PRIVACY POLICY

Your privacy is important to Turtlelogi Mobility India Private Limited (the “Company”, “we”, “Turtle”, “us”, or “our”).

This Privacy Policy (“Policy”) outlines our policies and procedures regarding the collection, use, processing, storage, retrieval, disclosure, transfer, and protection of your information—including personal and sensitive personal data (“Information”)—that Turtle may collect through:

• Your online access, interaction, or use of the Turtle mobile applications (“Turtle App”) or our websites:
  • https://turtleindia.in/

• Your offline interactions with us, including via mail, phone, or in-person communication.

• Your use of any services offered by Turtle (“Services”), as defined in our Terms & Conditions available on the Turtle Platform.

1. USER ACCEPTANCE

By accessing or using the Turtle Platform or its Services, you consent to this Policy and any amendments posted by the Company from time to time.

Your Information is collected, processed, used, stored, and protected in accordance with:

• This Privacy Policy

• Applicable laws, including the Information Technology Act, 2000

If you do not agree with this Policy, please do not use the Turtle Platform.

By providing your Information to Turtle, you confirm that:

1.      The Information is accurate, current, and updated.

2.      You have the necessary rights, permissions, and consents to provide such Information.

3.      Providing this Information does not violate any applicable laws or agreements.

If you provide Information about another person, you represent that you have their authorization to do so and to permit us to use it as per this Policy.

2. DEFINITIONS

• Riders – Independent third-party vehicle operators or riders offering services on the Turtle Platform.

• Customers – Individuals seeking services from Riders or Vendor Partners on the Turtle Platform.

• Vendor Partners – Third-party providers offering 2-wheeler rental services via the Turtle Platform.

• Device – Any computer, mobile, or other device used to access the Services.

• Device Identifier – A unique identifier such as an IP address associated with your Device.

• Personal Information – Data that can identify you, including name, email, and mobile number.

• TPSP (Third-Party Service Provider) – External service providers engaged by Turtle.

• Usage Information – Data collected about your interaction with the Turtle Platform.

3. INFORMATION WE COLLECT

(I) Information You Provide to Us

We may collect Personal Information through various means, including account registrations, contact forms, and customer interactions. This includes:

• Account Information – Name, email, address, mobile number, gender, date of birth, profile photo, login details, payment details (where applicable), etc.

• Saved Information – Address, billing details, emergency contacts, etc., to enhance your user experience.

• Verification Information (for Riders & Vendor Partners) – Government-issued ID (Aadhaar, PAN), driver’s license, vehicle documents (registration, permit, fitness certificate, insurance, pollution certificate), and real-time selfies for identity verification.

• Background Check Information (for Riders & Vendor Partners) – Criminal records, driver history, and right-to-work documents (collected via TPSPs).

• Other Apps Data (for Riders & Vendor Partners) – Certain app permissions to prevent fraud.

• Customer Support Interactions – Data from queries, complaints, in-app messages, ratings, and reviews.

• Referral Information – Contact details of people you refer to the Turtle Platform.

🚫 Prohibited Content: You must not upload, share, or transmit any content that is:

• Offensive, harassing, obscene, or illegal.

• False, misleading, or deceptive.

• A threat to national security, public order, or encourages criminal activity.

(II) Information We Collect Automatically

When you use the Turtle App, we may collect:

• Transaction Information – Ride details, pickup/drop-off locations, payment data, and trip history.

• Location Data:
  • For Riders & Vendor Partners – Real-time location is collected only when "On-Duty" is enabled in the Turtle App.

  • For Customers – Location is collected during rides for navigation, safety, and fraud prevention.

• Usage Information – How you interact with the Turtle App (e.g., screen visits, search behavior).

• Device Information – Device type, operating system, mobile network details, and app activity.

• Health-Related Information (for Riders) – Health declarations (e.g., body temperature, vaccination status).

• SMS/Text Messages – With your permission, we may collect SMS details for OTP verification and secure transactions.

• Call Details (for Riders & Vendor Partners) – Calls with Turtle support may be recorded for quality and security purposes.

• Cookies – Used for analytics and customization. You may disable cookies via browser settings.

(III) Information from Third Parties

We may receive Information from:

• Business Partners – For analytics, fraud prevention, and verification purposes.

• TPSPs – For payment processing, background checks, and other services.

• Public Sources – Such as marketing databases and social networks.

4. HOW WE USE YOUR INFORMATION

We collect Information to:

✅ Enable access to the Turtle Platform.
✅ Verify identities (for Riders & Vendor Partners).
✅ Improve user experience, troubleshoot issues, and enhance security.
✅ Provide customer support and communicate important updates.
✅ Prevent fraud, unauthorized access, and policy violations.
✅ Facilitate transactions, including payments and ride history.
✅ Track rides, enhance safety, and improve pick-up/drop-off locations.
✅ Send promotional offers (optional; you may opt out).
✅ Comply with legal obligations and respond to regulatory authorities.

📌 Note: We do not use your Information for targeted advertising.

5. INFORMATION SHARING & DISCLOSURE

We may share your Information with:

• Riders & Vendor Partners (for service fulfillment) – Your name, pickup location, and contact details.

• Third-Party Service Providers (for payments, analytics, fraud prevention, etc.)

• Legal Authorities (when required by law, court orders, or investigations)

• Business Partners (when you avail co-branded services or corporate discounts)

We do not sell or rent your personal information to third parties.

6. DATA SECURITY

We implement industry-standard security measures to protect your Information. However, no method of transmission over the Internet is 100% secure. Please safeguard your account credentials.

7. YOUR RIGHTS & CHOICES

🔹 Access & Correction – You can review and update your Information via the Turtle App.
🔹 Data Retention – We retain your Information as long as necessary for legal and operational purposes.
🔹 Opt-Out – You may opt out of promotional communications anytime.

8. CHANGES TO THIS POLICY

Turtle reserves the right to update this Policy from time to time. Any significant changes will be notified via the Turtle App or website.

Last Updated: [Insert Date]

For questions, contact us at support@turtle.bike.

9. SECURITY

The information we collect is securely stored within our databases, and we implement industry-standard security measures such as encryption, firewalls, and SSL (Secure Socket Layers) to protect your data. However, while encryption technology enhances security, no system is completely impenetrable. We cannot guarantee absolute security for our databases or that information you transmit to us over the Internet or wireless networks will not be intercepted. You share your information at your own risk, and we strongly recommend keeping your password confidential.

10. INFORMATION OF CHILDREN

Turtle does not knowingly solicit or collect information from individuals under 18 years of age. The Turtle App is only available for users who are legally eligible to enter into binding contracts as per applicable laws.

11. GRIEVANCE OFFICER

If you have any questions, requests, or complaints regarding how we process your information, you may contact our Grievance Officer at the details provided below. We will make every effort to address your concerns promptly.

Grievance Officer:
Name – Manasvi Mann
Email – nodalofficer@turtle.bike

12. CHANGES TO THE PRIVACY POLICY

Turtle reserves the right to update or modify this Privacy Policy periodically to reflect changes in our data practices. Any updates will take effect immediately upon being posted on the Turtle Platform. If we make significant changes, we will notify you via email (using the address linked to your account) or through a notice on the Turtle App before the changes take effect.

We encourage you to review this policy periodically for updates. Your continued use of the Turtle App or services after any changes take effect will constitute your acceptance of the revised Privacy Policy.