Kabby Cabs LLP ("Kabby," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, store, share, and protect your information when you access or use our mobile application ("App"), website (https://www.Kabby.in), and related services (collectively, the "Services").

This Privacy Policy is an electronic record in terms of the Information Technology Act, 2000, and the rules thereunder. It is generated by a computer system and does not require any physical or digital signature.

By using our Services, you ("You" or "User") expressly consent to the collection, processing, and storage of your personal information as described in this Privacy Policy. If you do not agree with this policy, please do not use our Services.

1. DEFINITIONS

In this Privacy Policy, the following terms shall have the meanings assigned to them:

- "Data Fiduciary" means Kabby Cabs LLP, which determines the purpose and means of processing personal data.

- "Data Principal" means the individual to whom the personal data relates (i.e., You).

- "Personal Data" means any data about an individual who is identifiable by or in relation to such data.

- "Processing" means the entire cycle of operations with respect to personal data, including collection, storage, use, sharing, disclosure, and deletion.

- "Sensitive Personal Data or Information (SPDI)" shall have the meaning assigned under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, including passwords, financial information, physical and mental health condition, sexual orientation, medical records, biometric information, and any detail relating to the above as provided to Kabby for providing the Services.

2. TYPES OF INFORMATION COLLECTED

We collect the following categories of information to provide and improve our Services:

2.1. Information You Voluntarily Provide

| Category | Details | Purpose |

| :--- | :--- | :--- |

| Registration Data | Full name, email address, mobile phone number, date of birth, profile photo (optional), and home/work address. | To create and manage your Account, verify identity, and communicate with you. |

| Payment Information | Payment card details, UPI ID, bank account details, billing address, and transaction history. (Note: Full payment details are stored by our PCI-DSS compliant payment processors, not on our primary servers). | To process payments, issue refunds, and prevent fraud. |

| Ride & Travel Details | Pickup and drop-off locations, date and time of travel, special requests (e.g., pet-friendly, luggage), and purpose of travel (if provided). | To facilitate the ride, calculate fares, and provide customer support. |

| Communications | Records of your calls, emails, chats, and SMS exchanges with our customer support team. These may be recorded for quality assurance and training. | To resolve disputes, improve service quality, and train our representatives. |

| Identity Verification | Government-issued ID (e.g., Aadhaar, PAN, Driver’s License) or business information for corporate accounts, collected with your consent. | To comply with legal requirements, prevent fraud, and ensure safety. |

| User-Generated Content | Ratings, reviews, feedback, and any other content you post on the App or Site. | To improve services, provide transparency to other users, and personalize your experience.

2.2. Information Collected Automatically

When you use our Services, we automatically collect the following information:

| Category | Details | Purpose |

| :--- | :--- | :--- |

| Location Data | Precise GPS location collected when the App is in the foreground (during ride requests and trips). With your explicit consent, we may collect background location data to offer better pickup suggestions and safety features. | To connect you with nearby drivers, track rides, calculate accurate fares, and enable safety features like the SOS button. |

| Device Information | Mobile device model, operating system version, unique device identifiers (e.g., IDFA, Android ID), IP address, mobile network carrier, and language settings. | To optimize App performance, troubleshoot issues, and detect fraudulent activity. |

| Usage Data | App features used, pages visited, time and date of access, clicks, scrolls, and other in-app actions. | To analyze user behavior, improve the user interface, and personalize your experience. |

| Cookies and Tracking Technologies | We use cookies, web beacons, and similar technologies on our website to collect information about your browsing activities. | To remember your preferences, understand site usage, and deliver relevant content and advertisements. |

3. LEGAL BASIS FOR PROCESSING (COMPLIANCE WITH DPDPA, 2023)

We process your personal data only when we have a valid legal basis to do so. These bases include:

Consent: Where you have given explicit consent for processing your personal data for a specific purpose (e.g., collecting background location data, processing SPDI).

Performance of a Contract: Where processing is necessary for the performance of our contract with you (e.g., providing ride services, processing payments).

Compliance with Law: Where processing is necessary to comply with a legal obligation (e.g., sharing information with law enforcement, maintaining transaction records).

Vital Interests: Where processing is necessary to protect your vital interests or those of another person (e.g., in a medical emergency).

Legitimate Interests: Where processing is necessary for our legitimate business interests, provided such interests are not overridden by your fundamental rights and freedoms (e.g., improving our services, preventing fraud).

4. USE OF YOUR INFORMATION - We use the collected information for the following purposes:-

4.1. Service Provision and Management: To create and manage your account, process ride requests, match you with drivers, calculate and collect fares, provide customer support, and facilitate communication between you and drivers.

4.2. Safety and Security: To monitor rides for safety, enable the SOS feature to share your location with emergency contacts and services, verify user identities, detect and prevent fraud, and enforce our Terms and Conditions.

4.3. Personalization and Improvement: To remember your preferences, suggest favorite locations, personalize your ride experience, and analyze usage patterns to improve our technology, user interface, and service offerings.

4.4. Communications:

Transactional: To send booking confirmations, ride receipts, service updates, and responses to your inquiries.

Promotional: To send you marketing communications, offers, surveys, and newsletters. You can opt out of these at any time by clicking the "unsubscribe" link in the email or by adjusting your notification preferences in the App.

4.5. Legal and Regulatory Compliance: To comply with applicable laws, regulations, court orders, or government requests.

5. DISCLOSURE AND SHARING OF INFORMATION

We do not sell your personal data to third parties. We share your information only in the following limited circumstances:-

5.1. With Drivers: To facilitate your ride, we share your name, pickup location, and contact number with the driver who accepts your request. The driver is an independent third-party provider and is subject to their own privacy obligations.

5.2. With Service Providers and Business Partners: We engage trusted third-party vendors to perform functions on our behalf, including:

- Payment Processors: To securely handle transactions.

- Mapping and Navigation Services: To enable location-based services.

- Cloud Storage Providers: To securely host our data.

- Customer Support Platforms: To manage support tickets.

- Insurance Providers: If you purchase insurance through our platform.

- Marketing and Analytics Partners: To help us understand usage and run campaigns.

These partners are contractually bound to use your information only for the specific services they provide to us and to maintain its confidentiality.

5.3. For Emergency Response: With your consent (by activating the SOS button), we may share your real-time location, trip details, name, and contact information with emergency services, private security agencies, or government authorities (including police) to assist you.

5.4. For Legal and Safety Purposes: We may disclose your information if we believe it is necessary to:

- Comply with a legal obligation, court order, or government request.

- Protect the rights, property, or safety of Kabby, our users, or the public.

- Enforce our Terms and Conditions.

- Investigate and defend against any third-party claims or allegations.

5.5. For Corporate Transactions: In the event of a merger, acquisition, restructuring, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.

5.6. With Your Consent: We may share your information for any other purpose with your explicit consent.

6. DATA SECURITY - We implement robust security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These include:-

6.1. Encryption: We use industry-standard encryption protocols (SSL/TLS) to protect data transmitted between your device and our servers. Sensitive data stored on our servers is also encrypted.

6.2. Access Controls: Access to personal data is strictly limited to authorized employees, contractors, and agents who need it to perform their job functions. They are bound by strict confidentiality obligations.

6.3. Security Audits: We regularly conduct internal and external security audits to identify and mitigate vulnerabilities.

6.4. Payment Security: We utilize Razorpay as our payment gateway to process all payment transactions.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee its absolute security.

7. DATA RETENTION

We retain your personal data for as long as your account is active or as necessary to provide you with the Services. We will also retain and use your information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

Ride History & Transaction Records: Retained for a minimum of 1 (year) to comply with tax and accounting laws.

Customer Support Call Recordings: Retained for a period of up to 1 (one) year for quality and training purposes.

Location Data: Retained for 07 days to provide the Service and for a limited period thereafter for safety and fraud prevention analysis.

After the retention period, your personal data will be securely deleted or anonymized for analytical purposes.

8. YOUR DATA RIGHTS (UNDER DPDPA, 2023)

As a Data Principal, you have the following rights regarding your personal data. To exercise these rights, please contact our Grievance Officer at grievance@Kabbycabs.com.

8.1. Right to Confirmation and Access: You have the right to obtain confirmation from us on whether we are processing your personal data and to request a summary of such data.

8.2. Right to Correction: You have the right to correct inaccurate or outdated personal data and to update incomplete data through your Account settings or by contacting us.

8.3. Right to Erasure: You have the right to request the deletion of your personal data, subject to legal retention obligations we may have.

8.4. Right to Withdraw Consent: If processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing prior to the withdrawal.

8.5. Right to Grieve: You have the right to register a complaint with us and, if not satisfied, with the Data Protection Board of India.

9. DATA TRANSFER

Your personal data is primarily stored and processed on servers located within India. We do not transfer your personal data outside India without your consent, except as required to comply with applicable law or to facilitate a specific service for which you have authorized us.

10. CHILDREN'S PRIVACY

Our Services are not intended for individuals under the age of 18 (eighteen). We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data, please contact us immediately. If we become aware that we have collected personal data from a child without verification of parental consent, we will take steps to delete that information.

11. THIRD-PARTY LINKS

The App or Site may contain links to third-party websites or services (e.g., payment gateways, insurance providers). This Privacy Policy does not apply to such third parties. We are not responsible for the privacy practices or content of these third parties. We encourage you to read the privacy policies of any third-party websites you visit.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

- Posting the updated policy on this page with a new "Last Updated" date.

- Sending you a notification via email or the App (for significant changes).

Your continued use of the Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

13. GRIEVANCE OFFICER

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data handling practices, please contact our designated Grievance Officer. We will endeavour to address your grievance within a reasonable timeframe, not exceeding 30 (thirty) days, in accordance with the law.

Ms. Kanika

Sector 16, Panchkula, Haryana – 134109

Email: admin@Kabby.in

Phone: 8699149204

For any inquiries or grievances, please mention "Privacy Concern" in the subject line of your email.

14. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by and construed in accordance with the laws of India. Any disputes arising under or in connection with this policy shall be subject to the exclusive jurisdiction of the courts in Panchkula, Haryana.