PRIVACY POLICY

SPIDON RIDERS MOBILE APPLICATION

Effective Date: July 8, 2026

Last Updated: July 24, 2026

1. CORPORATE IDENTIFICATION & STRUCTURAL SCOPE

This Privacy Policy ("Policy") establishes the comprehensive legal and operational protocols governing the compilation, transmission, storage, structural processing, and lawful disclosure of personal, professional, telemetric, and regulatory data acquired from independent transport providers, fleet drivers, delivery agents, and logistics partners ("Riders", "Drivers", "You", or "Your") by SPIDO Mobility Private Limited ("Company", "We", "Us", or "Our").

The Company is incorporated under the statutory framework of the Companies Act, 2013, via the Ministry of Corporate Affairs (MCA), Government of India, registered under Corporate Identity Number (CIN) U49224MP2026PTC083412. Our legally declared statutory registered address is located at D-196, ALKAPURI, Ujjain Madhonagar, Ujjain, Ujjain, Madhya Pradesh, India, 456010, and our principal corporate operations desk is structured at our Office Address: 2nd Floor, 24/4, above Speed Colorlab, near Vasavada Petrol Pump, Freeganj, Madhav Nagar, Ujjain, Madhya Pradesh 456010.

This Policy strictly applies to the SPIDON Riders mobile application ("Rider App") available on the Android platform. By downloading, completing the merchant registration sequence, logging into, or interacting with the Rider App, you acknowledge that you are operating as an independent merchant, commercial service provider, or third-party contractor, and you provide your absolute, explicit, and informed consent to the data dynamics outlined in this document.

2. STATUTORY ALIGNMENT & REGULATORY COMPLIANCE

The processing architecture within the SPIDON Riders App is carefully structured to remain fully compliant with contemporary Indian digital governance laws and transport frameworks, specifically:

• The Digital Personal Data Protection (DPDP) Act, 2023, acting as a Data Fiduciary managing the records of our onboarding partners (Data Principals).
• The Motor Vehicle Aggregator Guidelines, 2020 (and subsequent state-specific amendments for Madhya Pradesh) issued by the Ministry of Road Transport and Highways (MoRTH), Government of India.
• Section 43A and Section 72A of the Information Technology Act, 2000 along with the Information Technology Rules, 2011.
• The latest Google Play Developer Program Policies regarding prominent in-app disclosure, explicit consent capture, and minimal data access for high-risk background processing.

3. DETAILED REGULATORY AND PROFESSIONAL DATA COLLECTION

To safely manage our digital marketplace, combat commercial identity fraud, and verify legal transit authority, the Company collects several data points from you:

A. Statutory Onboarding & Verification Data (DL & RC APIs)

Before a Rider account can be activated for dispatch tracking, we perform programmatic background checks using certified, secure third-party verification APIs linked to national and state registries (including VAHAN and SARATHI frameworks):

• Driving Licence (DL) Records: Programmatic extraction and verification of your raw DL number, name, date of birth, license status, expiration date, and vehicle class endorsement (e.g., transport, non-transport, two-wheeler, light motor vehicle).
• Registration Certificate (RC) Records: Automated verification of vehicle registration plates, engine numbers, chassis numbers, commercial fitness test logs, pollution under control (PUC) statuses, and commercial insurance policies.
• Identity Verification Parameters: Masked Aadhaar card coordinates collected via secure e-KYC channels, Permanent Account Number (PAN) profiles for compliance with Indian Income Tax laws (including TDS under Section 194C and Section 194O), and mandatory criminal background verification records or police clearance certificates.

B. Device, Hardware, and Telemetric Technical Logs

• Hardware Context: Manufacturer name, commercial model designation, Android OS version, IP addresses, internet service provider details, MAC addresses, and unique device identifier tokens (including Android ID and IMEI numbers).
• Sensor Analytics: Continuous monitoring of internal hardware sensors—including the device's accelerometer, gyroscope, and compass data—to compute speed dynamics, identify erratic driving, analyze sudden deceleration events, and record severe transit shocks that may indicate road accidents.

4. MANDATORY CRITICAL DISCLOSURE: PERSISTENT BACKGROUND LOCATION TRACKING

CRITICAL GOOGLE PLAY CONSOLE POLICY COMPLIANCE NOTICE:

The SPIDON Riders App compiles, processes, and transmits precise real-time geolocation telemetry (including fine GPS coordinates, cellular network triangulation variables, and nearby WiFi signal maps) in the background. This tracking is persistently executed even when the application is closed, completely minimized, running implicitly behind other operational programs, or when the mobile device display screen is locked.

Core Functional Reasons Supporting Background Location Capture:

1. Algorithmic Dispatch & Proximity Allocation: To guarantee balanced marketplace dispatching, the platform's core matching engine relies on continuous location logs to assign incoming user pick-ups, vehicle rental updates, or upcoming food delivery dispatches to the geographically closest available Rider. This prevents dispatch delays and optimizes driver efficiency.
2. Dynamic Metering & Fare Verification: Your payouts are calculated mathematically using precise physical distances traversed and total trip time elapsed. Background tracking guarantees that if network connectivity drops or you switch to an alternative app (such as external map navigators) during an active ride, your trip metrics are fully captured to prevent payment discrepancies.
3. Emergency Monitoring & State Aggregator Safety: In strict compliance with the Motor Vehicle Aggregator regulations, background location monitoring feeds directly into our real-time safety system. This allows the Company to immediately flag unauthorized route deviations, abnormal stationary statuses, or respond directly to emergencies if panic buttons are activated within the system.

5. DETAILED PROCESSING PURPOSE MATRIX

Rider datasets are processed exclusively for specific operational and legal functions, summarized in the matrix below:

6. DATA SHARING PROTOCOLS & THIRD-PARTY LIMITATIONS

The Company maintains absolute confidentiality over all Rider profiles. We do not sell or lease driver databases to third-party marketing companies. Data is shared only with the following entities:

1. With the End User (Customer): Once a ride, rental request, or food delivery dispatch is confirmed, your first name, vehicle registration plate details, profile photo, cellular phone number (protected via routing or masking technologies), and real-time map location are transmitted to the customer via the "SPIDON" User App to facilitate the booking.
2. With State and Central Transport Authorities: In accordance with the conditions of our aggregator operations in Madhya Pradesh, all driver registries, vehicle fitness tracking logs, and active trip telemetry are subject to inspection by lawful regulatory requests.
3. With Banking Providers and Tax Aggregators: Your financial profiles and transaction history metadata are shared securely with RBI-regulated payment gateways to handle your earnings distributions.

7. DATA SECURITY, MINIMIZATION, AND PROTECTIVE COMPLIANCE

• Transit Encryption: All programmatic telemetry, identity parameters, and API interactions are encrypted using secure Transport Layer Security (TLS 1.3) protocols.
• Storage Security: Critical identifiers and background check records are secured on our servers using Advanced Encryption Standard (AES-256) encryption.
• Data Minimization Frameworks: In accordance with Google Play's privacy requirements, the SPIDON Riders App does not request access to personal contact lists, global device call histories, or generic shared storage directories.

8. RIDER RIGHTS UNDER THE DPDP ACT, 2023

As a Data Principal in India, you hold fundamental legal rights regarding your information, which you can manage by raising formal queries through https://helpdesk.spidomobility.com/:

• Right to Review & Summarize: You can request a clear report detailing all personal data we process, along with a list of the third-party verification engines used.
• Right to Correction & Alignment: You can update old or inaccurate driver credentials or vehicle profiles on the system at any time.
• Right to Deactivation & Account Erasure: If you decide to cease operating on the SPIDON marketplace, you may request account deactivation. Your background tracking immediately ceases upon app uninstallation or logging out. Certain vehicle log details are legally kept for an archived timeframe to comply with state accident liability and tax audits.

9. SCHEDULING MODIFICATIONS AND POLICY EXPANSIONS

As SPIDON Mobility Private Limited rolls out its upcoming Food Module services, specialized multi-modal vehicle rentals, or updates its tracking features across Madhya Pradesh, this Policy will be adjusted accordingly. When amendments are implemented, we will update the "Last Updated" date at the top of this document and publish an explicit prompt inside the SPIDON Riders App to capture your updated electronic signature or consent confirmation.

10. GRIEVANCE REDRESSAL DESK AND DISPUTE RESOLUTION

In accordance with the provisions of the IT Rules, 2011, and the rules of the DPDP Act, 2023, the contact details of our internal Grievance Officer are published below for any security concerns or data processing inquiries:

Attn: Grievance Redressal Officer (Rider Relations Division)

Legal Desk: SPIDO Mobility Private Limited

Office Address: 2nd Floor, 24/4, above Speed Colorlab, near Vasavada Petrol Pump, Freeganj, Madhav Nagar, Ujjain, Madhya Pradesh 456010

Corporate Email Inquiries: support@spidomobility.com & spidomobility2026@gmail.com

Toll Free Helpline: 18002020877

Digital Support Portal: https://helpdesk.spidomobility.com/

Copyright © 2026 SPIDON Mobility Private Limited. All Rights Reserved.