(January 2025)

Clipped Assist India Pvt Ltd Privacy Policy

Clipped Assist is committed to providing quality services to you and the Indian public. This policy outlines our continuous obligations with respect to how we manage your Personal Information in compliance with applicable Indian laws.

We have adopted and incorporated the provisions of the Information Technology Act, 2000, and any rules and regulations made thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“IT Rules”). This policy governs the way we collect, use, disclose, store, secure, and dispose of your Personal Information.

A copy of the IT Rules and other related information may be obtained from the website of the Ministry of Electronics and Information Technology at https://www.meity.gov.in.

What is Personal Information and Why Do We Collect It?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include but are not limited to:

• Names;
• Physical addresses;
• Email addresses;
• Phone numbers;
• Social media account information;
• Marketing information;
• Account log-in credentials;
• Troubleshooting and support data;
• Payment information;
• Identification information;
• Date of birth; and
• Timestamps for and types of activities (e.g., membership joining times,
  transaction/booking times, etc.).

Clipped Assist is affiliated with third parties to provide scratch and dent repair services. Personal Information is primarily collected by these third parties (pursuant to their respective privacy policies) that partner with Clipped Assist. We may obtain a copy of this information for delivering and maintaining our services. For the purposes of providing you and others with Clipped Assist’s services, we may also obtain your Personal Information from other third parties.

We collect your Personal Information for the primary purpose of:

• Providing our services to you and the third parties you have engaged with;
• Marketing and statistical analysis; and
• Meeting legal, regulatory, or contractual obligations.

You may unsubscribe from our mailing/marketing lists, alerts, notifications, or other general communication lists at any time by contacting us in writing.

Sensitive Personal Data or Information
Sensitive Personal Data or Information (“SPDI”) is defined under the IT Rules to include information about an individual’s passwords, financial information (such as bank account or credit card details), physical, physiological, and mental health conditions, sexual orientation, medical records, biometric information, etc.

This information may be collected by third parties engaged with us and shared with Clipped Assist for service delivery purposes. We may also collect SPDI directly from you where necessary for providing our services.

Clipped Assist collects SPDI for the primary purpose of:

• Providing, marketing, and improving vehicle scratch and dent repair services and related offerings; and
• Conducting business analysis and marketing research.

Use and Disclosure of Personal Information and SPDI
We will use and disclose your Personal Information and SPDI only for the following
purposes:

• For the primary purpose for which it was collected;
• For secondary purposes closely related to the primary purpose;
• For purposes disclosed to you and consented to by you; and
• As required by applicable laws and regulations.

By engaging with Clipped Assist, you consent to us using or disclosing your Personal
Information and SPDI for additional purposes, including:

• Sending system alerts, account notifications, and security updates;
•  Providing customer support and administering services;
• Enforcing compliance with terms of use and applicable laws;
• Complying with lawful requests from public authorities or courts;
• Sharing information with our service providers, legal advisors, or affiliates to enhance service delivery; and
• Conducting data analytics and personalized marketing.

Sharing Your Information
We may share Personal Information and SPDI with:

• Our service providers who support our operations;
• Advertising partners for marketing purposes;
• Law enforcement or government agencies as required by law;
• Potential buyers in case of a business merger or acquisition, subject to confidentiality obligations.

Data Retention
We retain Personal Information and SPDI as long as necessary to fulfill the purposes
outlined in this policy or as required by law. When no longer needed, we will delete or anonymize your data, or securely store it until deletion is possible.

Security of Personal Information
Your Personal Information and SPDI are stored securely to protect against misuse,
unauthorized access, modification, or disclosure. We employ reasonable security practices as mandated under the IT Rules.

When Personal Information and SPDI are no longer required, we will take reasonable steps to securely destroy or de-identify it. However, some records may be retained for a minimum period as mandated by law or regulatory requirements.

Cross-Border Data Transfer
We may transfer your Personal Information and SPDI to our affiliates or service providers located outside India. In such cases, we ensure that the data is transferred in compliance with applicable Indian laws, including ensuring a similar level of data protection as provided under Indian regulations.

Accessing and Updating Your Information
You have the right to access and update the Personal Information and SPDI we hold about you. To do so, please contact us in writing. We will take reasonable steps to ensure the information is accurate and up-to-date.

Complaints and Enquiries
If you have any queries or complaints about this privacy policy, please contact us at
[email protected]. We will respond to all queries within a reasonable time frame.

Changes to This Policy
We may update this privacy policy from time to time. The most recent version will be
available on our website, and we encourage you to review it regularly. By continuing to use our services after updates, you consent to the revised policy.

Consent
By engaging with or using Clipped Assist services, you acknowledge that you have read, understood, and agree to comply with this privacy policy.