Privacy Policy

Last Updated: May 14, 2025

This Privacy Policy explains how Druscilla Private Limited (“Druscilla,” “we,” “us,” or “our”), a company incorporated under the Companies Act, 2013 [CIN: U47711UP2023PTC183575], with its registered office at 52, Ground Floor, Block F, Pratap Vihar, Ghaziabad, Uttar Pradesh – 201009, India, collects, uses, shares, stores, and protects personal data in connection with the Motorbuff mobile application and related services (collectively, the “Service”). By using the Service, you (“User,” “you,” or “your”) consent to the data practices described in this Privacy Policy, in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and other applicable laws.

1. Scope of this Privacy Policy

This Privacy Policy applies to all personal data collected through the Service, including data provided by users, collected automatically, or obtained from third parties. It does not apply to third-party websites, services, or applications linked from the Service, which are governed by their own privacy policies. Please review the privacy policies of any third-party services you access.

2. Data We Collect

We collect the following types of data to provide, improve, and personalize the Service:

2.1 Personal Data Provided by You

• Account Information: When you register for an account, we collect your name, email address, phone number, and other details you provide.
• User Content: Content you post, such as reviews, photos, or vehicle listings, may include personal data (e.g., your name or contact details).
• Communications: Information you provide when contacting us (e.g., via contact@druscilla.com or grievance@druscilla.com) or consenting to receive notifications (e.g., SMS, email).
• Payment Information: If you use premium Services (if introduced), we collect payment details (e.g., card information, UPI ID) through secure third-party gateways. We do not store payment details directly.

2.2 Data Collected Automatically

• Usage Data: Information about your interactions with the Service, such as pages viewed, features used (e.g., vehicle comparisons, discussions), time spent, and search queries.
• Device and Technical Data: Device type, operating system, IP address, browser type, unique device identifiers, and crash data.
• Location Data: Approximate location (e.g., city-level) based on IP address or precise location (if you enable location services) to provide location-based features (e.g., dealer locations).
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track usage, serve ads, and improve functionality. Third-party vendors (e.g., Google) may also use cookies for personalized advertising (see Section 6).

2.3 Data from Third Parties

• Third-Party Services: Data from third-party integrations (e.g., loan providers, insurance partners) if you connect to their services via the Service, subject to their privacy policies.
• Analytics Providers: Aggregated or anonymized data from analytics partners to understand usage trends.
• Advertising Partners: Data from ad networks (e.g., Google Ads) to serve personalized ads, as described in Section 6.

3. How We Use Your Data

We use your data for the following purposes, with your consent or as permitted by law:

• To Provide the Service: Create and manage your account, display vehicle information, facilitate user content posting, and enable features like vehicle comparisons or notifications.
• To Personalize Your Experience: Tailor content, recommendations, and ads based on your preferences and usage.
• To Improve the Service: Analyze usage data to enhance functionality, fix bugs, and develop new features.
• To Communicate: Respond to inquiries, send Service-related notifications (e.g., updates, account alerts), or marketing communications (with your consent).
• To Process Payments: Handle transactions for premium Services (if introduced) via third-party gateways.
• To Ensure Security: Detect and prevent fraud, unauthorized access, or violations of our Terms of Service.
• To Comply with Legal Obligations: Meet requirements under the DPDP Act, IT Act, 2000, or other laws, including responding to government requests.
• For Advertising: Serve personalized ads through third-party vendors (e.g., Google) based on your interactions with the Service or other websites.

4. Legal Basis for Processing

We process personal data based on:

• Consent: Your explicit consent for data collection, use, or sharing, as required by the DPDP Act (e.g., for marketing or location data).
• Contractual Necessity: To fulfill our obligations under the Terms of Service (e.g., providing account access or features).
• Legal Obligation: To comply with applicable laws or government requests.
• Legitimate Interests: For purposes like improving the Service, ensuring security, or serving non-intrusive ads, where such interests do not override your rights.

5. How We Share Your Data

We may share your data as follows, with appropriate safeguards:

• Service Providers: With third-party vendors (e.g., cloud hosting, analytics, payment processors) who process data on our behalf under strict confidentiality agreements.
• Advertising Partners: With ad networks (e.g., Google) to serve personalized ads, as described in Section 6.
• Third-Party Integrations: With partners (e.g., loan providers, insurance companies) if you choose to connect to their services, subject to their privacy policies.
• Legal Compliance: With government authorities or law enforcement to comply with legal obligations, respond to court orders, or investigate violations of our Terms of Service (e.g., fraud, illegal content).
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to you and safeguards for your data.
• User Content: Content you post (e.g., reviews, image posts) may be publicly accessible and shared with third parties (e.g., search engines, co-branding partners), as noted in Section 6.

We do not sell your personal data to third parties.

6. Third-Party Advertising and Content

The Service may include third-party advertisements or content (e.g., dealer details, vehicle specifications). Third-party vendors, such as Google, use cookies or other tracking technologies to serve personalized ads based on your interactions with the Service or other websites. For more information, visit Google’s advertising policies at https://policies.google.com/technologies/ads. You can manage or opt out of personalized ads via:

• Google’s Ads Settings: https://adssettings.google.com
• Network Advertising Initiative (NAI) opt-out: https://www.networkadvertising.org/choices

User Content you post (e.g., posts, reviews) may appear in search engine results (e.g., Google, Bing), caches, feeds, or third-party websites through co-branding or syndication agreements. Druscilla is not responsible for how third parties index, cache, or remove such content, and it is their responsibility to update or remove it.

7. Your Data Rights

Under the DPDP Act, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your data, subject to legal retention obligations (e.g., transaction records).
• Portability: Request a transferable copy of your data in a structured format.
• Withdraw Consent: Withdraw consent for data processing (e.g., marketing emails), though this may limit Service functionality.
• Grievance Redressal: Raise concerns about data handling with our Data Protection Officer.

To exercise these rights, contact our Data Protection Officer at support@druscilla.com. We will respond within 30 days, as required by law. You may also lodge complaints with the Data Protection Board of India if unsatisfied with our response.

8. Account Deletion

To delete your account and associated personal data:

1. Open the Motorbuff mobile application and log in.
2. Go to My Account > Profile Settings.
3. Select Delete Account, agree to the terms, and confirm.

Upon deletion, we will remove your personal data from our database, except for data required for legal or compliance purposes (e.g., transaction records, audit logs). Deletion requests can also be sent to contact@druscilla.com.

9. Data Security

We implement reasonable technical and organizational measures to protect your data, including encryption, access controls, and secure servers. However, no system is completely secure, and we cannot guarantee absolute security. In case of a data breach, we will notify you and the Data Protection Board of India within 72 hours, as required by the DPDP Act, and take steps to mitigate harm.

10. Data Storage and Retention

Your data is primarily stored and processed in India, in compliance with the DPDP Act. We retain personal data only for as long as necessary to:

• Provide the Service and fulfill our obligations under the Terms of Service.
• Comply with legal requirements (e.g., tax or audit records).
• Resolve disputes or enforce our rights.

After this period, we will securely delete or anonymize your data. For example, account data is deleted within 30 days of an account deletion request, except for legally required records.

11. International Data Transfers

If you access the Service from outside India, your data may be transferred to India for processing. Any cross-border transfers will comply with the DPDP Act and include safeguards like standard contractual clauses. By using the Service, you consent to such transfers where necessary.

12. Children’s Privacy

The Service is not intended for users under 18 years of age, as stated in the Terms of Service. We do not knowingly collect personal data from minors. If a minor provides data without parental consent, we will delete it upon discovery. Parents or guardians can contact contact@druscilla.com to request deletion of a minor’s data.

13. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze usage, and serve ads. You can manage cookie preferences through your device or browser settings. For third-party ad cookies, use the opt-out options in Section 6. Disabling cookies may affect Service functionality.

14. Updates to this Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted at www.druscilla.com/privacy-policy and notified via email, Service notification, or website posting. Changes take effect 7 days after notification. Continued use of the Service constitutes acceptance of the updated Privacy Policy.

15. Contact Us

For questions, concerns, or to exercise your data rights, contact:

• Data Protection Officer: contact@druscilla.com
• Grievance Officer: grievance@druscilla.com (for complaints about data handling or Service issues)
• Postal Address: Druscilla Private Limited, 52, Ground Floor, Block F, Pratap Vihar, Ghaziabad, Uttar Pradesh – 2010109, India

We will respond to inquiries within 30 days, as required by the DPDP Act and IT Rules, 2021. For urgent issues (e.g., unlawful content), we will respond within 72 hours.

16. Compliance with Applicable Laws

This Privacy Policy complies with the Digital Personal Data Protection Act, 2023, Information Technology Act, 2000, Information Technology (Intermediaries Guidelines) Rules, 2021, and other applicable Indian laws. In case of conflict with foreign laws, Indian law prevails, as the Service is primarily intended for users in India.