PRIVACY POLICY FOR VEELO MOBILITY PRIVATE LIMITED

Last Updated 20TH JANUARY 2023

This policy applies to our Company (Veelo Mobility Private Limited, “Veelo”) and our product Veelo Rider App and Veelo Battery Point App (hereafter collectively referred to as "Veelo Suite"). This privacy policy is applicable to the information we collect on the company website (www.veelomobi.com) through products under Veelo Suite i.e. Veelo Battery Point Application, Veelo Rider Application & Veelo GPS Device . This privacy policy describes the type of information we collect and policies governing the use of that information.

Information Collected on Veelo’s website

Veelo is sensitive to privacy issues on the Internet and in general has no objection to User accessing its Site without providing any personal information. However, there are circumstances like those listed below when Veelo may request you to provide your personal information.

Collection of personal information for propagating business

In some circumstances, Veelo may request for some personal information from you, like your name, e-mail address, address, aadhaar number, alternate address, alternate mobile number and telephone number. You are at liberty to respond or not to respond to these inquiries and any and all information provided is strictly voluntary. Veelo uses this information to get valuable feedback from your experience on our Site. In addition, Veelo may also use your personal information for its other business purposes or in order to help serve you better be it by informing you of new services, products, alliances etc. that could be of use to you. In general, you can visit the Site without disclosing any personal information. However, there are areas of this site that require this information to completeā certain functions, and may not be available to those choosing not to reveal the information requested. You recognize and understand that there is no compulsion on you to provide us with your personal information and any and all personal information provided by you to us is with your full consent, own volition and desire to provide such personal information. You also understand that we are under no obligation to verify the source from which the personal information about you is provided to us, and they are deemed to be provided by you.

Any material, information, or idea submitted or posted on this Site or to the mail addresses given on this Site will be considered non-confidential and non-proprietary. Veelo may share or otherwise use your submission for any purpose whatsoever. If any of the information submitted constitutes personal data, you agree that Veelo may transmit such personal data for any Veelo's business purpose.

Collecting information for online surveys

At times we conduct on-line surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will try to let you know how we will use the information at the time we collect information from you on the Internet. If you are not happy with the reasons of the survey you may refrain from contributing to it.

Collecting domain information

Veelo collects domain information and not the email addresses of its visitors as part of its analysis of the use of this site. This data enables us to become more familiar with which customers visit our site, how often they visit, and what parts of the site they visit most often. Veelo uses this information to improve its Web-based offerings. This information is collected automatically and requires no action on your part. By accessing our Site you grant your unconditional consent to allow Veelo to collect your domain names.

Disclosure to third parties

In cases where we believe that business interests will be served, Veelo may share your information with its Business Partners, who can alert you about new products and services. Upon receipt of any alert if you desire to be removed from such alert list, you may inform the sender or unsubscribe from the list as provided in each mail alert.

We may also be required to disclose your personal information in the event of a legal proceeding, court process, investigation or any such other process where we are required to do so by applicable law or where we have to establish our legal rights or where disclosure is required to prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person etc. We may also be required to disclose your personal information in the event of a business reorganization, amalgamation or merger.

Use of cookies

Some pages on this site use "cookies," which are small files that the Site places on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit us. Your Web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. By not accepting cookies, some pages may not fully function and you may not be able to access certain information on this Site.

Information Collected via Veelo Suite of Apps & Veelo Device

The following information is collected by our Veelo GPS Device when it is plugged into your vehicle or Veelo’s Battery Point App or Veelo Rider App while using the app and while using in the background: 

  1. Geolocation of the device (GPS coordinates).

  2. Vehicle’s acceleration information from accelerometer sensor in Veelo device.

  3. Based on any additional sensors that may be connected to the Veelo Device in the vehicle, additional information from those sensors in the vehicle may also be collected.

The information collected by our Battery Point App while you are using the app on any mobile device or the app is working on your mobile device in the background with your express permission is only Location information of your mobile device at any given point of time. 

The following information is collected by our Veelo Rider App: 

  1. Information related to location of Mobile phone, identification details of your Mobile phone, phone type and OS. 

  2. Aadhar Card information, Name, Phone Number, Alternate phone number, registered address as per Aadhar card, Age, Sex, alternate address & any other personal information to be able to allow you to use our Veelo Rider app with your express permission.

  3. Information related to Mobile sensors such as Accelerometer and Gyroscope. 

Use of Information

We store the information collected from the Veelo Website, Veelo Software and Veelo suite of Apps onto our backend server in the cloud hosted by third party cloud infrastructure providers. The servers on which your information is stored may be located outside India. The information is processed and analysed by automated means to offer a variety of features that you get from using the Veelo Software including real time vehicle location tracking, location based notification, mileage data, vehicle health reports, mobile device location. The mobile device location collected on the Veelo Battery Point app is used to geofence the location and decide your availability at the Battery Point. This information is then relayed to the Riders of the Veelo Rider app so that they can decide which battery point to visit for swapping the batteries. The information will also be used for advanced analytics to offer additional insightful features in future. We may also anonymize (de-personalize) your information we collect and combine it with other information sources for the purpose of advanced analytics and future use cases.

Access to Information

  1. Our engineers and other personnel may have access to your information for the purpose of development, testing, maintaining our service and also to provide you technical support in case of any issues.

  2. Our service providers, including outsourced development partners, technical support providers, business support services providers may have access to your parts of your information on need to know basis, as per our contractual terms with them.

  3. Additionally we may share your information, with your prior consent, with third parties, who may use the information to offer and provide additional customized products and services. For example, these many include car dealers, car service centers and motor vehicle insurers.

  4. Your anonymized data may be shared with third parties for purpose of marketing, analytics and other uses.

  5. Any individual with whom you may share your Veelo App login credentials or Veelo Device credentials may get access to your information via the Veelo Software.

  6. We may also be required to disclose your personal information in the event of a legal proceeding, court process, investigation or any such other process where we are required to do so by applicable law or where we have to establish our legal rights or where disclosure is required to prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person etc. We may also be required to disclose your personal information in the event of a business reorganization, amalgamation, merger, divestment, dissolution or asset sale.

Security of Data

We and our partners maintain commercially reasonably measures to maintain information security and prevent it from unauthorized access. However, no security is fool-proof and in case we become aware of any breach of security of your information, we will notify you using the email address that we have. If you do not agree to the terms discussed above, you should exit our website or stop using our Veelo website, Veelo Device in your vehicle & Veelo Suite of apps. When you access our website or use our Veelo Suite of Apps or Veelo Device, you acknowledge that you have read and agree to abide by the terms described above. Veelo Mobility Private Limited reserves the right to change these policies and terms & conditions without prior notice.

Force Majeure

Notwithstanding anything contained in this Privacy Policy or elsewhere, Veelo shall not be held responsible for any loss, damage or misuse of your user Information, if such loss, damage or misuse is attributable to a Force Majeure Event. "Force Majeure Event" shall mean any event that is beyond our reasonable control and shall include without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, network errors, computer hacking, technical snags, unauthorized access to computer data and storage device, breach of security and encryption and any other like event beyond the control of Veelo.



Changes in Privacy Policy

COLLECTION OF FINANCIAL SMS INFORMATION

We don’t collect, read or store your personal SMS from your inbox.We collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis. This process will enable you to take financial facilities from the regulated financial entities available on the Platform. This Financial SMS data also includes your historical data.

COLLECTION OF DEVICE LOCATION AND DEVICE INFORMATION

We collect and monitor the information about the location of your device to provide serviceability of your loan application, to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us to verify the address, make a better credit risk decision and expedite know your customer (KYC) process. Information the App collects, and its usage, depends on how you manage your privacy controls on your device. When you install the App, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the App and explicitly seek permissions from You to get the required information from the device. The information we collect from your device includes the hardware model, build model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID; SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorized device acts on your behalf to prevent frauds.

COLLECTION OF INSTALLED APPLICATIONS

We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.

COLLECTION OF CONTACTS INFORMATION

We collect a list the Contacts metadata information which includes the number of contacts, count of contacts with phone number, contacts created monthly to detect the fraudulent behavior and assess your credit worthiness. Personal contact information like name of the contacts or phone number of the contacts and other similar information is not collected.

STORAGE

We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the correct KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.

CAMERA

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.

COLLECTION OF OTHER NON-PERSONAL INFORMATION

We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address. Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Website more user friendly.

Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website. If you choose to make a purchase through the Platform, we collect information about your buying behaviour. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. if you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

LINK TO THIRD-PARTY SDK

The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data. Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data. Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.