary for the requested role.
• Where a law, regulator, contract or professional category requires a registration, licence, approval or qualification, the Professional is responsible for maintaining it and providing accurate information when requested.
• Approval is not a representation that Investor Setu endorses, guarantees, certifies or independently validates every service, property, project, claim or professional representation made by the Professional.

4. Professional Account and Credentials

• Each account and credential is personal to the authorised Professional or authorised user for whom it was issued. Credentials must not be sold, shared, transferred, rented or knowingly disclosed.
• The Professional is responsible for maintaining the security of credentials and promptly reporting suspected compromise, unauthorised access or misuse.
• Investor Setu may require additional verification or security measures and may restrict access where reasonably necessary for security, fraud prevention, legal compliance or protection of users and the platform.

5. Role-Based Hierarchy and Permissions

• Investor Setu may operate a minimum five-level professional permission structure, with additional levels or sub-levels where required.
• The general structure may include: Level 1 — Platform/Owner Control; Level 2 — Business/Vertical Administration; Level 3 — Professional Organisation/Principal; Level 4 — Team/Manager; Level 5 — Professional/User.
• The hierarchy is not identical for every Professional category. Reporting, approval, visibility, assignment, communication, export and execution permissions may differ by role and agreement.
• Permissions are controlled by the platform and are not determined merely by what a user interface appears to permit. A user must not attempt to obtain access beyond the scope expressly granted.
• Sensitive information is subject to purpose-based and permission-based access. Membership in a higher-level team does not automatically entitle a user to every underlying record or sensitive field.

6. Controlled Platform and Master Records

• The professional interface is a controlled access layer of the Investor Setu platform and is not an independent customer database.
• Professional records, requirements, property or project information, cases, activities, communications, approvals and related records may be maintained within Investor Setu’s controlled information environment.
• Investor Setu may maintain canonical records, historical information, stable references, audit records and operational history to support accuracy, continuity, attribution, security and lawful administration.
• Professional users must not attempt to reconstruct, copy or independently recreate Investor Setu’s complete data model, internal workflows, hidden identifiers, matching methodology or other confidential system design.

7. Professional Data, Ownership and Limited Licence

• The Professional retains ownership of rights it lawfully owns in material submitted by the Professional, subject to applicable law and any express written commercial arrangement.
• To the extent necessary to provide, secure, administer and improve the agreed professional services, the Professional grants Investor Setu a non-exclusive, worldwide, royalty-free licence, to the extent permitted by law, to host, store, reproduce, format, index, secure, back up and process Professional-submitted material.
• This licence does not transfer third-party intellectual-property rights that the Professional does not lawfully own or control.
• Investor Setu retains rights in its platform, software, branding, interfaces, documentation, workflows, templates, system architecture, configurations, automation, AI configurations, reports and other platform intellectual property to the extent protected by law, subject to third-party rights and express written agreements.
• Any special ownership, assignment, co-ownership or data-licensing arrangement must be expressly stated in the applicable written agreement or schedule.

8. Third-Party Data and Professional Responsibility

• A Professional must have a lawful basis, authority, permission, consent or other valid entitlement to submit or disclose Third-Party Data.
• The Professional must not upload or disclose personal, confidential or proprietary information that the Professional is prohibited from sharing.
• The Professional remains responsible for the accuracy and lawful provenance of information supplied by the Professional, while Investor Setu remains responsible for its own processing obligations under applicable law.
• Where required, the Professional must provide appropriate notices or obtain appropriate permissions from clients, owners, buyers, tenants, vendors or other persons before submitting their information.

9. Privacy, Data Protection and Consent

• Professional personal data is processed in accordance with the Investor Setu Privacy & Data Protection Notice and applicable Indian law, including applicable provisions of the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 as and when the relevant provisions apply.
• Investor Setu will use clear notices and purpose-specific processing descriptions. Consent, where it is the appropriate legal basis, will not be treated as unlimited or as permission for unrelated purposes.
• Core service communication and optional communication preferences will be distinguished. Optional communications must not be silently converted into mandatory consent.
• Where AI-assisted processing is offered and consent is the appropriate legal basis, the relevant AI-assisted purpose will be separately disclosed and recorded.
• Withdrawal or change of an optional communication preference operates prospectively and does not automatically require deletion of records that Investor Setu is lawfully required or permitted to retain.

10. Professional Communications

• Professionals must communicate accurately, lawfully and professionally with customers, owners, tenants, applicants, other professionals and Investor Setu personnel.
• Professionals must not use contact information obtained through Investor Setu for unrelated personal marketing, unauthorised solicitation, harassment, repeated unwanted contact or other unlawful purposes.
• Service-related communications must respect applicable consent, opt-out, privacy, telecom and communication requirements.
• Optional marketing or promotional communications require the applicable permission or other lawful basis. Investor Setu may impose additional communication controls by category, channel or contract.

11. Professional Code of Conduct

• Professionals must act honestly, fairly, professionally and in good faith.
• Professionals must not impersonate another person or organisation, misrepresent authority, qualifications, ownership, availability, pricing, approvals, registrations or transaction status.
• Professionals must not create fake, duplicate or misleading profiles, listings, requirements, enquiries, reviews, leads or business records.
• Professionals must not manipulate, fabricate or improperly influence ratings, reviews, enquiries, assignments, approvals, responses, outcomes or platform records.
• Professionals must not discriminate unlawfully, threaten, harass, intimidate, defame, deceive or engage in abusive conduct through the platform.
• Professionals must comply with applicable real-estate, consumer, advertising, contract, tax, financial, insurance, professional-licensing and other sector-specific requirements relevant to their activities.

12. Property, Project and Advertisement Conduct

• Property and project information must be materially accurate and must not knowingly contain false, misleading, deceptive or materially incomplete representations.
• Where a property, project, service or professional activity is subject to registration, approval, disclosure or advertising requirements, the Professional is responsible for complying with those requirements.
• Photographs, documents, logos, brochures, plans and other content must be lawfully obtained and used.
• Investor Setu may require corrections, supporting documents, status changes or removal of content that appears inaccurate, unlawful, misleading, unauthorised or inconsistent with platform rules.

13. Prohibited Data and Platform Misuse

• Professionals must not scrape, bulk-copy, harvest, export, reverse engineer, probe, circumvent, decode or attempt to derive confidential platform information except where expressly authorised in writing.
• Professionals must not attempt to discover or reproduce hidden identifiers, internal scoring, prioritisation, matching criteria, security controls, database structures, confidential workflows or other non-public system information.
• Professionals must not use automated tools, scripts, bots or other mechanisms to bypass access controls, rate limits, verification, permissions or other safeguards.
• Professionals must not use Investor Setu data to build a competing database or service, create unauthorised contact lists, facilitate spam, or circumvent a lawful platform restriction.
• Nothing in this section prevents lawful activity expressly authorised by Investor Setu or required by applicable law.

14. Confidentiality and Non-Circumvention

• Non-public information obtained through the professional relationship must be treated as confidential and used only for the authorised professional purpose.
• Confidential information includes non-public customer information, business information, commercial arrangements, platform documentation, system design, internal processes, security information, credentials, reports and other information identified or reasonably understood as confidential.
• Professionals must not disclose confidential information to unauthorised persons, use it for an unrelated purpose, or attempt to bypass Investor Setu to obtain an advantage from confidential information supplied through the platform, except where lawful and expressly permitted.
• These obligations do not apply to information that becomes public without breach, was lawfully known before disclosure, is independently developed without use of confidential information, or must be disclosed by law, subject to lawful notice where permitted.
• Confidentiality and non-circumvention obligations survive account closure to the extent necessary to protect continuing confidential interests.

15. Security, Audit and Monitoring

• Investor Setu may maintain security, access, consent, permission, communication, verification and audit records to the extent lawful and necessary for operation, security, compliance, dispute handling and accountability.
• Privileged actions may require stronger authentication, approval or additional verification.
• Access to sensitive information may be restricted, logged, reviewed, watermarked or disabled depending on role and risk.
• Investor Setu may use reasonable technical and organisational measures, including access controls, encryption, backups, monitoring and security protections appropriate to the service and information involved.
• Professionals must cooperate reasonably with legitimate security, compliance and incident-response measures.

16. AI-Assisted Features

• Investor Setu may use AI-assisted tools for disclosed functions such as search, classification, summarisation, drafting, workflow assistance, customer support or other approved purposes.
• AI output may be probabilistic or incomplete and must not automatically be treated as a binding professional, legal, tax, financial, investment, insurance or regulatory determination unless expressly stated and lawfully supported.
• Professionals remain responsible for decisions and representations they make using platform information or AI-assisted output.
• Sensitive information must be handled in accordance with applicable privacy, security, access and contractual controls.

17. Data Accuracy, Corrections and Retention

• Professionals must keep their own professional profile and submitted information reasonably accurate and promptly correct material errors.
• Investor Setu may preserve historical versions, status changes and audit history rather than overwriting material historical events.
• Records may be retained for periods determined by legal obligations, contractual requirements, security, fraud prevention, accounting, audit, dispute resolution, enforcement and legitimate operational requirements.
• Account closure does not necessarily result in immediate deletion of every record.

18. Suspension, Freeze, Restriction and Termination

• Investor Setu may suspend, freeze, restrict or terminate professional access where reasonably necessary because of suspected fraud, security risk, unlawful activity, material breach, misuse of confidential information, unauthorised access, repeated misconduct, inaccurate verification, non-payment where applicable, or other grounds under the governing agreement or law.
• Where appropriate, Investor Setu may restrict specific functions rather than terminate the entire account.
• Termination or suspension does not remove obligations that by their nature survive, including confidentiality, intellectual-property protection, lawful data use, payment obligations and dispute-related obligations.
• Professional export, handover or transition rights, where applicable, are governed by the applicable agreement and law.

19. Grievance, Review and Corrective Action

• A Professional may raise a genuine complaint, correction request, access issue or review request through the support or grievance channel specified by Investor Setu.
• Investor Setu may request evidence or clarification necessary to assess the issue.
• Investor Setu may take proportionate corrective action, including warning, correction request, content restriction, permission reduction, temporary suspension, freeze or termination, subject to applicable law and contractual rights.

20. Legal and Regulatory Compliance

• Professionals must comply with laws and regulatory requirements applicable to their own activities. Depending on the activity, these may include Indian contract, consumer-protection, privacy/data-protection, information-technology, telecommunications, advertising, intellectual-property, tax, real-estate and sector-specific requirements.
• Real-estate professionals must comply with applicable RERA requirements and relevant state or local requirements where applicable to their activity.
• Finance, insurance and other regulated activities must be conducted only within the permissions, registrations, licences and legal authority applicable to the Professional and the service.
• Nothing in these Terms authorises a Professional to perform a regulated activity for which the Professional lacks the required legal authority.

21. Intellectual Property and Content

• Investor Setu names, logos, branding, software, interface elements, documentation and platform materials may not be copied, modified, distributed, reverse engineered or commercially exploited without permission, except to the extent permitted by law.
• Professionals grant Investor Setu the rights reasonably necessary to display and process Professional-submitted content for the authorised platform purpose, subject to applicable law and the relevant agreement.
• Professionals must not upload content that infringes copyright, trademark, privacy, confidentiality, publicity, contractual or other rights.

22. Relationship and No Guarantee

• Unless a separate written agreement states otherwise, use of the professional platform does not by itself create a partnership, employment relationship, agency, franchise, joint venture or fiduciary relationship between Investor Setu and the Professional.
• Investor Setu does not guarantee that a particular enquiry, lead, property, project, customer, transaction, revenue result or business outcome will occur.
• Investor Setu may facilitate information exchange or business workflow but does not become a party to a transaction between a Professional and a customer unless expressly agreed in writing.

23. Governing Documents and Order of Precedence

• These Professional Terms operate together with the Investor Setu Master Terms & Conditions, Privacy & Data Protection Notice, Consent Framework, applicable Professional Agreement or Service Schedule, Acceptable Use Rules, Confidentiality Rules and category-specific rules.
• Where a signed or expressly accepted Professional Agreement or Service Schedule specifically addresses a commercial matter, that specific written term will govern that matter to the extent of the inconsistency.
• Mandatory law prevails over any contractual or platform term to the extent required by law.

24. Changes to These Terms

• Investor Setu may update these Terms to reflect legal requirements, security changes, service changes, operational requirements or improvements.
• Where a change is material and notice is legally required, Investor Setu will provide the applicable notice or acceptance mechanism.
• Continued use after the effective date of an applicable update may constitute acceptance only to the extent permitted by law and the applicable agreement.

25. Indian Law and Jurisdiction

• These Terms are intended to operate under the laws of India, subject to mandatory applicable law and any valid dispute-resolution provision in the applicable written agreement.
• Any dispute forum or jurisdiction clause must be read subject to applicable consumer, regulatory and other mandatory jurisdictional requirements.

26. Minimum-Disclosure and Confidential-System Rule

• Investor Setu will disclose to Professionals only the information reasonably necessary for their authorised role, service and legal rights.
• No Professional is entitled merely by virtue of platform access to the complete Investor Setu system map, internal data architecture, hidden identifiers, matching logic, scoring or prioritisation methods, security thresholds, database structure, internal operational rules or confidential administrative controls.
• Professionals must not seek to infer, reconstruct, document or disclose such non-public information. Detailed operational rules may be maintained in a separate internal Investor Setu rule book and are not incorporated into public or professional documentation merely by reference.

27. Acceptance and Effective Date

• By applying for, accepting or using an Investor Setu professional account or professional service, the Professional confirms that the Professional has had a reasonable opportunity to review the applicable terms, notices and permissions and agrees to comply with the terms applicable to the Professional’s role.
• Where a separate acceptance, signature, click acceptance or electronic record is required, that record will govern the applicable acceptance event.
• Effective Date: 6 October 2026.
• Version: 1.0.

28. Legal Review and Implementation Safeguard

• This document is prepared as a comprehensive operational and contractual draft for Investor Setu implementation and is intended to be aligned with applicable Indian law, including the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 as their provisions become applicable.
• Before public launch or professional onboarding at scale, Investor Setu should obtain a final review by an India-qualified lawyer or privacy/technology professional for the exact legal entity, contracts, sector-specific activities, state-specific requirements, data-processing roles, retention, cross-border processing, communication practices and implementation.