Legal Policies

Introduction

This privacy policy (the “Policy”) sets out data processing practices and approach to data privacy by Pravaig Dynamics Private Limited (“Pravaig”) in furtherance of its obligations under the applicable laws. Reference to “we”, us”, “our”, “ours”, “vehicles” and “Pravaig” refers to Pravaig Dynamics Private Limited (including its affiliates). Further, the terms “you”, “your”, “yours” refer to you as a user of the car/services. This Policy explains how we collect, use, share, and safeguard your information in order to offer you the most seamless experience imaginable.

What Information Do we Collect?

Pravaig generates vehicle data, diagnostic, radar data, sonar data around the vehicle, GNSS (global navigation / position data), accelerometer and gyroscope raw data, inertia, speed, altitude, heading, vehicle sub systems, battery status, charging, discharging, motor and propulsion systems data, air quality data, infotainment and autopilot data. Pravaig vehicles are equipped with 360 degrees camera system, microphones, gyroscope, sensors, ethernet communication lines, microcontrollers and computers within the car to provide safe, seamless and secure experience to the user. We collect audio data within and in the surroundings of the car, video and image data, radar data, sonar data around the vehicle, global navigation/ position data, accelerometer and gyroscope raw data, inertia, speed, altitude, heading, and vehicle sub systems, battery status, charging, discharging, motor and propulsion systems data, air quality data, to enhance our services.

1.Vehicle Data: In order to support vehicle's continuous performance, predictive maintenance, and improved functionality and experience, Pravaig collects and processes vehicle data related to the usage, operation, and condition of the vehicle. This information is used to triage and fix potential issues, and continuously improve the vehicle and services to you. Examples of the vehicle data collected include: acceleration, gyroscope raw data, inertia, altitude, heading, vehicle sub systems, charging, discharging, motor and propulsion systems data, air quality data, speed information, odometer readings, vehicle component signals, internet connectivity status, battery use management information, battery charging history, electrical system functions, software version information, infotainment system data, safety-related data, camera images, video clips, microphone audio clips and other data to assist in identifying issues and analysing the performance of the vehicle.Pravaig vehicle uses location to power features such as in-vehicle maps, navigation, or mobile app location services. Location Services may use a combination of GPS, bluetooth, IP address, and wi-fi and mobile towers to figure out the location. To protect your privacy, location data is either processed directly without leaving your vehicle, is in a form that does not personally identify you, or remains inaccessible to Pravaig. For safety purposes, your vehicle's location may be used when you experience a safety event to aid response efforts. This means that unless captured as a result of a safety event. Pravaig does not link your location to your identity or know where you've been.

2. Diagnostic Data: Pravaig uses diagnostic logs to keep our products and services up to date, troubleshoot or debug problems, and make continuous improvements. We aim to collect such level of diagnostic data necessary to help keep your vehicle or energy product reliable, secure, and operating normally. Diagnostics may include details about vehicle configuration, firmware, energy use, electronic systems state, and other system-to-system data used to identify bugs and conduct technical evaluations. On specific events, we use diagnostic logs as basic error information to help determine whether the problems experienced can be addressed by an immediate or future software release.

3. Autopilot Data: Pravaig vehicles make use of cameras that provides advanced features to improvise its vehicle such as autopilot, smart summon, and autopark. Camera functionality has been designed in such a way that protects your privacy. Pravaig Vehicles do not capture continuous recordings or have live-view functionality. By default, advanced autonomous features that rely on the external cameras are processed without ever leaving the vehicle.

Pravaig is dedicated towards improving the wellbeing of its customers and the local city infrastructure while providing utmost security; hence the vehicles provided by Pravaig have external cameras that recognizes lane lines, street signs, conditions of the streets and traffic light positions. By doing this, Pravaig is able to achieve its goal of improving the city infrastructure. Further, based on the learning of the road conditions based on the data collected, we are able to improve your experience of our services.

Our Vehicles are equipped with cameras that are located in the car. The cameras can determine driver inattentiveness and provide you with audible alerts, to remind the driver to keep their eyes on the road when Autopilot is engaged. The camera also enhances the safety and security of the users of fleet operators. Pravaig reserves the right and you expressly consent to us recording the movement, the events, processes, conversations, feedback, pertaining to our vehicles. Camera recordings remain anonymous and are not linked to you or your vehicle.

4.Infotainment System Data: When using your vehicle's touchscreen, our vehicles may collect certain information that is either stored on the vehicle itself, or if shared with us, is not associated with your account by default. To protect your privacy, your in-vehicle browser history and sign-in credentials are not shared with Pravaig. The Infotainment system data collected may include, for example, aggregated counts of the features or apps used, playback and browsing metadata (such as radio listening time and channel), and approximate location for local radio options. For certain infotainment apps that require sign-in, if you do not have your own account, Pravaig offers the option to use the app with a Pravaig provisioned account instead. If you choose to use our provisioned account, then your infotainment system data for that specific app may be associated with your account. Additionally, if you experience performance issues with your infotainment and require support, Pravaig may retrieve certain infotainment system data to fulfil your request, effectively troubleshoot or debug the issue, and improve our products and services.

Sources of Obtaining Data

The data that is processed by us can broadly be categorised as follows: (i) data shared by you; (ii) data obtained through our and (ii) data shared by third parties. The data provided by you in most cases is direct when you: (i) register to use our products and/or services including the registration for a free trial; or (ii) when you apply for the role of an instructor, a teaching assistant, a mentor or a career coach, as the case may be. The data collected from third parties includes, without limitation, access or login details, profile picture or any other text / image in relation to your data which may be available with such third parties. The third parties from whom we receive your data may include, without limitation, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our educational partners, scholarship providers, analytics providers, recruiters and such other third-party sources.

Use of Information Collected

Our primary goal in collecting your information is to provide you with an enhanced experience when using our vehicle Services. We intend to use the data for following purposes:

• To recognize things like lane lines, street signs, traffic light positions and potholes to improve the infrastructure of the city;
• To assist, operate, enhance, and fulfil services on our behalf based on our legitimate interests to outsource certain operation;
• To conduct research, develop and promote new products and services, and to improve or modify our existing services;
• Functions that allow drivers to reach a destination quickly, and in a cost-efficient manner, by providing timely information about GPS navigation, potentially dangerous environmental conditions (e.g., icy roads), traffic congestion or road construction work, parking lot or garage assistance, optimised fuel consumption or road pricing;
• Functions that are supposed to aid drivers in reducing operating costs and improving ease of use, such as notification of vehicle condition and service reminders, transfer of usage data;
• Functions that warn the driver of external hazards and internal responses, such as collision protection, hazard warnings, lane departure warnings, driver drowsiness detection, emergency call (eCall) or crash investigation;
• Functions providing information to and involving the entertainment of the driver and passengers, such as smart phone interfaces (hands free phone calls, voice generated text messages), WLAN hot spots, music, video, Internet, social media, mobile office or “smart home” services;
• Functions involving partially or fully automated driving, such as operational assistance or autopilot in heavy traffic, in parking, or on highways;
• Functions monitoring the driver’s comfort, ability and fitness to drive such as fatigue detection or medical assistance;
• To analyse and improve the safety and security of our products and services;
• Provide you with the websites and services, together with any support you may request;
• Respond to your inquiries or fulfil your requests;
• Diagnose technical problems;
• Relay announcements, newsletters, educational materials, and event information;
• Enhance and improve our services;
• Prevent, detect and mitigate any fraudulent activities; and
• Comply with our legal obligations, resolving disputes with users, enforcing our agreements.

Sharing of Data

• Our service providers, business partners and affiliates

  We may share the data collected with our parent, subsidiaries and affiliates for internal reasons, including business and operational purposes. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

• Third parties for market study and other benefits

  We may share your information, with third parties for any purpose, including but not limited to undertaking market research/ study, conduct data analysis, determine and customize product or service offerings, to improve the products or Services or to make any other benefits/products/ services available to you.

• Government Bodies and Law enforcement authorities.

  We may also use and disclose information about you if we believe in good faith that that the law requires it for purposes of security, fulfilling our legal obligations law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also share information about you, where there are legal grounds to do so, if we determine that disclosure is reasonably necessary to enforce our Terms of Use or protect our operations or customers. This could include providing information to public or governmental authorities for improvement of city infrastructure.

Legal Basis of Collecting Data

Our basis for collecting your Data is based on the fact that you have consented to us processing your Data for a specific reason. By using our services or by providing your information, you consent to the collection, use, storage, disclosure and otherwise processing of your information (including sensitive personal information) with Pravaig in accordance with this Policy.

If you disclose to us any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

Cookies

When you visit our website or app, we may collect information from you automatically through cookies or similar technology. Cookies are essentially small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website. We essentially use cookies for a variety of reasons such as: (i) improve the way our website works; (ii) to create greater content for you and remember your likes and dislikes and other preferences; and (iii) to formulate information relevant to the user’s area of interests.

Most browsers allow you to refuse to accept cookies and to delete cookies. Disabling some cookies from the website may have a negative impact and may result in some features be unavailable. If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless you adjust your Internet browser settings. You may opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain targeted advertising delivered by NAI members’ advertising networks.

External Links

Our website may contain links to websites of other organizations. This Policy does not cover how those organizations process your data. Further, we do not endorse and are not responsible for the privacy practices of these third-party sites. Therefore, we encourage you to read the privacy policies available on the other websites you visit.

During, and as part of the services being offered by Pravaig, the users might be required to access, visit, browse and make use of third-party websites and content, the use of which is governed by terms and conditions of such third parties. The information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information that we have collected directly through our applications. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal data.

Safeguarding and Securing the Data

Pravaig uses administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the data and the threats posed. Pravaig has implemented a variety of safety and security features to consistently protect your information. Pravaig has done all in its power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help us safeguard all the information we collect. The data we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls, SSL (Secure Socket Layers) and ISO 27001 for protecting your information. Further, Pravaig is dedicated towards your safety and hence we have an ever-evolving structure including but not limited to hardware, software, and full end to end encryption of data at rest and in flight. The personal data is also completely anonymized to ensure no connection to the origin. The personal data is also completely anonymised to ensure no connection to the origin.

No Sale of your Personal Data

We do not intend to sell the data collected to anyone for any purpose.

Retention of your Personal Data

We keep the Personal Data we collect about you for as long as it is required for the purposes set out in this Policy and for legal or regulatory reasons, or as otherwise communicated to you. Pravaig retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including as described in this Policy, in our service-specific notices, or as required by law. The criteria for determining data retention may include the analysis and model requirements of data science we have to run or if there is a legal requirement to retain certain data. We carefully examine whether it is necessary to retain the personal data collected and work to ensure that the data is retained for the shortest period possible.

Rights of the User

We want you to be in control of how your personal data is used by us. Subject to local law, you may have the right to be informed of, and request access to, the personal data we process about you; update and correct inaccuracies in that information; have the information restricted or deleted; object or withdraw your consent to certain uses of data; and lodge a complaint with your local data protection authority. You may also have the right to data portability with regard to the data you provided to us.

Transfer of Data outside India

By using Pravaig vehicles and submitting your personal data to us, your information may be transferred to countries other than your place of residence or in which the information was originally collected. For example, where we have facilities or in which we engage service providers. Pravaig complies with laws on the transfer of personal data between countries to help ensure your data is protected as described in this Policy, wherever it may be.

Electronic Communication

You hereby explicitly consent to receive email messages from us, our subsidiaries, associates, or affiliates, for the purpose of providing alerts and information related to services. Further, you understand and agree that we and our subsidiaries, associates and affiliates at their sole discretion and without any obligation to disclose or inform you or anyone, may decide whether any of our information, offerings and promotions of our subsidiaries’, associates’, or affiliates’ is an update or upgrade to any goods or services being availed or having availed by you from us. If you would like to discontinue receiving this communication, you can update your preferences by using the ‘Unsubscribe’ link at the end of such emails or by contacting us through email on [email protected]

Breach Notification

Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority in a timely manner in compliance with applicable laws. Individuals will be informed directly where required by law.

Notification of Change

We regularly review and update our Policy to ensure it is up-to-date and accurate. Any changes we may make to this Policy will be in effect immediately after being posted on this page. We reserve the right to update or change our Policy at any time and you should check this Policy, periodically. Your continued use of the service after we post any modifications to the Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Policy.

Grievance Officer

In the event you have any queries regarding the policy, including but not limited to reporting any violation of this Policy, kindly contact us at Pravaig Dynamics ([email protected]). You may address any grievances you may have in respect of this privacy policy or usage of your data or other data to him/her.