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PRIVACY POLICY

Introduction

Welcome to Eicher Motors Limited’s privacy policy, applicable to the Flying Flea website (https://flyingflea.royalenfield.com/in/en) and the mobile application (collectively referred to as the "Platform"). Flying Flea, a brand by Royal Enfield (a unit of Eicher Motors Limited), is deeply committed to protecting your personal information when you are using our Platform. Our priority is to ensure that our digital services remain safe, secure, and transparent for all our users.

To achieve this, we rely on uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring, or otherwise processing your data. These standardized practices assist us in handling your personal information fairly and appropriately, ensuring it is only disclosed or transferred under appropriate circumstances. This privacy policy relates specifically to our use of any personal information we collect from you across the Flying Flea Platform.

This policy outlines exactly how we utilize the personal information gathered through our digital touchpoints. Please read this privacy policy thoroughly before using the Flying Flea Platform or submitting any personal details. Understanding these practices helps ensure a secure and trustworthy digital environment as you explore the world of Flying Flea.

1. Important information and who we are

Purpose

This privacy policy aims to provide you with comprehensive information on how we collect and process your personal data through your use of the Flying Flea website and mobile application (the "Platform"). This includes any data you may provide when you register interest, pre-book a vehicle, or sync your mobile device with your Flying Flea motorcycle. It is designed to help you understand what data we collect, why we collect it, and how we ensure its protection throughout its lifecycle.

Age Restriction

The Flying Flea Platform is designed for adults of legal riding age. It is not intended for children, and we do not knowingly collect or solicit any personal data relating to children. If we learn that we have collected personal information from a child without verifiable parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

Data fiduciary

Eicher Motors Limited ("we", "us" or "our" in this privacy policy) is the data fiduciary in respect of the processing of personal data as set out in this privacy policy.

Grievance officer

If you would like to exercise any of your legal rights in relation to your processing of personal data under this privacy policy or have any questions, concerns or complaints about this privacy policy or our privacy practices, please contact our Grievance Redressal Officer using the details provided below.

We will review and respond to all grievances and requests relating to the processing of personal data in accordance with the applicable law.
Name: Harender Pal Singh
Designation: Grievance Redressal Officer
Email address: harenps@royalenfield.com
Postal address: Eicher Motors Limited #96, Sector 32, Gurgaon - 122 001, Haryana, India

If you are not satisfied with the resolution provided, you may have the right to escalate your grievance to the appropriate regulatory authority in accordance with applicable law.

Changes to the privacy policy and your duty to inform us of changes in your personal data

We may update this privacy policy from time to time to reflect changes to the Platform, our services, applicable laws, regulatory requirements, or our personal data processing practices.

Where such updates materially affect how your personal data is collected, used, stored, or shared, we will take reasonable steps to notify you of such changes through the Platform or through other appropriate communication channels. Where required under applicable law, we will obtain your consent before processing your personal data in accordance with the updated privacy policy.

The updated privacy policy will be made available on the Platform along with the date of the latest revision. We encourage you to review this privacy policy periodically to remain informed about how your personal data is processed.

It is important that the personal data we hold about you remains accurate and up to date. You are responsible for ensuring that the information you provide through the Platform is accurate and for updating such information if it changes during your use of the Platform. Where you become aware that the personal data we hold about you is inaccurate or incomplete, you may update the information through the Platform or contact us using the details provided in this privacy policy.

Third-party links and services

The Platform may contain links to third-party websites, applications, plug-ins, or services that are operated by entities other than Eicher Motors Limited. These links may be provided for you convenience or to enable access to services that may complement the Flying Flea ecosystem.

If you choose to access or interact with such third-party platforms, your interaction with those services will be governed by the respective privacy policies, terms of use, and data handling practices of those third parties. We do not control the privacy or data protection practices of such external platforms and are not responsible for how they collect, process, or store your personal data, unless they are acting specifically on our behalf under a contractual arrangement.

You are encouraged to review the privacy policies of such third-party platforms before providing any personal data or using their services.

2. The personal data we collect about you

Personal data or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity/identifier has been removed (anonymous data).

We may collect, use, process, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data – This includes your first name, last name, date of birth, or any other government ID Proofs.
Contact Data – This includes information used to communicate with you, such as your mobile number, email address, and postal address.
Profile Data – This includes information associated with your user account on the Platform, such as your username, password, profile picture, preferences, feedback, queries, and other information you choose to provide while using the Platform.
Technical Data - This includes information relating to the device and technology used to access the Platform, such as internet protocol (IP) address, device identifiers, operating system, browser type and version, application usage information, and information relating to Bluetooth-enabled or connected devices used to interact with the Platform.
Usage Data – This includes information about how you use the Platform, including your interactions with features, services, and functionalities available through the Platform.
Location Data - Where you enable location services on your device, the Platform may collect GPS-based location information when you use features such as navigation, trip tracking, or other location-enabled services available through the Platform.
Vehicle and telemetry Data - Where the Platform interacts with a Flying Flea vehicle, certain vehicle-related information may be collected to support connected vehicle services. This may include information relating to battery status, temperature, voltage levels, motor RPM, vehicle diagnostics, and certain riding behaviour information such as speed patterns, braking patterns, or ride activity.
Financial Data - Where you make payments or transactions through the Platform, certain transaction-related information such as transaction identifiers, payment confirmations, or order details may be collected. Payment processing may be carried out through authorised third-party payment service providers.
Marketing and Communications Data - This includes your preferences regarding receiving marketing communications, updates, or promotional information from us. Some of the personal data described above may be collected directly from you when you use the Platform, while other information may be generated automatically through your interaction with the Platform or through connected vehicle services enabled through the Platform.

If you fail to provide personal data

Where we are required to collect certain personal data from you in order to provide services through the Platform, and you choose not to provide such information, we may not be able to provide you with certain features, services, or functionalities available on the Platform.

For example, certain services on the Platform may require personal data to enable account creation, vehicle connectivity, navigation features, transaction processing, customer support, or other service-related functionalities. If you choose not to provide the required personal data or withdraw consent for its processing, the relevant services or functionalities may not be available to you.

We will only request personal data that is reasonably necessary for the purposes described in this privacy policy and in accordance with applicable data protection laws.

3. How is your personal data collected?

We use different methods to collect personal data from and about you including through:

Direct interactions: You may give us your Identity, Contact, Profile, Technical, Usage, Location, Telemetry, Transaction, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account on our Platform and update details;
- Apply to join the Platform;
- Apply for, order or purchase our products and services;
- Make an enquiry on our Platform;
- Request a brochure or other marketing to be sent to you;
- Participate in surveys or promotional activities; orGive us feedback or contact us by telephone, email or social media.
- Give us feedback or contact us by telephone, email or social media.
Automated technologies or interactions: When you use the Platform, certain technical and usage information may be collected automatically through technologies such as device identifiers, and similar technologies that help us operate and improve the Platform. These technologies may include cookies and similar tracking technologies that enable us to analyse how the platform is used and improve its functionality and performance.
Connected vehicle interactions: Where you connect your mobile device to a Flying Flea vehicle through the Platform, certain vehicle-related and operational information may be generated through the connected vehicle systems and transmitted to the Platform to enable connected vehicle features, diagnostics, and service-related functionalities.
Third parties or publicly available sources: We may receive your personal data from various third parties, our dealer network, service providers and public sources where such information is shared with us in connection with your interaction with Flying Flea products or services. This includes:
- Technical and Usage Data from analytics providers.
- Identity, Contact, Financial and Profile Data from our dealer network (where applicable); and
- Identity, Contact and Marketing and Communications Data from our marketing and research providers (where applicable).

4. How we use your personal data

We will process your personal data only for specific and lawful purposes that are disclosed to you through this privacy policy or otherwise at the time of collection, and only where permitted under applicable law.

In most cases, we process your personal data on the basis of your consent provided through the Platform. In certain circumstances, we may also process personal data where such processing is necessary to provide the services requested by you, or where processing is required to comply with applicable legal and/or regulatory obligations.

Purposes for which we will use your personal data

We have set out below the purposes for which we may process your personal data collected under this privacy policy:

Purpose/Activity	Type of data
To create and administer your user account on the platform, verify your identity where necessary and enable you to manage your profile information.	Identity data, Contact data, and Profile data.
To enable and operate services available through the Platform, including connected vehicle functionalities such as vehicle pairing, digital connectivity, navigation, trip recording, and related features	Identity data, Contact data, Technical data, Usage data, Location data, Vehicle and telemetry data.
To facilitate product enquiries, vehicle reservations, or other service requests submitted through the Platform	Identity data, Contact data, and Profile data.
To process and manage transactions carried out through the Platform, including recording transaction identifiers and maintaining payment records	Identity data, Contact data, and Financial data.
To communicate with you regarding your account, service requests, vehicle-related updates, maintenance reminders, safety notifications or other operational communications relating to the Platform or connected vehicle services.	Identity data, Contact data and Technical data.
To respond to your enquiries, customer support request, complaints, or feedback submitted through the Platform or customer support channels	Identity data, Contact data and Profile data.
To analyse usage of the Platform and connected vehicle systems in order to improve the functionality, reliability and performance of our products, services and digital systems.	Technical data, Usage data, Vehicle & telemetry data.
To provide navigation and trip-related services where location-enabled features are activated by you on your device.	Location data, Technical data, and Usage data.
To send you information relating to promotions, product updates, events or marketing communications relating to Flying Flea products or services, where you have chosen to receive such communications	Identity data, Contact data, Marketing and communication data.
To operate, maintain, monitor and secure the platform, including system administration, troubleshooting, prevention of misuse, and protection of our digital infrastructure.	Identity data, Contact data, Technical data, and Usage data.
To comply with applicable legal, regulatory or contractual obligations, including responding to lawful requests from authorities.	Identity data, Contact data, Transaction data and Technical data.
To support corporate transactions such as business restructuring, mergers, acquisition, or transfer of assets where such processing is necessary.	Identity data, Contact data, Technical data and Usage data.

We will not process your personal data for purposes that are incompatible with those described above without providing you with appropriate notice and/or obtaining your consent where required under applicable law.

5. Disclosures of your personal data

We may share your personal data with the categories of recipients set out below where such sharing is necessary to operate the Platform, provide the services requested by you, or comply with applicable legal obligations.

Internal group entities - We may share personal data within the other group companies in the Eicher Motors Limited group where such sharing is necessary for the operation, administration, or support of the Platform and related services.
Authorised dealers and service partners - Where relevant, we may share personal data with authorised dealers, service centres, or partners involved in providing vehicle-related services, customer support, or other services associated with Flying Flea vehicles.
Service providers and technology partners - We may share personal data with third-party service providers that support the operation of the Platform, including providers of information technology services, system administration, analytics services, payment processing, customer support systems, and communication infrastructure.
Mobility and vehicle ecosystem partners - In connection with services associated with Flying Flea vehicles, personal data may be shared with certain partners such as roadside assistance providers, charging infrastructure operators, insurance providers, or financing partners where such services are requested by you or enabled through the Platform.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Professional advisers - We may share personal data with professional advisers such as lawyers, auditors, insurers, and consultants where necessary for legal, regulatory, or operational purposes.
Regulators and authorities - Personal data may be disclosed to courts, regulators, law enforcement agencies, or other governmental authorities where such disclosure is required under applicable law or in response to lawful requests.
Corporate transactions - If we undergo a business transaction such as a merger, acquisition, restructuring, or transfer of assets, personal data may be shared with relevant parties involved in the transaction, subject to appropriate safeguards.

Where personal data is shared with third parties, we take reasonable steps to ensure that such parties process the personal data in accordance with applicable data protection laws and appropriate confidentiality and security obligations.

6. International transfers

Your personal data may be processed or stored on systems located within India. In certain circumstances, personal data may also be transferred to or accessed from locations outside India where our group entities, service providers, or partners operate.

Where such cross-border transfers occur, we will take reasonable steps to ensure that the personal data continues to receive a level of protection consistent with applicable data protection laws.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, accidental loss, misuse, alteration, or disclosure.

Access to personal data is restricted to employees, agents, service providers, and partners who require such access for the purposes described in this privacy policy. Such persons are permitted to process personal data only on our instructions and are subject to confidentiality and security obligations.

8. Data retention: How long will you use my personal data for?

We retain your personal data only for as long as it is necessary to fulfil the purposes for which it was collected, including for the provision of services through the Platform and for compliance with applicable legal, regulatory, accounting, or reporting requirements.

Where you choose to close your account on the Platform, or where your association with the Flying Flea vehicle linked to your account ends (for example, upon transfer or sale of the vehicle), we will take reasonable steps to delete or anonymise the personal data associated with your account, unless retention of such data is required under applicable law.

In certain circumstances, we may retain information in an aggregated or anonymised form for analytics, product improvement, or research purposes where such information no longer identifies you. You may request deletion of your personal data by contacting us through the details provided in this privacy policy, subject to any legal or regulatory obligations requiring us to retain certain information.

9. Your legal rights

You have certain rights under data protection laws in relation to your personal data as set out below:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Right to withdraw consent.
Right to grievance redressal.
Right to nomination in case of your death or incapacity.

If you wish to exercise any of the rights set out above, please contact us using the details set out in section 1 above. We may request certain information from you to verify your identity before responding to your request.

What we may need from you

When you submit a request to exercise any of your rights under this privacy policy, we may request certain information from you to verify your identity and confirm your entitlement to make such a request.

This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to request additional information where necessary to clarify or process your request.

Consent

By accessing or using the Platform and providing your personal data, you acknowledge that you have read and understood this privacy policy and consent to the collection, use, storage, and processing of your personal data in the manner described herein.

Where the Platform requests your consent for specific functionalities or services, such consent will be obtained through appropriate mechanisms available on the Platform. You may withdraw your consent at any time by contacting us using the details provided in this privacy policy or by adjusting the relevant settings available on the Platform, where applicable.

Withdrawal of consent will not affect the lawfulness of any processing carried out prior to such withdrawal. However, where processing of personal data is necessary for providing certain services or functionalities on the Platform, withdrawal of consent may result in such services or functionalities no longer being available to you.