Privacy Policy – Windson Connect

PLEASE READ THIS PRIVACY POLICY CAREFULLY

Hexense Labs Private Limited, operating under the trade name Six Sense Mobility (“we”, “us” or “our”), regards your information as significant. We release this Privacy Policy to inform you what information we collect through the Windson mobile application and the related vehicle tracking services (the “Services”), which we have built and operate for Windson Motors and which Windson makes available to its customers, and how we use it to personalize and continually improve your experience.

Information We Collect

a. Personal Information. “Personal Information” is information that identifies you or another person, such as your first name and last name, physical address, email address and telephone number. We collect only the Personal Information that you give us when you register or contact us, and that is needed to provide the Services.

b. Vehicle Information. The telematics device fitted in your vehicle sends us data about your vehicle, such as its location, speed, distance traveled and operation.

c. Non-Personal Information. We collect your non-personal information when you visit and use our app. We may collect your information when you communicate with us or when you give it to us.

d. We also get your mobile device Id.

e. KYC Documents. The tracking device in your vehicle contains an M2M SIM. Telecom rules require the SIM user to be verified before the SIM is activated, so we collect KYC documents and details from you, such as a government-issued identity proof, address proof and photograph, as required by those rules.

f. Immobilization Records. If the Immobilization Feature is used for your vehicle (by you or by the Windson Motors dealer), we collect the immobilization or restore requests, the result of the PIN verification, the time of each request and the status returned by the vehicle.

How We Use Information

a. Personal Information. We use your Personal Information to provide the Services and to communicate with you about your account. We do not disclose your Personal Information, except as set out in this policy.

b. Non-Personal Information. We do not sell, trade, or otherwise transfer your information to outside parties, other than service providers who help us run the Services on our instructions.

c. We will use the device number for updating or deleting the push notification key (GCM/FCM) from our app’s database.

d. Legal Reasons. We will access, use or disclose your information with other organizations or entities for reasons required by any applicable law, regulation, legal process or enforceable governmental request; to detect, prevent, or otherwise address fraud, security, or technical issues; and to protect against harm to the rights, property, or safety of our company, our users, or the public, as required or permitted by law.

e. KYC Documents. We use your KYC documents only to activate and maintain the M2M SIM in your device and to meet telecom KYC rules. We share them only with our telecom service provider and, when the law requires, with the Department of Telecommunications and other authorities. We do not use them for marketing or for any other purpose.

f. Immobilization Records. We use these records to carry out Immobilization Feature requests, to check what happened in each case, and to resolve disputes.

Security

Our company is very concerned about safeguarding the confidentiality of your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access and use. Please be aware that no security measure that we take to protect your information is absolutely guaranteed to avoid unauthorized access or use, and no system is impenetrable. Your KYC documents are stored in encrypted form, protected by access controls, and can be seen only by authorized staff who need them for SIM activation or legal compliance.

KYC Documents and Data Protection

We handle your personal data, including your KYC documents, in line with applicable Indian law, including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023.

We keep your KYC documents only for as long as your SIM is active and for the period the telecom rules require after that. After this period, we delete them or make them unreadable.

You may ask us to show, correct or delete your personal data, or withdraw your consent, by writing to us at care@sixsensemobility.com. If you delete your KYC documents or withdraw your consent, the SIM and the services can no longer be provided, and we may have to keep some records where the telecom rules require it.

If a personal data breach affects your data, we will inform you and the authorities as the law requires.

Contact: Hexense Labs Private Limited (Six Sense Mobility), care@sixsensemobility.com.

Immobilization Feature

If the Immobilization Feature is available for your vehicle, it is operated only by you (the end user) or by the authorized Windson Motors dealer who has been given access to it. Only the end user or that dealer can enable, trigger or reverse immobilization through the app, and each use requires verification with the applicable security PIN. We do not start, schedule, approve or monitor any immobilization. We only send the request to the vehicle through the tracking device.

Please do not share your PIN with anyone. We will never ask you for it.

We keep a record of each request (whether made by you or by the dealer), its verification and the status returned by the vehicle, so that you and we can check what happened and resolve disputes. We keep these records for as long as your account is active.

Sensitive Information

We ask that you not send us, and that you not disclose, any sensitive Personal Information (for example, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background, or membership in past organizations, including trade union memberships) on or through the app, the Services or our website, or otherwise to us.

Children

The Services are not focused on children. If you are under 18, you may use our app only when you are with a parent or guardian.

Changes

Our Privacy Policy may change from time to time, but a change will not reduce your rights under this Privacy Policy. We will post any changes to the Privacy Policy on this page, so please review it periodically. If you do not agree to any modification, you may immediately stop using all the Services. Your continued use of the Services after a modification is posted will constitute your acceptance of the revised policy. Please note that none of our employees or agents has the authority to vary any of our policies.

Grievance Officer

If you have questions about this Privacy Policy, want to use your rights, or wish to make a complaint, please contact our Grievance Officer:

Name: Rishabh Jain

Email: care@sixsensemobility.com

Address: Hexense Labs Private Limited (Six Sense Mobility), D 182, Hosiery Complex, Block D, Phase-2, Noida, Uttar Pradesh 201304

We will acknowledge your complaint within 20 days and aim to resolve it within 20 days.

Governing Law

This Privacy Policy is governed by the laws of India. Any dispute about it is subject to the jurisdiction of the courts at Delhi, India.