Privacy Policy

SECTION 1 – PURPOSE

This Data Privacy and Data Protection describes how GaragePlug collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our applications

SECTION 2 – DATA PRIVACY AND DATA PROTECTION POLICY

By accessing this application and/or by availing any of the services, you agree to the terms of this Data Privacy and Data Protection Policy.

CONTENTS

1. Terms used in this policy

2. Our commitment towards protecting personal information

3. What data do we collect about you, and for what purpose?

4. Whom do we share your data with?

5. How long do we retain your data?

6. What are your rights regarding your data with us?

7. Contact us

1. Terms Used In This Policy

In this Data Privacy and Data Protection Policy:

• “GDPR” means the EU General Data Protection Regulation.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Policy” means this Data Privacy and Data Protection Policy.
• “Service” refers to a service that GaragePlug’ provides, for a fee or gratis. You are using our Service when you actively sign up or sign in to get access to any Service provided by us.
• “we”, “us”, “our”, and “GaragePlug” refer to GaragePlug (India) Inc.
• “application” refers to GaragePlug’ application. You are using our “application” when you are visiting our application
• “you” refers to you, as a user or subscriber of the services provided by us.

2. Our Commitment Towards Protecting Personal Information

Your privacy is important to us. We will use your personal information only in the manner set out in this Policy. We act in accordance with the applicable data protection laws, including GDPR. We are committed to safeguarding the privacy of our application visitors, clients, prospects, and research participants. This Policy sets out how we deal with your personal information.

Our commitment towards protecting your personal information includes the following obligations:

• We promise to protect your privacy and treat the information you give us as confidential.
• The information you provide to us will be used by us only for the purpose for which it was sought.
• We will not release your personal information to any third party without your consent.
• We will never try to sell you anything and we will never sell your personal data to anyone.
• Your decision to provide or not to provide any information will be respected without question.

3. What Data Do We Collect Or Process About You, And For What Purpose?

• We may process data about your use of our application and services (“usage data”).

The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, as well as information about the timing, frequency and pattern of your Service use. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analysing the use of the application and Services in order to improve our performance metrics, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving our application and Services.

• We may process your data that is provided to us during the course of application use (“response data”).

The response data may include your name, area of residence, email address, your responses to the questions that we may ask you. The source of the response data is you. The response data may be processed for the purposes of providing our services, ensuring the integrity of our operations and processes, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent.

• We may process your information included in your personal profile on our application (“profile data”).

The profile data may include your name, address, telephone number, email address and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our application and services and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our application and Services.

• We may process your personal data that are provided in the course of the use of our Services (“service data”).

The service data may include your name, address, telephone number, email address. The source of the service data is you or your customers. The service data may be processed for the purposes of providing our Services, ensuring the security of our application and Services, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our application and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

• We may process information relating to our customer relationships, including customer contact information (“customer relationship data”).

The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, promoting our products and services to customers, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our application and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”).

The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.

• We may process information contained in or relating to any communication that you send to us (“correspondence data”).

The correspondence data may include the communication content and metadata associated with the communication. Our application will generate the metadata associated with communications made using the application contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our application and business and communications with our business counterparts.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:

• The establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this process is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• The purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• Compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. Whom Do We Share Your Data With?

• We may disclose your personal data to any of our employees, officers, and agents as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to any member of our group of companies (this means our ultimate holding company and all its subsidiaries and joint venture partners) as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to our insurers and professional advisers as long as such disclosure is reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• We may disclose your personal data to our suppliers or subcontractors as long as such disclosure is reasonably necessary for providing Services to you.
• Financial transactions relating to our application and Services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
• In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We will not sell, share, rent or otherwise intentionally transfer your name, address, telephone number or e-mail address to market research companies, direct marketing companies or anyone else. The only exceptions when we may disclose your personal information to third parties are as follows:

• You request us to share, or consent to us sharing, your data with the third parties for a specified purpose
• We provide your responses to a third party who is contractually bound to keep the information confidential and use it only for research or statistical purposes
• In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements.

5. How Long Do We Retain Your Data?

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

• Usage data will be retained for a minimum period of one month, and for a maximum period of 1 years following the date of your visit.
• Response data will be retained for a minimum period of one month following the submission of your response, and for a maximum period of ten years following the submission of your response.
• Profile data will be retained for a minimum period of one day following the date of deletion of your profile on our application, and for a maximum period of ten years following such deletion.
• Service data will be retained for a minimum period of one month following the fulfilment of the Service, and for a maximum period of ten years following the last date on which any obligation in respect of such Service concludes.
• Customer relationship data will be retained for a minimum period of one month following the conclusion of the said relationship, and for a maximum period of ten years following the conclusion of the said relationship.
• Notification data will be retained for a minimum period of one day following the date of unsubscribing from our newsletters, and for a maximum period of ten years following the date of request for such unsubscribing.
• Correspondence data will be retained for a minimum period of one day following the date of the communication, and for a maximum period of twenty years following the date of the communication.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

Not with standing the foregoing provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. What Are Your Rights Regarding Your Data With Us?

This Section summarises the rights that you have under data protection law. Please note that some of the rights available to you are convoluted and may not be represented in detail in this Policy. We advise you to peruse the relevant laws for a complete understanding of your rights. Your principal rights concerning your Personal Data under GDPR are as below:

• Right to access:You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

Subject to the condition that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data with us, by emailing us on support@garageplug.com.

• Right to rectification:You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.


• Right to erasure:In certain circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data provided to us is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

• Right to restrict processing:In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you do not desire erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.


• Right to object to processing:You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

• Right to data portability:To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.


• Right to complain to a supervisory authority:If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.


• Right to withdraw consent:To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by a written notice to us on support@garageplug.com. In order for us to comply with your request, your notice must clearly state the right that you wish to exercise and identify your information in respect of which you wish to exercise such right. Please note that as a security measure, we may require you to verify your identity before accepting any request concerning your Personal Data.

7. CONTACT US

• This application is owned and operated by the GaragePlug team.
• You can contact us (a) by email: on support@garageplug.com; (b) by telephone: on the contact number published on our application from time to time;



For additional information, please refer to our:

• Privacy Policy

SECTION 3 – RELATIONSHIP WITH EXISTING POLICIES

This policy forms part of the Information Security Management Framework. It should be read in conjunction with the Information Security Policy and all supporting policies.

SECTION 4 – POLICY REVIEW

GaragePlug Policies shall be reviewed at least once annually to reflect changes to Business environment, landscape and improvements considered at various phases of implementation and practices.

It is the responsibility of the Information Technology Function to facilitate the review of this policy on a regular basis. Personnel and Department Head from relevant departments should also participate in the annual review of this policy.

Deficiencies within this policy should be immediately communicated to the Information Technology Function. Policy changes should require the approval of Management.

Change log should be kept current and should be updated as soon as any change has been made

SECTION 5 – DEVIATIONS AND EXCEPTIONS

There shall be a business case represented to GaragePlug Management Leaders for a formal approval on the deviations of policies and describing challenges.

SECTION 6 – NON COMPLIANCE TO POLICY

Failure to comply with this policy by violating the policies set forth in this document may lead to disciplinary action up to and including termination

SECTION 7 – ENFORCEMENT

Necessary disciplinary action will be taken against any employee not following the policies and procedures laid down by GaragePlug Similarly, action will be taken against those employees encouraging/observing such an activity and not reporting the same to the concerned authority.

Any user found to have violated this policy may be subject to disciplinary action, including but not limited to:

• Account suspension
• Revocation of device access to GaragePlug System
• Data removal from the device
• Employee termination

APPENDIX