PRIVACY POLICY

Chargingo is operated by Pryolt Private Limited, a company incorporated under the Companies Act, 2013, bearing CIN U77309RJ2025PTC104622, with its registered office at 376, Surana Bhawan, Hanuman Ji Ka Rasta, Jaipur, Rajasthan - 302003, India (hereinafter alternatively referred to as "Company", "Chargingo", "we", "us", or "our"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what personal information we collect, when and how we collect it, how we use and protect it, and the rights available to you in respect of such information.

This Privacy Policy applies to all visitors, registered Users, and other individuals (hereinafter alternatively referred to as "you", "User", or "Data Principal") who access or use the Chargingo website (www.chargingo.in), mobile application, self-service charging kiosks, and related services (collectively referred to as the "Platform"), and to anyone who contacts us through our communication channels. This Privacy Policy should be read together with the Company's Terms & Conditions.

By visiting the Platform, creating an Account, initiating a rental, making a payment, or otherwise engaging with the Services, you provide your free, specific, informed, and unambiguous consent to the practices described in this Privacy Policy, to the extent such consent is required under applicable law.

This Policy is intended to comply with applicable Indian law, including the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (hereinafter referred to as the "DPDP Act"), to the extent applicable.

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ABOUT US

1. Chargingo is a technology-driven power bank rental and smart advertising platform operated by Pryolt Private Limited. Through a network of self-service charging kiosks located at cafes, restaurants, lounges, co-working spaces, educational institutions, and other high-footfall venues, Users can rent portable power banks, charge their devices, and return them through a compatible kiosk.
2. In addition to providing charging solutions, Chargingo also operates a smart advertising network enabling brands to engage with consumers through digital displays across the kiosk network.
3. Our mission is to make device charging convenient, accessible, and reliable, while creating value for Users, venue partners, and advertisers through technology.

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DEFINITIONS

In these Terms, unless the context otherwise requires, the following expressions shall have the meanings set out below, and general principles of interpretation set out at the end of this Article shall apply:

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INFORMATION WE COLLECT

1. Information you provide directly: We collect information that you voluntarily provide, including:
   1. your name, mobile number, email address, and other Account registration details;
   2. information relating to your payment instrument (such as the type of instrument and masked or tokenised references) required to initiate a Payment Mandate and process rental transactions and refunds;
   3. information provided when you contact customer support, submit feedback, reviews, ratings, complaints, or participate in surveys or promotions; and
   4. any other information you choose to provide while using the Services.
2. Information collected automatically: When you access the Platform or use a kiosk, we automatically collect:
   1. device information, such as device type, manufacturer, model, operating system, and device identifiers;
   2. network information, such as IP address, mobile carrier, and connection type;
   3. usage data, such as pages visited, session duration, and click patterns;
   4. location information, including approximate location derived from your IP address and precise location where you have granted the relevant permission;
   5. information relating to Kiosk and Power Bank usage, including the Kiosk location, rental and return time, Power Bank identification details, transaction records, charging status, and the battery percentage or battery level of the Power Bank during the Rental Period; and
   6. information collected through cookies and similar technologies, as described in Article 7.
3. Information received from third parties: We may receive information from third-party service providers and business partners, including payment processors, payment service providers and banks (in connection with the Payment Mandate), analytics providers, authentication services, advertising partners, and Partner Venues, to facilitate the Services, verify transactions, improve platform functionality, and maintain operational efficiency.

LEGAL BASIS FOR PROCESSING

1. We process your personal data primarily on the basis of your free, specific, informed, and unambiguous consent, given at the time you create an Account, initiate a rental, complete a Payment Mandate, or otherwise interact with the Platform.
2. Where permitted under Section 7 of the DPDP Act, we may process certain personal data without separate consent for specified legitimate uses, including:
   1. the specified purpose for which you have voluntarily provided personal data and have not indicated that you do not consent to its use;
   2. compliance with any judgment, decree, or order issued under Indian law, or any law relating to contracts;
   3. responding to a medical emergency involving a threat to life or health; and
   4. such other legitimate uses as may be recognised under applicable law from time to time.
3. You may withdraw your consent at any time, to the extent processing is based on consent, in accordance with Article 11. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal, and may affect our ability to provide certain Services to you, including the ability to process rentals or Payment Mandates.

HOW WE USE YOUR INFORMATION

1. We use personal information for legitimate business, operational, contractual, security, customer support, and legal compliance purposes connected with the Services, including to:
   1. create and manage your Account;
   2. facilitate Power Bank rentals, returns, and related transactions;
   3. initiate, process, and reconcile the Payment Mandate, and process rental charges, refunds, and other applicable payments;
   4. communicate with you regarding your Account, rentals, Payment Mandate status, support requests, and service updates;
   5. monitor and improve the performance, security, and reliability of the Platform and kiosk network;
   6. analyse usage trends and Service performance;
   7. monitor the charging status, battery percentage, battery health, usage status and operational performance of Power Banks for rental management, maintenance, safety, inventory management, troubleshooting and service improvement purposes;
   8. prevent fraud, misuse, and unauthorised activity, including in relation to the Payment Mandate and rental transactions;
   9. operate and measure the effectiveness of advertising and promotional campaigns;
   10. comply with legal and regulatory obligations; and
   11. protect the rights, safety, and legitimate interests of the Company, Users, and business partners.
2. The Company may share, disclose, license, transfer, monetise or otherwise make Personal Data available to third parties, including for advertising, marketing, analytics, business-development or commercial purposes, where permitted under Applicable Law and, where required, after obtaining the User's consent. The nature of the information shared, the identity or category of the recipient, and the purpose of such sharing shall be governed by this Privacy Policy, any consent or notice presented to the User, and Applicable Law.

PAYMENT PROCESSING, PAYMENT MANDATE AND SECURITY

1. Nature of the Payment Mandate: To initiate a Power Bank rental, the Company facilitates a one-time, pre-authorised payment mandate of ₹1,000 (or such other amount as may be notified on the Platform) through your chosen payment method, as described in the Terms & Conditions. This amount is blocked or held by your issuing bank or payment service provider and is not debited at the time of initiation.
2. Information we collect in connection with the Payment Mandate: In connection with the Payment Mandate and rental payments, we may collect and maintain limited transaction-related information, such as the payment method selected, mandate initiation and approval status, mandate reference and transaction identifiers, timestamps of dispensing and return, the actual rental charges levied, and confirmation of release of the unutilised Payment Mandate Amount by your bank/PSP.
3. No storage of sensitive payment credentials: All payment transactions, including the Payment Mandate, are processed through authorised third-party payment gateways and payment service providers. Chargingo does not store complete debit card, credit card, net banking, UPI PIN, CVV, or other sensitive payment credentials on its own servers, except to the limited extent expressly permitted under applicable law and industry standards, such as tokenised references.
4. Third-Party processing: The release of the unutilised portion of the Payment Mandate Amount is performed by your issuing bank/PSP and is governed by their own systems, policies, and processing timelines, and their respective privacy and security practices, over which the Company has no control.
5. Security measures: We implement reasonable technical and organisational safeguards to protect payment-related information and work with payment partners that maintain industry-standard security measures. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
6. Payment-related concerns: If you experience a failed transaction, a delay in release of the Payment Mandate Amount, an incorrect charge, a duplicate payment, or any other payment-related concern, you may contact our support team through the Platform, and we will make commercially reasonable efforts to investigate and resolve such issues in coordination with our payment service providers and banking partners.

COOKIES AND TRACKING TECHNOLOGIES

1. We use cookies and similar technologies to enhance your experience, improve the functionality of the Platform, analyse usage patterns, and maintain the security of the Services.
2. These technologies help us remember your preferences, understand how Users engage with the Services, measure the effectiveness of promotional activities, and improve overall platform performance.
3. You may disable or manage cookies through your browser or device settings; however, doing so may affect the availability or functionality of certain features of the Platform.
4. By continuing to use the Platform, you consent to our use of cookies and similar technologies in accordance with this Policy.

SHARING AND DISCLOSURE OF INFORMATION

1. The Company may share, disclose, transfer, license, monetise or otherwise make Personal Data available to third parties for purposes connected with the operation, improvement, promotion, analysis or commercial development of the Platform and the Services, where permitted under Applicable Law. Where the sharing or use of Personal Data requires the User's consent, the Company shall obtain such consent in the manner prescribed under Applicable Law.
2. We may share Personal Data with third parties that assist us in operating, maintaining, developing, securing, supporting or improving the Platform and the Services. Such third parties may include: (a) payment processors, payment gateways, banks and Payment Service Providers involved in Payment Mandates, rental payments, refunds and transaction settlement; (b) cloud-hosting, data-storage, server, cybersecurity and information-technology service providers; (c) software developers, application developers, technology consultants, maintenance providers and other persons engaged in the design, development, testing, integration, troubleshooting, updating or operation of the Platform, Kiosks, software systems or related technological infrastructure; (d) analytics, research, advertising, marketing and campaign-management partners; (e) communication service providers facilitating email, SMS, push notifications, telephone, WhatsApp or other communications; (f) customer-support platforms, AI-based support providers and service-management vendors; (g) Partner Venues, where such sharing is reasonably necessary for Kiosk operations, rental verification, return verification, complaint resolution, fraud prevention or service delivery; and (h) professional advisers, auditors, insurers, legal representatives and other consultants engaged by the Company.
3. We may also disclose information where required by law, to comply with a legal obligation or an order of a court or authority, to protect our rights and interests, to investigate fraud or security incidents (including in relation to the Payment Mandate or rental transactions), or in connection with a merger, acquisition, restructuring, or transfer of business assets.
4. Where Personal Data is shared with a service provider, software developer, contractor or other person acting on behalf of the Company, the Company shall take reasonable steps to require such recipient to process the Personal Data only for authorised purposes and to maintain appropriate confidentiality, privacy and security safeguards. However, where Personal Data is shared with an independent third party for its own purposes, such third party may process the information in accordance with its own privacy policy, terms and Applicable Law.

CROSS-BORDER DATA TRANSFERS

1. Certain information may be stored, processed, or accessed through servers, cloud infrastructure, or service providers located outside India.
2. Such transfers shall be undertaken in accordance with the DPDP Act and other applicable law, including any restrictions that the Central Government may notify from time to time in respect of transfer of personal data to specific countries or territories.
3. Where such transfers occur, the Company shall take reasonable steps to ensure that the information continues to receive a level of protection consistent with applicable law and contractual obligations.

DATA RETENTION

1. We retain personal information only for as long as necessary to provide the Services, fulfil the purposes described in this Policy, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements.
2. Transaction records, Payment Mandate records, rental history, payment information, support communications, and compliance-related records may be retained for longer periods where required by applicable law, including under the Information Technology Act, 2000 and tax and accounting laws, or legitimate business requirements, including fraud prevention and dispute resolution.
3. Where personal information is no longer required for the purposes for which it was collected, and retention is not otherwise required by law, such information shall be securely deleted, anonymised, or aggregated.

YOUR RIGHTS AS A DATA PRINCIPAL

1. Subject to applicable laws, you may:
   1. request a summary of the personal data we process about you and the processing activities undertaken;
   2. seek correction, completion, and updating of your personal data;
   3. seek erasure of personal data that is no longer necessary for the purpose for which it was processed, subject to Article 10;
   4. withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out prior to such withdrawal;
   5. nominate another individual to exercise your rights under applicable law in the event of your death or incapacity; and
   6. file a grievance with us in the manner described in Article 15, and thereafter approach the Data Protection Board of India or other competent authority, if applicable.
2. We may request reasonable verification of your identity before processing certain requests relating to personal information.
3. We reserve the right to decline or limit requests where permitted under applicable law, including where retention or processing of information is necessary for legal, regulatory, fraud prevention, security, or dispute resolution purposes.
4. Requests regarding your personal information may be submitted through the support section available within the Chargingo application. We will take reasonable steps to respond to such requests within the timelines required under applicable law.

ACCOUNT DEACTIVATION AND DELETION

1. A User may request deletion of their Account through the account settings, support section, email support, telephone support, or such other method as may be made available by the Company from time to time.
2. The Company does not presently offer a separate Account-deactivation facility. A User who no longer wishes to use the Services may request deletion of the Account.
3. Upon receiving and verifying a valid deletion request, the Company shall take reasonable steps to delete the User's Account and the Personal Data associated with it, subject to any information that the Company is required or permitted to retain under Applicable Law or for legitimate purposes, including: (a) compliance with legal, tax, accounting or regulatory obligations; (b) maintenance of transaction, rental and Payment Mandate records; (c) fraud prevention, security, investigation and enforcement; (d) resolution of disputes, complaints, claims or payment-related concerns; (e) recovery of unpaid rental charges, damage charges, the Applicable Lost Power Bank Charge or other outstanding amounts; and (f) establishment, exercise or defence of legal claims.
4. Deletion of an Account shall not affect any rights, obligations, payments, charges, claims or liabilities that arose before the Account was deleted.
5. After deletion of the Account, the User may register again and create a new Account if the User wishes to use the Services in the future, subject to the Terms & Conditions, this Privacy Policy, eligibility requirements, verification procedures and any restrictions lawfully imposed by the Company.
6. Personal Data retained after Account deletion shall be used only for the purposes for which its continued retention is required or permitted and shall be deleted, anonymised or securely disposed of when such retention is no longer necessary.

DATA SECURITY AND BREACH NOTIFICATION

1. We take reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss, or misuse, including encryption, secure servers, access controls, authentication mechanisms, and periodic security reviews.
2. In the event of a personal data breach, we shall take such steps as may be required under the DPDP Act, including intimation to the Data Protection Board of India and affected Data Principals, in the manner and within the timelines prescribed under applicable law.
3. No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. Users are encouraged to take appropriate precautions, including safeguarding login credentials, OTPs, and account access information, and to promptly notify us of any unauthorised use of their Account or other security concerns through the support features available within the Chargingo application.
4. Access to personal information is restricted to authorised personnel and service providers who require such access for legitimate business purposes.

CHILDREN'S PRIVACY

1. Under the DPDP Act, an individual below the age of 18 years is treated as a "child", and the processing of a child's personal data requires the verifiable consent of a parent or lawful guardian.
2. In accordance with the eligibility criteria set out in the Terms & Conditions, individuals between 16 and 17 years of age may use the Services only with the verifiable consent and under the supervision of a parent or legal guardian, who shall be responsible for such consent and for the child's use of the Services.
3. We do not knowingly undertake tracking or behavioural monitoring of children, or serve targeted advertisements directed at children, except to the extent permitted under applicable law.
4. If we become aware that personal data of a child has been collected without appropriate verifiable parental or guardian consent, we will take reasonable steps to delete such information and restrict further access to the Services, unless retention is otherwise required by law.
5. If you believe that a child's information has been provided to us without appropriate consent, please contact us through the support section available on the Platform.

GRIEVANCE OFFICER

1. In accordance with applicable law, including the DPDP Act and the Information Technology Act, 2000, the Company hereby designates the Grievance Officer to be contacted in case of any grievances:

2. Any grievance or complaint relating to the processing of your personal data may be addressed to the Grievance Officer, who shall endeavour to resolve the grievance within the timelines prescribed under applicable law.
3. If you are not satisfied with the resolution provided, you may approach the Data Protection Board of India or such other competent authority as may be applicable.

AUTOMATED DECISION-MAKING

1. Chargingo may use automated tools and systems to analyse usage patterns and transaction-related information for legitimate business and operational purposes, including fraud detection (including in relation to the Payment Mandate), rental verification, prevention of misuse of the Platform, operational optimisation, and service improvement.
2. Such automated processes are intended to enhance the security, reliability, and efficiency of the Services and are not used to make solely automated decisions that produce significant legal effects concerning Users, except where permitted under applicable law.

THIRD-PARTY SERVICES AND LINKS

1. The Platform may contain links to third-party websites, applications, payment gateways, or services that are not owned or controlled by Chargingo.
2. We are not responsible for the privacy practices, content, or security measures of such third parties. Users are encouraged to review the applicable privacy policies and terms of use before interacting with any third-party service.

CHANGES TO THIS PRIVACY POLICY

1. We may revise this Privacy Policy from time to time to reflect changes in our Services, legal requirements, or business practices.
2. Any updated version will be made available on the Platform and will become effective from the date specified therein. Continued use of the Services following such update constitutes acceptance of the revised Privacy Policy.

APPLICABLE LAW

1. This Privacy Policy has been prepared in accordance with applicable Indian law, including 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, and any rules, regulations, or guidelines issued thereunder from time to time.
2. In the event of any inconsistency between this Privacy Policy and applicable law, the provisions of applicable law shall prevail to the extent of such inconsistency.

GOVERNING LAW AND JURISDICTION

1. This Privacy Policy shall be governed by and construed in accordance with the laws of India.
2. Subject to applicable laws, any dispute arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts at Jaipur, Rajasthan.

MISCELLANEOUS

1. No Waiver: Any failure or delay by the Company in exercising any right, power, or remedy under this Privacy Policy shall not constitute a waiver of such right, power, or remedy, nor shall any partial exercise thereof preclude any further exercise of the same or any other right, power, or remedy.
2. Severability: If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable by a court or competent authority, such provision shall be enforced to the maximum extent permissible under applicable law, and the remaining provisions shall continue in full force and effect.
3. Entire Privacy Policy: This Privacy Policy constitutes the entire understanding between the Company and the User in relation to the collection, processing, storage, disclosure, and protection of Personal Data through the Platform, and shall be read together with the Company's Terms & Conditions and such other policies as may be published by the Company from time to time.
4. Assignment: The Company may assign, transfer, or novate its rights and obligations under this Privacy Policy in connection with a merger, acquisition, corporate restructuring, or transfer of business or assets, subject to compliance with applicable law. Such assignment shall not adversely affect the level of protection afforded to the User's Personal Data under this Privacy Policy.
5. Language: This Privacy Policy is prepared in the English language. In the event of any inconsistency between the English version and any translated version made available for convenience, the English version shall prevail to the extent permitted under applicable law.

CONTACT US

If you have any questions regarding this Privacy Policy or our privacy practices, you may contact us at: