Invictus Spot Events Private Limited and Reach for Sure Privacy Notice

Introduction

When you use our services, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this before you start using our services.

Overview

This notice applies to users of our services anywhere in the world. This notice describes how we and our affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice.

Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

Data Controller & Transfer

Invictus Spot Events Private Limited and Reach for Sure are the data controller for the personal data collected in connection with use of our services.

Data Collection & Uses

We collect personal data,

  • provided by users, such as during account creation
  • created during use of our services, such as location, app usage, and device data

The following personal data is collected by or on behalf of Invictus and Reach for Sure,

1. Data provided by users
    • User profile and vehicle details: We collect data when users create or update their accounts. This may include their name, email, phone number, login name and password, address, profile picture, driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo), insurance, vehicle registration, and vehicle fitness related documents. This may also include emergency contact information, gender and/or occupation.We may use the photos submitted by users to create their profiles. We may also use the photos and videos of the user’s vehicle(s) for verification and audit purposes. For more information, please see the section titled “How we use personal data.”
    • Background check and identity verification: This may include information such as driver history or criminal record (where permitted by law), license status, known aliases and prior addresses, and right to work.
    • User content: We collect the data submitted by users when they contact Invictus or Reach for Sure customer support, provide ratings or compliments, or otherwise contact us. This may include feedback, photographs, GPS device data or other recordings collected by users, including audio or video recordings (such as from dashcams and/or mobiles) submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with us.
    • Travel information: We collect travel details, including the times and dates of travel. We collect such information when users manually input their information into this App.

 

2. Data created during use of our services
    • Location data: We collect user’s precise or approximate location data, including to enable ride/trip tracking and safety features, to prevent and detect fraud, and to satisfy legal/ organizational requirements. We collect this data when the Reach for Sure app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how riders, and order recipients can enable location data collection). We collect such data from the time a ride / trip is configured and started in the App, until it is finished / ended by the user and any time the app is running in the foreground (app open and on-screen) of their mobile device.Users may use the Reach for Sure app without enabling collection of precise location data from their mobile devices. However, this may affect features in the app.
    • Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
    • Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
    • Communications data: We enable users to communicate with each other, with Invictus and Reach for Sure support and with Emergency services and contacts through the Reach for Sure mobile app and websites. This communication may be through call, text, or by sending other files (photos and/or videos). To provide this service, we receive some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. We may also use this data for customer support services, for safety and security purposes, to improve our services and features, and for analytics.
    • Safety recordings: When permitted by users, the app can record the audio and/or video of their trips through an in-app feature or using a dashcam. In app recordings are encrypted and stored on users’ devices, and are only shared with Invictus, Reach for Sure, user’s organization and / or law enforcement in case of violations connected to safety incidents.

3. Data from other sources
    • This includes data provided by user’s employer or organization. Invictus and Reach for Sure may combine the data collected from these sources with other data in its possession.
    How We Use Personal Data

    We use such data:

    • to create and update accounts / user profiles
    • to verify users’ identity and eligibility, including through reviews of background checks, to help prevent use of our services by unsafe drivers and/or riders
    • to track and share the progress of rides / trips
    • to enhance the safety and security of our users and services
    • to perform pre-trip safety checks, which prompts users to share a photos and or videos of themselves, their vehicles, and the legally mandated documents.
    • to verify that users are wearing masks, helmets, other safety gear, and are not indulging in any unsafe driving activity.
    • to detect unsafe driving behavior such as speeding, harsh braking and acceleration, harsh turns, distracted driving, drowsy or fatigued driver
    • to warn the users of potential risks on their routes
    • to prevent, detect, and combat fraud
    • for customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes
    • for research and development, testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easier-to-use, enhance the safety and security of our services, and develop new services and features.
    • to enable communications between users
    • to send marketing and non-marketing communications to users
    • in connection with legal proceedings
    • to rate, score and reward users on their driving skills
    • to provide user specific trainings
    • to perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

    Invictus and Reach for Sure perform the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users.

    Invictus and Reach for Sure do not sell or share user personal data with third parties. The user data may however be shared with their employer / organization, other users of the app, emergency services & contacts, law enforcement, judiciary or other government authorities, and Invictus and Reach for Sure partners, stakeholders, lawyers, accountants, consultants & other professional service providers

     

    Data Retention & Deletion

    We retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, the purposes for which we collected the data.

    Users may request deletion of their account at any time. Following an account deletion request, Invictus and Reach for Sure deletes the user’s account and data within 90 days, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as any unresolved claim or dispute. Because we are at times subject to contractual requirements with the user’s employer / organization, this generally means that we may retain their account and data for the period of contract, if necessary, after a deletion request.

    We provide users with a variety of ways to learn about, control, and submit questions and comments about our handling of their personal data.

    • Accessing data: Users can access data including their profile data and trip history through this app. Users can also view an online summary of information about their account, such as number of trips, distance driven, rewards status, and number of days since they’ve been a user. Users can also request access to their data by contacting us at support@invictus.in.
    • Receiving data: Users can request a copy of their personal data from the app. Users may also request a copy of their data by contacting us at support@invictus.in.
    • Changing or updating data: Users can edit the name, phone number, email address, photo associated with their account, their vehicle details etc. through the app itself. Users may also request to update or correct their data  by contacting us at support@invictus.in.
    • Deleting data: Users may request deletion of their account at any time by contacting us at support@invictus.in.
    • Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data.

    Privacy Settings

    Invictus & Reach for Sure app allows riders and order recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications

    Updates to this Policy

    We may occasionally update this policy. If we make significant changes, we will notify users in advance of the changes through the app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.