Privacy Policy & Data Protection Notice
IndoGreen Mobility Private Limited - National Capital Territory of Delhi (Delhi-NCR)
I. Statutory Compliance and Commitment
Governing Law: This policy is governed by the laws of the Republic of India, primarily the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Motor Vehicles Aggregator Guidelines, 2025 (MVAG, 2025).
Data Fiduciary Duty: IndoGreen Mobility acknowledges its role as a Data Fiduciary and assumes the responsibility to process your digital personal data with a duty of care and loyalty, ensuring it is processed lawfully, fairly, and transparently.
Data Security: The Company maintains reasonable security safeguards to prevent a data breach, including data encryption, access control mechanisms, and regular cybersecurity audits, as required for the secure storage of data.
II. Information Collected and Purpose of Processing
IndoGreen collects digital personal data for a Lawful Purpose, which is explicitly defined below.
| Category of Data Collected | Specific Purpose of Processing (Lawful Purpose) | MVAG/DPDP Requirement |
|---|---|---|
| A. Identity & Registration Data Name, Mobile Number, Email, Address, Age/Gender. Driver Specific: Driving License, PAN, Aadhar, Bank Account Details, Police Verification Records, Medical/Psychological Fitness Records. | To create, maintain your account, and verify your eligibility for services. To communicate service updates and security alerts. Mandatory onboarding and compliance with MVAG, 2025 to verify eligibility, fitness, and antecedents of Drivers. To process daily fare settlements. | Consent for a Lawful Purpose. Legal Obligation (MVAG, 2025). |
| B. Location and Trip Data (Sensitive Data) Precise GPS Location (collected from the time a service is requested until it is finished). Trip history, date, time, distance travelled, requested pickup/drop-off addresses. | Core function of the service: Matching Users with Drivers, real-time trip tracking, optimizing routes, and ensuring passenger safety. For customer support, generating trip receipts, analysis of demand/supply, and compliance with MVAG data reporting to authorities. | Consent for a Lawful Purpose. MVAG requirement for VLTD/GPS. MVAG requirement for Data Generation. |
| C. Usage and Device Data Device ID, IP address, operating system, app features viewed, app crash reports. | For troubleshooting, security, preventing fraud, and optimizing app performance and service delivery. | Security and Data Protection Obligation. |
| D. Communications Data Call records or chat logs between Driver and Passenger (only when notified of recording). | For quality control, safety investigations, and dispute resolution. | Consent required where recording takes place. |
III. Consent, Withdrawal, and Data Principal Rights (DPDP Act)
Consent Mechanism: By creating an account and accepting this policy, you are providing free, specific, informed, unconditional, and unambiguous consent to the processing of your personal data for the purposes explicitly mentioned in Section 2.
Data Principal Rights: As a Data Principal, you have the following rights:
| Right | Description | How to Exercise |
|---|---|---|
| Right to Information | To obtain confirmation whether your data is being processed and to obtain a summary of the data and processing activities. | Via the "My Data" section in the App or by writing to the Grievance Officer. |
| Right to Correction & Erasure | To request the correction of inaccuracies in your data or the deletion/erasure of your data when the purpose for which it was collected is no longer being served (Right to be Forgotten). | Via the "My Data" section in the App or by writing to the Grievance Officer. |
| Right to Withdraw Consent | To withdraw your consent at any point in time. The process to withdraw is comparable to the ease with which consent was given. | Via the Account Settings in the App. Withdrawal may require deactivation of the account as data is necessary for core service delivery. |
| Right to Grievance Redressal | To file a complaint with the Data Protection Board (DPB). | By following the internal grievance process (Section 5) and, if unsatisfied, approaching the DPB. |
IV. Disclosure and Data Sharing
Your personal data may be shared only under the following strictly limited circumstances:
Sharing Between Users and Drivers:
- During a Trip: To facilitate the service, we share the User's name, pickup location, drop-off location, and contact information with the assigned Driver. We share the Driver's name, photograph, vehicle registration number, and real-time location with the User. No financial details are ever shared.
- Post-Trip: The Driver's contact information remains accessible to the Passenger via the App for seven (7) days from the end of the journey for support/safety purposes.
Disclosure to Government and Authorities: IndoGreen will disclose data, including trip logs, User/Driver contact information, and fare details, to statutory, lawful enforcement bodies, regulatory bodies, or the Competent Authority if required by law or a valid legal order, particularly concerning safety investigations. This includes the sharing of VLTD/GPS feeds with the State/UT Integrated Command and Control Centre.
Third-Party Service Providers (Data Processors): We may share data with third-party service providers (Data Processors) who perform functions on our behalf (e.g., cloud hosting, payment processing, background verification). These third parties are contractually obligated to maintain the same level of data protection as IndoGreen and may not use the data for any other purpose.
V. Data Retention and Grievance
Data Retention: IndoGreen will only retain your Personal Data for as long as it is necessary to fulfill the purposes outlined in this policy or as required by law. Driver data, including verification records, is retained for the tenure of their association with the platform and a reasonable period thereafter for compliance auditing.
Grievance Redressal: If you have any concern, question, or complaint regarding this Privacy Policy or the processing of your data, you can contact our appointed Grievance Officer:
- Grievance Officer: [Name of Officer]
- Email Address: [Grievance Email Address]
- Telephone: [Grievance Phone Number]
The details of the Grievance Officer are available on the IndoGreen App and website. The Company is committed to resolving all grievances within a maximum of three (3) days.
Questions About Privacy?
If you have any questions about this Privacy Policy, please contact our Grievance Officer.
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