SCOPE AND PURPOSE
This policy is applicable to the Processing of customers’ Personal Data at all companies included in Sujan Ventures LLP (“HUSE”, “our”, “us” or “we”). The purpose of this policy is to provide our current, former and potential customers (jointly referred to as “customers” or “you”) with 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 at HUSE, and
Contact details for us so you can receive information about and claim your rights in relation to our processing of your Personal Data.
This policy is updated continuously to reflect the measures taken by us in relation to your Personal Data.
The following definitions are used in this policy:
Anonymous data or anonymized data – This is the category of data which is not identifiable to a natural person. Even if coupled with other information, identification of such natural person is not possible.
Automated decision making- Automated decision making is the process of making a decision by automated means through algorithms without any human involvement. These decisions can be based on factual data, digitally created profiles or through data inferred.
Consent – Any freely given, informed and unambiguous statement which maybe given by a clear affirmative action maybe referred to as consent.
Data Processor – The natural or legal person who processes personal data of data principals on behalf of the data fiduciary.
Erasure or Deletion – the irretrievable obliteration or destruction of your saved personal data stored with us, such that your reidentification through this data becomes impossible.
HMI or Human Machine Interface- It is a user interface or dashboard that connects a person to a machine, system, or device. We integrate HMI in our Scooters and this acts as a point of interaction between you and the scooter.
Personal Data – This refers to any information identified or identifiable to a natural person (‘data principal’). This refers to any direct or indirect identification of natural person. This also includes any inference drawn from such data about the data principal.
Processing- It means any operation or set of operations, performed on personal data or sets of personal data, including but not limited to processing by automated means. This may include collection, recording, structuring, alteration, adaptation, organization, use, disclosure, dissemination, alignment or combination and analysis of your personal data. Anonymization of data is also a form of processing.
Pseudonymization – A processing technique where the processed data is not identifiable to a natural person unless coupled with some other information. This data is kept separately with technical and security standards since this data may be converted personal data.
Third Party – ‘third party’ means a natural or legal person, public authority, agency or body other than the data principal, data fiduciary, processor and persons who, under the direct authority of the data fiduciary or processor, are authorized to process personal data;
DETAILS OF THE DATA FIDUCIARY/JOINT DATA FIDUCIARY
TYPE OF PERSONAL INFORMATION AND MANNER OF COLLECTION
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 demo, or finally may be 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. In case you would not like to provide your personal information, then you may not be able to avail such Services.
We wish to assure you that your personal information is safe with us. We will only process your personal information lawfully and for purposes, details of which we have provided in the next section.
The following are the types of personal information pertaining to you:
Date of birth;
Location information, including the GPS location of (a) any person placing an order through HUSE website or any other mode; (b) while using location-based services through Products and Services; and (b) addresses provided for providing the Products or Services by us;
Address (including city or town);
Photograph of the user;
Emergency Contact Information;
Billing and shipping address;
Account login credentials and password;
Details of the Products or Services ordered including pricing;
Date of purchase of Products or Services;
Details of the product purchased;
Telematics data such as performance, operations, performance, usage of Products;
Payment information and history (excluding payment details that shall be collected and processed by an authorized payment service provider, which we do not collect);
Financial information, e.g., credit card or debit card number including expiry date;
Any device and device identifier information as may be deemed necessary;
Any other additional information as specified below.
Personal details of the secondary user, if provided
Of the above types of personal information, your financial information is considered to be sensitive personal data. 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. In such cases, we will inform you of the same and obtain your consent as, and if required.
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.
Personal information you give to us:
This is information about you that you give to us by entering information via our website, or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), etc., for example provided at the time of registering with for our Service.
Personal Information we collect about you:
Some additional information may be collected via your device or your vehicle. For example, we determine your real time location in order to provide various location- enabled services, such as navigation. You will have to specify whether determining and collecting real time location is to be active or not.
When you visit our Website, usage data is collected automatically through the Website. Such usage data can include the type of device, the IP address, and the current location. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud. We also collect information about your click and search behaviour. We use this data to adjust the Website or enhance the features of our Products and Services, and to change the order of search results, to design certain pages differently. We may collect information through cookies for the purposes of advertising and analytics. We collect usage data by using various types of cookies (small pieces of data stored in your device) and other tracking tools.
To further improve your Product and safety, to facilitate the (helpdesk) servicing of your Product and to give you insight on your driving behaviour, we will collect certain telematics data from the vehicle. This may include personal information, such as vehicle identification number, and other device related information, such as performance, usage, operation, condition of your vehicle, etc. We collect such information either in person (such as during a demo appointment).
Personal information we may receive from other sources:
The third parties from whom we may receive information may include our subsidiaries, affiliates, or parent companies or other third-party companies.
In any instance, we will use the personal information we obtain from these sources for the purposes as mentioned below. The remaining provisions of this policy also apply to any personal information we obtain from these sources as well.
PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL INFORMATION
Your personal information is collected at the following stages:
When you create a HUSE user account and provide us your information (the “User Account”);
When you visit our website (the “Website”);
When you book a test demo;
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 champion, and/or other promotional activities, etc.
Your personal information will generally be used to enable us to serve you better. This may include the following:
To provide you with Products and Services, which include
1. Providing you with information about various models of the vehicle
2. Opening your account on our Platform
3. Booking your demo
4. Ordering and purchasing the vehicle of your choice
To verify your eligibility for certain purchases and services
To offer you additional offers and enhanced experiences while using the website, or while using the product and while availing the Products/Services;
To inform you of updates to, or changes in, our Products and Services;
To share any changes to our Terms and Conditions and policies;
To inform you of new Products, Services, and Events;
To provide vehicle support and servicing in an efficient and timely manner;
For product development purposes, for example to improve vehicle performance, quality and safety;
To evaluate and improve our offering to, and communication with you and other customers;
To comply with legal requirements or lawful authority requests;
To inform you about our Products and Services and identify those that may be of interest to you;
To carry out market research; and
For analysis and customer profiling purposes (online and social included) performed by our Analytics Partner.
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 to 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 avail the services being offered by us.
HOW INFORMATION IS PROCESSED
The information may be processed by our platform, Website. Your Personal Information is processed by us under different circumstances and under different lawful basis. The same is provided below for your information:
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
Process your contact information, such as your email ID, full name and contact number to create a user account on our platform
Process your personal information, such as your name, contact information and an address location for arranging for test drives, or where you have requested a call back for further information about our Products and Services. Such information may be further processed when the test drive has been completed;
Process your personal information, such as contact information, photograph, address of delivery, driving license or any other ID proof for processing and completing your purchase;
Processing personal information as indicated above to process a return, if you are not happy with your vehicle,
Process payments (or refunds as the case may be) on your behalf by using your financial info;
If you have opted for location-based features, we may collect and process various location specific information, in the form of your favourite locations, saved locations, pinned locations, searched locations, etc., for providing various location-based services, such as our stores, charging stations, repair facilities and other Services relating to the Products that are close to your location;
Processing personal information and vehicle information for servicing and/or repair activities;
To supply brochures and other material you have specifically requested from us;
Where you have opted in, to be contacted by us or by our authorised dealers or our recommended third-party partners via email, text message, post or telephone with marketing information about their Products and Services (see Marketing section below for further details); and
Complete and perform other processing activities that you have expressly requested us to complete or you have expressly agreed to us performing, as the case may be. In such cases, we will again be taking your consent for such requested processing activities.
Your data is yours – if you wish to withdraw your consent at any time, you can let us know at email@example.com. Certain operations, such as processing your vehicle purchase, we would require certain personal information which is essential for completion of such operations. If you choose to withdraw your consent, we may not be able to provide you with our services.
Where required to perform a CONTRACT with you
We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including, but not limited to, for the following purposes.
To provide information pertaining to your purchase and your vehicle information to complete the purchase of your vehicle;
For post-sale activities, as contractually agreed, in relation to your vehicle;
For contacting or sharing information to assist you in configuring the vehicle for your use; and
To share your contact information with our Delivery Partner for having your vehicle delivered to you.
Where it is in your VITAL INTEREST in emergent situations
We may use your personal information to reach to you if there are any urgent safety or product recall notices to communicate to you to ensure your safety. We may also use the contact information of your Emergency Contact in the event of an incident, or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you or others.
Where there is a LEGITIMATE INTEREST or for other REASONABLE PURPOSES
We may use and process your personal information where it is necessary for us to pursue our legitimate interests and for other reasonable purposes as a business without compromising your privacy for the following purposes:
For analysis which will aid our marketing strategy;
To improve, enhance and personalise your customer or visitor experience;
For market research in order to continually improve the products and services that we and our authorised dealers deliver to you;
To manage and maintained our websites, and for internal practices, including troubleshooting, testing for security, statistical purposes, and for prevention of any misuse or fraud;
For network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access of your personal information, and for ensuring that the underlying systems operate with efficiency;
For marketing activities (other than where we rely on your consent), e.g., to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
to undertake credit checks in case you wish to have your vehicle financed; and
To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our ‘marketing black lists’ in order to be able to comply with your request. Please refer to our Marketing Section for more details); and
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.
For Compliance with Existing or Applicable Laws
Wherever the law mandates us to process certain data for compliance or other legal purposes, we will have to collect your information to abide by it. This may include information like collecting your age proof or driving license before you are permitted to have a test drive.
Marketing based on voluntarily provided data
We may from time to time run promotional campaigns at different locations or have salespeople designated at our affiliate stores/sites/repair centres/charging network sites for brand outreach. Any data voluntarily provided by you during the afore-stated interactions shall be presumed to be based on consent. This data shall be used to reach out to you for promotional offers/direct marketing campaigns run by us. The legal basis for such markets is based on your consent. Such consent may be revoked at any time by reaching out to us.
If you would like to withdraw your consent to the above processing, please submit a request by using this WEB FORM
Marketing based on your online web behaviour data
The legal ground for placing, collecting and having access to information from cookies is your consent. The purpose of our processing of the Online Web Behaviour Data is to identify you as return visitor to our website, to analyze the behaviour of the visitors to our website, to enhance our communication and structure of our website and to build a profile of your interests to be able to show you relevant adverts for our products and services also on other websites. The profiles we create based on your Online Web Behaviour Data can for example include, “people that visited the product page, started configuration and chose the colour black”.
Marketing based on your personal data, third-party data and online web behaviour data
If you consent by clicking the consent box presented in our website banner we will combine your Online Web Behaviour Data with data obtained from third-party data providers. If you provide your consent when interacting with us, e.g., when signing up for a newsletter, we will combine the personal data that you have provided when interacting with us with your Online Web Behaviour Data and with data obtained from third-party data providers. Further, if any personal data has been voluntarily provided to us during our physical promotional activities or at our affiliate stores/sites evincing your interest in our products, we will use this data and reconcile it with your online web behaviour data and data obtained from third parties wherever possible. Thus, for such processing the legal basis will be consent.
The data obtained from third parties consist of data that have been collected through cookies and may include information regarding your personal preferences, demographics and content consumption including your browser history. Such data will be provided to us in aggregated form and the Online Web Behaviour Data and the third-party data is combined by matching your unique online identifier collected through cookies. Thus, all information stored about you is connected to an online identifier consisting of an 8-character ID with uppercase letters, lowercase letters, numbers and special characters as described above. The purposes of combining this data is to enrich your Online Web Behaviour Data and create segments to provide you with personalised marketing on our own website and also on other websites that you visit. The segments may for example be based on your estimated age, your education, income and your product preferences and the profiling is always conducted on group level meaning that you will receive the same type of marketing as other individuals included in that same segment.
The Personal Data that you have provided in connection with your interaction with us may consist of name, email address, phone number, age, gender, country, orders, pre-orders, configuration ID and booked test drives. If you consent, we may combine this data with your Online Web Behaviour Data for the purposes of sending you targeted marketing through email, on our websites and other websites you visit and by sending you mobile push notifications. By combining such data we will be able to create segments and send, e.g. customised online marketing that is based on the fact that a customer pre-ordered a car. We are able to match the different data sets by using a pseudonymised version of your email address, meaning that your real email address is replaced with a combination of numbers and letters by using an algorithm. Your email address will for example be collected when you register for a unique id on our platform and in such case the email address will be connected to your online identifier. In that manner we will be able to store information regarding your online behaviour and connect it to your pseudonymised email address. By doing this, we will for example be able to send you personalised marketing by email.
If you would like to withdraw your consent to the above processing, please submit a request by using this WEB FORM
The profiles described above are also used to create so-called lookalike audiences, meaning that we create audiences based on the characteristics of the profiles described above to be able to target individuals that have similar interests, behaviour or characteristics as the people that we already have targeted. In other words, we will use the segments in which you are included to be able to target other individuals. Such processing is based on our legitimate interest to provide targeted marketing to a wider audience based on profiles that we have created by using data from our website visitors and customers. When using the profiles in which you are included to create the lookalike segments, your Personal Data will be pseudonymised and, thus, it will not be possible to directly identify you. Based on this, we have made the assessment that we have a legitimate interest to process your Personal Data for this purpose.
You are always entitled to object to this processing by using this WEB FORM.
You may access certain applications and other services linked with the vehicle but provided by a third party, which may, for example, require the transmission of location data and other Vehicle-recorded data to such third party. We are not responsible for the collection or use of Personal Data in applications or services provided by a third party and recommend that you carefully review applicable terms for (and any integrity policy related to) such applications or services before you use them. If you have questions concerning a certain third party’s use of your Personal Data, please contact the third party directly.
SHARING/TRANSFER OF PERSONAL DATA
We might share your personal information with our partners in order to improve our service. We make sure that they are as committed as we are to protecting your data and information.
Our dealers use your information to provide you with a better service. This includes handling special requests, personalised offers, and keeping you informed of relevant information and news.
Service Providers and Analytics Partners
We share information with companies that provide services on our behalf. This includes:
Contests and promotions
Customer research and satisfaction surveys
These companies all have strict obligations to protect your information.
We may share information with other group companies and transfer it to a third party in case of a merger or reorganisation.
Compliance and Security
It may be necessary for us to disclose your personal data to governmental and public authorities for reasons of national security, law enforcement or other issues of public importance. Where legally permitted we will inform you ahead of such transfer.
We may also disclose personal information if we determine in good faith that disclosure is necessary to protect our rights, resolve legal conflict, enforce our terms and conditions, investigate fraud or protect our users.
We may transfer your Personal Data to recipients in countries outside India that may have differing data protection laws. This includes countries which may not have an adequate level of protection for Personal Data. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. We will ensure there is a legal ground for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal ground, what safeguards were implemented, and where you can obtain a copy of information on these safeguards. In case of sensitive personal data, we will specifically seek your consent before such transfers to other countries, and will also ensure that the conditions as required under law for such international transfer of sensitive data are complied with.
We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that when you have consented to our Processing of your Personal Data, we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your consent. If you have revoked your consent, we may nevertheless retain certain Personal Data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not received your consent for Processing, the Personal Data will only be retained to the extent we are permitted to do so by law.
RIGHTS OF DATA PRINCIPALS
If you live anywhere in India, the law has various rights bestowed on you in relation to your personal data. We will have to confirm your identity, wherever applicable, to ensure that your rights are being exercised appropriately. To exercise these rights you will have to write to us at firstname.lastname@example.org. Except in exceptional circumstances, we will respond to your request within 30 days from the date we receive your email. We may charge a minor sum to comply with your exercise of these rights to aid the cost we incur for this compliance. You will be informed of these charges once you write to us. You have the following rights under applicable laws in your country –
Accessing your personal information
You have the right to access a copy your personal information that we hold in a standard form that will be easy and understandable. In rare occasions we may not provide you with a copy of your information in which case we will convey you this message with appropriate reasons. Generally, we can only deny you your right of access if it concerns the right of other individuals or we have another lawful reason to withhold that information and not otherwise. You also have the right to access in one place the identities of the data fiduciaries with whom your personal data has been shared by us together with the categories of personal data shared with them,
Verify and rectify
Accuracy is an important principle of data protection and you have the right to verify your information with us and ask us to rectify it if it is inaccurate. You can correct, complete and update your name, address, contact details and other personal information you give us.
Withdrawing your consent
You can always withdraw your consent you have given us. We will be bound to stop collecting or processing your data we collect from you solely on basis of your consent. For instance, there are certain data points for which we take your explicit consent like GPS tracking. However, we will accordingly be unable to offer you other services that are dependent on GPS tracking like navigation. (other mechanisms if they exist for consent withdrawal to be mentioned)
Also, we are legally permitted to continue collecting or processing your personal data if we can rely on grounds other than consent to process your information.
Objecting to our use of your personal information and automated decisions made about you
You have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent. But you will have to provide reasons for such withdrawal. Where your personal data is processed for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. We will temporarily stop processing your personal data until we have assessed your concerns. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we may continue using your data.
When your data is processed for direct marketing purposes, you can object to that processing at any time. (for more details as to how your personal information may be used for marketing purposes, please refer to our Marketing Section)
You may at any time opt to unsubscribe from any of our optional services or make changes in the settings of the website.
You may object to a decision made about you based on automated processing by contacting our data protection officer.
Erasing your personal information
You have the right to get your information erased from our systems. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
Your right to port your data
You have the right to ask for a copy of information that we collect from you in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form.
You can also ask us to send your personal information directly to another data fiduciary, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Your right to be forgotten
You may also ask us to restrict or prevent processing your personal information in the following situations:
where you believe it is unlawful for us to do so,
you have objected to its use or withdrawn your consent and our assessment is pending or
Where your data has served the purpose
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
USER SIGN-UP CONSENT
We will be collecting and storing the following details from you during the sign-up process to create your profile:
The above-mentioned information will be utilized to create your profile on our platform and will enable us to identify and contact you in case you decide to use our services. They have to be mandatorily provided for creation of your profile. The information that we collect is stored securely on cloud servers, located in India and abroad, employing state of the art security measures to keep your data secure.
This data may also be shared with third parties for marketing and analytics purposes to provide you the best user experience, if we have your consent. You may select the applicable option for selecting how such information may be used by such vendors. Not selecting one or more of the option will not have any impact in how we would provide our services to you.
By selecting the applicable option, you allow us to use your information as indicated:
We may use your information for analytics which will enable us to improve our services, platforms and identify information which may be of specific interest for you.
We may share notifications about features of the vehicle, offers and deals for the Products and Services offered by using your contact information. We will contact you on your –
1. Phone Number
2. Email Id
3. Push notifications
We may share the above information with third parties or our other partners including partners located abroad for marketing purposes so as to apprise you of any promotional campaigns, offers, advertisements, surveys, etc., in relation to their products or services.
LODGING OF COMPLAINT
If you have any issues with the way we process data or you need any clarification on our privacy practices you can always contact us at email@example.com. Your issues will be addressed by us as soon as possible and within a maximum period of one month.
However, if you are still of the opinion that we are processing your personal data in violation of data protection laws and regulations you have the right to lodge a complaint with the supervisory authority. You may also lodge a complaint if you are not satisfied with our response to your query.