PRIVACY POLICY

We at GRO DIGITALS PLATFORMS LIMITED (“Gro”, “We” or “Us”) consider customer trust as our top priority. This Privacy Policy (hereinafter referred to as “Policy”), which is a part of Gro’s Terms & Conditions (“T&C”), explains the type of information that Gro collects through its Services from you (“You” or “Your”) and what it does with the collected information.

Capitalized terms used herein and not defined shall have the meanings assigned to them in the T&C, except as expressly otherwise defined herein.

1. Scope

This Policy shall govern Gro’s collection and use of data, handling of Personal Information and Sensitive Personal Data or Information as provided by You in accordance with the Rules. In outlining the scope of the Agreement, Gro shall abide by all laws, more specifically the Information Technology Act, 2000, The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 or any other Statutes or Applicable Law which is in place to govern data privacy and information technology practices in India.

2. Definitions

“PERSONAL INFORMATION” means any information that relates to a natural person, which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

“SENSITIVE PERSONAL DATA or INFORMATION” means such Personal Information which consists of information relating to:

1. Password
2. Financial information such as bank account or credit card or debit card or other payment instrument details;
3. Physical, physiological and mental health condition;
4. Sexual orientation;
5. Medical records and history;
6. Biometric information

Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Information.

3. Information we collect

We at Gro may collect information in different ways:

1. Information you voluntarily provide.

Personally identifiable information (PII) voluntarily provided may be collected, if it is necessary, to administer the Services.

For example, while registering on Gro’s App/Platform, we ask You for various kinds of information such as:

1. Name
2. Company Name
3. Address
4. Mobile Number
5. PAN Number
6. GST Number
7. Company Bank details
8. Company Credit rating etc.

We DO NOT use your Personal Information for anything other than to administer the Services. We may combine the information you submit under your user account with information from other services or third parties in order to provide you with a better experience and to improve the quality of our Services.

2. Information we may collect from your use of our Services

Our system may access and use data collected from you as part of your usage of our Services to use predictive analytics to further improve your experience with the platform in the long run. These might include information such as but not limited to “Frequency of load posting”, “Number of loads posted in a specific time period” etc. Such information is used by Gro and its Services and is not shared with any other external party other than for reasons mentioned as part of this Policy. The information collected may include but is not limited to:
1. Server Logs.
Our servers automatically record information that your browser sends and the Uniform Resource Locator ("URL") of the web page from which you came to us whenever you visit our websites. These server logs may include information such as your Internet Protocol ("IP") address, browser type, browser language, date and time of your request, search terms and may include a domain name and the date and time for each page you view. We also collect the name of and information about any advertisement or other link that brought you to us. This information does not personally identify you. We use IP addresses to diagnose problems with our servers and to administer our website. Your IP address also is used by us to gather broad demographic information, such as your general geographic location and internet service provider. IP addresses are further used to help determine the number of our users to maintain efficient administration of our Services. This demographic information may also be used by us to analyse aggregate usage behaviour.
2. Cookies
“Cookies” are small files that collect information that we use to track trends and patterns of how people search. We may send one or more cookies to your computer that uniquely identifies your user account or computer. We use cookies for such functions as verifying that you are one of our users, maintaining a history of services provided and enabling the fulfilment of our Services. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, many of our Services or features may not function properly if your receipt of cookies is disabled.
3. Geo-Location Information
Some devices, mobile or otherwise, allow applications to access real-time location-based information (Example GPS). Our Platform uses your location information for enabling you to choose your loading/unloading points accurately and does so only after your approval.
4. Communications
Any emails or calls that you send or have with us could be stored by us for future references. This can result in the collection of your email address or other personally identifiable information you may have in your email text, addresses, or other fields, as well as the collection of your IP address, the Internet or other routing of your communication, and the date and time of your communication. All transmissions between you and us, including emails, URL’s, cookie identification numbers, usage paths, and any personally identifiable information they might contain, pass through many third-party machines, operating systems, programs, browsers, web servers, networks, routers, Ethernet switches, ISP’s, proxy servers, intranets, the public telephone systems, or other devices, any of which may create activity logs containing such transmissions, and many of which we cannot control. When you send email, feedback, comments or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests, improve our Services, and may post or use such communications without any obligation to you.

3. Relevant Android/IOS Permissions requested by Pilot Mobile App:

1. Location Permission:Used for accessing location of the user to enable accurate posting of loading & unloading location of shipments and for improving user experience

2. Camera: To capture image for documents such as GST, PAN card that need to be submitted as proofs

3. Internal Storage: The App seeks permission to storage for storing & retrieving documents as needed

4. SMS: Used for auto filling of OTP for faster login experience

5. Phone Dialer: To read phone status and identity for auto-dial to the customer support number

4. Protection of Personal and Sensitive Data:

We use standardized and state of art technologies to keep the data safe and secure from any outside threat. We also use cryptography to encrypt the user sensitive data stored on our systems. All communications are done by HTTPS thereby ensuring a secure connection between our App and our server. However, we shall not be responsible for any loss of information due to reasons of theft, cyber-attack, act of Government or any other event or circumstance beyond our reasonable control.
5. What we do/may do with the information we collect/store?

1. Display it for your use:

We will display your Personal Information on your profile page. We will display and make accessible the information and files, materials, and content that you choose to share or make public using our Services. We use the information we collect for providing you with the Services that you select, and therefore, as a natural part of providing the Services, we may share this information with our employees, contractors and agents on an as needed basis in our sole discretion. We may contact you by email/phone to respond to your customer service inquiries and to verify the quality of the Services provided.

2. Use it for legal compliance:

We may share your Personal Information, IP address or content with persons outside of Gro if we have a good faith belief that access, use, preservation or disclosure of such information or content is reasonably necessary to (a) satisfy any Applicable Law, regulation, legal process or enforceable governmental request, (b) enforce agreements or resolve disputes between you and us, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Gro, its users or the public as required or permitted by law. We will disclose any information or content we possess that is directly responsive to subpoenas, court orders, or other legal or governmental inquiries, and such information might be used by the receiving party to determine your identity.

3. Transfer of Business

If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, we shall notify you if such a transaction results in your information being subject to a different privacy policy.

4. Group Companies, Service Providers, Business Partners and Others.

We may use certain trusted third-party companies and individuals to help us provide, analyse, and improve our Services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Service’s features). We may also share certain information with our affiliate and subsidiary companies, if any, in order to use their help to provide additional benefits & Services to our users. These companies may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy and must apply appropriate confidentiality and security measures

To provide the fuel-related services, we will be sharing your information with the following entities:
1. Hinduja Leyland Finance Limited (“HLFL”) for credit assessment
2. Hindustan Petroleum Corporation Ltd. (“HPCL”) and Indian Oil Corporation Ltd. (“IOCL”) for the user KYC
3. Any employee, agent, contractor or third party or service provider in connection with the Company’s business
4. Any other person under duty of confidentiality to the Company.

5. Non-Personal Information Disclosure:

We may disclose or share non-personal or anonymous or aggregated information with third parties, such as usage statistics of our Services or IP addresses. Aggregated non-personally identifiable information is information recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user. These third parties may collect information when users visit our Services. These third parties may use this aggregated information about your visits to this and other websites in order to provide advertisements on the other websites and other forms of media about goods and services of interest to you. For example, this is how anonymous data may contribute to or be used to improve our Services and your experience:

a. Advertising Research: Non-personally identifiable data, which includes web use and demographic information, may be shared anonymously with third parties so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions.

b. Media Use Analysis: Non-personally identifiable data may be shared anonymously with clients so they can understand where consumers go online and how consumers interact with digital media which includes website content and advertising that is seen through web and mobile browsers.

c. Addressable Marketing Segments: We may use non-personally identifiable data to identify certain consumer segments reachable with advertising.

d. Third-Party Applications: We may share your information with a third-party application with your request or consent, for example when you choose to access our Services through such an application, for example through a mobile device application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you prior to accessing our Services using any third-party applications.

6. What are your rights as a user?

As a user of the Gro platform, you have the right to:

1. Inquire about the personal data that we hold on you
2. Inquire about the recipients who could get your data
3. Inquire about the purpose of analysing your data
4. Know if we did not directly collect the data from you, then the information regarding the source
5. Have incorrect/incomplete data captured by us corrected
6. Delete all personal data as well as your account with us at any time; Ask Gro for erasure of any personal data (wherever applicable) which was indirectly captured & restrict processing in accordance with data protection laws

7. Changes to this Privacy Policy:
Gro may modify/update certain or entire terms and conditions of this Privacy Policy from time to time. Any aspect of Privacy Policy may be changed, supplemented, deleted or updated based on Gro’s requirements.
8. Consent
By using our services, you consent to our Privacy policy. You shall, at all times, be responsible for regularly reviewing this Privacy Policy and also note the changes made on this Privacy Policy. Your continued usage of the Platform after any change is posted constitutes your acceptance of the amended Privacy Policy.