Privacy Policy

The Company is concerned about the privacy of its users (“User(s)” and/or “You” and/or “Your”) while using the Comptech Scooter and accessing the ‘Comptech scooter’ whether through a computer or a mobile phone.

Please read this Privacy Policy (“Policy”) carefully. Your use of the Application or the services provided by the Application signifies Your acceptance of this Policy and Your agreement to be legally bound by the same. You may withdraw Your consent by uninstalling the Application and withdrawing from the services at any time.

If You do not agree with the terms of this Policy, do not use the Application or avail any of the services offered through the Application.

About the Policy

This Policy intends to inform You about how We collect, receive, hold, use, transfer and/or disclose Your personal information, in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, as amended from time to time (“Indian Data Protection Law”).

Please note that this Policy will give You a general understanding of:

• The circumstances under which We collect and process Your Personal Data;
• The types of Personal Data We collect;
• The reasons for collecting Your Personal Data;
• How We handle Your Personal Data;
• Distribution of responsibility for the Processing of Personal Data between various legal entities of the Company; and
• Contact details for Us so You can receive information about and claim Your rights in relation to our processing of Your Personal Data.

Collection of Information and its Use

The types of information that We collect about You will depend on our relationship with You, the circumstances of collection and the type of service You request from us. The information collected by Us may be categorized as “Personal Information/Data” and “Sensitive Personal Information” (each as explained below). Personal Information/Data and Sensitive Personal Information shall collectively be referred to as “Information” for the purposes of this Policy.

Personal Information/Data

As per the Indian Data Protection Laws, Personal Information shall include any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. For example, Personal Information would include names, postal addresses, and telephone numbers.

To elaborate, Personal Data means any information relating to an identified or identifiable natural person (‘data subject’). Please note that an identifiable natural person is one who can be identified (directly or indirectly), through a particular reference such as a name, an identification number, location data, an online identifier or to one or more specific factors with respect to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Sensitive Personal Information

As per the Indian Data Protection Laws, “Sensitive Personal Information” means Personal Information which consists of information relating to:

• Password;
• Financial information such as Bank account or credit card or debit card or other payment instrument details;
• Physical, physiological, and mental health condition;
• Sexual orientation;
• Medical records and history;
• Biometric information;
• Any detail relating to the above clauses as provided to a body corporate for providing service; and
• Any of the information received under the above clauses by a body corporate for processing and/or is stored or processed under lawful contract or otherwise.

For example, Sensitive Personal Information would include age, medical history/records, weight etc. However, any information that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005 or any other applicable law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Policy.

In light of the above, please be informed that We may collect and process one or more of the following Information pertaining to You. The type of Information We may require may change depending on whether You have just created an account, booking a test ride, or processing such Information. Any or all Information that is to be provided by You would be based on Your consent. However, We would like You to note that certain information would be required for performing one or more services. We are also required to collect certain Personal Information as required under applicable laws. You may opt-out from providing us your Personal Information or Sensitive Personal Information; however, You may not be able to avail Our services in such cases.

We wish to assure you that Your Information is safe with us. We will only process your Information lawfully and for purposes, details of which We have provided in the below section.

The following are the types of Personal Information pertaining to You that We may collect:

• Full name;
• E-mail address;
• Date of birth;
• Location information, including but not limited to the current location, saved location, pinned locations, searched locations and the GPS location of (a) any person placing an order through the Application; (b) while using location-based services through products and services; and (b) addresses provided for providing the products or services;
• Address (including city or town);
• Photograph of the user;
• Emergency Contact Information;
• Billing and shipping address;
• Phone numbers;
• Account login credentials and password;
• Customer ID;
• IP addresses;
• Details of the products or services ordered including pricing;
• Date of purchase of products or services;
• Details of the vehicle purchased, e.g., vehicle license number, VIN, etc.;
• Driving license no. and expiry date or any other official identification proof;
• Vehicle insurance policy number;
• Vehicle repair history;
• Telematics data such as performance, operations, performance, usage of products;
• User behavior and activities including but not limited to clicks done, marketing e-mails opened, number of page views, time of first session, time of last session, facebook clicks, google plus clicks, first conversion date, last e-mail sent date, number of submissions etc.;
• Cookies;
• Payment information and history (excluding payment details that shall be collected and processed by an authorized payment service provider, which we do not collect);
• Various certificates, e.g., registration certificate, insurance certificate, road tax certificate, etc.;
• Financial information, e.g., credit card or debit card number including expiry date;
• Any device and device identifier information as may be deemed necessary;
• Personal details of the secondary user, if provided;
• We may automatically receive data on the successful pairing of the bluetooth.
• Such other Personal Data as may be required from time to time.

Of the above types of Personal Information, your financial information is considered to be Sensitive Personal Data. Please note that the Personal Information as listed above, other than financial information, is not Sensitive Personal Information. We wish to share that it is possible that the Government of India may categorize some of the other types of Personal Information as Sensitive Personal Data/Information. In such cases, We will inform You of the same and obtain Your consent as, and if required.

It is also clarified that if You provide any data relating to Your Aadhaar then the same shall be stored in the manner as mandated by UIDAI.

The Personal Information may have been provided by You, may have been collected by Us during our interaction with You, or may have been obtained by Us from third parties or from our affiliates.

Purpose of Collection and Processing of Personal Information

Your Personal Information is collected at the following stages:

• When You register on the Application and create a user account (the “User Account”);
• When You visit and/or use our Application;
• When You book a test ride;
• When You pre-order or purchase our products or services;
• When You set up and drive any of our products;
• When We communicate or undertake activities such as servicing, referrals, affiliates, brand champions, and/or other promotional activities, etc.

Where reasonably practical or as required by applicable law, We will obtain Your consent prior to collecting or using Your Personal Information. The request for Your consent will be clear and specific and provide You with a reasonable basis on which You may make Your decision. We will make sure that You can provide Your consent in a clear and transparent manner. Your consent is voluntary and may always be revoked, for example by terminating a particular service or contacting our representative in the manner indicated in later sections. As mentioned before, where Your consent is required and You do not give Your consent, it may not be possible for You to use the Application and/or avail the services being offered by us.

How Your Information is Processed

Your Personal Information is processed by us under different circumstances and under different lawful bases. Below are the details:

Where You Have Provided CONSENT

• Process your contact information to create your user account.
• Process your personal information for arranging test drives or callbacks.
• Process personal information for completing your purchase and user account creation.
• Process information for processing returns if you are not happy with your vehicle.
• Process payments or refunds using your financial information.
• Collect and process location-specific information for providing location-based services.
• Process personal and vehicle information for servicing and repair activities.
• Supply brochures and materials you have specifically requested.
• If opted in, contact you with marketing information about products and services.
• Complete other processing activities you have expressly requested.

You can withdraw your consent at any time, but certain operations may require essential personal information.

Where Required to Perform a CONTRACT with You

• Provide information necessary to complete your vehicle purchase.
• Perform post-sale activities as agreed in relation to your vehicle.
• Assist in configuring your vehicle for your use.
• Share contact information with delivery and service partners.

Where It Is in Your VITAL INTEREST in Emergent Situations

• Contact you in case of urgent safety or product recall notices.
• Use emergency contact information in case of an incident.
• Verify your identity if login attempts fail.

Where There Is a LEGITIMATE INTEREST or for Other REASONABLE PURPOSES

• Analyze data to aid marketing strategies.
• Improve and personalize your customer experience.
• Conduct market research to enhance products and services.
• Manage and maintain the application for security and efficiency.
• Engage in marketing activities and credit checks.
• Comply with requests related to your rights.
• Enforce or protect contractual or legal rights.

For Compliance with Existing or Applicable Laws

We may need to process personal data to comply with legal obligations, such as verifying age before test drives.

Marketing

Marketing Based on Voluntarily Provided Data

We may use data provided during promotional campaigns for marketing purposes. Consent may be revoked at any time.

Marketing Based on Your Behavior Data

We collect and process behavior data through cookies, with consent, to analyze and enhance your experience. You can withdraw consent to cookies as described in our cookie policy.

Marketing Based on Personal Data, Third-Party Data, and Behavior Data

With consent, we combine behavior data with third-party data for personalized marketing. You may opt-out of such processing at any time.

Sharing Your Information

Dealers

Dealers use your information to provide better service and personalized offers.

Service Providers and Analytics Partners

We share information with service providers and partners for various services. They are obligated to protect your information.

Corporate Affiliates

We may share information within our group companies or during mergers and reorganizations.

Compliance and Security

We may disclose information to authorities for legal reasons or to protect our rights and users.

International Transfers

Personal data may be transferred outside India with appropriate safeguards. Consent will be sought for sensitive data transfers.

Retention

We retain personal data only as long as necessary for the purposes outlined. Data may be kept longer if required by law or legal disputes.

Your Rights

• Access your personal information.
• Verify and rectify inaccuracies.
• Withdraw consent where applicable.
• Object to processing and automated decisions.
• Request erasure or restriction of your personal data.
• Port your information in a structured format.

Data Breach

We will notify you of any data breaches as required by law, including details about the breach and our response.

Security

We take measures to protect your information but are not liable for breaches due to your negligence.

Phishing

We do not request sensitive information through non-secure communications. Be cautious with your personal information.

Cookies

We use cookies to enhance your experience and improve our services. Some cookies are essential, while others collect usage data.