PRIVACY POLICY

1. INTRODUCTION

Trapy Private Limited ("Trapy", "Company", "we", "our" or "us") is committed to protecting the privacy and personal data of users of the Trapy platform.

This Privacy Policy explains how Trapy collects, processes, stores, uses, shares and protects personal data when individuals access or use the Trapy mobile application, website, software platform and related services (collectively, the "Platform").

This Privacy Policy is issued in accordance with:

• The Digital Personal Data Protection Act, 2023;
• The Information Technology Act, 2000;
• Applicable rules, regulations, notifications and guidelines issued thereunder;
• Any other applicable laws relating to privacy, cybersecurity and digital services in India.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. DEFINITIONS

Unless the context otherwise requires:

• Personal Data means any data about an individual who is identifiable by or in relation to such data.
• Processing means any operation performed on Personal Data including collection, storage, use, disclosure, sharing, retrieval, transmission, deletion or destruction.
• User means any individual accessing or using the Platform.
• Driver means a User offering a ride through the Platform.
• Rider means a User booking or participating in a ride through the Platform.
• Consent means a free, specific, informed, unconditional and unambiguous indication of agreement to the processing of Personal Data for a specified purpose.

3. DATA WE COLLECT

Depending upon the nature of services used, Trapy may collect the following categories of information.

a. Account Information

• Full name;
• Mobile number;
• Email address;
• Date of birth;
• Gender (optional);
• Profile photograph;
• Login credentials.

b. Identity Verification Information

Where applicable and with your consent:

• Driving licence details;
• Vehicle registration details;
• Insurance details;
• Government-issued identity information;
• Verification records obtained through DigiLocker, API Setu or other authorized systems.

c. Vehicle Information

For Drivers:

• Vehicle registration number;
• Vehicle make and model;
• Vehicle colour;
• Vehicle category;
• Vehicle insurance details;
• Pollution Under Control Certificate details.

d. Ride Information

• Ride origin and destination;
• Route information;
• Travel schedules;
• Ride bookings;
• Ride history;
• Ride preferences;
• Cancellation history.

e. Location Information

Subject to device permissions:

• Real-time GPS location;
• Device location;
• Trip location history;
• Approximate location.

f. Device and Technical Information

• Device identifiers;
• IP address;
• Browser type;
• Device model;
• Operating system;
• Application version;
• Network information;
• Log data.

g. Communication Information

• Customer support interactions;
• Feedback and reviews;
• Chat communications made through the Platform;
• Complaint records.

h. Payment Information

Payments may be processed through regulated third-party payment service providers.

Trapy may receive:

• Transaction identifiers;
• Payment status;
• Refund information;
• Payment-related metadata.

Trapy does not store complete debit card, credit card or banking credentials unless specifically permitted by applicable law and payment regulations.

4. PURPOSES OF PROCESSING

Trapy processes Personal Data only for lawful purposes including:

Account Creation and Management

• Creating and maintaining user accounts;
• User authentication;
• Account recovery.

Ride Matching and Service Delivery

• Facilitating ride-sharing services;
• Matching Riders and Drivers;
• Managing bookings and cancellations;
• Facilitating communication between Users.

Safety and Security

• Identity verification;
• Fraud prevention;
• Risk assessment;
• User safety monitoring;
• Investigation of complaints and incidents.

Regulatory Compliance

• Compliance with legal obligations;
• Responding to governmental requests;
• Law enforcement cooperation;
• Regulatory reporting.

Platform Improvement

• Analytics;
• Service optimization;
• Product development;
• Performance monitoring.

Customer Support

• Addressing complaints;
• Responding to queries;
• Resolving disputes.

5. CONSENT

Where required under applicable law, Trapy shall process Personal Data only after obtaining valid consent.

Users may provide consent through:

• Account registration;
• Platform permissions;
• Verification processes;
• In-app consent mechanisms;
• Electronic acknowledgements.

Users may withdraw consent at any time by contacting Trapy or through available account settings.

Withdrawal of consent may affect availability of certain Platform features and services.

6. DIGILOCKER AND API SETU INTEGRATION

Trapy may integrate with DigiLocker, API Setu and other Government-authorized digital public infrastructure platforms.

Where Users voluntarily choose to verify documents through such systems:

• Trapy shall access records only after obtaining the User's explicit consent;
• Trapy acts solely as a requesting entity;
• Trapy does not create, modify or authenticate government-issued documents;
• Information retrieved may be used for identity verification, safety compliance, fraud prevention and regulatory compliance purposes.

Users acknowledge that the availability, accuracy and operation of government systems remain under the control of the relevant authorities.

7. LOCATION DATA

Location information is essential for providing ride-sharing functionality.

Trapy may collect location information:

• During active rides;
• While searching for rides;
• During safety-related events;
• For emergency response features.

Users may disable location permissions through device settings; however, certain features may become unavailable.

8. DATA SHARING AND DISCLOSURE

Trapy does not sell Personal Data.

Personal Data may be shared only where reasonably necessary with:

Other Users

Limited information may be displayed to facilitate rides, including:

• First name;
• Profile picture;
• Ratings;
• Vehicle information;
• Ride details.

Service Providers

• Cloud service providers;
• Customer support providers;
• Analytics providers;
• Verification service providers;
• Payment processors.

Government Authorities

Where required by law or lawful order.

Professional Advisors

• Auditors;
• Lawyers;
• Consultants.

Corporate Transactions

In connection with mergers, acquisitions, restructuring or business transfers.

9. DATA RETENTION

Trapy retains Personal Data only for as long as necessary to:

• Provide services;
• Fulfil legal obligations;
• Resolve disputes;
• Enforce contractual rights;
• Maintain safety and fraud prevention measures.

Data no longer required shall be deleted, anonymized or securely destroyed in accordance with applicable law.

10. DATA SECURITY

Trapy implements reasonable technical and organizational security measures including:

• Encryption;
• Access controls;
• Authentication mechanisms;
• Monitoring systems;
• Security audits;
• Incident response procedures.

Despite such measures, no electronic system can be guaranteed to be completely secure.

11. YOUR RIGHTS

Subject to applicable law, Users may have the right to:

• Access Personal Data;
• Request correction of inaccurate data;
• Request updating of information;
• Request erasure of Personal Data;
• Withdraw consent;
• Nominate another person to exercise rights where permitted under law;
• Seek grievance redressal.

Requests may be submitted through the contact details provided below.

12. CHILDREN'S PRIVACY

The Platform is intended only for individuals who are at least eighteen (18) years of age.

Trapy does not knowingly collect Personal Data from children.

If Trapy becomes aware that Personal Data of a child has been collected contrary to applicable law, appropriate action shall be taken including deletion of such information.

13. COOKIES AND ANALYTICS

Trapy may use cookies, SDKs and similar technologies for:

• Authentication;
• Security;
• Analytics;
• Performance monitoring;
• User preferences;
• Service optimization.

Users may control cookies through browser settings, although some functionality may be affected.

14. CROSS-BORDER DATA TRANSFERS

Personal Data may be processed, stored or transferred outside India only in accordance with applicable law and subject to appropriate safeguards.

15. GRIEVANCE REDRESSAL

For privacy-related concerns, requests or complaints:

The Grievance Officer shall address grievances within timelines prescribed under applicable law.

16. CHANGES TO THIS PRIVACY POLICY

Trapy may update this Privacy Policy from time to time.

Updated versions shall become effective upon publication on the Platform.

Continued use of the Platform after such publication shall constitute acceptance of the revised Privacy Policy.

17. CONTACT US

For privacy-related queries, requests or concerns:

By using the Platform, you acknowledge that you have read, understood and agreed to this Privacy Policy.