Privacy Policy

1. OVERVIEW – WHO THIS POLICY APPLIES TO AND WHAT IT IS FOR

At Tigerville Enterprises, we value your privacy and want to be accountable, fair and transparent with you in the way that we handle your personal information. This policy has been designed to provide you with information about how we collect, hold, use, store and disclose personal information about our customers, potential customers, employees, suppliers and others. It also sets out your rights in relation to your personal information that we have and what you can do if you are unhappy with how we handle your personal information.

This Privacy Policy (“policy”) applies to all personal information held by Tigerville Enterprises Pvt. Ltd. (CIN U74999CH2016PTC041250) and its related entities (we, us, our, EFUEL, EFUEL APP, EFUEL STATION APP, TIGERVILLE ENTERPRISES).

We are bound by The Information Technology Act (2000), The Information Technology (Amendment) Act 2008 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Acknowledgement

By engaging with us in the ways set out in this policy, you confirm that you have read and understood this policy, as it applies to you. All references in this policy to “our website”, refer to the website owned by us at www.efuel.app

This Privacy Policy may be updated and changed from time to time at our discretion (also see section 10 of this policy). By continuing to use our website, apps or otherwise continuing to deal with us, you acknowledge and accept those updates and changes made to this Privacy Policy as it applies from time to time.

2. HOW WE COLLECT PERSONAL INFORMATION

The main way in which we collect personal information is directly from you, including through completion of paper-based or electronic forms, in person or other forms of digital meetings, during phone calls made to or written correspondence with our Support Team, through security video surveillance at our sites or by any other means (including social media, promotions or competitions) through which you engage with us in order to receive information, services or other benefits from us. We also collect personal information through your use of our mobile applications (“the Apps”) and our website.

We may also receive information about you from third parties. This may happen without your direct involvement. For instance, we may collect your personal information from:

If you provide personal information to us about another person (such as a nominated user of our Apps), you will need to obtain consent to share such information with us from that person and notify them of this Privacy Policy.

3. COLLECTION AND USE OF YOUR PERSONAL INFORMATION

The purpose for which we use your personal information will depend on the circumstances in which it is collected. Generally, we may use and disclose your personal information:

Where we hold personal information about you that we have collected from different sources, we may combine this personal information into a single record or a collection of linked records. We may also combine or share any information that we collect from you with information collected by any of our related entities (whether within the country where the information was collected or overseas).

The types of personal information we may collect about you and its specific use is dependent upon your relationship with us.

3.1. Visitors to our website

We, or third parties* on our behalf, may collect and use any of the following information about you when you visit our website:

* We may use Google Analytics to help analyse how you use our website. Google Analytics generates statistical and other information about website use (by means of cookies, which are stored on users’ computers). Google will store this information.

3.1.1. How we specifically use your personal information

We will collect, use and store the personal information listed above for the following reasons:

3.1.2. Cookies and other tracking technologies

3.2. Our customers (both consumers and merchant partners (including their franchisees), and including users of our Apps)

3.2.1. How we specifically use your personal information

3.3. Job candidates

We may collect the following personal information about job candidates to facilitate our recruitment processes and pre-employment relationship with them:

Our Careers services may be supported by third parties, whose privacy policy and contact details will be available via their own websites.

3.4. Employees and individual contractors

In addition to the personal information collected by us in connection with our recruitment activities, other personal information that may be collected by us about our employees and contractors to support a variety of our business and workforce related functions and to comply with applicable laws, includes:

3.5. Suppliers and Vendors

In order to facilitate the acquisition of products and services supporting our business activities and to ensure that our suppliers and vendors are of good character and have the necessary skills and experience, we may collect the following personal information about our suppliers and service providers:

3.6. Merchant partners (including their franchisees), other operators of participating locations and distributors of our products and services

We collect a range of personal information about directors, shareholders, partners, trustees or principals of the businesses that enter into various types of partnership, distribution or similar arrangements with us to support our commercial activities related to business-to-business and distribution initiatives. This may include the following categories of personal information:

3.7. Shareholders

Tigerville Enterprises (including its associated bodies corporate) collects personal information about its shareholders, such as:

3.8. All others

If you contact our Support Team, we may collect personal information from you to assist you with your query or to process your complaint. While you can contact us anonymously, if you do so, we may not be able to assist you.

Whatever your relationship with us is, we may also collect, use and store your personal information (including Credit Agreement information) for the following additional reasons:

3.9. Credit related information

We collect and holds Credit Agreement related personal information about you in connection with you application/s for credit with our merchant partners (or their franchisees), which are predominantly applications for a credit limit for your orders.

In this policy, credit-related personal information includes, but is not limited to:

3.10. Sensitive information

Sensitive information is a special category of personal information, such as health information, criminal record information, or information about your trade union memberships, race, religion, sexual orientation or beliefs. As you can see from the above section, we may collect some sensitive information about you in certain circumstances. However, we will only collect such information with your prior consent, unless we are permitted or required by law to do so without your consent.

If you disclose sensitive information to us for any reason, you consent to us collecting the information and using and disclosing it for the purpose for which it was disclosed and as permitted by the relevant laws and regulations.

3.11. Unsolicited personal information

If we receive personal information where we have taken no steps to collect the information, then within a reasonable time we will decide whether we could, under the relevant laws and regulations, have solicited that personal information ourselves.

If we determine that we would not, under the relevant laws and regulation, have been permitted to solicit the personal information, we will as soon as practical (where lawful and reasonable to do so) destroy or de-identify that unsolicited personal information. If we could, under the relevant laws and regulations, have solicited the personal information then we may use and disclose the personal information for the purpose for which it was disclosed and as permitted by the relevant laws and regulations.

3.12. Legal basis for use of your personal information

3.13. Children

4. DISCLOSURE OF YOUR PERSONAL INFORMATION

Generally, we will only disclose your personal information internally, within our group entities, and/or to third parties:

However, if we sell or buy any business or assets (irrespective of the mechanism i.e. liquidation, takeover, divestment, acquisition etc.), we may disclose your personal information to the prospective seller or buyer of such business or assets and if substantially all of our or any of our affiliates’ assets are acquired by a third party, personal information held by us will be one of the transferred assets.

The third parties that we may disclose your personal information to, vary depending on the particular circumstances in each case, but typically involve service providers that assist us to run our business and fall into the following broad categories:

We may also disclose your personal information to comply with relevant legislative and regulatory requirements or in connection with law enforcement activities, for example, to assist police investigations.

If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should withdraw consent by contacting us and we will stop doing so.

^ Specifically, as an example, the Apps incorporate a Google product called Google Maps API for Business or 'Google Maps'. This product helps end users like yourself to locate our participating Locations using the App, and may also provide other features and services. The way it works, generally, is that the EFUEL App will send Device Information and, in some instances, user Content, including information about your location, to Google (including cached data). Google will then be able to display, through the EFUEL App, nearby, favourite and frequently visited Locations. Google may use the information we provide through the EFUEL App in various ways. To understand how Google may use that information, please make sure you read Google’s Privacy Policy.

By using the Google Maps features, you are agreeing to the Google Privacy Policy, which is different from EFUEL's Privacy Policy. For the avoidance of doubt, by using the Google Maps features you affirmatively accept and consent to: (1) all of Google’s terms and conditions, (2) Tigerville Enterprises’ use and incorporation of Google Maps into the Apps, and (3) Tigerville Enterprises’ acceptance of the Google terms outlined herein and elsewhere. If at any point in time you decide

If at any point in time you decide you do not wish to consent to any of the above Google terms, you must uninstall the App immediately. There is no other way to revoke or opt out of the Google Maps functionality and its associated terms, restrictions, and data privacy implications.

4.1. Anonymised and aggregated data

We may also use and disclose anonymised, aggregated reporting and statistics about users of our website, our apps or our services for the purposes of, or in connection with, the supply of products and services to you, internal reporting or reporting to our group or other third parties and for marketing and promotion purposes.

None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

4.2. Transfer of your personal information

5. MARKETING COMMUNICATIONS

We may collect and use your personal information from time to time to contact you for marketing e.g. our news, information relating to the Apps, schemes, special offers and other promotional communications, by various means, including post, email, SMS, phone calls, through social media and targeted advertising or by other electronic means (including app-native pop-ups). We may also contact you about products and services offered by our partners. In our marketing activities, we will comply with the applicable privacy legislation, including by obtaining your consent as may be required.

If you use any of our mobile applications, we may also send you direct marketing through in-app push notifications. You can manage these directly in your mobile device settings.

If you wish to modify your preferences or opt-out from receiving marketing communications from Tigerville Enterprises, you can contact us at support@efuel.app. If direct marketing is by electronic means, such as email or SMS, you can also use the unsubscribe facilities provided in the relevant messages to opt-out. We will not charge you or in any way disadvantage you if you choose to opt out of receiving marketing communications.

If you opt out of receiving marketing communications from us, we will still send you transactional and account maintenance related information and may contact you if we are required to do so by law.

6. YOUR RIGHTS – ACCESS, UPDATE AND OPTING OUT

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us (see contact details in section 11 below) at any time.

We may request you provide us with information necessary to verify your identity before responding to any request you make. We will consider all such requests and provide our response within a reasonable period and in accordance with applicable laws and regulations.

There may be situations where we may refuse requests, for example if giving access would be unlawful or giving access would have an unreasonable impact on the privacy of other individuals. If we deny you access to the personal information (including credit related information) we hold about you, or refuse to correct your personal information (including credit related information), we will provide you with an explanation for the refusal.

6.1. Access to your information

Subject to any exceptions in the relevant laws and regulations, you have a right of access to any personal information (including credit related information) we hold about you.

If you want to access your personal information held by us, please put your request in writing and clearly identify the personal information you seek access to. This is important to ensure that the information can be retrieved quickly and cost effectively. All requests for access must be addressed to our Privacy Officer (see contact details below).

Depending on the circumstances, we reserve the right to charge you a reasonable administrative fee in connection with your request to access personal information. For example, our reasonable administrative costs might include:

If a fee is charged for providing access, you will be advised of the likely cost in advance.

In some instances, we may not release the personal information. For example, if the information reveals the details of a commercially sensitive decision-making process, then we may decide to give you an explanation about the commercially sensitive decision rather than direct access to the information.

6.2. Update or correction of your information

You have a right to request an update or correction to any of your personal information (including credit related information) that we hold.

We are committed to ensuring that your personal information is kept accurate, up to date and complete. We will take reasonable steps to correct personal information that is inaccurate. However, we can only correct or update your personal information if you notify us of any inaccuracies or changes, or if we otherwise become aware that your personal information is no longer accurate. You should contact and notify us if your personal information changes in order for us to keep your information up to date.

If we believe that it is inappropriate to delete or alter the original information, we will discuss with you alternative ways of correcting the information that satisfies the needs of both parties. In this situation, you may also request us to append a statement to your personal information that there is a dispute as to its accuracy.

Where we do not agree to amend credit related personal information held about you, we will provide you with written reasons for our decision and details of how you may make a complaint about our decision.

6.3. Opting out of marketing communications

You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose but may still contact you for transactional or account maintenance purposes.

Please also refer to section 5 above in this policy.

7. PROTECTION OF YOUR PERSONAL INFORMATION

The main risk of our handling of your personal information is if it is lost, stolen or misused. As such, Tigerville Enterprises is committed to protecting your personal information from loss, theft, unauthorised access and disclosure, alteration or any other misuse. We take all reasonable precautions to safeguard the confidentiality and security of your personal information, including through use of appropriate contractual, legal, organisational, physical and technical measures.

The security of your personal information is important to us and we take reasonable steps to ensure that the personal information we hold is secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable laws and regulations.

In the unlikely event of a data breach affecting your personal information, we will notify you and/or other relevant authorities, as required by applicable laws and regulations. You should also notify us immediately if you become aware of any breach of security.

Where we have given you (or where you have chosen) a PIN or password, which enables you to access your account with us, you are responsible for keeping this PIN or password confidential. We ask you not to share your PIN or password with anyone.

We store personal information in a range of paper-based and electronic forms.

7.1. Physical security

Where personal information is stored in physical form, we use a variety of mechanisms to protect the security and integrity of such information, which might include:

7.2. Computer and network security

We adopt a number of security measures to protect personal information from unauthorised access via computer systems and networks, which might include:

7.3. Communications security

In the course of provision of your personal information to us and our ongoing business activities, your personal information may be transferred over the internet or other telecommunications infrastructure, which are not always secure. Although we make every effort to protect the personal information which you provide to us, we cannot provide any assurance regarding the transmission of information over the internet or such telecommunications infrastructure, which usually sits outside our direct control.

As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website or mobile applications and that any such transmission is at your own risk.

Once we have received your personal information, we enhance the security of our transmissions using a variety of mechanisms, which may include:

7.4. Storage and destruction or de-identification

We will never see nor store the full details of your nominated payment method/s (except your bank account details and payment interface details (e.g. UPI ID etc.)), unless you provide these to us via e-mail or over the phone. Such details are collected, stored and processed by the relevant payment service providers (including payment gateways), who process your payment when you use our Apps.

Personal information in our possession may be retained in archival storage along with our other business-related information (including confidential information). Generally, we will securely destroy or de-identify personal information after a period of seven (7) years following its collection or following an end of your relationship with us unless it is required, or may be required, to be kept for a longer period because of the purpose(s) for which it was originally collected or in line with relevant laws and regulations.

8. LINKS TO OTHER THIRD PARTY WEBSITES OR CONTENT

Our website and mobile applications may contain hyperlinks to websites or content that are not operated by us but by third parties. These hyperlinks are provided for your reference and convenience only and may not remain current or be maintained. They do not imply our endorsement of the activities of such third-party websites or any association with their operators.

This policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, which you should read carefully before you submit any personal information to them. The privacy policies that apply to those other websites may differ substantially from Tigerville Enterprises’ Privacy Policy, so you should read and understand them before using those websites. If you have any privacy concerns, we encourage you to contact the providers of such third party websites and content directly.

We make no representations or warranties in relation to the privacy practices of any third party website or content. We are not responsible or liable for the privacy policies or practices of those linked websites and have no control over them.

9. MAKING A COMPLAINT

If you wish to make a complaint to Tigerville Enterprises about any matters related to our handling of your personal information (including credit related information), such as where you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this policy in respect of your personal information, please provide full details of your complaint to us in writing (see contact details below).

We will need to verify your identity. We take all complaints seriously and will respond to you within a reasonable period of time to both acknowledge (usually within 7 days of receipt of a complaint) and respond to (where practicable, within 30 days of receiving a complaint) your query or complaint. If that is not possible, we will seek to agree a longer period with you. We will notify you of the outcome of our investigation in writing.

10. CHANGES TO THIS POLICY

We may amend this Privacy Policy from time to time to take into account new laws and regulations, evolving technology, changes to our operations and practices and the changing business environment. All personal information handled by us will be governed by our most recent Privacy Policy.

The most recent and current version of this policy will be available on our website at www.efuel.app/privacy-policy or through the 'Privacy Policy' tab in the About section of the App. Where appropriate, we will notify you of updates by the most practical electronic means (including by email).

A copy of the most current version of the policy can also be obtained by contacting the Privacy Officer (see contact details below).

11. CONTACT US

If you have any queries or concerns about our collection, holding, use, disclosure or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, use the following contact details:

The Privacy Officer

Tigerville Enterprises Pvt. Ltd.

Email: support@efuel.app

This policy was last updated on 9 January 2022.