Privacy Policy

1. Introduction & Status as Data Fiduciary

DriveLabs OPC Pvt Ltd (“DriveLabs”, “Company”, “we”, “our”, “us”) provides structured driving training programs and RTO facilitation services in Kolkata, West Bengal, India.

For the purposes of the Digital Personal Data Protection Act, 2023 (“DPDP Act”), DriveLabs acts as a Data Fiduciary in respect of personal data processed through its platform, vehicles, and administrative systems.

This Privacy Policy explains how personal data is collected, used, processed, stored, retained, shared, and protected.

2. Consent Standards

Consent is obtained through clear affirmative action and digital acknowledgement during account registration and before activation of services. Processing of personal data is based on user consent, performance of contractual services, and compliance with applicable legal obligations.

Users may withdraw consent by writing to the Grievance Officer. Withdrawal may impact or terminate the Company’s ability to provide certain services, particularly RTO facilitation.

3. Categories of Data Collected

3.1 Identity & Contact Data

• Name
• Phone number (Phone numbers are collected because they are essential for learner account creation, instructor communication, lesson scheduling, attendance tracking, booking management, OTP verification (where applicable), and other core driving school services. Without a valid phone number, the core functionality of the DriveLabs platform cannot be provided.)
• Email address
• Gender (Gender information is optional and is collected only for learner profile records and driving school administration. It is not used for advertising, profiling, or marketing purposes.)
• Date of Birth (Date of birth is collected to verify that the learner meets the minimum age requirement under applicable Indian laws for obtaining a learner's licence. It is also used for identity verification and regulatory record-keeping.)
• Residential address

3.2 Government Documentation

• Aadhaar Card
• Learner's Licence / Driving Licence
• Other statutory documents required for learner registration and RTO services

DriveLabs collects Aadhaar and Driving Licence details to verify learner identity, prevent duplicate registrations, maintain learner records, facilitate driving school enrollment, and support RTO-related processes where applicable.

DriveLabs is not affiliated with UIDAI or the Government of India. Aadhaar information is collected directly from the user and is not retrieved from any government database. The information is used only for learner identity verification, learner registration, statutory compliance, and driving school services. It is never used for advertising, profiling, or marketing purposes.

Submission of Aadhaar is mandatory for learner enrollment because identity verification is required to provide driving school services, prevent fraudulent registrations, maintain learner records, comply with applicable legal obligations, and facilitate RTO-related processes where applicable.

3.3 Transaction Data

Payments are processed through ICICI Bank Orange Payment Gateway. DriveLabs does not store full card numbers or sensitive financial credentials.

3.4 Surveillance Data

Training vehicles are equipped with audio and video monitoring systems during active training sessions for safety assurance, instructor conduct review, dispute resolution, and operational compliance.

Visible notice is placed inside vehicles and users are informed during onboarding that monitoring occurs.

Audio and video recordings are not used for advertising, marketing, profiling, or any purpose unrelated to learner safety, quality assurance, dispute resolution, or legal compliance.

4. Purpose Limitation

• Delivery of structured driving training
• RTO facilitation
• Safety monitoring
• Dispute resolution
• Regulatory compliance
• Service-related communication
• Limited promotional communication (opt-out available)

DriveLabs does not sell personal data.

5. Data Retention & Storage Limitation

5.1 Surveillance Recordings

• Stored locally on secure SD storage
• Access restricted to authorised personnel
• Automatically overwritten
• Automatically deleted within 7 days
• Maximum retention 30 days for legal purposes

5.2 Aadhaar & Government Documentation

• Stored in secured digital or physical environments
• Access restricted on need-to-know basis
• Retained only for as long as necessary to fulfill legal and operational requirements, and for a maximum of 90 days unless a longer retention period is required by applicable law.

5.3 Transaction Records

Transaction records are retained as required under applicable financial and tax laws.

6. Security Safeguards

• Firewall protection
• HTTPS encryption
• Role-based access controls
• Restricted physical storage access
• Controlled SD storage environment
• Secure access logging and periodic security monitoring

7. Data Sharing

Personal data may be shared only with:

• RTO or statutory authorities
• ICICI Bank Orange Payment Gateway
• Authorised service providers that process data on behalf of DriveLabs under appropriate contractual and confidentiality obligations, where necessary to provide the Services.
• Regulatory authorities where legally required

DriveLabs does not sell, rent, or disclose personal data to third parties for advertising, profiling, or marketing purposes.

8. User Rights

Users have the following rights, subject to applicable law:

• Request access to their personal data.
• Request correction of inaccurate or incomplete personal data.
• Request deletion of their personal data.
• Delete their account and associated personal data directly through the DriveLabs mobile application, subject to any legal or regulatory retention requirements.
• Withdraw consent for the processing of personal data.
• Lodge a grievance with the Grievance Officer.

Where deletion is requested or an account is deleted, DriveLabs will delete or anonymise the user's personal data unless retention is required under applicable law or is necessary to establish, exercise, or defend legal claims.

9. Children

Services are available only to individuals aged 18 years or above. If minor data is inadvertently collected, it shall be deleted upon discovery.

10. Grievance Redressal

Archit Gupta
Chief Executive Officer

Email: support@drivelabs.app

Grievances shall be addressed within 30 days.