Privacy Policy

1 Introduction

This Privacy Policy (“Policy”) applies specifically to Zingbus Driver App and describes how Gozing Technologies Pvt Ltd (which operates the Zingbus brand and platform; “Zingbus”, “Company”, “we”, “our”, or “us”) collects, uses, stores, shares, and protects information of the Zingbus Driver App’s user (“Driver”, “User”, or “you”, or “your”) who downloads, installs and registers itself or use the Zingbus Driver application (“Driver App”) in furtherance to Vendor Agreement between the Cab Service Providers / Cab Owners with the Zingbus to provide first mile and last mile passenger pickup and drop services in connection with bookings made by passengers on the Zingbus platform on such terms and conditions as detailed in the Vendor Agreement.

By downloading, installing, registering on, or using the Driver App, you acknowledge that you have read, explained by and understood this Policy and consent to the collection, use, storage, disclosure, and processing of your information in the manner described here. If you do not agree with this Policy, you should not register on or use the Driver App.

This Policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023 (“DPDP Act”), and other applicable Indian data protection laws.

2 Scope and Applicability

This Policy applies to all Drivers who use the Driver App in furtherance to cab service provider Agreement between the Vendor and the Zingbus, including independent driver-partners, drivers employed by fleet operators or vendors associated with Zingbus, who accesses the Driver App for the purpose of providing first mile or last mile cab services as per the said Agreement. It covers all information collected through the Driver App, related websites, customer support interactions, and any other Zingbus channels used in connection with driver onboarding and operations.

This Policy does not apply to: (a) third-party applications, websites, or services that may be linked from the Driver App; (b) the Zingbus passenger-facing application, which is governed by a separate privacy policy; or (c) information you choose to share publicly outside the Driver App.

3 Information We Collect

We collect information necessary to verify your identity, dispatch trips to you, enable safe pickups and drops, location assessment and analysis, comply with the law, and continuously improve the service.

3.1 Identity, Verification and Onboarding Information

• Full name, father’s/spouse’s name, date of birth, gender, and photograph.
• Mobile number, email address, residential address, and emergency contact details.
• Government-issued identity and verification documents, including valid driving licence, Aadhaar (in masked form to the extent permitted), PAN, voter ID, passport, and police verification certificates, where applicable.
• Selfie or live photograph for facial verification at onboarding and for periodic re-verification or trip-start checks.
• Educational, employment, or training history if you choose to provide it during onboarding.

3.2 Vehicle and Permit Information

• Vehicle registration number, make, model, year of manufacture, fuel type, colour, seating capacity, and vehicle photographs.
• Registration Certificate (RC), commercial permit, fitness certificate, Pollution Under Control (PUC) certificate, motor insurance details, and tax records.
• Ownership status of the vehicle and details of the registered owner (if different from you).

3.3 Location Information

Location data is essential to providing first mile and last mile services. With your consent, we collect precise (GPS) and approximate (cell tower / Wi-Fi) location information from your device, including:

• Continuous, real-time location while you are logged in and marked “online”, “available”, or “on-duty” in the Driver App, even when the App is running in the background.
• Location at the start, during, and end of each assigned trip, including pickup and drop coordinates, route taken, distance travelled, halts, and idle time.
• Location accessed for limited periods around the start of a duty shift, near a scheduled bus departure or arrival, or when you receive a trip request, to confirm proximity to the boarding point.

You can disable background location collection through your device settings; however, doing so may prevent us from assigning trips to you and may impact your ability to use the Driver App.

3.4 Trip and Performance Information

• Trip identifiers, pickup and drop addresses, scheduled and actual timings, status of each trip (accepted, started, completed, cancelled, no-show), and reason for cancellation if applicable.
• Distance travelled, duration of trip and route adjustments.
• Driving behaviour signals such as speed, acceleration, braking, cornering, and adherence to assigned routes, where collected through the Driver App or paired telematics devices.
• Ratings, reviews, complaints, and feedback received from passengers, Zingbus operations staff, and other drivers.

3.5 Device, Network and Technical Information

• Device model, manufacturer, operating system and version, unique device identifiers, advertising identifiers, mobile network operator, IP address, and time zone.
• App version, crash reports, diagnostics, performance logs, and information about other Zingbus-approved applications running on the device that are necessary for the Driver App to function.
• Battery level, signal strength, connectivity status, and network type, used to optimise dispatch and prevent service disruption.

3.6 Communications and Support Information

• Records of in-app chat, calls (including masked or proxy calls between you and passengers or operations staff), SMS, and email correspondence with Zingbus.
• Audio recordings of calls made to or from our support centre for training, quality assurance, dispute resolution, and safety purposes, where permitted by law and after appropriate notice.
• Information you submit through grievance, dispute, or feedback channels.

3.7 Safety and Audio/Video Information

• Where the Driver App or a paired in-vehicle device captures audio or video for safety, fraud prevention, or training purposes, we collect such recordings only after providing notice to you (and, where applicable, to passengers) and in accordance with applicable law.
• Information related to safety incidents, accidents, complaints, or investigations involving you, your vehicle, or a trip.

3.8 Information from Third Parties

• Background verification agencies, who confirm the validity of your identity, address, criminal records, and driving history.
• Government databases and authorised verification services (such as DigiLocker or RTO portals) used to validate your driving licence, RC, PAN, or other documents.
• Fleet operators, vendors, or sub-contractors that engage you and share information with us in connection with your onboarding and engagement.
• Insurance providers, and other partners who share information necessary to provide insurance cover, incidence reports, or settle insurance claims.

4 Children’s Information

The Driver App is intended only for individuals who are at least 18 years old and who hold a valid commercial driving licence under Indian law. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will take reasonable steps to delete it.

5 How We Use Your Information

We use your information for the following purposes:

5.1 Onboarding, Verification and Account Management

• To verify your identity, eligibility, and credentials, including running background and document checks.
• To create and manage your driver account, including maintaining records of training, certifications, and ratings.
• To enable secure log-in, password recovery, and two-factor authentication.

5.2 Trip Dispatch, Pickup and Drop Operations

• To match you with first mile / last mile pickup and drop requests based on your location, vehicle type, and availability.
• To share your real-time location, vehicle details, and arrival estimates with the assigned passenger, the operations team, and (where relevant) the bus crew at the boarding point.
• To provide turn-by-turn navigation, traffic information, and optimal routing.
• To enable masked or proxy communication between you and the passenger so that personal phone numbers are not exposed.

5.3 Invoicing and Tax Compliance

• To calculate and disburse trip summary on periodic basis as detailed in the last mile service Agreement.
• To assist the Vendor in generating invoices, statements based on the trip details collected through the App.

5.4 Safety, Security and Fraud Prevention

• To monitor trips for safety, including detecting unusual stops, deviations from the assigned route, prolonged idling, or potential incidents.
• To investigate complaints, accidents, and disputes, and to respond to emergencies.
• To detect, prevent, and act upon fraudulent or abusive activity, identity theft, account takeover, and policy violations.
• To enforce our terms of service, driver code of conduct, and applicable laws.

5.5 Customer and Driver Support

• To respond to your questions, complaints, or grievances, and to those raised by passengers about your trips.
• To provide training, coaching, and feedback that improves service quality.

5.6 Analytics, Research and Service Improvement

• To analyse usage trends, demand patterns, route performance, and service quality.
• To improve our matching algorithms, ETA models.
• To conduct internal research; where used for research and analytics, information is, wherever feasible, aggregated or de-identified.

5.7 Legal, Regulatory and Compliance

• To comply with applicable laws, regulations, court orders, and lawful requests from government, regulatory, or law enforcement authorities.
• To establish, exercise, or defend legal claims, and to enforce contracts.
• To meet record-keeping and audit obligations under transport and motor vehicle laws.

5.8 Communications and Promotions

• To send you operational notifications relating to trips, document expiry, training, and policy updates.
• To inform you about new features, and promotions, where you have opted in to receive such communications. You may opt out of marketing communications at any time without affecting essential operational messages.

6 Legal Basis for Processing

We process your personal data on one or more of the following lawful bases under the DPDP Act and other applicable laws:

• Your consent, obtained at the time of onboarding and, where required, at the time of enabling specific features (such as background location, camera, microphone, or notifications).
• Performance of the contract or terms governing your engagement with Zingbus.
• Compliance with legal obligations, including transport, motor vehicle, and law enforcement requirements.
• Legitimate uses, such as preventing fraud, ensuring information security, responding to safety incidents, and protecting our rights and the rights of passengers and other drivers.

7 Sharing and Disclosure of Information

We do not sell your personal information. We share information only as described below.

7.1 Passengers and Bus Crew

Your name, photograph, vehicle details, ratings, and real-time location and ETA are shared with the assigned passenger and, where applicable, with the Zingbus bus crew or station staff so that the pickup or drop can be coordinated safely. Personal contact numbers are not shared in plain form. Communication between you and the passenger is enabled through masking or in-app channels.

7.2 Fleet Operators, Vendors and Aggregators

Where you are engaged through a fleet operator, vendor, or aggregator, we share trip performance with that operator as required for engagement and settlement.

7.3 Insurance, Safety and Emergency Partners

In the event of an accident, safety incident, or emergency, we may share relevant information with insurance providers, hospitals, the police, road safety authorities, and emergency contacts you have provided.

7.4 Government, Regulatory and Law Enforcement Authorities

We disclose information to government, regulatory, and law enforcement authorities when required by law, by valid legal process, or where we believe in good faith that disclosure is necessary to protect our rights, the safety of any person, or the integrity of the platform.

7.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, financing, or sale of all or part of our business, your information may be transferred to the relevant counterparties subject to confidentiality obligations and applicable law.

7.6 With Your Consent

We may share information for any other purpose disclosed to you and to which you specifically consent.

8 Cookies, SDKs and Similar Technologies

The Driver App uses software development kits (SDKs), beacons, and similar technologies for analytics, crash reporting, push notifications, fraud prevention, and routing. These tools may collect device and usage information automatically. Where these technologies are used for non-essential purposes, we will seek your consent or provide you with controls in your device or app settings.

9 Data Storage, Transfer and Retention

• Your information is primarily stored on servers and cloud infrastructure located in India. Where information is transferred outside India, we transfer it only to jurisdictions and recipients that satisfy the requirements of applicable Indian law and only to the extent permitted by the Central Government under the DPDP Act.
• We retain your personal information for as long as necessary to provide services to you and to comply with our legal, regulatory, accounting, dispute resolution, and contractual obligations.
• Trip records and verification documents are typically retained for the period required by motor vehicle, and other applicable laws (which may extend up to 8 years or longer for certain categories of records).
• Where information is no longer required, it is securely deleted, anonymised, or archived in line with our data retention policy.
• Your information may also be deleted in case we find them incorrect or irrelevant or at your instance if requested in writing.

10 Information Security

We implement reasonable security practices and procedures, including encryption in transit, access controls, role-based permissions, audit logging, secure development practices, vulnerability management, and periodic security reviews, that are appropriate to the nature, scope, and sensitivity of the information we hold. While we strive to protect your information, no method of transmission or storage is fully secure, and we cannot guarantee absolute security.

You are responsible for keeping your account credentials, OTPs, and device safe, and for promptly notifying us of any suspected unauthorised access or compromise of your account.

11 Your Rights

Subject to applicable law, you have the following rights with respect to your personal information:

• Right to access a summary of the personal data we process about you and the activities for which it is used.
• Right to request correction or updating of inaccurate, incomplete, or outdated information.
• Right to request erasure of your personal data, subject to retention obligations under applicable law and our legitimate need to retain certain records.
• Right to withdraw consent for processing that is based on consent, at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal and may impact your ability to continue using the Driver App.
• Right to nominate another individual to exercise your rights in the event of your death or incapacity, in the manner notified under the DPDP Act.
• Right to grievance redressal as set out in Section 14.

You can exercise most of these rights directly from the Driver App settings or by contacting our Grievance Officer using the details in Section 14.

12 Your Choices and Controls

• Permissions: You can control access to location, camera, microphone, contacts, storage, and notifications through your device settings. Disabling certain permissions may impair core features such as receiving trip requests.
• Marketing communications: You can opt out of promotional messages through in-app settings or by following the unsubscribe instructions in the relevant message.
• Account closure: You may request closure of your driver account at any time, subject to settlement of dues and statutory retention requirements.
• Account Deletion: In case any of your information is found fake, or incorrect or you have been found engaged in any activity detrimental to Zingbus or its passengers or you have been found engaged in any act of moral turpitude, or asked by a law enforcement agency, your account may be either suspended or deleted as the case may be and you will be informed of such action in a timely manner.

13 Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you through the Driver App, by email, or by other reasonable means before the changes take effect. Your continued use of the Driver App after the effective date of the updated Policy constitutes acceptance of the changes.

14 Grievance Officer and Contact Details

In accordance with the Information Technology Act, 2000, the rules made thereunder, and the DPDP Act, 2023, the contact details of our Grievance Officer / Data Protection Officer are set out below. We will acknowledge complaints within the timelines required by law and endeavour to resolve them as soon as reasonably possible.

15 Governing Law and Jurisdiction

This Policy is governed by the laws of India. Any dispute arising out of or in connection with this Policy or your use of the Driver App shall be subject to the exclusive jurisdiction of the competent courts at Gurgaon, Haryana, India. Any dispute arising out of the use of this Driver App shall be settled by arbitration by sole arbitrator who shall be appointed mutually by the Parties or appointed as per the provisions of the Arbitration and Conciliation Act. The Seat of Arbitration shall be at Delhi and the language of arbitration shall be English.