Privacy Policy

1. GENERAL

This is the privacy policy (the "Privacy Policy") of VE Commercial Vehicles Limited (referred to as 'VECV', 'We', 'Us', or 'Our').

VECV recognizes the need for protection and management of information shared by a User (referred to as 'User', 'You' or 'Your') with VECV while accessing and using its website i.e., https://www.smalltrucks.eichertrucksandbuses.com (the "Website") and is committed to respecting the online privacy and safeguarding the same. This Privacy Policy explains the various methods / purposes for the collection, use and disclosure of Personal Information of a User by VECV.

This Privacy Policy is aimed at providing You with comprehensive information, inter alia, with respect to the following:

What Personal Information we collect from You;
The manner in which Personal Information is collected;
How we use/process Personal Information during and after Your engagement with us;
Purposes (both specific and general) for which we use the Personal Information;
How we protect the Personal Information and keep it safe; and
What are Your rights with respect to the Personal Information which You choose to share with us.

In general, a User may visit the Website without revealing any Personal Information. However, for availing the services of VECV through the Website, the User shall be required to voluntarily furnish his / her Personal Information as provided under this Privacy Policy.

The information contained under this Privacy Policy is intended to enable You to provide us with a free, informed, unconditional and unambiguous consent for sharing and processing Your Personal Information for the specific purposes as provided hereunder.

For the purposes of this Privacy Policy, "Personal Information / Personal Data" shall mean and include any information or piece of information that could identify You either directly (e.g., Your name, phone number, email ID, etc.) or indirectly (e.g., a unique ID number). If anything in this Privacy policy conflicts with the local law, the local law shall prevail.

In compliance with the applicable laws, this Privacy Policy is being made available to You in multiple language(s). You are requested to kindly select the language which is most comfortable for You to read and understand for providing your consent.

By using this Website, You agree to the terms outlined in this Privacy Policy. If You do not agree with any part of this Privacy Policy, please refrain from using the Website.

2. WHY THIS PRIVACY POLICY?

2.1. Compliance with Applicable Laws

This Privacy Policy is published, inter alia, in compliance with the following laws:

Section 43A of the Information Technology Act, 2000;
Regulation 4 of the Information Technology (Reasonable Security Practices and procedures and Sensitive Personal Information) Rules 2011 (the "SPDI Rules");
Information Technology (Intermediaries Guidelines) Rules, 2011; and
Digital Personal Data Protection Act, 2023 and its rules (as and when notified).

The above as well as the applicable data privacy and protection laws currently in force, shall be referred to as Applicable Laws under this Privacy Policy.

2.2. Extent of the Privacy Policy

This Privacy Policy states the following:

The type of Personal Information collected from the User, including sensitive Personal Information or information;
The purpose, means and modes of usage of such Personal Information;
How and to whom such information will be disclosed; and
How the Personal Information collected is going to be protected?

3. Applicability

This Privacy Policy is applicable upon all the visitors or Users of the Website in respect of the Personal Information shared by them with VECV. By visiting the Website, the Users agree and acknowledge that the terms contained under this Privacy Policy shall be applicable upon them. The said Users agree to abide by the terms contained under this Privacy Policy.

This Privacy Policy shall be effective from the date and time of publication on the Website and may be updated / amended by VECV in its sole discretion from time to time, with or without a prior notice to the Users.

The User agrees that by using the Website, the User is expressly and affirmatively consenting to the use and disclosure of Personal Information provided by the User in the manner described hereunder and the User also consents to receive communication, as described under VECV's Terms and Conditions and under this Privacy Policy.

4. Who is the data fiduciary of Your data including Personal Information?

VE Commercial Vehicles Limited, a company duly incorporated under the laws of India with its registered address at 3rd Floor, Select Citywalk, A-3, District Centre, Saket, New Delhi – 110017, India with corporate identity number U74900DL2008PLC175032 is the data fiduciary of Your data including Personal Data.

5. What information will VECV collect?

To provide a personalized experience and facilitate various services offered through our Website, VECV may collect the following information from visitors (including the Users) of the Website from time to time:

a) Personal Identifiable Information (PII): This includes Your name, telephone number, email address, biometric information, company name, designation, contact details of the company (in case of a corporate User).

b) Demographic data: This includes information such as such as gender, birthday, zip code, city, country.

c) Content / Information specifically uploaded by the User such as photographs, reviews, comments or any other information voluntarily shared by the User etc.

d) Website Usage Data: Information related to visits on the website, such as pages visited, number of visits, average duration of visits cookies. The Website's tracking technologies may record information such as internet domain and host names; internet protocol (IP) addresses; browser software and operating systems types; clickstream patterns; and dates and times that the Website is accessed.

e) Service Requests & Interactions: Details of services accessed or requested through the website, including:

Vehicle booking for purchase or test drive.
Loan application submissions.
Booking for vehicle exchange evaluation.
Customization preferences for vehicles.
Queries submitted to connect with VECV experts.
Approximate periodic service cost calculations.
Operating benefit calculations.

f) Total Cost of Ownership (TCO) Data: Information provided by Users to calculate operational costs, including:

Number of trips per month, kilometers per trip, payload per trip, and freight per month.
Electricity cost per unit, range, and estimated tyre life.
Cost of a new tyre, manpower's salary, and maintenance costs.

g) Product Configurator Data: User preferences related to vehicle configuration, such as:

Fuel type, application, body type, gross vehicle weight (GVW), deck length, battery size, trim, and color.

h) Service Cost Calculator Inputs: Details provided by users to estimate service costs, including:

Selected state, city, and dealer.
Type and sub-type of periodic maintenance schedule (e.g., 30,000 km, 60,000 km).
Mobile number to receive cost estimates for selected maintenance schedules.

i) Online Booking Information: Data collected when users book a vehicle online, including:

Mobile number, email ID, state, city, dealer, model, Aadhaar number, and address.

j) Finance Aggregator Details: Information provided by Users seeking financing options, including:

Name, mobile number, gender, marital status, date of birth, and address.
Details related to existing business, agricultural land, and place of stay (rented or owned).
Bank accounts, credit and debit card details or other payment instrument details.
Co-applicant information, Aadhaar number, PAN, number of commercial vehicles owned, income tax return (ITR) filing status, and details of existing loans (if applicable).

k) Test Drive Booking Information: Details collected when booking a test drive, including:

Name, mobile number, email ID, model, preferred date and time slot, test drive location, address, dealer, state, and city.

l) Exchange Platform Data: Information submitted by users to evaluate old vehicle exchange options, including:

Make, model, and variant of the old vehicle.
Price expectation, place of evaluation, address, date, preferred time slot, dealer, state, and city.

VECV collects this information to enhance user experience, process service requests, and provide tailored recommendations based on user preferences and interactions.

Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as Personal Information or sensitive Personal Information.

Since Sensitive Personal Data or Information means a particular kind of Personal Information, any refences to Personal Information in this Privacy Policy should be construed to include a reference to sensitive Personal Data or Information.

Collection for Lawful Purpose: VECV confirms that the collection of User's information is for a lawful purpose and is connected to and necessary for the functions and activities of VECV as well as of any third parties (including its parent and affiliates) which include providing the services in the manner set out in the Terms of Use.

6. How do we collect the information?

VECV collects personal data directly from You through various sources and channels, including:

a) Forms Submitted on the Website: Information provided when filling out forms for vehicle bookings, test drives, exchange evaluations, loan applications, service cost calculations, and other requests.

b) Website Interactions via Cookies: Data collected through cookies and similar tracking technologies to analyze website usage, enhance user experience, and provide personalized content. The User may reset its browser to refuse all cookies or to indicate when a cookie is being sent. Some of the features or services of the Website may not function properly without cookies.

c) Communications with VECV: Information obtained through interactions over various communication channels, including but not limited to:

Phone calls
Emails
SMS messages
WhatsApp and other digital communication platforms

d) Third-Party Sources: In certain cases, VECV may receive information from third-party partners, service providers, or affiliates, which the User may have shared with specific consent in this regard. The third parties sharing the information with VECV may include the following:

Authorized vehicle dealerships
Financial institutions processing loan applications
Other service providers assisting in fulfilling Your requests

VECV ensures that all data collection methods align with applicable privacy laws and are used only for legitimate business purposes, including service fulfillment, user engagement, and website optimization.

7. Voluntary

All the information provided to VECV on the Website by the User, including sensitive Personal Information or Personal Information, is voluntary Collection of information which has been designated as 'Sensitive Personal Data or Information' under the Applicable Laws as well as sharing of such information with any third Party for third party services requires your express consent. By affirming your assent to this Privacy Policy, you (i.e., the User) provide your consent to such collection as required under appliable law. The services on the Website may be unavailable to you in the event such consent is not given. All statements in this Privacy Policy apply to all Users and all Users are expected to read and understand the Privacy Policy.

8. How do we use the information?

The Personal Information collected by VECV is aimed at personalizing User experience, facilitate service requests such as vehicle bookings, test drives, exchange evaluations, and loan applications, and improving VECV's products and services, including but not limited to the following:

8.1. Service Fulfillment & Customer Support

Processing vehicle bookings, test drives, exchange requests, and loan applications.
Logging customer queries to be addressed by VECV experts via call.
Creating exchange requests submitted to dealerships for vehicle evaluation.
Generating loan applications that are sent to financial partners for further processing, if any.

8.2. Customer Insights & Business Analytics

Calculating monetary benefits based on Your fixed and operating business expenses.
Understanding Your preferences and business needs to offer tailored recommendations.

8.3. Marketing & Sales Engagement

Creating a profile of the user to enable personalized digital campaigns.
Generating leads for follow-ups by the VECV's call center, dealership team or any other team, including third party service providers.
Sending marketing communications related to VECV products, services, and third-party offerings via calls, email, SMS, or other electronic messaging platforms.

8.4. Internal Research & Service Improvement

Enhancing our products and services based on customer interactions and feedback.
Conducting product research and development to better meet customer needs.
Ensuring compliance with internal policies, agreements, and regulatory requirements.

8.5. Third-Party & Designated Personnel Data Handling

If Your request involves additional personnel (e.g., co-applicants, drivers), their personal data may also be processed. However, You, as the customer, are responsible for obtaining their consent and informing them of how their Personal Information will be used and would be deemed to be the Data Fiduciary in case of such additional personnel(s) under the Applicable Laws.

VECV is committed to handling Your Personal Information responsibly, ensuring that all processing activities comply with applicable data protection laws and regulations.

9. Why are we allowed to collect and use Your Personal Information?

We may collect and use Your Personal Information when one of the following applies:

To fulfill contractual obligations when You request a service (such as vehicle booking, test drive, loan application, or exchange evaluation) or use the Website, we process Your Personal Information to take steps before entering into a contract or to perform a contract;
To comply with the Applicable Laws;
We need to use Your Personal Information for legitimate business purposes i.e. for running our business successfully;
For the establishment, exercise or defense of legal claims or proceedings, if required;
To protect Your vital interests or those of others; and
Because it is necessary for reasons of substantial public interest, based on the Applicable Laws.

10. For how long will VECV keep the Personal Information?

VECV will retain Your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including providing the services You have requested, such as vehicle bookings, test drives, exchange requests, and loan applications.

Your data will be retained until one or more of the following conditions are met:

You continue to use VECV's digital platforms, services and/or Website without requesting the deletion of Your Personal Information.
You remain subscribed to VECV's communications or marketing materials and have not revoked Your consent.
You maintain an active relationship with VECV, including engagement in ongoing or future services.
You have not specifically requested that we cease processing or delete Your Personal Information.

11. With whom will VECV share the information?

VECV may disclose the Personal Information to other companies within the VECV Group, affiliates, subcontractors, vendors and suppliers who perform services on behalf of VECV, for any of the purposes set out in this Privacy Policy. VECV may also disclose the Personal Information to other entities if required to do so by law or court order. VECV may also disclose the Personal Information and the information / data approved by You for providing the necessary services including but not limited to the financiers (institutional or otherwise). If VECV is involved in a sale or transfer of all or some of VECV's business assets or operations, the Personal Information may further be transferred to the acquiring organization. Additionally, VECV may share the information including Personal Information with third parties for the purposes of such third parties' marketing.

VECV has implemented reasonable market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User's electronic devices through which the User avails the services including the Services listed in the Terms of Use, VECV shall not be held liable for any loss whatsoever incurred by the User. Users may note that VECV endeavours to ensure that its vendors, service providers and third party agencies agree to implement all market practices and security policies to control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss of the User / Personal Information. However, VECV bears no liability for any loss whatsoever in case of any data loss or theft from the custody of the third parties and its affiliates.

VECV shall undertake reasonable and appropriate security measures to protect the Personal Information of the User against unauthorized access to or authorized alteration, disclosure or destruction of data on a best efforts basis.

VECV will restrict access to the Personal Information to VECV's employees and partners who need to know that information in order to operate, develop, provide or improve our services.

User's Personal Information is maintained by VECV in electronic form on its equipment, and on the equipment of its employees. Such Personal Information may also be converted to physical form from time to time. VECV takes all necessary precautions to protect the Personal Information both online and offline, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the Personal Information being collected and the nature of VECV 's business.

VECV may disclose such basic Personal Information to another entity purchasing (including for diligence purposes prior to purchase) the assets of VECV, provided that entity abides by this or a similar privacy policy.

VECV takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy and may disclose your Personal Information in case it is legally required to do so under any of the following conditions:

To satisfy any applicable law, rule, regulation, governmental requests or legal process;
To secure VECV systems;
To ensure the safety of the user and the public in general for any reason;
To detect, prevent or otherwise address fraud, security or technical issues; or
To prevent or stop activity VECV may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.

In case of any illegal, unethical or legally actionable activity, VECV may use IP address to identify users and may do so in cooperation with third parties such as internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such Personal Information to third parties, all in our discretion. Such disclosures may be carried out without notice.

VECV shall not sell, share or rent your Personal Information to any third party or use your e-mail id for sending mails for purposes other than as provided under this Privacy Policy.

12. In what instances do we transfer Your Personal Information outside of Your home country?

We work in multiple countries across the world. Therefore, we may need to transfer and use Your Personal Information outside of the country where we collect it from You. We implement appropriate measures to protect Your Personal Information when we transfer Your Personal Information outside of Your home country and any such transfer of Personal Information outside India shall be undertaken in accordance with applicable laws. The data privacy laws in the countries we transfer it to may not be the same as the laws in Your home country. Law enforcement agencies, regulatory agencies, security authorities or courts in the countries we transfer Your Personal Information to may have the right to access Your Personal Information.

13. How do we protect your Personal Information?

We want to make sure that Your Personal Information is not shared with or used by unauthorized parties. We use a variety of security measures and technologies to help protect Your Personal Information which is maintained at all times as per the procedures and parameters provided under Applicable Laws.

We carefully choose service providers to work with and ensure they have security measures and technologies in place to protect Your Personal Information, compliant with Applicable Laws.

While VECV has deployed the applicable security measures, VECV does not in any manner guarantee that the data transmission or storage system would at all times be secure and unbreachable. If You have reason to believe that Your interaction, or Personal Information with us is no longer secure, please immediately notify us using the details in the 'Contact information' section.

14. What are Your rights regarding your Personal Information?

As the owner of Personal Information, You have the right to:

Withdraw Your consent to us for processing Your Personal Information;
Access information about Your Personal Information;
Ask us to correct Personal Information You think is inaccurate or incomplete;
Ask us to delete Your Personal Information;
Seek grievance redressal before the applicable forum including but not limited to the Data Protection Board of India (as and when constituted);
In the event of Your death or incapacitation (either mentally or physically) and You are no longer in a position to exercise Your rights hereunder or under the Applicable Law, You may also nominate any other person to exercise such right on Your behalf; and

You can find out how to get in touch with us to exercise any of the abovementioned rights by looking at the 'Contact information' section.

For Your protection, and to protect the privacy of others, we may need to verify Your identity before fulfilling Your request.

You may note that the processing of Your Personal Information is required by VECV for providing the services as described in the 'How do we use Your Personal Information' section. In the event You withdraw Your consent for the processing of Your Personal Information by VECV, VECV may not be able to provide You with certain or all services in a comprehensive manner.

15. Children's Personal Information

We do not knowingly or intentionally collect or process any Personal Information from children under the age of 18 years. If You are under the age of 18 years, You are strongly advised to not submit any Personal Information to VECV through any mode or means. Parents and legal guardians are encouraged to monitor their children's activities and help us enforce this Privacy Policy by teaching their children never to provide Personal Information to VECV. If You have reason to believe that we may have received Personal Information of a child under the age of 18 years, please feel free to contact us at Privacy@VECV.in and we will use reasonable efforts to delete such Personal Information and share a confirmation of the same with You.

16. Terms of Use

This Privacy Policy is to be read with the Terms of Use of the Website establishing the use, disclaimers, and limitations of liability governing the use of the Website.

17. Contact Information

If You want to exercise Your rights, have any questions about this Privacy Policy, need more information or would like to raise a concern, You can do so by contacting VECV at Privacy@VECV.in.

18. Governing Law

This Privacy Policy and the terms contained herein, shall at all times be governed by the laws of India.

19. Updates to this Privacy Policy

From time to time, we will update this Privacy Policy. Any changes that are made to the contents of this Privacy Policy shall be shared by VECV with You (if required under Applicable Law) You would be required to provide a fresh consent to VECV.

By consenting to this Privacy Policy You represents that You have read and understood the contents and terms of the Privacy Policy in the vernacular and You are willingly providing Your informed, unconditional and unambiguous consent to VECV for collection, processing, using and sharing the Personal Information as described above for the purposes as described in this Privacy Policy (as may be updated from time to time by VECV).