1. General

AP Mobility India Private Limited, with its registered office at C-156 Radha garden, Ganga Nagar Meerut 250001 Uttar Pradesh India (“RideBuddy”, “we”, “our” or “us”), acting as data controller, is committed to safeguarding and respecting your privacy. This privacy notice (the “Privacy Notice”) outlines our practices concerning the collection, usage, and disclosure of information you may provide via our mobile application or website (collectively referred to as the “Platform”).

This Privacy Notice, together with our Terms and Conditions, any referenced documents, and our Cookie Notice, explains how we process any personal data collected from you or provided by you. Please read these terms carefully to understand our views and practices regarding your personal data and how we handle it.

2. What Information Do We Collect From You and for How Long?

We may collect and process the following data about you:

1. 2.1 Information You Provide

   You may provide us with information, including data that identifies you (“Personal Data”), when using our Platform. This includes filling in forms, participating in competitions or surveys, corresponding with us, or reporting issues with our Platform. The information you provide may include:

   • 2.1.1. Mandatory information required to register for the service we provide on our Platforms or to access other services provided by us, including your name, email address, date of birth, gender, mobile phone number and a OTP. All these fields are mandatory. Ridebuddy will not be able to provide you with the services offered on our Platforms if the required information is not provided, consequently you will not be able to register for a user account on our Platforms;
   • 2.1.2. A photograph;
   • 2.1.3. A postal address;
   • 2.1.4. Details on your cars;
   • 2.1.5. Your mini-biography;
   • 2.1.6. A record of any correspondence between you and us;
   • 2.1.7. A record of any bookings you have made or trip related advertisements you have placed with or through our Platforms;
   • 2.1.8. Details of accounting or financial transactions including transactions carried out through our Platforms or otherwise. This may include information such as your payment card or bank account details, details of trips or legs you have booked or offered through our Platforms;
   • 2.1.9. Details of your visits to our Platforms and the resources that you access;
   • 2.1.10. Your replies to any surveys or questionnaires, such as your reviews on the trips you have shared with other members of our community. Such information may be used for analytic & user understanding purposes;
   • 2.1.11. Information we may require from you when you report a problem with our Platforms or our service, such as the subject of your request for support;
   • 2.1.12. Location information when you have given consent to the collection and processing of these data; and
   • 2.1.13. Passport, Driving Licence, ID Card, biometric data, real-time geolocation data which can identify an individual, business secrets deemed highly confidential (e.g., highly confidential business strategies and communications, sensitive attorney-client privileged and confidential communications), and such other documents that you have agreed to provide to us.
   • 2.1.14. Authentication/authorization credentials, information under strict regulatory or contractual handling requirements (e.g., PCI, HIPAA, and state and federal data security laws) such as credit card information, credit card numbers, CIV numbers (three-digit codes for Visa and MasterCard, four-digit code for American Express), and magnetic stripe information.

2. 2.2. Information We Collect Automatically

   • 2.2.1. If you sign up via social media authentication methods, Ridebuddy will access certain Personal Data (e.g. first name, surname, picture, email, etc.) in your social media account pursuant to the applicable terms and conditions of these social media platforms. We may also collect some of your Personal Data when you interact with third party social media features, such as “Like” functions.
   • 2.2.2. With regard to each of your visits to our Platforms we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Platforms, products you viewed or searched for, download errors, length of visits to certain pages, page interaction and any phone number used to call our customer service number. We collect this information through the use of various technologies including cookies (for further information please refer to our Cookie Notice).
   • 2.2.3. We also collect aggregated information regarding your activity on our Platform (such as the amount of rides offered, your message response rate, etc.). Such information may be published on your public profile on our Platform.

3. 2.3. Data Retention

   • 2.3.1. Except regarding the categories of Personal Data mentioned in clauses 2.3.2 and 2.3.3 below, your Personal Data will be stored for the duration of your relationship with us and then put beyond use:

3. How Do We Use the Information We Collect From You?

We utilize the information we collect to:

PURPOSES LEGAL BASIS

• 3.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you requested from us; This processing is necessary for the performance of our mutual contractual obligations.
• 3.2. to send you service-related information by email and/or text message and/or any other communication means (e.g. your booking confirmation); This processing is necessary for the performance of our mutual obligations and/or carried out with your consent.
• 3.3. to collect payments from you or to transfer to you the payments we collect on your behalf; This processing is necessary for the performance of our mutual contractual obligations.
• 3.4. to enable you to personalize your user profile on our Platforms; This processing is carried out with your consent.
• 3.5. to enable you to communicate and interact with other members about our services or about the trips(s) you have/will share with other members and/or to organize such trips; This processing is necessary for the performance of our mutual contractual obligations and/or carried out with your consent.
• 3.6. to give you access to our support services and to enable you to communicate with our member relations team; This processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent and/or (iii) necessary for the establishment, exercise or defense of legal claims.
• 3.7. to ensure compliance with (i) applicable laws, (ii) our Terms and Conditions, and (iii) our Privacy Notice. Certain breaches that we regard as inappropriate may lead to the suspension of your account; This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations and/or (iii) for the establishment, exercise or defense of legal claims.
• 3.8. to send you, in accordance with applicable laws and where required, with your consent, marketing materials and information necessary to facilitate the service or the booking process and to make you suggestions and recommendations about goods or services related to our services that may interest you. We also use your data to target you in order to serve our ads on social media platforms. You can learn more about how these features work, and the data that we obtain about you, by visiting the relevant sections of the third party social media platforms; and This processing is based on your consent and/or our legitimate interest (i.e. providing you with meaningful advertising).
• 3.9. to notify you about changes to our services; This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations and/or (iii) the establishment, exercise or defense of legal claims. for different durations:
• Financial data (e.g. payments, reimbursements, etc.) is stored for the duration required by applicable tax and accounting laws;
• All user-generated content (e.g. comments and ratings) is anonymized but remains available on our Platforms.
• 2.3.3. In the event that your account is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our Platforms.

4. Who Are the Recipients of the Information We Collect From You and for Which Purposes?

4.1. When you use our services, some information about you is shared with the members of our communities, either on your public profile or during the booking process (e.g. we give your telephone number to the members with whom you will share a ride).

4.2. We may receive and send information about you, including your Personal Data, if you use any of the platforms we operate or from other Ridebuddy entities and affiliates, for the purposes outlined in this Privacy Notice.

4.3. We are also working closely with third parties which may be the recipients of your Personal Data such as:

• Our business partners who are social media platforms and which may provide you with connecting services, such as the connection of the information of your profile, from their social media platforms to our Platforms;
• Our business partners who may advertise their services on our Platforms and to which you may decide to sign up for: these services may be any service related to our services such as insurance services, banking services, rental services, etc. For instance, we may provide insurance companies such as AXA with some of your information in order to confirm that you are eligible for insurance cover;
• Our business partners who may advertise our services on their websites;
• Our sub-contractors in technical, payment, identity verification and delivery services, or analytics providers.

4.4. We only share your Personal Data with any of these third parties in the following cases:

• 4.4.1. Where it is necessary to involve a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. if we charge you any fees or collect any money from you in relation to any services on the Platforms);
• 4.4.2. As part of the booking process and in order to provide the requested services, information such as your name, photography, mobile phone number and/or email address, may be displayed on the Platforms and/or passed on to a passenger (if you are a driver) or a driver (if you are a passenger);
• 4.4.3. As part of our rating system, the reviews you write will be published on the Platforms. The reviews including your abbreviated name and photography are visible to all visitors of the Platforms;
• 4.4.4. We use analytics and search engine providers to assist us in the improvement and optimization of our Platforms;
• 4.4.5. It is explicitly requested by you (e.g. with when using social media authentication methods);
• 4.4.6. We may distribute parts of our Platforms (including the trips you have posted) for display on our business partners’ websites through API or widgets. In these cases, some information from your public profile may be displayed on these websites;
• 4.4.7. Ridebuddy may also disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (i) respond to claims asserted against Ridebuddy, (ii) to comply with legal proceedings, (iii) to enforce any agreement with our users such as our Terms and Conditions and our Privacy Notice, (iv) in the event of an emergency involving the danger of public health, death or physical injury to a person (v) in the framework of investigation or (vi) to protect the rights, property or personal safety of Ridebuddy, its members or others;
• 4.4.8. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; and
• 4.4.9. If Ridebuddy or all or part of its assets are acquired by a third party, in which case Personal Data held by it about its members will be one of the transferred assets.

4.5. In accordance with applicable laws and where required with your consent, we may combine information about you, including your Personal Data and cookie information, we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above.

4.6. We draw your attention on the fact that if you decide to share your information, including Personal Data, with us through our business partners’ connecting services, any of our business partners’ privacy policies and/or notices may also be applicable to you, in addition to this Privacy Notice. We do not control the collection and/or the processing of your information eventually made by our business partners on their own platforms.

5. How do we use and moderate your messages?

5.1. We may review, scan, or analyze the messages you exchange with other members of our community through our Platforms for fraud prevention, service improvement, customer support purposes, and enforcement of the contracts entered into with our members (such as our Terms and Conditions). For example, in order to prevent the circumventing of our online booking system, we may scan and analyze messages sent through our Platforms to check that they do not include any contact details or references to other websites.

5.2. We will never scan or analyze your messages with other members of our community for commercial and advertising purposes. We may use automated methods to carry out the moderation of these messages, but no automated individual decision-making is performed in this regard.

6. Targeted Ads on Social Media Platforms and Our Communications Sent by Email and/or Text Messages

In compliance with applicable laws and subject to your consent, we may utilize the information you provide on our Platform for electronic direct marketing purposes. This includes receiving newsletters, event invitations, or other communications we believe may interest you, as well as serving targeted advertising on social media platforms or third-party websites.

For Electronic Marketing Communications: You may withdraw your consent at any time by (i) unticking the relevant box in your member account, (ii) clicking on the unsubscribe link provided in each RideBuddy communication, or (iii) contacting us using the contact details provided in section 13 below.

For Targeted Ads and Content:

• - On social media platforms (e.g., Facebook and Twitter), you can object at any time by configuring your advertisement settings via your social media account.
• - On third-party websites, please refer to our Cookie Policy to learn how to object.

7. Is Your Information Being Transferred? How and Where?

We primarily store Personal Data we hold about you in India. However, since some of our service providers are based in countries outside of India (“third countries”), we may transfer some of your data to such third countries. We ensure that such transfers comply with applicable legislation and that appropriate safeguards, such as standard contractual clauses, are implemented to ensure a sufficient level of protection of individuals’ privacy and fundamental rights. For details on these safeguards, you may send a request to the Group Data Protection Officer at [email protected].

8. What Are Your Rights in Respect of Your Personal Data?

• 8.1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).

• 8.2. You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so (e.g., our legitimate interest to keep the platform safe and secure for other users).

• 8.3. You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) to the processing of your personal data for other purposes on grounds relating to your particular situation (your right to object to processing). Please note that in the latter case, this right only applies if the processing of your personal data is based on our legitimate interest.

• 8.4. You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether our legitimate grounds to process your personal data in that case override your interests, rights and freedoms; or (iii) your personal data has been processed by us in an unlawful way but you either oppose the erasure of the personal data or want us to keep your personal data in order to establish, exercise or defend a legal claim.

• 8.5. You have the right to receive and/or have us transfer to another data controller a subset of personal data, that concern you and that you provided us with, and which we process for the performance of our contract or because you previously consented to it, in a structured, commonly used and machine-readable format (your right to data portability).

• 8.6. To exercise your rights, please contact the Group Data Protection Officer (see under Article 13).

• 8.7. You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.

9. Cookies & Similar Technologies

For more information, please refer to our Cookie Notice.

10. Confidentiality of Your Password

You are responsible for maintaining the confidentiality of your password used to access our Platform. Please refrain from sharing your password with anyone.

11. Links to Other Websites and Social Media

Our Platform may contain links to third-party websites. Please note that these websites have their own privacy practices, and we do not accept any responsibility or liability for them. Please review their policies before submitting any Personal Data.

12. Changes to Our Privacy Notice

Any updates or changes to our Privacy Notice will be posted on this page. Where appropriate, we will notify you or seek your consent. Please check back frequently to stay informed of any updates.

13. Contact & Data Protection Officer

If you have any questions, concerns, or inquiries regarding your Personal Data or our privacy practices, you can reach out to our Data Protection Officer at [email protected].