Privacy Policy

Important Notice Concerning Your Privacy Rights Poorakh India Services Private Limited. Effective Date: July 10,2022

Thank you for choosing Poorakh India Services (the "Poorakh India Services") made available to you by Poorakh India Services Private Limited (the "Company"), provided to you through the website and/or web application accessed at https://www.Poorakh India.com (the "Website"), mobile applications and other digital applications (collectively, the "Mobile Application" and, when referenced together with the Website, the "Application"), provided by us and made available to you through third party application distribution sites ("App Distribution site). The terms "we: "our," and "us" in this Privacy Policy refer to the Company.

This Privacy Policy covers both our "online" (e.g., digital and mobile services, including any websites and applications operated by us including, the Application however accessed and/or used, whether via personal computers, mobile or other electronic devices, including, without limitation, smartphones, tablets, or any electronic device (collectively, "Device)) and "offline" (e.g., collection of data through mailings, telephone, or in person) activities owned, operated, provided, or made available by the Company. Our "online" and "offline" activities are collectively referenced in this Privacy Policy as the "Poorakh India Services" or the "Services".

By using the Poorakh India Services or by otherwise giving us your information, you agree to the terms of this privacy policy.

Types of Information We Collect

a) Information You Provide To Us

Personal Information. Personal information is captured when you browse, access, register or use the Services and/or download and install the Application. When you use the Application, we may ask you to provide us with certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address, and mobile number ("Personal Information"). The information provided in the user profile and/or in connection with your request for Poorakh India Services is voluntarily furnished by you. We may collect this information through various forms and in various places through the Poorakh India Services, including through the Application, account registration forms, contact us forms, over the phone with one of our call center agents, or when you otherwise interact with us. The current required data fields with respect to a request for Poorakh India Services are:

• First Name

• Last Name

• Mobile Phone Number

• Email Address

• Current Location Information, including the address, city, state where you and your vehicle are currently located and the location type of your current location (residence, work/office building, street, highway, parking garage, parking lot, or other)

• Vehicle Information (Make, Model, Color, and Year)

• Preferred method of contact (Email or Text)

• For payment, you will be required to provide your credit card number, expiration date, security code, and billing zip code.

b) Automatically Collected Information

In addition to any Personal Information or other information that you choose to provide to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services ("UsageInformation"). Usage Information may include,

• Usage Details. When you access and use the Application, we may automatically collect certain details of your access to and use of the Application, including, date, time and duration of your use, and/or the specific pages, buttons, images, videos, links, or forms that you access on this Application.

• Device Information. We may collect information about your Device, including, the preferred language and country site (if applicable); your Device's unique device identifier, the type and version of software, internet browsers and operating system you use; type of Device (e.g. laptop, smartphone, tablet), including the manufacturer and model of your Device; your IP address and Internet service provider; and your Device's mobile operating system, mobile network provider and mobile phone number.

• Location Information. This Application may collect information about the real-time geographic location of your mobile Device.

If you do not want us to collect this information, please do not use the Application and, if applicable, uninstall the Mobile Application from your Device.

Information Collection and Online Tracking Technologies

This Application may use tracking technologies to automatically collect this information. A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):

Cookies

We may collect and track information (including personal information) on your Device using mechanisms such as cookies. A cookie is a data file placed on a Device when it is used to access the Services. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your Device. If you choose to disable cookies on your Device, the functionality of the Application may be impacted or not function. Since every browser and Device is different, you will need to follow your browser's instructions for disabling or deleting cookies.

Online Tracking

This Application does not respond to web browser "Do Not Track" signals or other similar mechanisms regarding the collection of personal information.

Third Party Information Collection

When you use the Application, certain third parties may use automatic information collection technologies to collect information about you or your Device. These third parties may include, the manufacturer of your Device, the App Distribution Site, the web browser that you use, your mobile network provider and/or your Internet service provider. The information these third parties collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, applications and other online services websites. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have questions about an advertisement or other targeted content, you should contact the responsible service provider directly to obtain instructions for how to opt-out of having your information collected or used in this way.

How We Use and Share Your Information

We use the information we collect from you to administer our business, provide superior service, offer opportunities that we think would be of benefit to you, and ensure technological compatibility with your Device.

The information we collect is used to help deliver the Poorakh India Services that you request. From time to time, we may use and share information that personally identifies you to our affiliates and to other non-affiliated entities including in the following manner:

• As may be required to deliver the requested Poorakh India Services, including sharing selected information with, our affiliates, and other third party companies and individuals to (i) facilitate our Services (which may include, without limitation, wireless service providers and internet service providers), (ii) provide or perform certain aspects of the Poorakh India Services on our behalf — such as Poorakh India and towing service providers, emergency service providers, first responders, automobile dealers, service centers and repair shops, (iii) host the Services, design and/or operate the Services' features, track the Services' analytics, (iv) process payments, including debit and credit card payments through the Application, (v) engage in anti-fraud and security measures, (vi) provide customer support, (vii) provide geo-location information to our call center agents and service providers, (viii) enable us to send you special offers, promotions or marketing communications concerning products or services that may interest you; (ix) enable us to perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services' features), and/or (x) perform other administrative services. We may use third party analytics service providers to evaluate and provide us with information about the use of the Services and viewing of our content; these analytics service providers may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information. We may use a third-party hosting provider who hosts our support section of our website. Information collected within this section of our web site is governed by our Privacy Policy.

• We may share your information, including your Personal Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Blink Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of some or all of our equity and/or assets, or other corporate change of control, including, during the course of any due diligence process related to such corporate change.

• We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; (ii) to protect and/or defend the Terms for Poorakh India Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Company, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP address or other unique Device identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.

• As disclosed in other applicable policies, terms of use, or other agreements.

• As permitted or required by law or as authorized by you.

a) You agree that the Company may collect and use technical and related information, including but not limited to information about your Device, system, application software, peripherals, and other similar information, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to this Application. The Company may also use this information to operate and improve our Application and Poorakh India Services, our products and/or services or to provide better services or technologies to you moving forward; to create aggregated and anonymised information to determine which Application features are most popular, useful to users, and for other statistical analysis; and to customize the content or services in the Applications for you, or the communications sent to you through the Application.

b) The Poorakh India Services provided through this Application rely upon location information. To provide these Poorakh India Services, the Company, its affiliates and partners may transmit, collect, maintain, process and use your location data, including the real-time geographic location of your Device for the purposes of performing the Poorakh India Services requested. By using this Application, you agree and consent to the Company, its affiliates and partners' transmission, collection, maintenance, processing and use of your location data to provide you with Poorakh India Services, which may include, without limitation, the identification of your current location in order to dispatch an ISP to perform the Poorakh India Services requested, and, if applicable, to assist you in determining your preferred tow-to location. The location data is collected in a form that personally identifies you and/or your vehicles. You may at any time opt-out from allowing the Application to use your location information by turning off this feature at the Device level, by going into Settings and switching off "Location Services" for the Application. Note, however, that opting out of the Application's collection of location information will cause its location-based features to be disabled and some parts of the Application may then be inaccessible or not function properly. We also provide some of your Personal Information to the ISP (which includes the Personal Information provided by you in your request for Poorakh India Services, your current location information and any additional information or notes provided by you in connection with your request), so that the ISP may find you and has all relevant information necessary in order to perform the Poorakh India Services.

c) You acknowledge and agree that communications, including phone calls or "chat" services, with the Company or its third-party agents may be monitored or recorded and retained by the Company. You consent to the monitoring and recording of all conversations between you the Company and you release us from and against any and all claims, liabilities and losses that may result from any such monitored and/or recorded conversations.

d) Email communications and text messages sent from us or through us are designed to make your experience using this Application and receiving Poorakh India Services more efficient.You expressly acknowledge and agree that, we may communicate with you by email, telephone or text message (including communications sent by automated equipment or interactive voice response), in accordance with your preferences designated in your user profile or in your specific request for Poorakh India Services, (i) in response to your inquiries, (ii) in connection with the Poorakh India Services requested, (iii) to confirm customer satisfaction, (iv) to inform you of updated features and services, and (v) to manage your account. If you change your mobile phone service provider, the notification service may be deactivated for your phone number and you may need to re-enroll in the notification service. We reserve the right to cancel the notification service at any time. You may cancel (opt-out) of receiving future email and/or text message communications from us at any time by following the instructions to unsubscribe provided at the bottom of an email sent to you and/or by replying to a text message sent to you with a reply text message containing the word STOP.

Our definition of Personal Information does not include "aggregate" information. Aggregate information is data we collect about a group or category of products, services or customers, from which individual customer identities have been removed. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but no personally identifiable information will be included in the resulting data. Likewise, information about the services and/or products you purchase may be collected and combined with information about the services and/or products purchased by others. Aggregate data helps us understand trends and customer needs so that we can better consider new products and services, and tailor existing products and services to customer desires. We may disclose to third parties aggregated information about our users, such as aggregated user statistics and log data and other information that does not identify any individual or Device, without restriction.

Security

The Personal Information and Usage Information we collect is stored within our databases on cloud-based servers (which we may elect at any time to transfer to servers stored within our facilities), with the use of standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information - such as any portions of your credit card number which we retain and geo-location information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to the Company you do at your own risk.

Links and External Websites

This Application may contain links to and from websites. We make no representations whatsoever about any other website that you may have accessed from our website or through this Application. We are not responsible for the privacy practices or content of those websites and we expressly deny any liability whatsoever for use of such websites. It is up to you to take precautions to ensure that whatever you select for your use is free of items of a destructive nature.

Notice to Persons Accessing this Application Outside India

If you reside outside the India, any information you provide to us on this Application will be transferred out of your country and into India. If you do not want your personally identifiable information to leave your country, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to India Personally identifiable information collected on this Application or during the provision of Poorakh India Services may be stored and processed in India or any other country in which the Company or its affiliates, subsidiaries or service providers maintain facilities.

Maintaining Your Account Information

You are responsible for the accuracy of the information you submit to us, such as your contact information provided as part of your request for Poorakh India Services. We will retain your Personal Information and Usage Information (including geo-location) for as long as your account with the Services is active and as needed to provide you services. Even after your account is terminated, we will retain your Personal Information and Usage Information (including geo¬location, trip history, credit card information and transaction history) as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively.

Changes to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Application prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Questions or Comments

Should you have any questions, comments, complaints or claims relating to the Application, the Poorakh India Service or this Privacy Policy, please contact us at Poorakh India Services Private Limited., registered at A-140, Sector-63, Noida, Uttar Pradesh, India (201301), Attention: Legal/Consumer Privacy Inquiries Mailbox (Poorakh India); or by email at info@Poorakh India.com. Please be sure to provide sufficient detail so that we may appropriately respond to your question or concern.

Information We Collect / Disclose

Through our website and/or the provision of Services, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (" personal information"). In particular, through the provision of Services, Poorakh India has collected the following categories of personal information from consumers, and/or disclosed for a business purpose such categories to third parties, within the last twelve (12) months:

• Name

• Address

• Vehicle details

• Age

• Gender

• Aadhar card

• PAN card

• Riding Quality

Note: The information collected may change with time.

Personal information does not include:

• Publicly available information from government records.

• Deidentified or aggregated consumer information.

• Information specifically excluded from the CCPA's scope.

Sources of Personal Information

Poorakh India obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, (i) by calling or electronically accessing one of our call centers to request Services or make inquiries, (ii) by the submission of your information through written or electronic forms you complete, or products and services you request through any communication channel (this includes your purchase of a retail motor club membership or your purchase of on-demand services at the time of your vehicle's disablement).

• Indirectly from you. For example, from observing your actions when visiting our website(s) or requesting Services through our website(s), mobile applications or other digital channels.

• From Clients. For example, when you enter into a Service Agreement with a Client, the Client will share your personal information with us so that we may provide Services to you on behalf of the Client.

• From independent contractors providing us services. For example, we may receive certain personal information about you, including, without limitation your real-time geolocation, in connection with the emergency services provided.

• From dealers, repair facilities, overnight storage facilities, vehicle inspection stations, salvage lots and other third parties that provide similar services. For example, we may receive certain personal information about you, including, without limitation, your name, phone number, vehicle information, and vehicle location as part of a request to pick-up or deliver the disabled vehicle to these types of locations, or information related to repairs, including, without limitation, the date of loss of service, the repair services provided to your vehicle and the costs associated with such repair services.

Use of Personal Information

We may use, or disclose the personal information we collect from consumers for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to request services, make customer service related inquiries, or obtain information related to a recent transaction, we will use and disclose that information to facilitate performance of the requested services.

• To comply with contractual requirements with our Clients, including data retention requirements.

• To process your requests, transactions, and payments and prevent transactional fraud.

• To provide you with support and to respond to your inquiries, reviews, comments or other feedback you provide us, including to investigate and address your concerns and monitor and improve our responses.

• To help maintain the safety, security, and integrity of our website(s), digital services, databases and other technology assets, and our business.

• To perform analysis to better understand the Clients' customers, our suppliers and customers, and to assist with product testing and product development, including to develop and improve our website(s), digital services, and Services.

• To comply with legal, regulatory or administrative requirements of governmental authorities.

• To respond to judicial proceeding, subpoena, court order or other legal process; or as reasonably necessary to (i) investigate, prevent or take action regarding suspected or actual illegal activities; (ii) investigate and defend ourselves against third party claims or allegations; or (iii) protect the security or integrity of our Services.

• As described to you, or directed or authorized by you, when collecting your personal information, or as otherwise set forth in applicable law, including the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Poorakh India's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Poorakh India about you is among the assets transferred.

Poorakh India will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Poorakh India may disclose your personal information to a third party for a business purpose.

We share your personal information with the following categories of third parties:

• Service providers who are towing, roadside, and vehicle repair industry participants, and other service providers that provide support services. We share your information with companies we work with in connection with the provision of our Services. These companies provide services that include towing and Poorakh India, vehicle appraisal, vehicle repair, call center services, customer support, payment processing, cloud computing and communications, data analytics, document and records management, data backup and recovery, digital communications, and other support services. These companies will only have access to your personal information that is reasonably necessary to perform services on our behalf.

• Third parties who provide customer requested services, such as ride sharing, taxi services, vehicle repair, vehicle transport, concierge services, public emergency and first response services, and membership discount benefits.

Sales of Personal Information

In the preceding twelve (12) months, Poorakh India has not sold personal information of consumers

Your Rights and Choices

The CCPA provides consumers who are Indian residents with specific rights regarding their personal information. This section describes your rights and explains how you may exercise those rights.

A.Access to Specific Information and Data Portability Rights

You have the right to request that Poorakh India disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (please see the Section titled "Exercising Access, Data Portability, and Deletion Rights" below), we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

•If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o Sales, identifying the personal information categories that each category of recipient purchased; and

o Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to request that Poorakh India delete any of your personal information that we collected from you and retained, subject to certain permitted exceptions. Once we receive and confirm your verifiable consumer request (please see the Section titled "Exercising Access, Data Portability, and Deletion Rights" below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if permitted under the CCPA, including situations in which retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide the services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Other situations as may be permitted by law.

B. Exercising Access, Data Portability, and Deletion Rights

If you are receiving Poorakh India Services and benefits through a Service Agreement between you and a Client, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request directly to the Client by visiting the Client's website.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including the information and documentation required on the Data Access, Portability and Deletion Request Form.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, along with such other required information as specified on the Data Access, Portability and Deletion Request Form to validate and verify the authenticity of the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Making a verifiable consumer request does not require you to create an account with us. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Poorakh India & Poorakh India logo are trademarks of Poorakh India Services Private Limited.

Poorakh India Services Private Limited, doing business as Poorakh India Services or Poorakh India Services or Poorakh India

©2022 Poorakh India Services Private Limited. All rights reserved.