Introduction

1. Thriving Billions Private Limited ("Thriving") is committed to responsible privacy practices and to complying with Indian law.
2. This Privacy Policy sets out our policies on the management of personal information, that is, how we collect personal information, the purposes for which we use this information and to whom this information is disclosed.
3. We may change our Privacy Policy from time to time at our discretion. At any time, the latest version of our Privacy Policy is available from our website (“Site”) at website name

What is personal information?

1. In this Privacy Policy, “personal information” has the meaning set out in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. Essentially, personal information is information that could identify you such as your name, address, telephone number, photo and email address or any other information, which are available or likely to be available of identifying you.

What types of personal information does Thriving collect?

1. The types of personal information Thriving collects from you depend on the circumstances in which the information is collected.
2. Thriving may collect contact details including your name, address, email address and phone and fax numbers.
3. Where relevant, Thriving may also collect your driver’s licence and registration details, date of birth or age group, occupation, gender, information about your vehicle (including its number plate and vehicle identification number), answers you provide to questions we ask and other information in relation to your dealings with Thriving or Dealers (such as types of vehicle purchased and replaced and repair/service history).
4. If you are an individual engaged with Thriving to provide services (directly or indirectly) to Thriving may collect information relevant to your engagement with Thriving including qualifications, length of engagement, resume and salary, bank details, feedback from supervisors, training records and logs of your usage of Thriving equipment (e.g. phones, computers and vehicles). If you are employed by or contracted to a Thriving authorised dealer (“Dealer”), we may also collect and maintain training records about you.
5. When using the Site, we or our third party service providers may collect the Site usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the Site that referred you to us and the next Site you go to, the pages you request, the date and time of those requests and the country you are in. Except where you provide it to us via the Site, we do not collect personal information such as your name, mailing address, email address or phone number when you are browsing our Site.
6. Thriving does not generally require customers to disclose any sensitive data or information (e.g. details of race, religious beliefs, sexual orientation, health information etc.) to us.
7. If you do provide sensitive data or information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Information Technology Rules, 2011 and other relevant laws.
8. In addition to the types of personal information identified above, Thriving may collect personal information as otherwise permitted or required by law.

How do we collect your personal information?

1. Thriving collects personal information in a number of ways. The most common ways we collect your personal information are:
   • directly from you when you provide it to us or our Customer Relationship Centre or our dealers or agents or contractors;
   • via Dealers from which you purchase Thriving related goods or services;
   • via our Site or when you deal with us online (including through social media);
   • via our market research agencies;
   • when you enter a competition or promotion or marketing campaign;
   • if you are an individual engaged with Thriving (directly or indirectly), from your employer or recruitment agency;
   • if you are employed by or contracted to a Dealer, from that Dealer;
   • via the SYNC owners forum;
   • from publicly available sources;
   • from our group or related companies; and
   • from third parties (for example, from referees if you apply for a position as an employee or contractor with us)
2. Interest-Based Advertising: Thriving some pages of this site we may allow third-party advertising partners, to set web tracking and storage technology tools (e.g., cookies, web beacons, pixels) to collect or receive information regarding your activities on those web pages (e.g., your IP address, page(s) visited, time of day). These third parties may use this information (and combine it with information collected from other websites, apps or other digital services) for purposes of delivering future targeted advertisements to you when you interact with other (non-Thriving) sites, mobile apps or digital services, and to provide measurement services. This practice is commonly referred to as "Interest-Based advertising".
3. Opting out of Interest-Based Advertising: You may learn about how to opt-out of this kind of collection and use of information for your browser or device by managing your settings, and for your social media accounts by managing your preferences in your account settings.
4. Opting out from Specific Advertisers: Facebook: To learn more about how to opt out of Facebook Interest-Based Advertising, go to the Privacy tab on the Facebook website footer, and then select Facebook Ads Controls.

For what purposes do we collect, use and disclose your personal information?

1. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
2. We may use or disclose your personal information:
   • For the purposes for which we collected it (and related purposes which would be reasonably expected by you);
   • For other purposes to which you have consented; and
   • As otherwise authorised or required by law.
3. In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
4. Some of the specific purposes for which we collect, use and disclose personal information are as follows:
   • To facilitate your request for a brochure or test drive, to add you to a mailing list or to respond if you request information (including via the Site or via an email you send to us);
   • to record and maintain the details of your purchase of a Thriving vehicle for warranty purposes or your purchase of a " Thriving " product or service for administration purposes;
   • to keep track of the repairs and servicing of your Thriving vehicle by Dealers;
   • to facilitate the provision of roadside assistance and other services you acquire from us, Dealers or our agents or contractors;
   • to inform you in the event of a field service action, for example a recall, affecting your Thriving vehicle;
   • to issue service reminders;
   • to improve our products and services;
   • facilitate the provision of roadside assistance services;
   • to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our products, services and Dealers through surveys;
   • to report to and evaluate Dealers;
   • to verify your identity;
   • to facilitate your entry and participation in a competition or campaign or trade promotion;
   • to consider you for a job at Thriving (whether as an employee or contractor) or other relationships with us;
   • to provide goods or services to you or to receive goods or services from you;
   • to address any issues or complaints that we or you have regarding our relationship; and
   • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
   • We may also use and disclose your personal information for the purpose of direct marketing to you where you have consented to us doing so; or it is otherwise permitted by law.
5. Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you and to provide you with special offers from Thriving or its Dealers. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS. You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us (see section 16 of this Privacy Policy). If you wish to unsubscribe from direct marketing you have received from a Dealer, please contact that Dealer directly.

What happens if you don't provide personal information?

Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with the products and services that depend on the collection of that information. As an example, if you did not provide the personal information requested on your new vehicle purchase, we would be unable to notify you directly of a product recall affecting your vehicle.

To whom do we disclose personal information?

1. We may disclose your personal information to third parties in connection with the purposes described in section 5 of this Privacy Policy.
2. This may include disclosing your personal information to the following types of third parties:
   • Dealers;
   • our group or related companies;
   • our contractors or service providers (including mailing houses, marketing agencies, insurance providers, site and data hosting providers and other IT suppliers);
   • other persons who perform services for, or in connection with, us (including to facilitate the delivery of purchases, to provide roadside assistance, for electronic direct mailing, for credit card payment authorisation, for trend analysis, for market research, for promotions and for the provision of statistical sales information to industry bodies);
   • companies who may use your personal information in order to tailor electronic advertising or Interest Based Advertising to you (e.g. on a Sitepage or Facebook) in relation to our products and services;
   • our accountants, insurers (including those that provide extended warranties), lawyers, auditors and other professional advisers;
   • if you are an individual engaged with Thriving (directly or indirectly), to your employer or agency in relation to the performance of your work with Thriving;
   • if you are an a prospective employee, to our medical service providers for any medical assessments or in relation to any health or safety incidents and to HR related service providers (e.g. for background checks, screening or aptitude testing);
   • any third parties to whom you have directed or permitted us to disclose your personal information;
   • Statistical information about sales to industry bodies. This may comprise data collected about you and other customers to form aggregate results but we will not provide any information that identifies you as our customer;
   • third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
   • otherwise as permitted or required by law.
3. Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the applicable laws of India. It is possible that certain third parties may use this information collected from the Site (and combine it with information collected from other websites, apps or other digital services) for purposes of delivering future targeted advertisements to you when you interact with other (non-Thriving) sites, mobile apps or digital services, and to provide measurement services. This practice is commonly referred to as "Interest-Based advertising". You are advised to read the other websites, apps or other digital services before sharing your personal information with them.
4. If you post information to certain public parts of our Site or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.

Does personal information leave India?

1. Some of the third parties to whom we disclose personal information may be located outside India. For example, we may disclose personal information to our group related companies overseas and to our overseas service providers.
2. The countries in which these third parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose personal information to parties located in the United States, China and Singapore (where our Thriving group data and business centers are located). If your information is transferred overseas it will remain subject to strict security safeguards.
3. For further information regarding Thriving's handling of your personal information or to request a copy of Thriving's privacy policy or information we hold about you, you may email us at reach@dehurdle.com.

How do we protect personal information?

1. Thriving will take reasonable steps to keep any personal information we hold about you 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 Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law. Please notify us immediately if you become aware of any breach of security.
2. Your personal information will not be “sold” by Thriving to any other organisation for that organisation's unrelated independent use. Further, we will not share your personal information with any organisations, other than those engaged by us to assist us in the provision of our products and services (as described above).
3. We endeavour to ensure that our employees are aware of, and comply with their obligations in relation to the handling of personal information. Only properly authorised employees are permitted to see or use personal information held by Thriving and, even then, only to the extent that it is relevant to their roles and responsibilities.

What about information you provide in job applications?

1. If you submit a job application to Thriving, we will use the information provided by you to assess your application. Thriving may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing, medical testing and human resources management activities.
2. If you submit a job application to Thriving, we will use the information provided by you to assess your application. Thriving may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing, medical testing and human resources management activities.
3. If you submit a job application to Thriving, we will use the information provided by you to assess your application. Thriving may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing, medical testing and human resources management activities.
4. Thriving will handle health information in accordance with applicable laws.

Electronic mail sent to us that contains personal information

Internet users may decide to send Thriving personally identifying information, for example, in a message containing information about your Thriving product or service. Thriving will only use this information to identify the user as a Thriving customer and to determine how to respond to the electronic mail. We will not use this information other than to resolve the matter identified in the email.

Is the personal information we hold accurate?

1. We endeavour to maintain your personal information as accurately as reasonably possible. However, we rely on the accuracy of personal information as provided to us both directly (from you) and indirectly (eg. from a Dealer).
2. We encourage you to contact us if the personal information we hold about you is incorrect or to notify us of a change in your personal information. Our contact details are set out in Section 16 of this Privacy Policy

Links, cookies and use of the Site

1. When using the Site, we or our third party service providers may collect Site usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the Site that referred you to us and the next Site you go to, the pages you request, the date and time of those requests and the country you are in. Except where you provide it to us via the Site, we do not collect personal information such as your name, mailing address, email address or phone number when you are browsing our Site.
2. Thriving and its third party service providers use technology such as "cookies", "pixel tags" and java code on Sites and in emails you have agreed to receive from us. The use of "cookies", "pixel tags" and java code is an industry standard, and helps us monitor the effectiveness of our advertising and how visitors use the Site. A "cookie" is a small data element stored by your Site browser on your computer system. If selected by you, the Site will store your username and password in a "cookie" to enable you to be automatically logged in when you return. The Site "cookies" do not store your email address or other personal information about you.
3. When using the Site, we or our third party service providers may collect Site usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the Site that referred you to us and the next Site you go to, the pages you request, the date and time of those requests and the country you are in. We or our third party service providers use this information to generate statistics and measure site activity to improve the usefulness of customer visits. During normal Site usage we do not collect or store personally identifiable information such as name, mailing address, email address, or phone number.
4. Each time you access the Site, the Thriving server may deliver certain customised information, including ads, to you based on the data stored in your cookie. Third party vendors may show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Site and other Internet activity. Thriving may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns.

How can you access or correct the personal information we hold about you?

1. You may seek access to personal information which Thriving holds about you by contacting us as described in section 16 of this Privacy Policy. We will provide access to that information in accordance with the applicable laws, subject to certain exemptions which may apply. We may require that the person requesting access provide suitable identification and where permitted by law we may charge an administration fee for granting access to your personal information.
2. If you become aware that any personal information we hold about you is incorrect or if you wish to update your information, please contact Thriving (see section 16 of this Privacy Policy).
3. If you wish to access, correct or update personal information held by a Dealer, or unsubscribe from direct marketing from the Dealer, please contact that Dealer directly.

Queries, comments and complaints about our handling of personal information

1. If you have any questions, concerns or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy, please contact us (see section 16 of this Privacy Policy).
2. When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
3. Thriving will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

Contact details

If you wish to seek access to or correct or update any personal information we hold about you, or to unsubscribe from or change your contact preferences in relation to our direct marketing, you can also contact us as follows:

1. Phoning the Thriving Customer Relationship Centre on 9971629973
2. Emailing us at reach@dehurdle.com
3. Writing to us at: Thriving Billions Private Limited, Tower C, Apartment No 802 Ireo Uptown, Sector 66, Haryana, Gurgaon 122018 India.