Partner Privacy Policy

1. About This Policy

This Partner Privacy Policy explains how SetuRa Mobility Private Limited (“SetuRa”, “we”, “our”, or “us”) collects, receives, uses, stores, shares, protects and deletes personal data in connection with the SetuRa Partner Application (the “App”) and related operational services.

It applies to individuals authorised to use the App for an approved operational role (“Partners”): Marshals, Conductors, Bus Drivers and Cab Drivers. The information we process depends on each Partner’s actual role and duties.

This policy is a notice about our data practices. It supplements, and does not replace, the Partner Terms & Conditions and any employment, contractor, fleet-partner or other engagement agreement that applies to you. For our website and passenger services, see our general Privacy Policy.

2. Information We Collect

Depending on your role, we collect only the information reasonably necessary for it:

• Identity and contact information: name, mobile number, email address, profile details and profile photo.
• Verification and qualification records: identity documents, driving licence, qualification evidence and other documents required for your role’s eligibility and safety.
• Vehicle and compliance records (driving roles): vehicle registration, permits, insurance, fitness and inspection details.
• Duty and attendance records: assigned role, shift schedules, check-in and check-out events and duty status.
• Trip and location records: booking references, pickup and drop-off details, route events, timestamps, trip status and location coordinates (see section 5).
• Financial and transaction records: authorised fare records, transaction references, receipts, reimbursements and payment reconciliation details.
• Device, security and support information: device type, operating system, app version, login events, error logs, security events, support requests, complaints and incident records.
• Photos you take in the App: your profile photo and trip or incident evidence photos (see section 6).

3. How We Collect It

• From you: during registration, verification, profile updates, support requests and when you use the App.
• Through your use of the App: attendance records, trip events, location features and payment reconciliation.
• From authorised third parties, where permitted by law: fleet operators, transport partners and verification providers.

4. How We Use It

We use personal data to:

• Create and manage your account and verify your eligibility for your role.
• Allocate assignments, dispatch trips and record attendance.
• Coordinate passengers, boarding and trip progress.
• Administer payments, fares and reconciliation.
• Provide support and handle complaints.
• Protect safety, investigate incidents and prevent fraud.
• Keep the App and our systems secure and reliable.
• Comply with legal obligations.

By role: Marshals and Conductors use information for boarding verification, passenger coordination, attendance, ticketing and incident reporting. Bus Drivers and Cab Drivers also use licence and vehicle verification, dispatch details, navigation, trip status and safety information. Access is limited to what each role needs. Partners cannot view passenger or operational records unrelated to their assignments.

We do not use your information for a new or materially different purpose without first assessing it and, where required, giving you notice or asking for your consent. We do not sell your personal data.

5. Location Information

Location data is used for trip allocation, navigation, estimated arrival, attendance verification, route coordination, safety and the investigation of material incidents. It is available only to authorised SetuRa personnel and, where needed for the trip, the relevant fleet operator or transport partner.

We limit location collection to the precision, frequency and duration reasonably needed for these purposes. You can change the location permission at any time in your device settings. If you deny it, trip, navigation and attendance features that depend on location may not work, but this will not affect unrelated features.

6. Camera, Notifications and Other Permissions

The App asks for device permissions only for features that need them, and explains why when it asks:

• Camera: to take your profile photo and to capture trip or incident evidence photos. Photos are stored securely with your account or the related trip or incident record. They are visible only to authorised SetuRa personnel and, where relevant to a trip or incident, the fleet operator or transport partner involved.
• Notifications: for assignment alerts, trip updates and security messages. You can manage notifications in your device settings.
• Location: as described in section 5.

The App does not access your microphone or contacts.

We also process technical information such as device type, operating system, app version, error logs and security events to keep the App reliable and secure.

7. Passenger Information You Can See

To perform an assigned task, you may see limited passenger information such as names, booking references, contact details, pickup points, destinations or boarding information. You may use it only for the relevant service, approved coordination or complaint handling.

You must not export passenger lists, keep contact details for personal use, make unauthorised recordings or share passenger travel information with anyone else. Report any accidental disclosure or misuse to us straight away.

8. Sharing and Third-Party Services

We share personal data only where necessary for the purposes in this policy, and only the information each recipient needs:

• Authorised SetuRa personnel.
• Fleet operators and transport partners involved in your assignments.
• Service providers for hosting, communications, identity and document verification, maps and payments, under appropriate contractual and security safeguards.
• Courts, regulators, law enforcement or other authorities where required or permitted by law.

The App may use external services for maps, communications, authentication or payments. Information handled by those services is also subject to their own terms and privacy notices.

9. Storage and Security

Personal data is stored and processed on SetuRa systems and authorised third-party infrastructure, including cloud services. Any transfer outside India is handled in line with applicable Indian law.

We use reasonable technical and organisational safeguards. These include role-based access, authentication, secure transmission, encryption where appropriate, access logging, vulnerability management, staff confidentiality obligations and vendor controls. We review them regularly. No system can be completely secure, but this does not reduce our obligation to protect your data.

10. How Long We Keep It

We keep personal data only as long as needed for its purpose, our contractual obligations, dispute resolution, security investigations and legal requirements. When that basis ends, we securely delete or anonymise it.

• Account and verification records: for the duration of your engagement and any further period required for legal obligations or disputes.
• Attendance and duty records: as required by applicable contractual, employment, audit and legal requirements.
• Trip and location records: for operational coordination, safety investigations, disputes and legal requirements, not indefinitely.
• Financial and transaction records: for the periods required by accounting, tax, contractual and legal obligations.
• Support and incident records: while a matter is open and for any justified period afterwards for investigations, claims or legal obligations.
• Security logs and backups: under documented rotation and expiry procedures.

11. Your Rights and Consent

Subject to applicable Indian law, you may request:

• Access to information about the personal data we hold about you.
• Correction or completion of inaccurate personal data.
• Erasure of personal data, where permitted.
• Withdrawal of consent, where processing relies on consent.
• Information about our grievance process.

Send requests through the App, where available, or by emailing support@seturamobility.com. We may need to verify your identity, and we respond within the timelines required by law.

Accepting the Partner Terms & Conditions, giving privacy consent and granting device permissions are separate choices. Accepting the terms is not blanket consent to every kind of processing.

13. Automated Decisions

Automated systems may help with trip allocation, attendance validation, fraud detection, account security and operational recommendations. Material adverse decisions, such as restricting or suspending your account, are subject to review. You can ask for a review through the contact details below.

14. Children and Eligibility

The App is only for individuals who meet the minimum age and eligibility requirements for their role. It is not intended for children, and we do not knowingly authorise anyone ineligible to use it.

15. Security Incidents

If we become aware of a breach involving your personal data, we assess and contain it, preserve the relevant evidence and take remedial steps. Where the law requires, we notify affected individuals and the relevant authorities. Please report a lost device, compromised credentials or accidental disclosure of passenger information to us promptly.

16. Changes to This Policy

We may update this policy to reflect changes in law, App features, service providers or our data practices. We will tell you about material changes through the App or another appropriate channel and ask for renewed consent where the law requires it. The current version and effective date are always shown at the top of this page.

17. Contact and Grievances

For privacy questions, complaints or requests about your personal data, contact:

We record, assess and respond to complaints within the timelines required by applicable law. See our Grievance Redressal Policy for how complaints are handled and escalated.