Privacy Policy

SUGAM SURAKSHA SARTHI INDIA PRIVATE LIMITED

INTRODUCTION

1.1 Data Protection Commitment

SUGAM SURAKSHA SARTHI INDIA PRIVATE LIMITED (“Company”, “We”, “Us”) is committed to protecting your privacy and personal data in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and other applicable data protection laws.

1.2 Scope of Policy

This Privacy Policy applies to the Drivergill mobile application and all related services. It explains how we collect, use, store, share, and protect your personal data.

1.3 Data Controller

The Company acts as the data fiduciary (controller) for personal data collected through the App/website.

DATA COLLECTION

2.1 Personal Information Collected

We collect the following categories of personal data:

Account Information:

Name, phone number, email address
Profile picture (optional)
Date of birth (for age verification)
Government ID details (for verification)
Location Data:
Pickup and drop-off locations
Real-time GPS location during trips
Approximate location for service availability
Vehicle Information

Payment Information:

Credit/debit card details (tokenized)
Digital wallet information
UPI IDs and transaction history
Billing addresses
Device Information:
Device type, operating system
App version and usage analytics
IP address and device identifiers
Push notification tokens

Communication Data:

Customer support interactions
In-app messages with drivers
Call logs for safety purposes

2.2 Data Collection Methods

Data is collected through:

Direct input during registration
Automatic collection during app usage
Third-party integrations (payment gateways, maps)
Cookies and tracking technologies

LEGAL BASIS FOR PROCESSING

We process personal data based on:

3.1 Consent

Marketing communications
Location tracking (beyond service requirements)
Optional features and services
Data sharing with third parties for non-essential services

3.2 Contractual Necessity

Service provision and trip facilitation
Payment processing
Account management
Customer support

3.3 Legitimate Interest

Fraud prevention and security
Service improvement and analytics
Safety monitoring
Business operations

3.4 Legal Compliance

Regulatory reporting
Law enforcement requests
Tax and financial compliance
Dispute resolution

USE OF DATA

4.1 Primary Uses Service Provision:

Connecting passengers with drivers
Route calculation and navigation
Trip tracking and completion
Payment processing

Safety and Security:

Identity verification
Fraud detection and prevention
Emergency response
Incident investigation

Customer Support:

Query resolution
Complaint handling
Service improvement
Technical support

4.2 Secondary Uses (with consent) Marketing and Communications:

Promotional offers and updates
New feature announcements
Surveys and feedback requests
Personalized recommendations

Analytics and Improvement:4.2 Secondary Uses (with consent) Marketing and Communications:

Usage pattern analysis
Service optimization
App performance monitoring
Business intelligence

DATA SHARING

5.1 Sharing with Drivers

Limited data shared with assigned drivers:
First name and phone number
Pickup and drop-off locations
Trip-specific information
Rating and feedback (anonymized)

5.2 Service Providers

Data shared with trusted third parties:
Payment processors (for transaction processing)
Map and navigation services
Cloud storage providers
Customer support platforms
Analytics and marketing tools

5.3 Legal Authorities

Data may be shared with:
Law enforcement agencies (upon legal request)
Regulatory authorities (for compliance)
Courts and tribunals (pursuant to legal orders)
Tax authorities (for financial compliance)

5.4 Business Transfers

In case of merger, acquisition, or business transfer, data may be transferred to the new entitywith appropriate safeguards.

5.5 No Sale of Personal Data

We do not sell, rent, or trade personal data to third parties for their marketing purposes.

DATA SECURITY

6.1 Security Measures

We implement industry-standard security measures:

Technical Safeguards:

End-to-end encryption for sensitive data
Secure data transmission-HTTPS/TLS
Regular security audits and penetration testing
Access controls and authentication
Data anonymization and pseudonymization

Organizational Safeguards:

Employee training on data protection
Data processing agreements with vendors
Privacy by design principles
Incident response procedures
Regular security policy updates

6.2 Data Breach Response

In case of data breaches:

Immediate containment and assessment

Notification to authorities within 72 hours

User notification for high-risk breaches Remedial measures and monitoring Regular breach response drills

DATA RETENTION

7.1 Retention Periods

Active User Data: Retained while account is active

Trip Data: 2 years (for legal and regulatory compliance)

Payment Data: As per RBI guidelines and tax requirements

Support Communications: 1 years

Marketing Consents: Until withdrawn

7.2 Deletion Procedures

Data deletion through:

Automated deletion after retention period
User-initiated account deletion
Data subject erasure requests
Secure deletion methods for all copies

7.3 Legal Retention Requirements

Some data may be retained longer for:

Legal proceedings
Regulatory investigations
Tax and financial audits
Fraud prevention

USER RIGHTS

8.1 Right to Access

Under the DPDP Act, you have the following rights: Request information about:

Personal data we hold about you
Purposes of processing
Categories of recipients
Retention periods

8.3 Right to Erasure

Request deletion of personal data when:

No longer necessary for original purpose
Consent is withdrawn
Data has been unlawfully processed
Required for legal compliance

8.4 Consent Management

Withdraw consent at any time
Granular consent controls
Easy consent modification options

COOKIES AND TRACKING

9.1 Types of Cookies Essential Cookies:

App functionality
Security features
User preferences

Analytics Cookies:

Usage statistics
Performance monitoring
Error tracking

Marketing Cookies:

Personalized content
Advertising optimization
Cross-platform tracking

9.2 Third-Party Analytics

We use third-party services like:
Google Analytics (with data anonymization)
Firebase Analytics
Custom analytics platforms

9.3 Opt-Out Options

Users can control tracking through:
App settings
Device privacy settings
Cookie preferences
Marketing communication preferences

INTERNATIONAL TRANSFERS

10.1 Data Localization

In compliance with RBI requirements:
Payment data stored within India
Primary user data stored locally
Copies may be transferred abroad with safeguards

10.2 Transfer Safeguards

When data is transferred internationally:
Adequacy decisions by Indian authorities
Standard contractual clauses
Corporate binding rules
Explicit user consent

10.3 Vendor Compliance

All international vendors must:

Provide adequate data protection
Sign data processing agreements
Comply with Indian data protection standards
Enable data localization when required

CHILDREN'S PRIVACY

11.1 Age Restrictions

Our service is not intended for users under 18 years of age.

POLICY UPDATES

12.1 Amendment Process

This policy may be updated to:

Comply with new laws and regulations
Reflect changes in our practices
Improve clarity and transparency
Add new features and services

12.2 Notification of Changes

Policy updates will be communicated through:

App notifications
Email notifications
Website banner notices
Push notifications for material change

12.3 Continued Use

Continued use of the App after policy updates constitutes acceptance of the revised policy.

CONTACT AND GRIEVANCES

13.1 Data Protection Queries

For privacy-related questions: Email: support@sugamsarthi.com

13.2 Grievance Redressal

Internal Process:

Submit complaint through app or email
48-hour acknowledgment
30-day resolution timeline
Escalation to senior management(if required)

13.3 Response Timeline

Query acknowledgment: Within 48 hours
Simple queries: Resolved within 1-2 business days
Complex investigations: Up to 30 days

Regular status updates provided This Privacy Policy is effective from September 2025 and was last updated on September 12,2025.