PRIVACY POLICY

This Privacy Policy describes our practices regarding the collection, processing, storage, disclosure, and protection of personal data and vehicle telemetry when you:

• Visit or interact with our official website at zenvy.in, our dealer and customer web portals, or any associated digital properties.
• Book a test ride, submit a dealership or franchise inquiry, or purchase a ZENVY electric scooter (such as ZENVY Urban, ZENVY Smart Pro 1, ZENVY Max, or ZENVY Eco Lite).
• Connect your smart electric scooter with the ZENVY Rider Companion Mobile Application or sync with our cloud-connected vehicle telemetry network.
• Utilize our customer support channels, warranty assistance, or visit our authorized physical experience centres and dealerships.

This policy is formulated in strict accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDPA), along with applicable international standards.

We collect information directly from you, automatically through your vehicle and device interactions, and from verified authorized dealer partners.

A. Information You Directly Provide

• Contact & Identity Credentials: Full name, telephone number, email address, physical billing and delivery address, and national identity credentials (such as Aadhaar, PAN, or Passport copy) solely when legally required for vehicle RTO registration and subsidy clearance.
• Driver Licensing & Eligibility: Valid two-wheeler driving license copies submitted when scheduling test rides on high-speed electric scooters or completing vehicle handover.
• Commercial & Financial Information: Pre-booking deposit records, invoice addresses, chosen payment methods, and EMI financing inquiries (processed securely through RBI-licensed banking and payment gateway partners; ZENVY never stores raw debit/credit card numbers or CVVs).
• Dealership Applications: Business entity name, GSTIN, proposed store location, commercial background, and financial capacity submitted through our franchise portal.

B. Vehicle Telemetry & Technical IoT Data

ZENVY smart scooters are equipped with an on-board Telematics Control Unit (TCU) that periodically communicates with our encrypted cloud servers:

• Battery Management System (BMS) Telemetry: State of Charge (SoC), State of Health (SoH), individual cell voltages, temperature, charging cycle counts, and charging rate.
• Operational & Diagnostic Data: Odometer readings, speedometer logs, motor controller temperatures, regenerative braking efficiency, tire pressure (where equipped), and error/fault diagnostic trouble codes (DTCs).
• Geospatial & Location Data: Real-time GPS coordinates, vehicle heading, and trip trajectories utilized for turn-by-turn navigation, geofencing alarms, anti-theft tracking, and crash detection.

C. Digital Platform & Device Information

• Device Identifiers: IP address, operating system, browser type, app version, unique mobile device identifiers (UUID), and cellular network carrier.
• Session Telemetry: Page response times, clickstream data, download errors, and login authentication timestamps.

We process your personal and vehicle data only for clear, lawful, and specified purposes:

Connected vehicle intelligence is at the heart of ZENVY's engineering. We apply strict isolation protocols to ensure telemetry data cannot be exploited:

For research, engineering improvements, and traffic pattern modeling, telemetry logs (such as regenerative braking curves, ambient temperature impact on range, and road incline power draws) are fully anonymized and de-linked from your Vehicle Identification Number (VIN) and personal identity.

We process your personal information under the following recognized legal bases:

• Explicit Consent: You give us clear consent when opting in to smart app features, marketing updates, or booking a test ride.
• Performance of a Contract: Processing necessary to fulfill your scooter purchase, deliver warranty commitments, or operate the dealership franchise agreement.
• Compliance with Legal Obligations: Adhering to Central Motor Vehicle Rules (CMVR), RTO vehicle registrations, GST reporting, and lawful directives from judicial authorities.
• Legitimate Interests: Protecting our systems against cybersecurity threats, preventing warranty fraud, and maintaining vehicle safety diagnostics.

ZENVY does not sell, rent, or trade your personal information. We share data solely with trusted entities bound by strict confidentiality and data protection agreements:

• Authorized ZENVY Dealers & Service Hubs: To coordinate test rides, vehicle delivery handovers, scheduled warranty servicing, and replacement part installations.
• Government Transport Portals (VAHAN / RTO): To process statutory permanent vehicle registration, road tax, and regional green mobility incentives.
• Cloud & IoT Infrastructure Providers: Secure enterprise cloud servers (Amazon Web Services India) hosting our microservices, real-time telemetry processing pipelines, and encrypted database stores.
• Banking & Insurance Partners: Only upon your explicit request to compare vehicle insurance policies or apply for zero-down-payment EV vehicle financing.
• Emergency & Roadside Assistance Providers: Dispatching towing, roadside battery swap, or emergency medics when a breakdown or collision is reported.

We employ defense-in-depth security architecture spanning physical hardware, network boundaries, and cloud databases:

• End-to-End Cryptography: All data transmitted between your scooter's Telematics Control Unit, companion app, and our cloud is encrypted via TLS 1.3. Stored databases utilize AES-256 bit encryption at rest.
• Hardware Secure Boot: Vehicle controllers and dashboard microchips feature cryptographic signature validation to prevent unauthorized firmware tampering or remote hijacking.
• Strict Role-Based Access Controls (RBAC): Employee access to customer records is restricted on a strict need-to-know basis and audited with continuous access logging.
• Data Localization: All core customer information and vehicle telemetry are stored within secure data centers physically situated inside the territory of the Republic of India.

We retain your personal data only as long as necessary to fulfill the purposes outlined in this policy:

• Active Vehicle Ownership: We maintain vehicle history, warranty status, and connected app profiles throughout your active ownership of the scooter.
• Statutory Financial & Tax Records: Invoices, payment confirmations, and dealer settlement statements are preserved for 8 years in compliance with Indian corporate and taxation laws.
• High-Frequency GPS Logs: Detailed raw seconds-level GPS coordinate streams are automatically pruned and aggregated into generalized trip statistics within 90 days.
• Test Ride Inquiries: Inactive test ride inquiries that do not result in vehicle purchase are safely purged after 18 months.

Under the Digital Personal Data Protection Act (DPDPA) and applicable privacy regulations, you have sovereign rights regarding your data:

• Right to Access: You may request a summary of the personal data we hold about you, along with processing identities.
• Right to Correction & Completion: You may request correction of inaccurate, misleading, or outdated personal information through your customer portal or support.
• Right to Erasure: You can request deletion of personal information no longer necessary for vehicle safety, warranty, or statutory compliance.
• Right to Withdraw Consent: You may toggle off optional features (such as promotional newsletters or non-critical trip insights) at any time.
• Right of Grievance Redressal: You have the right to readily accessible grievance redressal mechanisms regarding any data privacy concern.

To exercise any of these rights, email us at privacy@zenvy.in with your registered phone number and Vehicle Identification Number (VIN). We respond to all verified requests within 30 days.

ZENVY digital platforms, vehicle purchase contracts, and dealership portals are intended solely for individuals aged 18 years or older who are legally capable of entering binding agreements. We do not knowingly collect personal data from minors under the age of 18 without verifiable parental or guardian consent. If we discover inadvertent receipt of personal data from a minor without lawful authorization, we promptly delete such records.

As we release new smart electric scooter models, innovative IoT capabilities, or as statutory privacy frameworks evolve, we may update this Privacy Policy. Any modifications will be posted to this page with an updated “Last Updated” revision date. For significant material changes affecting your rights, we will provide prominent notification through our website banner, mobile app alert, or registered email before changes take effect.

In compliance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, the details of our designated Grievance Officer are provided below: