PRIVACY POLICY

1. Introduction

This Privacy Policy (“Policy”) describes how Velocity Pedia Private Limited (“CarInfo”, “Company”, “We”, “Us” or “Our”) collects, uses, stores, protects, transfers and otherwise processes Personal Data through carinfo.app and its related websites, domains, sub-domains, mobile sites, mobile applications and other digital interfaces, including the Google Assistant bot (collectively, the “Platform”).

For the purposes set out in this Policy, Carinfo may share Personal Data with CARS24 Services Private Limited (“CSPL”), the holding company of Carinfo and the entity operating under the CARS24 brand, and CARS24 Financial Services Private Limited (“CFSPL”), an RBI-regulated NBFC and a subsidiary of CSPL. CSPL and CFSPL may use such Personal Data only for the purposes specifically described in this Policy and in accordance with applicable law.

“You”, “Your” or “User” means any person accessing or using the Platform or any services offered through it. By accessing the Platform or using the services, You agree to this Policy.

2. Scope

This Policy has been designed and developed to help You to understand the following: The type of Personal Data (including digital personal data or information and physical personal data uploaded digitally) that We collect from the User; The purpose of collection, means and modes of usage of such Personal Data by the Company; how and to whom the Company will disclose such information; how the Company will protect the Personal Data that is collected from the Users; and how Users may access and/or modify their Personal Data. This Policy ensures compliance with privacy laws and regulations applicable to CarInfo’s collection, processing, storage, use, transmission, disclosure to third parties and retention of Personal Data.

3. Consent for Verification with Government and Authorized Databases

By accessing, registering, logging in or otherwise using Our Services, You expressly consent and authorise CarInfo, CSPL, CFSPL and their authorised representatives, service providers and business partners, as applicable, to process Your Personal Data for the purposes set out in this Policy and as permitted by applicable law:

3.1 Access, obtain, collect, retrieve, verify, validate, cross-check, monitor, review, and re verify from time to time any data and information relating to You, including but not limited to the Types of Personal Data Collected by the Company as set out in this Policy, as well as any other personal data or non-personal data relating to You that may be publicly available, lawfully accessible, or otherwise obtained from official, statutory, regulatory, government-maintained, or government-authorized databases, records, repositories, or sources, as may be required or permitted under applicable law.

3.2 Process such information for lawful business purposes, including identity verification, fraud prevention, compliance checks, vehicle-related and mobility services, resale, insurance and service facilitation. Where You express an interest in, request or apply for a financial product or service, CarInfo may share the relevant information with CFSPL for facilitating such request, evaluating eligibility and providing financial products or services. Any credit-bureau enquiry, KYC, loan processing, disbursal or repayment mandate shall be undertaken by CFSPL only after obtaining the separate consent or authorisation required for that specific activity

3.3 Retain Your consent for repeat transactions, renewals, or future engagements with the Company until expressly withdrawn by You in accordance with this Policy.

You further acknowledge that the information so provided by You is true, complete, and lawful, and You agree to indemnify and hold harmless the Company against any claims, liabilities, or losses arising from the use of such consented verifications. If You do not agree to this clause, You should refrain from logging in or using Our Services.

4. Categories of Data Collected

4.1 Personal Data

CarInfo may collect the following categories of Personal Data:

• Identity Data: Name, age, gender, photograph, date of birth.
• Contact Data: Mobile number, email address, city/state.
• Account Data: Login credentials, preferences, communication settings.
• Vehicle & Ownership Data: Vehicle registration number, RTO details, ownership history, hypothecation status, insurance, challans, fitness and compliance certificates any other data related to vehicle and its ownership that may also include historical ownership and usage records and any other data reasonably connected to vehicle ownership, use, compliance, valuation, transfer, or future services of the Company (including records derived or obtained from official, authorised, or commercially available sources).
• User-Generated Data: Data manually entered by Users, uploaded documents, feedback, reviews, and queries.
• Communication Data: Records of calls, emails, chats, or support interactions, subject to lawful consent.
• FASTag & Related Financial Details: FASTag ID, linked bank details, FASTag balance/recharge history, and usage data to the extent necessary for Our Services.
• Challan & Legal History: Pending and cleared challans, traffic violations, penalties, accident records, and any civil/criminal/legal/compliance matters associated with the vehicle.
• Service, Maintenance & Repair Records: Service/maintenance history, repair/accident records, odometer readings, structural/engine/gear/transmission work, workshop records, and related artefacts.

4.2 Automatically Collected Data

• Device information, IP address, operating system, app usage logs;
• Location data (where enabled);
• Cookies and similar tracking technologies.

4.3 Publicly Available and Third-Party Data

CarInfo may collect vehicle-related or other data from: (i) Public databases and government-authorised sources, (ii) Third-party data providers and contractual partners, (iii) User-authorised integrations.

By providing any information covered by clause mentioned above, You represent, warrant, and undertake that such consent/authorisation expressly permits the Company to collect, receive from authorised sources, store, process, use, and share in accordance with this Policy all related data, including but not limited to dependent/associated individuals’ details, vehicle registration particulars, insurance policies and certificates, fitness/PUCC, transfer certificates, FASTag details (including bank-linked information and balances), challan and legal/compliance records, service/maintenance and repair history, accident history, odometer/usage records, OEM specifications and modifications, vehicle history data, and any other related or reasonably foreseeable data required for current or future business operations or services of the Company.

We may in the future include other optional requests for information from the User including through User surveys to help Us customize the platform to deliver personalized information to the User and for other purposes as mentioned herein. Such information may also be collected during surveys/contests conducted by Us. Any such additional Personal Data will also be processed in accordance with this Policy.

5. Purpose of Collection and Processing

By providing Your information, You consent to its collection, sharing, disclosure, and use in accordance with this Policy. The information we collect may be utilized for various business, regulatory, and operational purposes, including but not limited to: (i) Improving Your Experience: Understanding how you interact with our Website and services, including your preferences, interests, and usage patterns, to improve features, personalize content, and provide tailored offerings; (ii) Service Delivery: Processing your transactions, queries, and requests, managing your account, sending periodic updates, and providing notifications about your vehicle, account, or scheduled appointments (e.g., self inspections or home inspections); (iii) Communication: Contacting you and/or sending you notices about your account, marketing/promotional activities, updates in policies via email, SMS, telephone, or other means for product updates, promotional offers, surveys, or general inquiries about our services; (iv) Platform Management: Registering You on the Platform, performing technical administration, auditing, data analysis, and customization to enhance the platform’s functionality, security, and user experience; (v) Research and Market: Conducting surveys, research, analysis, business intelligence, reporting and improvement/development/advancement for the Company’s business, internal purposes, technical and administrative, operational purposes of the Company, and customization of the platform and/or the services and promotional activities; sending targeted and non targeted advertisements; and analyzing user data to improve our services and develop new products in an effective manner; (vi) Compliance and Security: Verifying and identifying, preventing, detecting, and tackling fraud, money laundering, terrorism, and other crimes and political associations complying with legal obligations, investigating violations of terms, enforcing policies, and addressing disputes or security concerns; (vii) Legal and Administrative Purposes: Disclosing information to comply with legal requirements, court summons and orders, or law enforcement requests, and sharing data with authorized third parties for lawful purposes; (viii) CARS24 Group and Partner Offerings: Vehicleinfo may share Your Personal Data, on a need-to-know basis, with CSPL, CFSPL, its authorised service providers, alliance partners, channel partners, insurers, financial institutions and other business partners, where such sharing is necessary to provide, facilitate, improve or personalise vehicle-related, mobility, resale, insurance, financing or other services requested by You or made available through the Platform. Such sharing may also be undertaken to respond to Your request or enquiry, provide customer support, complete transactions and communicate relevant offers, in each case subject to Your communication preferences, any separate consent required for the relevant service and applicable law.; (ix) Advertisement Personalization: Using your data to display advertisements aligned with your interests to relevant target audiences. While personal data is not disclosed without consent, interaction with ads may indicate alignment with advertiser criteria; (x) Operational Efficiency: Completing transactions with You effectively and billing for the products/services provided, Performing administrative tasks such as testing systems, recovering outstanding payments, and ensuring effective service delivery, Contact User as a survey respondent; (xi) Any other purpose that may be necessary to provide the services that You have opted for; the Company may use the information collected from You to enable the Company to display advertisements to its advertisers’ target audiences. Even though the Company does not disclose Your personal information for these purposes without Your consent, if You agree on, or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria.

6. Cookies and Other Identifiers

To enable our systems to recognize your browser or device and to provide and improve Services, we use cookies and other identifiers. For more information about cookies and how we use them, please read our Cookies Policy.

7. Consent

By accepting this Policy and providing Your Personal Data, You consent to its collection, use, storage, disclosure and sharing as described in this Policy, including sharing of relevant Personal Data with CSPL, CFSPL and it’s affiliates, partners for the purposes specifically set out in this Policy. Such consent shall be freely given, specific, informed and unambiguous, and obtained through a clear affirmative action. You may withdraw Your consent at any time by contacting us at [email protected]. Withdrawal of consent shall not affect the lawfulness of processing carried out before such withdrawal or any processing that CarInfo, CSPL or CFSPL is required or permitted to undertake under applicable law. Any separate consent required for credit-bureau enquiry, KYC, loan processing, disbursal or repayment mandate shall be obtained by CFSPL at the relevant stage

8. Limiting use, Disclosure and Transfer of Personal Data

Group Entity and Partner Disclosure: Vehicleinfo may disclose or transfer Your Personal Data to CSPL, CFSPL, its affiliates, group entities, authorised service providers, alliance partners, channel partners, insurers, financial institutions and other business partners, where such disclosure or transfer is necessary for the purposes set out in this Policy, including providing, facilitating, improving or personalising the services requested by You or made available through the Platform. The Personal Data shared may include identity and contact details, vehicle and ownership details, Platform usage data, enquiry and transaction details, and documents or information submitted by You, but only to the extent relevant and necessary for the stated purpose. Each recipient shall process such Personal Data only for the stated purpose, subject to appropriate safeguards, any separate consent required for the relevant service and applicable law.

We may need to disclose/transfer Personal Data to certain third-party service providers to provide the services they have opted for. We may need to disclose/transfer Personal Data to government and judicial institutions/authorities, to the extent required:

• Under the laws, rules, and regulations and/or under orders of any relevant judicial or quasi-judicial authority
• To protect and defend the rights or property of the Company
• To fight fraud and credit risk
• To enforce the Company's Terms of use (to which this Notice is also a part)
• When the Company, in its sole discretion, deems it necessary to protect its rights or the rights of others

The Company may also make all Personal Data accessible to its employees and data processors/third party vendors only on a need-to-know basis and for the purposes set out in this Policy. The Company takes adequate steps to ensure that all the employees and data processors/third party vendors, who have access to, and are associated with the processing of Personal Data, respect its confidentiality and that such data processors/third party vendors adopt at least such reasonable level of security practices and procedures as required under applicable law. However, the Company does not disclose information, labelled, or aggregated, obtained through Marketplace application programming interface on behalf of a User, to other Users or any third parties, unless required by law.

Non-personally identifiable information may be disclosed to third party ad servers, ad agencies, technology vendors and research firms to serve non-targeted advertisements to the User. The Company may also share its aggregate findings (not specific information) in a non-personally identifiable form based on information relating to the User’s internet use (to the extent set out in this Notice) to prospective investors, strategic partners, sponsors, and others to help growth of the Company's business. We may also disclose or transfer the Personal Data, to another third party as part of reorganization or a sale of the assets or business of the Company. Any third party to which the Company transfers or sells its assets will have the right to continue to use.

9. User's Rights

1. Right to information and access information
2. Right to correction and erasure (“Right to be forgotten”)
3. Right to rectification
4. Right of grievance redressal
5. Right to nominate – in the event of death or incapacity

10. Third-Party Integration

You may access the Website through third-party Websites over which the Company has no control. You may optionally provide the Company with the information through third party sign-in services such as Facebook, Pinterest, Twitter, Instagram, and Google, etc. In such cases, the Company fetches and stores whatever information is made available to the Company by you through these sign-in services. The Company reserves its rights to use information provided by you in consonance with all relevant laws and guidelines. Further, it is clarified that while your usage of the Website, you might see the links to the third-party Websites / advertisements / electronic communication service, which are provided by the third parties. As operations of the third party are not under control of the Company, therefore the Company does not make any endorsement / guarantee of any service or product offered through such third-party Websites nor make any representation related to the privacy policy or other policies of such third party. Any usage of such third party Website or availing any service or product through such third parties shall be at your risk and the Company is not responsible for any loss / damage or otherwise. It is recommended that you should review the terms & conditions of use and policy of such third-party Websites prior to using such Websites.

11. Disclosure to Third Parties

The links to third-party advertisements, third party websites or any third-party electronic communication services (referred to as “Third Party Links”) may be provided on the platform which are operated by third parties and are not controlled by, or affiliated to, or associated with the Company, unless expressly specified on the platform. If You access any such Third-Party Links, We request You to review the concerned website’s privacy Policy. We shall not be responsible for the policies or practices of such third parties.

Personal data shall be disclosed to third parties only for identified lawful purposes and after obtaining appropriate consent or requires otherwise.

• CarInfo shall ensure that CSPL, CFSPL and partners, third parties collecting, storing or processing Personal Data on its behalf are subject to appropriate contractual confidentiality, data-protection and information-security obligations, and process such Personal Data only for the purposes authorised by CarInfo and permitted under applicable law
• Personal data may be transferred across geographies from where CFSPL operates for storage or processing where any of the following apply: (i) given consent to the transfer of information; (ii) transfer is necessary for the performance of a contract between the user and CFSPL, or the implementation of pre-contractual measures taken in response to the user’s request; (iii) transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between CFSPL and a third party; (iv) transfer is necessary or legally required on important public interest grounds or for the establishment, exercise, or defense of legal claims; (v) transfer is required by law; (vi) transfer is necessary to protect the vital interests of the User; (vi) transfer is made under a data transfer agreement; (vii) The transfer is otherwise legitimized by applicable law.
• Remedial action shall be taken in response to misuse or unauthorized disclosure of personal data by a third party collecting, storing, or processing personal data on behalf of CFSPL.

12. Marketing Communications

CarInfo, CSPL and CFSPL, partners, may send service-related or promotional communications through email, SMS, WhatsApp, calls, push notifications or other permitted channels, in accordance with Your communication preferences and applicable law.

13. Data Retention and Deletion

Personal Data is retained only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Upon withdrawal of consent or deletion request, data will be securely deleted or anonymised, unless retention is legally mandated.

14. User Rights

• Right to information and access information
• Right to correction and erasure (“Right to be forgotten”)
• Right to rectification
• Right of grievance redressal
• Right to nominate – in the event of death or incapacity

Requests may be made through the app or by contacting the grievance officer.

15. Updates/ Changes

We may alter Our Policy from time to time to incorporate necessary changes in technology, applicable law, or any other variant. In any case, We reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes We make will be effective immediately on notice, which We may give by posting the new policy on the Site. Your use of the CarInfo App Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform You via electronic mail. In any case, You are advised to review this Policy periodically on the Site to ensure that You are aware of the latest version.

16. Disclaimer

In case any personal data is shared by You with Us, which is not requested by Us during registration, (whether mandatorily or optionally), We will not be liable for any personal data breach or disclosure in relation to such data. If You have any questions regarding this Policy or the protection of Your personal data, please contact us at [email protected].

17. Grievance Redressal

Grievance Redressal Officer: Email: [email protected]

Address: As updated from time to time on the Platform

CarInfo shall endeavour to respond to grievances within the timelines prescribed under applicable law.