PRIVACY POLICY

A. COLLECTION OF THE USER’S DATA:

We collect, process and store the data provided by the Users on our Platform, including when the Users register their interest at “I’m interested!” tab or when the Users choose to use our Services and features by registering their account on the Platform (“Account”). The information collected on our Platform includes User’s name, phone number, email address, and any other personally identifiable information as supplied by the User on our Platform (“Personal Information”). We also collect information provided by the User voluntarily, while completing a customer survey or from the feedback provided by the User on any of our message boards or via email. The Company, situated in Ahmedabad, India, is the controller of the Users’ Personal Information.

In the event the User does not provide their Personal Information where required, we may not be able to provide all of the Services available on the Platform. For the purpose of creation of User Account on the Platform, the User will be required to provide their phone number, without the provision of which, User’s Account cannot be created on the Platform. In the event the User makes payment on the Platform via the payment gateway to complete any financial transaction on the Platform, we may collect and store his/her credit card/debit card, bank account number and other financial information in accordance with applicable law. The User acknowledge that the payment gateway may be provided by a third-party service provider in which case, applicable terms of use and privacy policy of such third-party service provider shall apply.

In order for us to be able to provide the Services to the Users, we may seek permission of the Users whether we may obtain access to contact list/phone book on their device, device location, camera, microphone and other sensitive device data. When this permission is sought, the Users shall have the control wherein they can select the ‘allow’ us to access such data or ‘deny’ us the permission to access the said data.

Cookies

Like many other websites, we use cookies, which are small files that are placed on User’s device by our Platform, through which we automatically collect and keep the information that the User’s browser sends whenever the User visits our Platform or when the User accesses our Platform by or through any device. This includes information such as User’s computer Internet Protocol address (IP address), browser type, browser version, the pages of our Platform that the User visits, the time spent on those pages, unique device identifiers and other diagnostic data. When the Users accesses the Platform with a device, we may collect and keep information such as the type of device Users use, their device unique ID, the IP address of their device, the operating system, the type of internet browser Users use, unique device identifiers and other diagnostic data. This is done mainly to customize Users current and future visits to and use of our Platform, and to deliver content relevant to their interests.

This Platform uses different analytics and tracking technologies on the Platform including Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google uses cookies, text files that are stored on Users’ computers and enables analysis of their use of the Platform. The types of information a cookie used by Google collects include unique device identifiers, unique User IDs (consisting of a string of numbers unique to each User on the website), the Internet Protocol Address (IP Address) of the Users’ device, the number of times Users have visited or accessed the Platform previously and the date and time of their visit to the Platform, information about how the Users found the Platform, their search and browsing history.

Cookies can be Persistent or Session cookies. Persistent cookies remain on Users’ device when they go offline, while session cookies are deleted as soon as the Users close their web browser.

We use the following categories of cookies for different purposes:

• Necessary/Essential Cookies: These cookies are essential to provide the User with Services available through the Platform and to enable the User to use some of its features. They help to authenticate the Users and prevent fraudulent use of Users’ Accounts.
• Functionality Cookies: These cookies allow the Platform to remember any choices the User makes about the Platform.
• Performance/ Statistical cookies: These cookies collect information about how the User uses our Platform. This data may be used to optimize our Platform and make it easier for the User to use it.
• Targeted Cookies: These cookies may be placed through our advertising partners and are used to track User’s online activity to help advertisers deliver more relevant advertising or to limit how many times the User sees an ad.

By clicking on “Accept”, the Users consent to the use of cookies by us to collect their data. By clicking on “Reject”, Users can reject the use of all non-essential cookies and no data shall be collected through non-essential cookies. The Users may also restrict the use of cookies by changing their browser settings. However, restricting the use of cookies may impact their experience of the Platform and the Services we offer.

In some instances, our third-party service providers may use cookies on the Platform. We cannot control or access cookies used by third-party service providers. This Privacy Policy covers only cookies used by us, and not any cookies used by third parties.

The Platform is an online interface conceptualized with the aim to communicate to our users, the Company’s endeavors to develop smart transformative and integrated technologies in order to empower our users with the option to choose a sustainable and a cleaner alternative and to provide Services to the users. From this perspective and in order to provide Services and to continually keep our Users updated about our growth, we collect, store and process the information provided by the Users or authorize third party service providers to store or process the same provided such third parties are also bound by obligations similar to those contained in this Privacy Policy and their storage/processing of the information of the User is limited to the purposes mentioned in this Privacy Policy and any such information shared is only on a need-to-know basis.

We have assumed that the Users have allowed us to access their internet network. If this permission is not given, then the Users will not be able to visit our Platform.

The Users can access our Website anonymously (as a guest user), but in that case, they shall not be qualified to receive any communications from us or they may not be able to access the privileges, if any, that we may provide to our members.

B. USAGE OF THE USER’S DATA

The purposes for which we collect, process and store User’s Personal Information depends upon the reasons for which we collect the said Personal Information. The Personal Information provided by the User and collected by us is kept strictly confidential and is used by us for automated profiling and for the below mentioned purposes:

• To create User Account on the basis of the information provided by the User, to manage their Account, to customize their experience;
• To notify the User regarding User Account, to confirm their identity in order to ensure that they are eligible to access the Platform;
• To share reports, news articles and other articles in relation to our R&D for development of platforms for electric vehicles and storage technology solutions and other related activities;
• To share promotional information regarding our products;
• To enable the User to avail the Services offered by us on the Platform;
• To share with the User offers initiated by the Company and to invite them, to events hosted by the Company;
• If the User is a user who has availed our pre-booking services, to share with the User the details of the authorized entities with whom the pre-booking has been made and other relevant details with respect to the pre-booking;
• To send reminders with respect to the vehicle services the Company offers;
• To comply with our legal obligations such as to conduct a product safety recall whenever necessary;
• To troubleshoot and provide the User an efficient service like providing the User customer service, resolving their technical issues, managing traffic on the Platform and the keyword searches;
• To display interest-based ads for products, services and features that might be of interest to the User. We do not use information that identifies the User personally in order to display such interest-based advertisements;
• To evaluate information on User’s recent visits to our Platform and how the User moves around different sections of our Platform for analytic purposes to understand how people generally use our Platform so that we can make it more relevant to the users.
• To send the User e-mails or other communications seeking for feedback or surveys; and
• If required to comply with legal requests, because the Company believes in good faith, that it is necessary to:
  • Fulfill legal obligations or to enforce these terms and conditions;
  • Defend accusations relating to the infringement of copyright/trademark laws;
  • Protect the Company’s systems and its user’s rights, property and security.

C. SHARING OF THE USER’S DATA

The Users’ Personal Information is kept confidential and secured with us and not disclosed to any third party. However, we may:

• share the Users’ Personal Information with the entities authorized by the Company who shall complete the intended sale of the vehicle (for eg the Company’s authorized dealers) and payment gateways if the User is someone who has availed our pre-booking service on the Platform;
• share the Users’ Personal Information with the related companies and affiliates of the Company;
• share the Users’ Personal Information with third party service providers on a need-to-know basis to process the Users’ Personal Information in order to fulfill the purposes set out in the Privacy Policy. The Company shall execute agreements with such third party service providers to cast an obligation on them to maintain the confidentiality of the Users’ Personal Information on terms that are at least at par with those set out in this Privacy Policy and to use the information only for the specific purpose for which the agreements have been executed. The third party service providers are contractually bound to carry out tasks based upon our instructions.
• share the Users’ Personal Information when required in order to comply with any legal requests.
• store information in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers or other service providers) and their use of the Platform shall constitute consent for the same.
• share the Users’ mobile number with other service providers who provide communication services on behalf of the Company like SMS, e-mails etc.
• transfer the Users’ Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. In the event of such sale or transfer, we may notify the User.
• transfer the Personal Information collected from the User to a country outside the European Economic Area, if the User is an user residing in the European Economic Area. The Company shall take appropriate safeguards to protect their Personal Information.

D. SECURITY

The Company takes reasonable commercial efforts to ensure the security of the systems with regard to the transmission of data during the usage of the Platform. We regularly carry out assessments to ensure the security of the data collected by us. However, please note that there is no guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any physical, technical, or managerial safeguards. It must be fully understood that neither the Company, nor any other website can completely eliminate such risks. If the Company becomes aware of a security system breach, then we shall immediately notify the User within the time-lines required by law by email or as a notification on the Platform so that the User can take appropriate protective steps.

The User will be responsible for maintaining the confidentiality of the username, password and other details related to his/her Account on the Platform and for all the activities that occur on the Account.

E. THIRD PARTY APPLICATIONS AND WEBSITES

In addition, the Platform may occasionally contain links to third-party websites. If the User clicks on the links to third-party websites, the User leaves our Platform. The Company is not responsible for the content of these third-party websites or for the security of User’s personal information when the User uses the third-party websites. These third-party websites may have their own privacy policies governing the storage and retention of their personal information that the User may be subject to. They may collect information such as their IP address, browser specification, or operating system. This Privacy Policy does not govern personal information provided to, stored on, or used by these third-party providers and third-party websites. We recommend that when the User enters a third-party website, they review the third-party website’s privacy policy as it relates to safeguarding their personal information.

F. STORAGE OF THE USER’S DATA

We will store the Users’ Personal Information as long as it is required to be stored for the purposes set out in this Privacy Policy and to comply with our legal obligations. When we no longer need to use the User’s Personal Information and there is no need for us to keep it to comply with our legal or regulatory or contractual obligations under the agreements executed with third party service providers like payment gateways, we will either delete it from our systems or depersonalize it so that we cannot identify the User.

G. USER RIGHTS

• Right to access: the User has the right: (a) to request copies of information we hold about the User at any time or; (b) request us to modify or update such information and (c) to request any other information with respect to his/her Personal Information collected and stored by us. We may require the User to provide suitable identification for security purposes before providing or allowing the User to access his/her Personal Information.
• Right to rectify/update the information provided by User: the User has the right to request to have his/her Personal Information rectified if it is inaccurate or incomplete. We rely on the Personal Information provided by the User in order to provide the User with the Services available on the Platform, and therefore it is important that the Personal Information provided by the User is accurate, complete and up to date. If the Personal Information provided by the User has undergone any changes, or if the User becomes aware that any information which we hold about the User is incorrect, incomplete or not up to date, kindly rectify or update the information by exercising this right.
• Right to erasure: the User has the right to request that we delete his/her data from our storage systems. However, please note that there might be latency in deleting the User’s Personal Information. Additionally, if the User has undertaken any financial transaction through our Platform, such details will be stored with us till such time as required under law or as per our contractual obligation under the agreements executed with third party service providers like payment gateways, although all other information may be deleted us.
• Right to restrict processing: If the User is a user from the EU Region, then the User has the right to restrict us from processing his/her Personal Information.
• Right to data portability: If the User is a user from the EU Region, then the User has the right to request us to move, copy or transfer his/her Personal Information.khskje
• Right to object: If the User is a user from the EU Region, then the User has the right to object to our use of his/her Personal Information for all or certain specific purposes.
• Right to opt out: We would be sending the User information about our products, newsletters, reports and other promotional communications. User has the right to opt out of receiving communications from us. The User can also unsubscribe to our promotional emails by following the unsubscribe instructions provided in those emails.

If the User wishes to exercise any of the abovementioned rights, the User shall submit his/her request by writing to us at customer.care@matter.in mentioning the nature of the right the User wishes to exercise in the subject line of the e-mail.

H. CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to change this Privacy Policy as it may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Platform alongwith the date of the modification and if the Users continue to use this Platform, they are deemed to have accepted the terms of the altered privacy policy.

I. GRIEVANCE OFFICER

For any complaints/grievances/discrepancies in respect of this Privacy Policy, please contact Mr. Rajeshwar Prasad at customer.grievance@matter.in, the designated ‘Grievance Officer’ under Information Technology Act, 2000 and any other applicable law for this purpose. The subject of User’s e-mail should state “Complaint arising from use of the Platform”. The Company shall immediately look into the same and undertake the requisite actions.