1 Scope & Preamble
VITRO Technologies Private Limited ("VITRO", "Company", "we", "our", or "us") operates a multi-vertical on-demand technology ecosystem comprising the VITRO Customer App, VITRO Merchant Partner App, VITRO Rider Partner App, and associated web properties.
We consider user privacy and data security foundational to our service. This Privacy Policy sets forth our mandatory data handling practices under the Digital Personal Data Protection (DPDP) Act, 2023 (India), the Information Technology Act, 2000 (along with the Sensitive Personal Data or Information Rules, 2011), the General Data Protection Regulation (GDPR), and Google Play Store and Apple App Store user data safety policies.
2 Data Taxonomy & Categories Collected
We limit data collection to the absolute minimum necessary to fulfill our contracts with you. The categories of data processed include:
| Data Category | Specific Data Points | Primary Purpose |
|---|---|---|
| Identity Data | Full Name, Mobile Number, Email Address, Profile Avatar | Account authentication, OTP verification, customer support, and user profile management. |
| Spatial & Geolocation | Real-time GPS coordinates (latitude, longitude), geocoded addresses, route vectors | Store proximity matching, turn-by-turn navigation, geofenced OTP validation, and rider dispatch. |
| Transaction & Financial | Order records, transaction reference IDs, UPI UTR numbers, Wallet balance | Order settlement, automated refunds, billing reconciliation, and anti-fraud auditing. |
| Partner KYC & Vetting | Driving License, Vehicle Registration (RC), Aadhaar verification, Store FSSAI/GST certificates | Mandatory regulatory compliance, criminal background vetting, and transport safety assurance. |
| Technical Telemetry | Device OS, app build version, IP address, push notification tokens (FCM/APNS) | Push alerts for order tracking, crash reporting, API rate limiting, and brute-force intrusion defense. |
3 Legal Grounds for Processing
Under applicable data protection frameworks, we process your personal data under the following legitimate grounds:
- Contractual Performance: Necessary to match, execute, route, and deliver your food, grocery, ride, or courier request.
- Explicit Consent: Granted by you when enabling device permissions (e.g., GPS background location, push notifications, camera for QR code scanning).
- Legal Obligation: Necessary to comply with tax laws, transport safety regulations, fraud prevention statutes, and lawful law enforcement requests.
- Vital Interests & Emergency Safety: In urgent situations involving passenger or driver road safety, sharing real-time ride tracking with designated emergency contacts.
4 Precise Location & Geofencing Policies
Precise location is critical to the operation of an on-demand logistics network. We operate under strict spatial minimization rules:
- Customer App: Location coordinates are requested solely during app active use to present nearby serviceable stores and deliver to your doorstep. We do not track customer location in the background when the app is closed.
- Rider Partner App: Location tracking operates while the rider is marked "On-Duty" to assign nearby pickup orders and provide passengers with live turn-by-turn ETA. Riders can toggle "Go Offline" at any time to immediately cease telemetry broadcasting.
- Geofenced Handshake: To protect merchants and consumers from false status updates, order arrival at store and customer doorstep requires a 300-meter GPS radius validation before status transitions are permitted.
5 Data Retention & Automated Purge Cycles
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy:
- Live Telemetry & GPS Breadcrumbs: Active ride and delivery breadcrumbs are downsampled and converted to aggregated distance records within 90 days of order completion.
- Order & Financial Records: Retained for 7 years in compliance with Indian taxation, GST, and corporate audit statutes.
- Authentication Tokens & Sessions: Mobile JWT session tokens expire automatically within 30 days of inactivity; Redis rate-limit tokens expire within 5–15 minutes.
- Partner KYC Archives: Maintained for the duration of the partner's active platform contract plus statutory limitation periods for road liability.
6 Technical & Organizational Security
VITRO implements defense-in-depth security controls reviewed against the OWASP Top 10 and ISO 27001 guidelines:
- Data in Transit: 100% of network traffic enforced via TLS 1.3 with HSTS (HTTP Strict Transport Security) and strong cipher suites.
- Data at Rest: MongoDB databases and backup snapshots are encrypted using AES-256 bit hardware-level encryption.
- Credentials: Passwords are one-way hashed using
bcryptwith 12 salt rounds. Secret keys and JWT signing credentials utilize distinct per-role secrets. - Dual OTP Handshake: Pickups and deliveries utilize cryptographically generated 4-digit codes with timing-safe comparison to prevent theft and unauthorized deliveries.
7 Third-Party Sub-Processors & Data Sharing
To provide high-availability infrastructure, VITRO contracts with SOC-2 and ISO-27001 certified sub-processors under strict Data Processing Agreements (DPAs):
- Cloud Infrastructure: MongoDB Atlas (Database), Cloudflare (CDN & Edge Security), AWS (Cloud Computing).
- Payment Processing: Razorpay Software Pvt. Ltd. (RBI-authorized Payment Aggregator, PCI-DSS Level 1 compliant).
- Mapping & Routing: MapLibre, OpenStreetMap, and OSRM for privacy-friendly geospatial road routing.
- Communication & SMS: Firebase Cloud Messaging (Google) for transactional push alerts; Telecom-authorized SMS gateways for login OTPs.
8 User Rights & Permanent Account Deletion
In full accordance with global privacy mandates and the Indian DPDP Act, every VITRO user holds the following unconditional rights:
- Right to Access & Portability: You can download a machine-readable JSON copy of your profile and order history directly via App Settings ➔ Privacy ➔ Export My Data.
- Right to Rectification: Edit your name, phone number, and saved delivery addresses at any time.
- Right to Erasure ("Right to be Forgotten"): You can permanently delete your account directly inside the app (Settings ➔ Account ➔ Delete Account). Upon request, all personal identifiers, addresses, and saved preferences are permanently sanitized within 30 days, subject only to statutory tax retention requirements.
9 Grievance Redressal & Data Protection Officer
Pursuant to Section 5(9) of the Digital Personal Data Protection Act, 2023 and Rule 5(9) of the Information Technology Rules, 2011, the details of our designated Grievance Redressal Officer are as follows:
Grievance & Data Protection Officer
VITRO Technologies Private Limited