A buyer’s enquiry is distributed to a channel-partner network of dozens to hundreds of brokers, each of whom calls independently — a distribution model built entirely on onward transfer nobody consented to, feeding the country’s most-complained-about consumer harm. Around it: RERA-mandated records that shield the agreement’s PAN but not the six phone numbers and the site-visit log in the CRM, across thirty-odd state rule sets nobody has mapped; and Aadhaar demanded at the sub-registrar by state mandate and photocopied at the sales office by habit, against a statute that restricts exactly that.
FROM THE SEPTEMBER 2026 PROBLEM REGISTER · 4 REAL-ESTATE PROBLEMS SWEPT · 4 SHOWN HERE, ONE LABELLED HYPOTHESISED · HOW THIS WAS BUILT
Confirmed means two independent sources, at least one the instrument itself or a practitioner record. Where a half of a problem rests on secondary sources only, the card says so.
Section 6(1) requires consent that is specific to a purpose. Sharing an enquiry with fifty partners who each dial is onward transfer the buyer never agreed to; the bundled “I authorise X and its partners” line is exactly the boilerplate s.6(1) is written against. TRAI’s telemarketing regulations and its 2024 direction disconnecting unregistered telemarketers already act on the symptom — real estate is among the top spam categories — while DPDP reaches the cause from mid-May 2027.
SOURCES · DPDP Act s.6(1) (statute) · PIB on TRAI’s spam-control measures (government, the enforcement record this feeds)
Confirmed · sweep of 2 Sep 2026 · this is the vertical’s revenue mechanicRERA s.4 and s.11 require promoter disclosures; s.10(b) requires agents to preserve records “as may be prescribed” — state by state. DPDP s.8(7) and s.12(3) let a fiduciary refuse erasure only for what a law in force requires. The carve-out covers the buyer’s PAN in the agreement, not the phone numbers and site-visit log in the CRM. Over-honouring breaks RERA and tax; blanket refusal breaks DPDP; the published response period runs either way. Not a hard legal conflict — an unmapped one.
SOURCES · RERA 2016, s.10(b) (statute) · DPDP Act s.8(7), s.12(3) (statute) · Vinod Kothari on DPDP for non-financial entities (practitioner)
Confirmed as a mapping problem · the state periods themselves are not enumerated anywhereUttar Pradesh made Aadhaar authentication with biometric verification mandatory for property registration from 1 February 2026; other states are moving to Aadhaar-linked e-registration. That is the state acting under its own law. The private-side habit — a full photocopy in the sales office file — sits against the Aadhaar Act’s s.29 restrictions, the Supreme Court’s 2018 ruling on private authentication, and DPDP s.6 minimisation. Masked Aadhaar and offline-verification XML are the legally preferred forms; adoption at sales offices is near nil.
SOURCES · The UP mandate, as reported by the public broadcaster (state instrument, as reported) · Aadhaar Act s.29; DPDP Act s.6 (statute)
Confirmed for the mandate and the restrictions · the photocopy half is attested by secondary sources onlyThe architecture is near-certain from the product surface: identity documents collected for a tenancy persist beside browsing and lead-generation data under a single signup consent, and the tenant’s Aadhaar outlives the tenancy. KYC-grade documents under lead-generation-grade governance is the shape. No second source yet establishes the cross-purpose reuse concretely, so this card is labelled rather than asserted.
SOURCES · DPDP Act s.6, s.8(7) (statute) · no practitioner record yet — stated as such
Hypothesised · the architecture is visible; the reuse is not yet on recordThe register started from AI-drafted hypotheses and kept only what the instruments supported. These are the property-specific claims that changed on the way.
Biometric authentication at registration is a state actor acting under a state mandate. What the private side collects is document copies. The two halves need different lawful-basis analyses, and material that blurs them gets both wrong.
The duty to preserve records is prescribed state by state. Any page that quotes a single number for it is quoting a state rule or inventing one. The register lists the enumeration of the state periods as exactly the mapping nobody has done.
Section 8(7) protects what a law in force requires — the mandated disclosure fields — not the whole customer record they sit in. A refusal that cites RERA for the CRM is a refusal that will not hold.
The penalty provisions commence in mid-May 2027 and the Board had no members as of 1 August 2026. What is enforced today is the telemarketing regime on the calls themselves. The DPDP penalty schedule is stated plainly here, once.
RULES NOTIFIED MID-NOV 2025 · CONSENT-MANAGER REGISTRATION OPENS MID-NOV 2026 · DUTIES, RIGHTS AND PENALTIES MID-MAY 2027 · DATES STATED AS THE NOTIFICATIONS STATE THEM
Everything below is live today and maps to shipped code — the same rule as every page on this site. Capabilities we are still building are not listed here.
Onward sharing with channel partners becomes a specified purpose the buyer decides on separately from the enquiry itself — never bundled, never pre-ticked; the widget enforces that rather than trusting the form. Notices are versioned so a change forces re-consent and the old version stays on record; withdrawal is as easy as the grant. Each decision produces a receipt the buyer keeps and anyone can verify. Who was actually shared with is your CRM’s record to keep — and our processor register to hold.
Live: purpose-by-purpose consent · no pre-ticked purpose · versioned notices · PDF receiptsEvery access, correction and erasure request carries a response deadline computed when it is filed and an escalation ladder when it slips. Erasure is executed against the stores you connect — a parameter-bound delete against the table and column you nominate, and deletion through connected CRM tools’ own APIs — and the destruction is recorded, not asserted. The refusal for the mandated fields lands in the same audit chain, citing the provision. Mapping the state rule is yours; the refusal that names it is evidenced here.
Live: DSR orchestration · SLA tracking · erasure connectorsA single inventory of your data assets, with visual lineage tracing how personal data flows between systems and purposes, and a discovery layer that finds identity documents where they sit. Minimisation starts with knowing where the maximum currently is. Which documents you keep collecting is a policy decision this page does not make for you.
Live: unified data inventory + visual lineage · Sentin-AI discoveryNotices and consent flows are rendered in twenty-two Indian languages by a self-hosted translation model — buyers across states are served one versioned notice. Every consent, erasure, refusal and notice publication is a linked record bound to the one before it, periodically stamped by an independent timestamp authority. Anyone can check it.
Live: 22 Indian languages · tamper-evident audit trail · verifiable receipts