Privacy Policy

We at Valuedrive Technologies Private Limited recognise the importance of maintaining our end users’
privacy. We value your privacy and appreciate the trust you place in us. As used in this Policy, Spinny
Connect Application means and refers to Company’s Mobile Application (app format) known as ‘Spinny
Connect’ and which enables users to benefit of the connected car features like live location, live
notifications, vehicle health reports, among other things.
This Privacy Policy explains how we, Valuedrive Technologies Private Limited with our registered office
at 801, Vipul Square, Sector 43, Sushant Lok 1, Gurugram, Haryana, 122002 (hereinafter “Spinny
Connect/Company”) collect and process your personal information by describing (i) the type of
information we may collect when you install, subscribe to, access, and/or use the features of Spinny
Connect Application; (ii) the type of information we may collect or that you may provide when any
advertisement or survey campaign is displayed by Company on Spinny Connect Application or as part
of your interaction with such advertisement by Company; (iii) how we use that information, and the
purposes for which we collect it; and (iv) how we disclose such information.
By installing, subscribing to, accessing or using the Spinny Connect, you agree to this Policy. As used in
this Policy, Spinny Connect means and refers to Company’s mobile application (app format) known as
‘Spinny Connect’ and which enables users to benefit of the connected car features like live location, live
notifications, vehicle health reports, among others. Spinny Connect is intended for all persons who are
interested to get all the information about the vehicles. We may request access or permission to certain
features from your mobile device, and other features. The data is gathered through the Spinny Connect
device (an OBD2 telematics devices) which is installed in the car. The device collects the data and makes
all the required information available to the user. To avail the access to data, the user permits the company to install and collect the data from the vehicle and thereby present it on the Spinny Connect application.
For smooth interaction with the app, we may request access or permission to certain features from your
mobile device, and other features. This Policy applies only to information we obtain from you through the
Spinny Application. It does not apply to information that we may obtain from sources other than Spinny
Connect Application who provide your information based on their privacy policies and your interaction
with their offerings. Spinny Connect may also be permitted to collect certain information about you from
the websites, applications, channels, services or landing pages (“Sites”) which you may access through
Spinny Connects Application by the provider/owner of such Sites, in which case, we will treat such
information in accordance with the privacy policies of such Sites in addition to this Policy, subject to the
terms of the former. This Policy does not apply to websites or landing pages you may access through the
Spinny Application or your direct interaction with any third party including an advertiser even if you
engage with any specific advertisement through the Spinny Connect, nor does it apply to information that
you provide to or that is collected by any third party. We encourage you to read any such third-party terms, conditions, policies, notices etc. before providing information on or to such third parties including Sites.

Spinny Connect , which has been made available as a pre-loaded feature or widget within an application
or on a smart device, please note that, the provider of the device may incorporate relevant terms of this
policy within their own privacy policies or provide for a different version of the Spinny Connect
application privacy policy and make the same available to you. Please refer to the settings page of
your smart device, or the terms of use of the application in which company is bundled to find the relevant
privacy policy.
Information we collect and how we collect it
We collect information from and about users of our Spinny Connect as stated herein.
Information you provide to us with prompts.
If you elect to install, launch, access and/or use the Spinny Connect application, we will ask you to provide
certain information to create your account such as name, email ID, telephone number, age and gender and other preferences. You may also provide Spinny Connect with additional information such as
content/category preferences, location, areas of interest, language, region preferences etc. in order to
customize the experience for you. Spinny Connect is meant for general audience and is not targeted
towards users below 18 years of age, therefore, we do not knowingly request access to, collect or process
personal information of any such user. We presume that you are agreeable and are competent to enter into this Agreement with us post perusal and acceptance of these terms.
Other Information we collect without prompts
When you access, and use the Spinny Connect application including when you view any advertisement
displayed there, the Spinny Connect may collect: Spinny Connect usage details. Details of your access
to and use of Spinny Connect, including interaction data, logs of access and usage, and other
performance data and the resources that you access and use on or through the Spinny Connect
application.
Location Information: The Spinny Connect application collects information about the location of your smart device if you permit. You can choose whether or not to allow Spinny Connect to collect information about your device's location by turning off the location settings on your device. If you block the use of location information, some parts of Spinny Connect may then be inaccessible or not function properly.
Third-Party Information Collection: When you use Spinny Connect or its content, certain third parties
may use automatic information collection technologies to collect information about you or your device.
How your information is used:
>you provide, to (collectively referred to as “Permitted Purposes”):
>as location-based events, featured stories, offers and any other content;
>Notify you about your subscription to the Spinny Connect, including expiration and renewal notices;
>Notify you any relevant Spinny Connect updates or upgrades are available and requires notification;
>Improve our customer services and account maintenance including to detect, deter and prevent fraud,
fraudulent traffic or to protect the security of our systems;
>Make disclosures in the event of a merger, sale, or other asset transfers, or other relevant corporate
transactions. If we are involved in a merger, acquisition, financing due diligence, reorganization,
bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then
your information may be sold or transferred as part of such a transaction, as permitted by law.
If you decide to opt-in to our mailing list, you will receive emails that may include Company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, please follow the detailed unsubscribe instructions at the bottom of each email or you may contact us via our Spinny Connect customer support handle at [•]
Disclosure of your information for Permitted Purpose
We may disclose aggregated information about our users, and information that does not identify any
individual or device. We may also disclose information that we collect, or you provide:
>To our key shareholders, board, investors (debt or equity) and Affiliates. Affiliates may use the
information for the permitted purposes set out herein;
>Partners. We may share your data with our Ad Partners, vendors, customers, data partners,
measurement companies, and other third parties we partner with for providing our products and
services;
>Legal Disclosures. We may access, preserve, and disclose any information we store associated with you
to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law
enforcement or national security requests and legal process, such as a court order or subpoena; protect
your, our or others’ rights, property, or safety, enforce our policies or contracts; collect amounts owed
to us; or assist with an investigation or prosecution of suspected or actual illegal activity;
>You acknowledge that some of the recipients of your information may be located outside your country
of residence. Where we transfer your information to such third parties, we will endeavour to ensure
that your information remains theft. To the extent required under data privacy laws of the applicable
jurisdiction, we may transfer such information pursuant to consent or through applicable data
protection agreements or other mechanisms permitted under such laws.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the information you provide to us. You may elect to
disable, uninstall or unsubscribe from the Spinny Connect Application.
Location data collection: You may opt out of the location data collection by Spinny Connect Application by turning off the location settings on your device. Note, however, that opting out of the Spinny Connect
Application’s collection of location information will cause its location-based features to be disabled. Spinny Connect Application may read your location on city level from your cellular network to enhance your experience and the content we serve you. This city level location data is solely used by our recommendation engine to serve you content.
Data Security
We have implemented suitable technical and organizational measures to secure your personal information in compliance with our legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, the transmission of information via the internet and mobile platforms is not
completely secure. Data Retention Period Company may retain the information relating to your device collected for undefined period, unless otherwise required by law or applicable contract.
Company may retain the information it obtains about you as per the instructions of its customers or
partners who provide such information or as required to fulfil our contractual obligations. In case any
information is provided by you in participation of a survey, Company will only retain your personal data
for as long as necessary to fulfil the purposes it collected the information for.
After the applicable retention period, Company may retain and use such data in an aggregated format, as
necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including
billing) and enforce agreements.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make any material changes, we will notify you
by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy
regularly to ensure you have read the latest version.
Contact Information
To ask questions, exercise applicable data subject rights or comment about this Policy and our privacy
practices, please e-mail us at [•]
To the extent you may enjoy any data subject rights as per privacy laws applicable to you, you may reach
out to [•]
Order of Prevalence:
Subject to applicable laws, the English language version of this Policy will prevail over any other language
version issued by us for your benefit.