Privacy Policy

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 and other applicable data protection laws. This Privacy Policy covers the DriverGill mobile application and related services, and explains how we collect, use, store, share and protect your information.

1. Introduction

This policy applies to the DriverGill App and website. The Company acts as the data fiduciary for personal data collected through the App and website.

2. Data we collect

• Account information: name, phone number, email address, optional profile picture, date of birth, government ID details.
• Location data: pickup and drop-off locations, real-time GPS during trips, and approximate location for service availability.
• Vehicle information: details about the vehicle used for a trip.
• Payment information: tokenised card details, digital wallet information, UPI IDs, transaction history and billing addresses.
• Device information: device type, operating system, app version, usage analytics, IP address, device identifiers and push tokens.
• Communication data: support interactions, in-app messages with drivers, and call logs for safety.

Data is collected through direct registration, automatic collection during app use, third-party integrations, and cookies and similar technologies.

3. Legal basis for processing

We process personal data on the basis of your consent (marketing, optional features, non-essential third-party sharing, location beyond service needs), contractual necessity (trip facilitation, payments, account management, support), legitimate interest (fraud prevention, security, analytics, safety monitoring) and legal compliance (regulatory reporting, lawful requests, tax and dispute resolution).

4. How we use data

Service provision: connecting passengers with drivers, route calculation and navigation, trip tracking and completion, and payment processing.

Safety and security: identity verification, fraud detection and prevention, emergency response and incident investigation.

Customer support: query resolution, complaint handling, service improvement and technical support.

With your consent we may also use data for promotional offers, feature announcements, surveys, personalised recommendations, usage analysis, service optimisation and business intelligence.

5. Data sharing

• With drivers: limited data such as first name and phone number, pickup and drop-off locations, and trip-specific information, plus anonymised ratings.
• Service providers: trusted third parties including payment processors, map and navigation services, cloud storage, support platforms and analytics tools.
• Legal authorities: law enforcement (on lawful request), regulators, courts and tax authorities.
• Business transfers: in a merger, acquisition or transfer, with appropriate safeguards.

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

6. Data security

We apply technical safeguards (encryption for sensitive data, HTTPS/TLS transmission, regular security audits and penetration testing, access controls, anonymisation and pseudonymisation) and organisational safeguards (staff training, data processing agreements, privacy by design, incident response procedures). In the event of a data breach we contain and assess it immediately, notify the authorities within 72 hours, and notify affected users for high-risk breaches.

7. Data retention

• Active user data: while your account is active.
• Trip data: 2 years, for legal and regulatory compliance.
• Payment data: as per RBI guidelines and tax requirements.
• Support communications: 1 year.
• Marketing consents: until withdrawn.

Data is deleted through automated deletion after retention periods, user-initiated account deletion, and erasure requests, using secure deletion methods. Some data may be retained longer where legally required.

8. Your rights

You have the right to access the personal data we hold about you, the purposes of processing, the categories of recipients and retention periods. You may request erasure where data is no longer necessary, consent is withdrawn, processing was unlawful, or deletion is legally required. You can withdraw consent at any time with granular controls.

9. Cookies and tracking

We use essential cookies (functionality, security, preferences), analytics cookies (usage statistics, performance, error tracking) and marketing cookies (personalised content, advertising optimisation). We use analytics tools including Google Analytics and Firebase Analytics. You can control tracking through app settings, device privacy settings and communication preferences.

10. International transfers

In compliance with RBI requirements, payment data and primary user data are stored within India, though copies may be transferred abroad with safeguards such as adequacy decisions, standard contractual clauses, binding corporate rules and explicit consent. International vendors must provide adequate protection and sign data processing agreements.

11. Children's privacy

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

12. Policy updates

We may update this policy to comply with new regulations, reflect changes in practice, improve clarity or add features. Updates are communicated through app notifications, email, website banners and push notifications for material changes. Continued use of the App after an update constitutes acceptance of the revised policy.

13. Contact and grievances

For data-protection queries or to exercise your rights, contact our Grievance Officer at support@drivergill.com. Complaints can be submitted through the app or by email; we acknowledge within 48 hours and aim to resolve within 30 days, with escalation to senior management where required.

[Name the Grievance Officer here — required under the DPDP Act, 2023 and the IT Rules.]