Privacy Policy

This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard information when you access https://www.ritzy-ride.com or the Ritzy mobile applications (including the Ritzy user and partner applications), collectively, the "Ritzy Platform", developed and operated by Ritzy Mobility Private Limited ("Ritzy," "Company," "we," "us," or "our"), a private company incorporated under the laws of India with its registered office at Second (2nd) Floor, plot no. 1969, Sector-45, Gurugram, Haryana-122003.

We are committed to protecting your privacy. If we request information that can identify you while you use the Ritzy Platform, we will use it in accordance with this Privacy Policy.

The terms "you" and "your" refer to a Customer, partners, or any visitor using the Ritzy Platform and/or the Services (defined below).

We may update this Policy periodically. Please review this page from time to time to stay informed about changes.

USER ACCEPTANCE

BY ACCEPTING OUR CUSTOMER TERMS AND CONDITIONS, ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY. Please read it carefully to understand our practices. If you do not agree, do not accept the Terms and Conditions or use our Services. This Policy forms part of, and is incorporated by reference into, the Terms and Conditions.

By accessing or using the Ritzy Platform or our Services, you consent to this Policy and to any updates we may post on the Ritzy Platform from time to time at our sole discretion.

Any collection, processing, retrieval, transfer, use, storage, disclosure, and protection of your information will be in accordance with this Policy and applicable laws, including (without limitation) the Information Technology Act, 2000, the rules framed thereunder, and the Digital Personal Data Protection Act, 2023 ("Applicable Laws"). If you do not agree with the Policy, please do not use or access the Ritzy Platform.

You represent and warrant to Ritzy that:

• a) The information you provide to Ritzy is and will remain accurate, current, and complete, and you have all necessary rights, permissions, and consents to share such information with us.
• b) Your provision of information to Ritzy, and Ritzy's collection, storage, use, transfer, access, or processing of such information, does not and will not violate any agreement, Applicable Laws, charter documents, judgments, orders, or decrees.
• c) If you share information relating to another person, you have authority to do so and to allow us to use that information as described in this Policy.

DEFINITIONS

a) Including but not limited to the Information Technology Act, 2000 (and rules thereunder) and the Digital Personal Data Protection Act, 2023 ("DPDP Act").

b) "Applicable Laws" means all laws, rules, regulations, and governmental orders applicable to the Ritzy Platform and the processing of personal data in India, Child" means a person under 18 years of age. The Services are intended for adults.

c) "Consent" means a specific, informed, unconditional, and unambiguous indication of your agreement to Processing for stated purposes, given by a clear affirmative action, and withdrawable at any time in accordance with the DPDP Act.

d) "Consent Manager" means an entity enabling you to give, manage, review, and withdraw Consent, as recognised under the DPDP Act.

e) "Cookies, SDKs & Similar Technologies" means small files or software components (including cookies, pixels, local/app storage, and mobile software development kits) used for authentication, preferences, analytics, security, and performance.

f) "Data Fiduciary" has the meaning given in the DPDP Act. For this Policy, Ritzy is the Data Fiduciary.

g) "Data Processor" or "Processor" means any person who Processes Personal Data on behalf of a Data Fiduciary. This includes contracted service providers (e.g., hosting, payments, analytics, KYC, messaging).

h) "Device" means a computer, smartphone, tablet, or other equipment used to access the Ritzy Platform.

i) "Enterprise/Partner Program" means an arrangement with an employer or third party through which you access coupons, discounts, or bookings on the Ritzy Platform.

j) "Geolocation Data" means approximate or precise location information derived from your Device (e.g., GPS, Wi-Fi, Bluetooth, cell-tower signals) when you enable location services.

k) "Government-Issued Identification" means documents used to verify identity (e.g. valid driving licence and, where applicable, proof of address or other IDs). Ritzy avoids collecting Aadhaar unless mandated by law; if collected, we prefer masked Aadhaar or Virtual ID.

l) "Operational Partners" means third parties engaged to fulfil or support chauffeur/driver bookings, including but not limited to Drivers, verification agencies, communication partners, insurance partners, and customer support partners.

m) "Payment Partners" means PCI-DSS compliant payment gateways or aggregators that process credit/debit card and other payments for the Services. Ritzy does not store card numbers or CVV on its servers.

n) "Personal Data" means any data about an individual who is identifiable by or in relation to such data, as interpreted under the DPDP Act.

o) "Processing" / "Process" means any operation performed on Personal Data, including collection, storage, use, sharing, disclosure, transmission, retention, or deletion.

p) "Ritzy," "Company," "we," "us," or "our" means Ritzy Mobility Private Limited.

q) "Ritzy Platform" means the website located at https://www.ritzy-ride.com and the Ritzy mobile applications, together with related domains, sub-domains, and services we operate. References in this Policy to "Website/Application" have the same meaning.

r) "Services" means chauffeur/driver services offered via the Ritzy Platform, and related customer support, billing, and safety/fraud-prevention features.

s) "Third-Party Cookies" means cookies set by domains other than the Ritzy Platform's domain(s); their placement and use are governed by the respective third party's privacy policies.

t) "You," "your," "User," or "Customer" means an individual who visits the Ritzy Platform or uses the Services.

INFORMATION WE COLLECT

Depending on how you use the Ritzy Platform and our Services, we may collect the following information:

• For our User application, we collect identity and contact details, including salutations, your first and last name, date of birth, your email address (used for transactional emails, receipts, and limited promotional messages), and your mobile number (used for verification and communications between you, Ritzy, and our driver/chauffeur partners).
• For our driver/chauffeur/rider partner application, we collect identity details, for the purpose of KYC verification, bank details, for the purpose of pay-outs, contact details, including salutations, your first and last name, father's name, mother's name, date of birth, current residential and permanent address, your email address (used for transactional emails, receipts, and limited promotional messages), & your mobile number (used for verification and communications between you, Ritzy, and our users), and vehicle details from rider partners.
• We collect location information for operational and safety purposes, including your device's GPS-based or approximate location, pick-up and drop-off points, and the driver's live location when "On Duty". You may choose to disable location access or allow location access only while accessing the application, but the Services may not function accurately and/or correctly without it.
• We collect device and diagnostics data, such as device identifiers (e.g., IMEI or equivalent), app version, and technical logs, to uniquely identify your device, diagnose issues, and prevent fraud.
• We collect usage analytics about how you interact with the Ritzy Platform to improve functionality, performance, and overall user experience.
• We collect limited payment details necessary to authenticate and complete transactions via our payment partners. Credit/Debit Card data is processed by PCI-DSS compliant payment partners using tokenisation; Ritzy does not store card numbers or CVV on its servers. Bank details, where collected, are used only for refunds or chargebacks, if applicable.
• We collect user-generated content, including feedback, ratings, reviews, and support requests, to operate, improve, and support the Services.
• We collect government-issued identification required by law or policy to verify your eligibility to meet Ritzy's eligibility and legal requirements [for example, a valid driving licence, Aadhaar, PAN, vehicle details (such as RC, insurance, PUC), and, where applicable, proof of address].
• We may process vehicle and telematics data such as odometer readings, fuel/battery level, and diagnostic codes, to protect assets, verify usage, prevent fraud, and manage billing and safety.
• We collect photos or videos of the vehicle before and/or after a trip, for the limited purposes of documenting the condition of the vehicle, preventing false liability claims, resolving disputes between Customers/Users, Drivers, and Ritzy, ensuring safety, transparency, and accountability.
• We collect basic vehicle details such as Make, Model, Car Type, Transmission Type and Registration number (limited usage, where necessary) to help Drivers locate the correct vehicle, facilitate accurate trip assignment, ensure safety and avoid mix-ups, support dispute resolution when needed.
• We also collect and use incident/claims data, including damage photos, accident or incident reports, and insurance documents, to assess, process, and resolve claims.

COOKIES

Usage information may be collected on the Ritzy Platform using cookies and similar technologies (including mobile SDKs and local storage). If you do not want information collected via cookies, you can manage, deny, or accept cookies through your browser or device settings. You can also disable or control cookies by setting preferences within your web browser or on your device. Please note that disabling some or all cookies may cause certain features of the Services to function improperly, and we may be unable to tailor content or settings to you. Ritzy does not control third-party cookies; their placement and use are governed by the third party's own policies and not by this Policy. Where available, you may also manage consent via in-app privacy controls or a DPDP-recognised Consent Manager. For clarity, Ritzy does not use cookies for targeted advertising.

HOW WE USE YOUR INFORMATION

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping;
• Improving our Services;
• Periodically sending promotional emails, WhatsApp, SMSs or push notifications about new products, special offers or other information which we think you may find interesting using the email address which you have provided; and from time to time, contacting you for market research purposes by email, phone, fax (where applicable) or mail;
• Customising the Website/Application according to your interests. We use your information to operate, improve, and secure the Ritzy Platform and to provide our Services. This includes:
• We enable your access to the Ritzy Platform and to your account.
• We verify your identity and your eligibility under Applicable Laws and our policies.
• We analyse feature usage, let you view booking history and submit ratings or reviews, or improve features, resources, and availability based on usage patterns and geography.
• We send an onboarding email or SMS to verify your username and password during onboarding.
• We provide the correct app build for your device, troubleshoot issues, and, where permitted, conduct limited marketing.
• We diagnose server or application issues and administer the Ritzy Platform.
• We send important service-related announcements (for example, temporary maintenance), and you may deactivate your account if you prefer not to receive such notices.
• We prevent, detect, and investigate potential breaches of this Policy or our terms.
• We identify and address security incidents, errors, fraud, money laundering, abuse, and other unlawful activity, and take appropriate remedial action.
• For customers/users, we use geolocation to identify nearby available Drivers, estimate arrival times, autofill pick-up locations, and allow optional safety features such as sharing ride details with trusted contacts.
• Where applicable, we use geolocation for partners (when set to "On-Duty") to receive nearby orders, coordinate pick-up and drop-off, and enable customers to track arrival for safety.
• We provide requested information or services, send newsletters or promotional materials (ours or carefully selected third parties'), enable participation in promotions or contests, contact you about your use of the Services and policy changes, support internal business purposes, and perform data analytics.
• We customise or personalise aspects of the Ritzy Platform or the Services to deliver a better user experience.
• We present relevant offers, discounts, or rewards based on lawful analysis of your preferences and consumption patterns.
• We enforce our terms and this Policy and resolve disputes.
• We provide functionality, analyse performance, fix errors and bugs, and improve overall usability and effectiveness.
• We comply with Applicable Laws and lawful requests from regulators, law enforcement, or courts, and where required under a contract with a third party.
• We perform our obligations and enforce our rights arising from contracts between you and us.
• We deliver notices, alerts, confirmations, and other relevant communications via SMS, WhatsApp, email, or in-app messaging.
• If you access the Services through an employer or partner program offering coupons or promotions, we may share limited information you provide with that organisation for its internal business use only.
• We use your information to fulfil the purpose for which you provided it and any other purpose for which you have given consent, and we do not use information collected from you for targeted advertising.

Sharing of Information

We may disclose personal data to:

• Affiliates and group entities on a need-to-know basis for support and operations.
• Service providers/Processors (e.g., payment gateways, insurance, analytics, cloud/hosting, security/fraud, customer support, document verification/KYC, telecom/SMS, mobile push providers) under contracts restricting use to specified purposes with reasonable safeguards.
• Operational partners (e.g., fleet partners, driver/chauffeurs, and route or navigation partners) and Users, separately and simultaneously, to fulfil bookings, provide support, and administer insurance/claims.
• Enterprise/partner programs where your booking is through such a program, limited to internal business use as necessary.
• Law enforcement, regulators, courts, or other third parties when required by law or to establish, exercise, or defend legal claims; to prevent fraud/abuse; or to protect rights, property, or safety.
• If Ritzy undergoes a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred to the acquiring or resulting entity, subject to the same or higher level of protection.

PROHIBITED USES

You must not, directly or indirectly:

• a) access data or content not intended for you, or log into a server or account you are not authorised to access;
• b) probe, scan, or test the vulnerability of the Ritzy Platform or any related system or network, or breach authentication or security measures;
• c) use automated means (e.g., robots, spiders, scrapers) to monitor, access, or copy content from the Ritzy Platform without written permission;
• d) interfere with or disrupt any user, host, or network (including by uploading malware, overloading systems, initiating/facilitating denial-of-service attacks, "flooding," "spamming," "mail bombing," or "crashing");
• e) use our systems to send unsolicited emails, including promotions or advertisements;
• f) forge headers or otherwise manipulate identifiers in emails or postings originating from our systems; or
• g) modify, reverse engineer, decompile, disassemble, or attempt to derive any source code relating to the Ritzy Platform or Services. Violations may result in civil and/or criminal liability and the loss of access to the Ritzy Platform.

You agree that any payment card or instrument used for transactions on the Ritzy Platform is lawfully yours and the details you provide are true and complete. You further agree that such information will not be used or shared by us with third parties except as required by law, regulation, or court order.

CONSENT, LEGITIMATE USES & CONSENT MANAGERS

Where we rely on consent, it will be specific, informed, unconditional, and unambiguous, and you may withdraw consent at any time through available settings or by contacting us. We may also process data under legitimate uses permitted by the DPDP Act (e.g., for compliance with law, to perform our contract with you, for employment-related purposes, to address medical emergencies or disasters, or for reasonable purposes notified under the law).

If you choose to use a Consent Manager (as defined under the DPDP Act), you may manage consents through such manager, and we will honour the instructions received through that channel, subject to verification.

CROSS-BORDER TRANSFERS

Your personal data may be processed outside India by our service providers or affiliates for the purposes described in this Policy. Such transfers will occur in compliance with the DPDP Act and Government notifications, including any country-specific restrictions that may be notified from time to time. We require recipients to protect your data with reasonable security safeguards and to process it only for specified purposes.

DATA RETENTION

We retain personal data only for as long as necessary to:

• provide the Services and manage your relationship with us;
• meet legal, regulatory, tax, accounting, insurance, and audit requirements; and
• resolve disputes and enforce our agreements. Retention periods vary by data category and context (e.g., account identifiers, KYC records, transaction/booking logs, communications).

When retention is no longer required, we will delete or irreversibly anonymise the data, subject to technical limitations and routine backup constraints.

If you request deletion, we will honour it in accordance with Applicable Laws and our legitimate business needs (for example, we may retain some records if required by law or for the establishment, exercise, or defence of legal claims).

SECURITY MEASURES & BREACH NOTIFICATION

We implement reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. While no system is completely secure, we continuously work to enhance our safeguards. If we become aware of a personal data breach that is likely to cause significant harm, we will notify the competent authority and, where required, affected users in accordance with the DPDP Act.

YOUR RIGHTS UNDER THE DPDP ACT, 2023

Subject to Applicable Laws, you have the following rights with respect to your personal data:

• Right to Access: To obtain a summary of your personal data and processing activities.
• Right to Correction and Erasure: To request correction, completion, updating, or deletion of personal data that is inaccurate, incomplete, or no longer necessary for the stated purpose.
• Right to Grievance Redressal: To raise a complaint with us and seek timely resolution.
• Right to Nominate: To nominate another individual to exercise your rights in the event of death or incapacity, in accordance with the DPDP Act.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time; this will not affect processing already carried out lawfully prior to withdrawal.

You may exercise these rights by contacting us. We may seek reasonable information to verify your identity and request, and we will respond within timelines required by law.

DEVICE PERMISSIONS

The app may request permissions such as Location (to find users, driver partners, vehicles and provide navigation/safety features), Camera/Photos for partners (to upload KYC documents and selfie style photos to start and end the ride), Camera/Photos for users (to upload/update profile picture in their user app), Notifications (to send service alerts), and Storage (to cache content). You can change these permissions in your device settings; some features may not function without the relevant permissions.

CHILDREN'S PRIVACY

Our Services are intended for adults. You must be at least 18 years old to create an account or use the Ritzy Platform to book or provide chauffeur/driver services. We do not knowingly collect personal data from children. If you believe a minor has provided data to us, please contact us so we can delete it or take appropriate action. Where Applicable Laws require parental consent for certain processing, we will obtain and verify such consent as needed.

CHANGES TO THIS POLICY

We may revise this Policy from time to time to reflect changes in our information practices. Updates take effect when posted on the Ritzy Platform. If we make material changes, we will notify you via email (to the address in your account) or by an in-app notice before the change becomes effective. Your continued use of the Ritzy Platform or Services after the effective date signifies your acceptance of the updated Policy.

GRIEVANCE REDRESSAL

In accordance with the Information Technology Act, 2000 and the rules framed thereunder, the Company has designated a Grievance Officer to address any complaints, concerns, or grievances relating to this Privacy Policy, the processing of your Personal/Protected Information, or any content or data-related issues on the Platform.

You may submit your grievance in writing or through an email signed with an electronic signature to the Grievance Officer at the details provided below. Upon receipt of such grievance, the Company shall acknowledge the complaint and take all reasonable steps to address and resolve the matter within the time frames prescribed under applicable law.