Mahindra & Mahindra Limited, having its registered office at Gateway Building, Apollo Bunder, Colaba, Mumbai 400 001, Maharashtra, India (“we” “us” “our” “M&M”) is committed to protecting the privacy and security of your personal data. Your privacy is important to us.

This Privacy Policy (“Policy”) explains how we collect, receive, store, share, handle and use your personal data for the purpose of your participation and consumption of services offered by us through our Car Connectivity Solution for establishing connectivity between individual’s (“you”, “your” or “user”) device and your vehicle (“Software Application”) and how you can use your privacy rights.

This Policy shall be referred and read as an integral part of the Terms and Conditions and Terms of Use of the Software Application. Before using our Software Application, you are advised to carefully review this Privacy Policy including the Terms and Conditions and Terms of Use of the Software Application. If you do not agree with the terms of this Policy or Terms of Use, please do not access this Software Application. By using our Software Application, you are consenting to process of your personal data in the manner as set forth in this Policy.

  1. DATA PRIVACY DISCLAIMER

    The scope of this policy is limited to the product and/or services provide by us within the territory of India and applies to users who request for these products and/or services within the Indian territory.

  2. Personal data that we collect:

    When you interact with us, we collect different types of information from you based on the type of interaction.

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

    “Processing”, “Processed”, “Process” in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment, or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.

    Any personal data provided by you will not be considered as private and confidential if it is freely accessible in the public domain like any comments, messages, blogs, available on social media platforms like Facebook, Twitter etc

    We endeavour to collect only such information that is reasonably necessary to perform our services for you, deliver our products to you or to respond to your enquiries.

    (a) IDENTIFIERS INFORMATION

    When you interact with our Software Application, we may collect the following personal data from you directly:

    1. For Your Registration:
    2. We collect the following personal data from you directly for your registration:

      • Name
      • Mobile number
      • Email ID
      • Gender
      • Mailing Address
      • Date of Birth
      • Residential Address
      • Pin code
      • Identification Number
      • Mahindra For You Registered Number
      • Vehicle Identification Number
      • Vehicle Registration Number
    3. Assistance in Emergency Conditions:
      • We collect limited contact details which are provided by you to provide personalized assistance during emergency conditions. The sharing of these contact details with us for required assistance during an emergency is purely at your discretion.

      • Name of contact person to whom you intend the SOS message to be sent
      • Mobile number of such contact person
    4. Your Vehicle Information:
      • Vehicle Identification Number
      • Vehicle Model and Variant
      • Vehicle Colour
      • Display Name
      • Purchase date of the Vehicle
      • Vehicle Registration Plate
      • Subscription Details and Payment history

    (b) ELECTRONIC INFORMATION

    The tools may collect the following information about you and how you are interacting with our Software Application:

    Electronic information is generally non-identifying in nature, but to process such usage information and to make it feasible for our legitimate business interests like promoting system security and stability, allowing for error and performance analysis, and serving internal statistical needs, we may associate the usage information with other information collected from you and such combination may be treated as your personal data. This data also enables us to optimize our online services.

    (c) VEHICLE TELEMATIC INFORMATION

    We will collect the telematic information generated by your vehicle’s systems, in order to enhance our understanding of your vehicle’s performance and track, monitor, and alert you to enable services and maintenance of your vehicle.

    You are under no obligation to provide the personal data that we ask you for. However, if you do not provide your personal data, you will not be able to make use of the features and functions of the Car Connectivity Solutions.

    We may use a third-party service provider to assist with some features of our Software Application. Our service provider will receive your personal data on our behalf but will not be permitted to use it for any other purpose.

  3. LINKS TO SOCIAL MEDIA AND THIRD-PARTY SITES

    The Software Application contains some pages that are hosted and served by third parties. In this case, M&M is not responsible for the privacy policies/notices/statements or the content of such Third-Party/Software or Services even if you accessed the third-party website using links from our Software Application.

    If you provide your personal data to any third-party website, then the use of your personal data is governed by their privacy policies. This Policy applies to our Software Application only. We encourage you to be aware when you leave our Software Application and to read the privacy policies of other Third-Party Software Applications that may collect your personal data.

  4. PURPOSE FOR WHICH WE PROCESS YOUR PERSONAL DATA

    We collect your personal data for the following purposes:

    a. To provide you with our services to:

    b. For our internal business purposes to:

    c. For marketing to:

  5. BASIS FOR PROCESSING YOUR PERSONAL DATA

    We use your personal data only if we have a legal basis for doing so. In case, we wish to use your personal data for purposes other than the legitimate uses, we shall seek specific consent from you in a separate process prior to processing your personal data for such additional purposes.

    We shall also use your personal data for legal and regulatory purposes, such as:

    1. To ensure compliance with our legal obligations and to also comply with our obligations towards public authorities;
    2. To enforce our terms and conditions;
    3. To enforce any legal right or claim;
    4. For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention or prevention of fraud;
    5. For our internal and external audit requirements and for information security purposes;
    6. As otherwise described to you at the time of collection of your personal data.
  6. SHARING/DISCLOSURE OF PERSONAL DATA

    As far as this is necessary for the purposes set out above, we will share your personal data with the following recipients who either have a need to know and who will process it for us based on our instructions and for no other purpose:

    6.1 M&M companies and potential partnerships:

    Our businesses around the world are supported by different teams and functions, and personal data will be made available to them if necessary, for the provision of product and/or services, account administration, sales and marketing, customer and technical support, and business and product development. All our employees and contractors are required to follow our data protection and security policies when handling personal data. Your personal data might also have to be shared in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

    6.2 External service providers:

    Occasionally, to provide our services, it is necessary to collaborate with external service providers. These external service providers shall process your personal data on our behalf subject to appropriate safeguards only insofar as it is necessary for them to provide their services to us. Our prior authorization is required before they are permitted to transfer responsibility for processing personal data to a third-party. We may share your personal data with our channel partners/service partners/third-party entities for the purpose of completing the transaction or establishing the relationship.

    We only share your personal data with recipients that have an adequate level of data protection by implementing appropriate technical and organizational security measures, or we take measures to ensure that all recipients provide an adequate level of data protection as prescribed by applicable law. We do not sell your personal data to anyone.

    6.3 Courts and public authorities:

    We will share your personal data when required for the following purposes:

  7. ACCURACY OF YOUR PERSONAL DATA

    Notwithstanding the obligation on us to put in place all necessary means to maintain the accuracy of your personal data, you agree to provide us with accurate personal data at all times and you will notify us promptly upon any changes to your personal data.

  8. SECURITY MEASURES

    We implement appropriate technical and organizational measures in relation to the information and personal data that is processed by us. We take reasonable measures to protect all personal data from unauthorized processing or accidental disclosure, acquisition, sharing, alteration, misuse, destruction or loss or unauthorized access and modification that compromises the confidentiality, integrity, and availability of such data.

    While we endeavor to always protect our systems, applications, operations, and information against unauthorized access, use, modification, and disclosure, due to the inherent nature of the Internet, we cannot guarantee that any information, during transmission or while stored on our systems, will be safe and secure from intrusion by others.

    You too have an important role in protecting your personal data. You should not share your user identity, password, or other authentication data provided to you with anyone. If you have any reason to believe that your user identity or password has been compromised, please contact us immediately by using the contact details given in paragraph 12 below.

  9. YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL DATA

    We respect your right to access and control your personal data, and we will respond to requests to exercise your rights under applicable laws for information and, where applicable, will correct, update, or erase your personal data.

    Please note that applicable law might require that we cannot comply with every request. We will be required to retain your personal data due to legitimate business/ regulatory/ statutory retention requirements despite your request for erasure

    You have the following rights:

    For exercising any of your rights, you can contact us using the contact details provided in paragraph 12. We will need you to furnish proof of your identity before you can exercise these rights. M&M may not be able to process any requests made in the event you fail to establish your identity or if M&M is unable to authenticate your identity.

    It is important that the personal data we hold about you is accurate and updated. Please write to us if the personal data given to us changes during the period for which we hold it.

  10. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

    We will retain your personal data which we have collected for as long as we reasonably consider it necessary for achieving the abovementioned purposes and as is permissible under applicable law. This is determined on a case-to-case basis.

    We will delete your personal data whenever you request us to do so. However, we may archive and/or retain your personal data for as long as there are statutory retention obligations or potential legal claims are not yet time barred.

  11. SAFEGUARDING PRIVACY OF CHILDREN

    We do not knowingly collect or solicit personal data from minors. Our services are not designed for any person who is under 18 years of age, and we do not knowingly permit such persons to register for the services. So, if you are under 18, please do not attempt to register for the services or send any personal data about yourself to us. Further, we do not undertake tracking and behavioral monitoring of children or targeted advertising directed to minors.

    If we learn that we have collected personal data from a minor without verified parental consent, we will erase such personal data.

    If you believe that a child under 18 years may have provided us their personal data, please contact us using the contact details provided in paragraph 12.

  12. OUR CONTACT DETAILS

    If you have questions or comments regarding this Policy or want to exercise any of your rights or express your grievances regarding the processing of your personal data, please contact us using the contact details given below:

    customercare@mahindra.com

  13. GRIEVANCE REDRESSAL

    If you have any grievances against our processing of your personal data, you may lodge your grievance with the Grievance Officer/ Data Protection Officer as per details provided in paragraph 12 above.

    If you are not satisfied with the resolution provided you may log your complaint with the Data Protection Board of India following the procedure prescribed by them.

  14. CHANGES TO THIS PRIVACY POLICY

    We reserve the right to change this Policy at our sole discretion at any time. Any material changes to this Policy will be posted on this page. We encourage you to review this Policy regularly for such changes. The updated Privacy Policy will take effect as soon as it has been updated.

    This Policy was last updated as of 18th April 2024.

  翻译: