Privacy policy

Privacy Statement for Customers, Partners and Delivery Executive

1. Scope

Our commitment Zepgrow is committed to respecting Users’/ Delivery Executive/ Partners (jointly named hereinafter as the “Data Subjects”) privacy and protecting their Personal data. In this sense, the aim of this Privacy Policy is to inform Data Subjects about Zepgrow processing activities as per Regulation requirements.

The purpose of the Privacy Policy This Privacy Policy provides information on the processing of personal data of Data Subjects who contact us via the Mobile App.

This Privacy Policy notice describes: how Zepgrow collects and processes the personal data, the different stakeholders involved in this processing as well as our Data Subjects rights with regard to their data. We recommend that both all stakeholders involved in the processing as well as Data Subjects read it carefully and on a frequent basis to fully understand this along with our privacy overview, which highlights key points about our current privacy practices.

Possible changes and updates on the Privacy Policy Due to the constant evolution of Zepgrow activities, this Privacy Policy may be subject to change or updates in the future.

Use of our Platform after this Privacy Policy has been updated shall be deemed to constitute consent by Data Subjects, whether located in the India or outside the India, to the updated or modified Privacy Policy to the extent permitted by local law.

Zepgrow will modify the Privacy Policy to the Data Subjects if necessary. Zepgrow will in no event modify its policies or practices to make them less effective in the protection of its Data Subjects personal data.

Any doubts? Contact us

If our Data Subjects have any doubt concerning this Privacy Policy or want to obtain more information on it, they can contact any time to this email address: zepgrowdelivery@gmail.com

DEFINITIONS

For the purpose of this document:

“Personal data” means any information relating to an identified or identifiable natural person; is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity (hereinafter referred to as “Concerned Person”).

“we” / “Us” / “We” / Our / Ours” shall mean refers to the company Zepgrow.

“Platform” means this mobile application and under domain names where applicable.

“you” any user/visitor of the Platform.

“Data Controller” shall mean: the entity in charge of determining the purposes and means of the processing of personal data

“Data Processor” shall mean: the entity in charge of processing personal data on behalf of the controller

“Local regulation” shall mean: the data protection regulation applicable to your country

“Order(s)” shall mean: food product requested by the User through the Zepgrow Platform

“Partner(s)” shall mean: local stores, physical “retailer”, “supplier”, or “seller” that offer to Users include their products in the Zepgrow Platform

“Personal data” shall mean: any information which directly relates to User(s), Delivery executive(s), Partner(s), or that may allow their identification

“Platform” shall mean: indifferently the Zepgrow Application

“App” shall mean: the word “App” is used interchangeably with the word “Platform”, both words means the same: indifferently the Zepgrow Application

“Processing of personal data” also referred to as “Data activity(ies)” shall mean: any activity performed on or with your Personal data, such as collecting, organising, accessing, holding, storing, disclosing, adapting, destroying, erasing or using the Data in any way

“Profiling” is the process of construction and application of user profiles generated by computerised data analysis also understandable as the use of algorithms or other mathematical techniques that allow the discovery of patterns or correlations in large quantities of data, aggregated in databases

“User(s)” shall mean: anyone who registers on Zepgrow App

“Data Subject”: any natural person from whom data is collected or processed by Zepgrow; in essence, the User(s), the Partner(s), the Delivery Executive(s).

PURPOSE OF THIS POLICY

We attach great importance to the protection of your Personal Data.

We have developed this policy to inform you of the conditions under which we collect, process, use and protect your Personal Data. This policy applies in particular to Personal Data processed by Zepgrow via the Platform. Please read it carefully to know which categories of Personal Data are collected and processed, how we use this data and with whom we may share it. This policy also describes what your rights are and how you can contact us to exercise them or to ask us any questions you may have about your Personal Data.

TYPES OF PERSONAL DATA THAT WE COLLECT AND USE AS PART OF OUR SERVICES

We may collect and process the following types of Personal Data in particular:

the information that you provide by completing the forms on the Platform, in particular for the purposes of registering and personalizing your account, participating in satisfaction studies (e.g.: title, name, first name, contact details, Restaurant name, telephone number internal number etc.);
the information you provide for authentication, connection and internet browsing purposes (e.g. identifiers, IP address, cookies, etc.);
the information you provide for the purposes of managing and paying for an order or service (e.g. dietary preferences, payment information, etc.);
information you provide through posts, comments or other content you share with us.

Unless indicated as optional, the Personal Data to be provided is mandatory and if you fail to provide this information, your request will not be taken into account.

PURPOSES FOR WHICH WE USE PERSONAL DATA IN THE CONTEXT OF OUR SERVICES IN A PROFESSIONAL ENVIRONMENT

No.	Purpose of processing	Legal basis	Data retention period
1	Manage and process requests for creation and management of accounts on the Platform	The execution and management of our contractual relationship with you and/or with our client (your employer)	Up to 12 months from last activity or immediately following processing of account deletion request
2	Provide the services and services ordered on the Platform	The execution and management of our contractual relationship with you and/or with our client (your employer)	Up to 5 years from the end of our contractual relationship with your employer
3	Respond to your contact requests with the sales team	The execution and management of our contractual relationship with you and/or with our client (your employer) Our legitimate interest in improving the quality and operational excellence of the services we offer you	Up to 3 years after last contact
4	Allow you to consult your balance and/or your history, your consumption	The execution and management of our contractual relationship with you and/or with our client (your employer)	Until your account is deleted
5	Provide you with offers for our products and services, send you offers, etc.	Our legitimate interest in improving the quality and operational excellence of the services we offer you Your consent to receive offers from our partners	For existing customers: Up to 36 months from last activity or immediately following processing of account deletion request
6	Share profile data with third-party partners for advertising targeting purposes for similar profile audiences	Your consent	Up to 12 months from last activity or immediately following processing of account deletion request
7	Carrying out satisfaction studies	Our legitimate interest in improving the quality and operational excellence of the services we offer you	Up to 12 months from last activity or immediately following processing of account deletion request
8	Personalize and improve your experience on our Platform	Our legitimate interest in improving the quality and operational excellence of the services we offer you	Up to 12 months from last activity or immediately following processing of account deletion request
9	Payment data	We are not store any payment related data.	-
10	Store data about your food preferences to personalize your orders	To analyse the data to make improvement in our product and marketing.	-
11	Keep data relating to invoices for tax or accounting purposes	Compliance with certain legal obligations	Up to 10 years

DURATION OF STORAGE OF YOUR PERSONAL DATA

We will keep your Personal Data for a period which does not exceed the period of necessary for the purposes for which they are collected and processed (see table above).

At the end of this period, the strictly relevant data may be kept (i) for evidentiary purposes (in the event of litigation or in the event of control by authorized bodies), (ii) for the purposes of compliance with limitation periods. legal or regulatory and/or (iii) to comply with a contractual obligation with our customers.

WITH WHOM WE SHARE YOUR DATA? AND COMMUNICATION OF PERSONAL DATA

We limit access to your Personal Data to our teams who need to know it in order to process your request or provide you with the requested service.

We do not disclose your Personal Data to unauthorized third parties. However, we may share your data with:

If you are a User we may share your data with two different group of recipients:

The recipients of data while we carry on your orders: the Delivery executive who carries out the task of collecting and delivering the product; the establishment or venue in charge of selling the product; the Customer Care Services available to you; the payment Platform and payment service providers; Telecommunications service providers; Providers rendering satisfaction survey services

Recipients of the data, during the actions undertaken to continue to provide the services offered through the App: service providers that send parcels, carry out orders and/or resolve incidents with delivery; Payment Platforms contracted by Zepgrow; Service providers for fraud control purposes and for the anonymisation of some data; Social media, Third parties associated with Zepgrow for the purposes of commercial communications.

Your data will be used for :-

users who have placed an order which you have agreed to carry out,
external service providers that provide commercial offers with benefits and/or discounts for you,
to group companies or third parties in charge of the filing and management of computer data.
In case of every Data Subject (Users, Delivery executive, Partners,) we may share personal data with:
any public authority that requests the sharing.
our clients in the context of performance of a contractual obligation;
the staff of subcontractors that Zepgrow may use for the management of services (e.g.: technical hosting and maintenance providers, advice, secure payment providers, etc.);
Zepgrow commercial partners (with your prior consent).

We ensure that these recipients implement appropriate security and confidentiality measures so that your Personal Data is protected.

We do not authorize these recipients to use or disclose your information except to the extent necessary to perform services on our behalf or comply with legal obligations. In addition, we may share Personal Data about you (i) if the law or legal process requires us to do so, (ii) in response to a request from any public authority, or (iii) if we consider that the transmission of this data is necessary or appropriate to ensure the safety of persons or protect the public and to protect the rights and property of us and our customers.

If you believe that Zepgrow is in breach of data protection law:

Do not hesitate to Contact us at the e-mail: zepgrowdelivery@gmail.com telling us what you consider to be the case, so that we can resolve the problem as soon as possible.

Please take into account that there may be some situations where the above rights could not be exercised or effectively executed by D Zepgrow, for example when asking us to erase all your personal data where there is contractual relationship with us.

Data Security

At Zepgrow, we prioritize the privacy and security of your personal information. This Data Security Clause outlines the measures we take to ensure your data is protected in compliance with applicable regulations and Google Play Store policies.

1. Data Collection and Usage

We collect only the necessary data required for app functionality and service improvement. The types of data collected may include:

Personal Information: Name, email address, phone number (if provided by the user).
Device Information: Device type, operating system, and app version for performance optimization.
Usage Data: Interaction data to understand how users engage with the app.

2. Data Storage and Transmission

All collected data is securely stored using industry-standard encryption methods.
Data transmitted between the app and our servers is encrypted using SSL/TLS protocols to prevent unauthorized access during transmission.
We implement regular security audits and vulnerability assessments to ensure ongoing protection.

3. Data Sharing

No third-party sharing without consent: We do not sell or share personal data with third parties for marketing purposes.
Data may be shared with trusted partners solely for the purpose of providing core app services, with strict data security agreements in place.

4. User Controls

Users have the right to access, modify, or delete their data by contacting us at zepgrowdelivery@gmail.com.
Users can revoke consent for data collection through app settings.

5. Data Retention

We retain user data only as long as necessary for the purposes outlined in this policy or as required by law.
Data is securely deleted when no longer needed.

6. Security Measures

We implement multi-layered security measures, including:
- Regular software updates to patch potential vulnerabilities.
- Role-based access control to limit access to sensitive data.
- Strong password policies and two-factor authentication for administrative access.

PERSONAL INFORMATION AND MINORS

The Platform is aimed at adults capable of contracting obligations in accordance with the legislation of the country in which you are located.

In India, Users who are minors under 18 years of age or incapable must obtain the prior consent of their legal guardian before entering their data on the Platform.

TRANSFERS OF PERSONAL DATA

In order to guarantee the security and confidentiality of the Personal Data thus transferred, we take all necessary measures to ensure that this data benefits from adequate protection.

YOUR RIGHTS

In accordance with applicable law, you have certain rights relating to the processing of your Personal Data.

Permission to access	You can request access to your Personal Data. You can also request the rectification of Personal Data that is inaccurate or that incomplete data be completed. You also have the right to know the sources of this Personal Data.
Right of deletion	Your right to be forgotten authorizes you to request the deletion of Personal Data when: the data are no longer necessary to achieve the purposes for which they were collected and processed; you choose to withdraw your consent (in cases where your consent was collected as the legal basis for the processing), this withdrawal not impacting the lawfulness of the processing before its implementation; you object to the processing; your data has been processed unlawfully; your data must be erased to comply with a legal obligation; Or their removal is required to ensure compliance with current legislation.
Right to limitation	You can also request the limitation of the processing of your Personal Data if: you contest the accuracy of this data; we no longer need this data for processing purposes; And you have objected to the processing of the data.
Right to object to direct marketing messages	You can at any time ask us to no longer receive advertisements or prospecting by contacting us directly and free of charge, or by means of the unsubscribe link included in any prospecting that we may send to you by email or by sending an email to the address indicated below. This opposition is without prejudice to the legality of shipments made before its implementation.
Right not to be subject to a decision based exclusively on automated data processing	You have the option not to be subject to a decision based exclusively on automated Processing producing legal effects concerning you or significantly affecting you.
Right to issue advance directives on the processing of your Personal Data after your death	In application of Indian law relating to the protection of Personal Data, you can also define directives on the exercise of your rights provided for in this section after your death, (in particular on their retention period, their deletion and/or their communication) as well as designating a person responsible for exercising these rights.
Right to lodge a complaint with a supervisory authority	If you have concerns or complaints regarding the protection of your Personal Data, you have the right to lodge a complaint. You can send us any request in advance by contacting us at the address indicated below so that we can process your request and find an amicable solution.

To exercise these rights, you can make your request by email to the address zepgrowdelivery@gmail.com, telling us your name, first name and the subject of your request. We may ask you for additional information in order to identify you and be able to process your request.

USEFUL INFORMATION IF YOU ARE A USER:

What are the data processing purposes and the legitimate basis of the processing?

Zepgrow will process your the personal data for the following purposes:

1. For legal purposes.

2. For contractual purposes.

3. For security purposes.

4. For statistics and research purposes.

5. For marketing and commercial purposes.

6. For non-marketing purposes.

7. Legal purposes

Zepgrow processes your personal data for:

i) detect and investigate fraud and possible crimes committed against our Platform and all the users,

ii) comply with the legislation in case any legal regulations oblige us to keep your data for a defined period of time,

iii) manage and execute your request(s) to exercise the rights established as per local regulations,

iv) file, submit and defend legal actions against any entity of our Group,

v) in any of the cases above-mentioned, Zepgrow shall be entitled to use any data obtained from you or arisen from your activity through our Platform (e.g. conversations between you and the Partner, you and the Delivery Executive, you and our Platform using the chat system) for the purpose of filing and/or defending any claims and/or legal actions that may be necessary, and to manage any incidents arising in connection with User’s orders.

Contractual purposes Zepgrow processes your personal data for:

i) grant you the possibility to create your own account,

ii) provide you with the services you have requested and any additional features on the Platform,

iii) locate the nearest Partners and Courier to the delivery point informed by you (which may involve using geolocation services, if you agreed to them when asked to by the Platform, as described above),

iv) perform payment processing and collection on behalf of you,

v) communicate your Order to the Partner selected by you and update you on the status of your Order,

vi) assist you in your decisions and use of the service, including the possibility to quickly reorder from the stores, where you have ordered in the past or suggest you stores based on your past orders or “popularity” among new users. Additionally, we could assist you in your decisions through automatically determined filters by the historical order you have placed in the past, providing in each case specific contents in the Platform tailored for you,

vii) send you the receipt corresponding to your Orders,

viii) provide you with a customer service to manage any incident related to your Orders and being able to answer your questions,

ix) allow your direct contact with the Delivery Executive in charge of your Order,

xi) be contacted by our Partners in case of any incident with your Orders,

xii) process reimbursements and refunds both via promo-codes or bank refunds,

xiii) notify you concerning changes or updates to our services, terms and conditions, privacy policy, any other corporate document that may affect you in a substantial way.

Security purposes Zepgrow processes your personal data for:

i) use device, location (including geolocation data, if you agreed to), profile, usage, and other data to prevent and detect malicious or unsafe activities (e.g. payment fraud, identity fraud, account hacking, phishing, incentive abuses). In particular, Zepgrow uses your device's IP address to detect fraudulent activity on your device and to keep the platform away from attackers who may try to access your account by impersonating you;

ii) monitor all actions that could cause fraud or in the commission of a criminal offence related to the payment method employed by you; if any irregularities are detected, Zepgrow reserves the right to retain the data provided and share it with the competent Authorities in order to carry out the relevant investigation,

iii) make sure that you follow the legal requirements related to specific products you may order through the Platform (e.g. legal age for alcoholic beverages).

For statistics and research purposes Zepgrow processes your statistics based on your Personal data for:

i) analyse trends, purchase behaviour and characteristics,

ii) understand how you use our Platform,

iii) manage and improve the services offered, including the possibility of adding new or different features and services to improve the quality of the services.

Marketing and Commercial purposes

Zepgrow processes your personal data for:

i) carry out marketing, communications, research and development activities,

ii) analyse and research how to improve our services both offline and on the Platform, by using the data provided by you (such as in focus groups, reviews, valuations of the services, satisfaction survey, feedback or any kind, etc.),

iii) provide you with personalised offers, promotions, discounts, suggestions, views and options in App, or by any other communication,

iv) carry out promotional activities for the delivery of samples or free products inside the order placed by you, which may be of your interest to promote Zepgrow and our Partner’s products or services,

vi) create custom audiences with Facebook or other providers to reach out to you or other people with similar characteristics, who might be interested in using Zepgrow services; you can manage your privacy in your Facebook or other third party platform settings,

vii) use as commercial or marketing material published by you on your social networks profiles when Zepgrow has been expressly mentioned by you (i.e. via hashtag or @).

We may personalize the marketing communications by using the User activity in our App (including your past orders) and the interaction with the App, online advertising, previous emails, promotions, etc. However, this personalisation is not made only by automated means, nor have any legal effect or affect the User similarly.

Zepgrow may use Push services on the User’s mobile device to provide marketing communications. If the User does not want to receive these marketing communications, he / she shall unsubscribe in the notifications centre. Please note that disabling Push notifications will also prevent the User from receiving notifications about the status of any order.

Non-marketing purposes

Zepgrow processes your personal data for:

i) generate and provide you with receipts from each of your Orders placed through our App,

ii) inform you about any incident on the Platform or the operation of the services, including incidents related to your orders. This information can be sent by e-mail or SMS messages, and any other messaging application, that may be used by you and Zepgrow at any moment,

iii) inform you about any changes to our Terms and Conditions, privacy policy, services, and more generally to inform you about any relevant non-marketing communications.

What kind of data do we hold about you and how is your personal data collected?

Zepgrow holds the following data about you:

1. Information supplied directly by you:

1.1. Registration Data: the information provided by you when you create an account on the Zepgrow Platform: username and OTP.

1.2. User Profile Information: the information added by you on the Platform in order to be able to use Zepgrow service, e.g.. your mobile phone number and delivery address. You can view and edit the personal data on your profile whenever you wish.

1.3. Payment information: payment information when processing your orders; card data will be processed by our electronic payment service providers, who will receive the data directly from you. Zepgrow will have access to this information only for complying with the request of any competent authority,

Zepgrow not offers its users to store the payment information or card details. the details of the card are never stored in our systems.

1.4. Additional information: any information that you could supply to Zepgrow for other purposes, e.g. your photograph or the billing address in the case if you have asked to receive invoices from Zepgrow.

1.5. Information about previous communications with Zepgrow: information supplied by you for the resolution of any queries or complaints about the use of the platform, whether through the phone no of the customer service.

1.7. Information of conversations held with Zepgrow: Transcription and recording of conversations for the processing of incidents, queries or other consultations that may be made to guarantee and improve the quality of our services and for security reasons.

1.8. Information on Communications: communications exchanged between you and the Delivery executive on the calling system provided on the Platform whenever it is necessary to address any incident or discussion between Users and Delivery executive, or to comply with any request made by authorities. Zepgrow will never access the communications if it is not strictly necessary and will always ensure the privacy of its users and the confidentiality of all information exchanged on its platform.

1.9. Any additional information that you provide in your requests, comments or questions.

Information indirectly supplied by Users:

2.1. Data arising from the Use of the Platform: Zepgrow collects the data arising from your Use of the Platform every time you interact with the Platform.

2.2. Data on the application and the device: Zepgrow stores data on the device and the Application used by you to access the services:

i) the IP address used by you to connect to the Internet using your computer or mobile phone, and to prevent fraudulent misappropriation or unauthorized access to your account by third parties,

ii) information about your mobile phone, such as your Internet connection and type of device,

iii) data from your account: information on the orders made by you, as well as feedback and/or comments made by you,

2.3. Data arising from the User’s origin: if you arrive at the Zepgrow Platform through an external source (such as a link from another website or a social network, as long as you have authorised it on those websites), Zepgrow collects data on the source from which you arrived.

2.4. Data resulting from the management of incidents: if you contact the Zepgrow Platform through the Contact using Zepgrow’s phone number, Zepgrow will store the incident to manage current or future incidents.

2.5. Geolocation Data: provided that you have authorised this, Zepgrow will collect data relating to your location, including the real-time geographic location of your mobile device.

What are the recipients of your data and why are we communicating it?

Zepgrow warrants that all commercial partners, technicians, suppliers or independent third parties are bound by contractually binding promises to process the information shared with them in accordance with Zepgrow’s indications, this Privacy Policy and the applicable data protection legislation.

We will not disclose your personal data to any third party who does not act under our instructions and no communication will involve selling, renting, sharing or in any other way revealing customers’ personal information for commercial purposes in breach of the commitments made in this Privacy Policy.

When carrying out an order, data may be shared with:

The Delivery executive who carries out the task of collecting and delivering the product.

The establishment or venue in charge of selling the product, if you have requested the purchase of a product. If you contact the above-mentioned providers directly and give them your data directly, Zepgrow will not be responsible for the providers’ use of such data.

The Customer Care Services contracted by Zepgrow for the purpose of warning you of any possible incidents or asking why negative feedback has been given; data will be used to manage any incidents that may occur during the provision of the services.

The payment Platform and payment service providers so that the amount can be charged to your account.

Telecommunications service providers, when they are used to send communications regarding orders or incidents relating to orders.

Providers rendering satisfaction survey services on Zepgrow’s behalf.

Sharing your data with third parties:

To continue providing the services offered through the Platform, Zepgrow may share your certain personal data with:

Service providers: service providers that send parcels, carry out orders and/or resolve incidents with deliveries have access to your personal information as may be necessary only to carry out their functions. They must process the said personal information as provided in this Privacy Policy and in the applicable data protection legislation.

Payment Service Providers: When you enter your card number on the App, this is stored directly by the Payment Platforms contracted by Zepgrow, which allows payment to be charged to your account. Payment service providers have been chosen based on their security measures. Zepgrow does not store such data in any event.

Service providers for fraud control purposes: if required Zepgrow will share your data with fraud control service providers to assess the risk of the transactions carried out.

Service providers for the anonymisation of some data: In order to prevent the misuse of your data by third-party service providers, your data may be being anonymised so that it can be used solely for the provision of the service.

Security companies and Law Enforcement Forces and Agencies: Zepgrow may disclose personal data on its customers’ accounts if such disclosure is necessary to comply with the law, to enforce or apply the “Terms of Use'' or to protect Zepgrow’s, its users’ or third parties’ rights, property or safety. It includes the exchange of information with other companies (for example, Zepgrow uses Google's reCAPTCHA Enterprise service to protect users from cyber attacks or threats to their accounts) and organisations and with Law Enforcement Forces and Agencies to protect against fraud and reduce credit risk.

Companies in the Zepgrow group: To be able to provide its services, Zepgrow may transfer your certain personal data to subsidiaries, based on the geographical area from which users request our services. When you register on the Platform from any country in which Zepgrow operates, your data is stored on Zepgrow’s database.

Social media connected by Users: If you connect your Zepgrow account to other social media or to a third-party platform, Zepgrow may use the information provided to such social media or third party in compliance with the privacy policy of the social media or third-party platform in question.

Third parties associated with Zepgrow for the purposes of commercial communications: Zepgrow may transfer your personal data to third parties associated with Zepgrow, provided that you have given your express informed and unequivocal consent to such transfer of data and that you are aware of the purpose and recipient of such transfer.

Changes of ownership: If Zepgrow’s ownership changes or the majority of its assets are acquired by a third party, you are informed that Zepgrow will transfer your data to the acquiring organisations to continue to provide the services subject to the processing of data. As Zepgrow keeps growing continuously, we may buy or sell business units, assets, shares or legal entities, so data subjects’ information may also be transferred. That information, when acquired by Zepgrow, shall be processed as any other information as described in our privacy policy. You acknowledge that such transfer may occur and that we will be allowed to use your personal information for any of the purposes described in this Privacy Policy. The new file controller will inform Users of its identification data. Zepgrow states that it will comply with its duty of information and it shall inform Users of the change of file controller if and when this happens. This processing shall be carried out under the contract entered into with Zepgrow.

Your data will not be disclosed to any third parties unless:

i) this is necessary to provide the services requested if Zepgrow is collaborating with third parties ;

ii) if Zepgrow has your express and unambiguous authorisation;

iii) where this has been requested by a competent authority pursuant to its functions (in order to investigate, prevent or take action in relation to illegal actions);

iv) finally, where required by law.

How long will we keep your data?

Zepgrow shall retain your data for the duration of the contractual relationship and, after this has come to an end, for the period established by law for filing or defending the appropriate legal actions. This is established at a maximum of fifteen (15) years in order to comply with Zepgrow’s legal obligations – which include the duty to assist the security forces as necessary in the investigation and prosecution of crimes pursuant to the higher interest of public safety – and defend itself or take any action in relation to criminal, tax and social security matters.

The said period may be shorter depending on the legal provision applicable to each purpose of data processing.

Useful information if you are a Delivery executive:

Zepgrow will process the personal data of Couriers for the following purposes:

1. For legal purposes.

2. For contractual purposes.

3. For security purposes.

4. For statistics and research purposes.

1. Legal purposes

Zepgrow processes your personal data for:

i) detect and investigate fraud and possible crimes committed against our Platform and all the users,

ii) comply with the legislation in case any legal regulations oblige us to keep your data for a defined period of time.

iii) manage and execute your request(s) to exercise the rights established in the local regulations,

iv) file, submit and defend legal actions against any entity of our Group,

v) manage and execute your claims related to an Order, problems with the delivery and different sorts of general incidents generated by the use of the Platform.

** These processing operations are carried out under our legitimate interest in detecting, investigating and preventing fraud, and to comply with all the legal obligations that Zepgrow and delivery executive may be subjected to, relating to any application law.

2. Contractual purposes

Zepgrow processes your personal data for:

i) manage Zepgrow’s activity, enabling you to access and communicate with the Zepgrow platform so as to provide their services through it,

ii) provide informative sessions to you before the starting of services (focus groups) and to comply with the services offered by the providers through the technological platform, and with obligations arising from the contractual relationship,

iii) studying the use of the platform performed by you and performance of focus groups with you to understand their opinion and feedback about the services provided,

iv) provide you with the equipment and material needed to provide the services, if requested,

v) assign Orders to you and show to the Customers your position while delivering their Orders,

vi) assist you during the performance of services by contacting customer centres,

vii) notify you concerning changes or updates to our services, terms and conditions, privacy policy and any other corporate document that may affect them in a substantial way

** The above processing’s are always carried out under the contractual obligations arising from the Terms and Conditions accepted when joining Zepgrow.

3. Security purposes

Zepgrow processes your personal data for:

i) control visitors’ access directly to Delivery Executive and ensure your goods’ and facilities’ safety,

ii) use device, location, profile, usage, and other data to prevent and detect improper payments, money laundering, especially when you pay by cash,

iii) when requested by any authority, administration or court, collaborate with Public Authorities whenever they request Zepgrow information useful to the aim of their investigation (e.g. anti-drug projects, anti-fraud projects, anti-terrorism projects),

iv) defend Zepgrow interests in case of a conflict between the parties related to the interpretation or execution of the contract,

v) comply with the compensation, accounting, tax and economic obligations.

** Zepgrow process Delivery Executive data when requested by any authority, administration or court, collaborate with Public Authorities whenever they request Zepgrow information userful to the aim of their investigation.

4. Statistics and Research purposes

Zepgrow processes your statistics based on your personal data for:

i) carry out statistical and financial calculations based on aggregate and non-identifiable data,

ii) send voluntary and anonymous questionnaires, as well as surveys, competitions and communications of your interest, for the purpose of assessing the quality of the relationship and any opinions that you may have.

** Zepgrow process statistical and research data of Delivery Executive under the legitimate interests to understand how Delivery executive interact with our App, to develop new services and improve them and to analyse the economic information derived from the services, When performing these data processing operations, we may collect information from Delivery Executive but we will anonymize and aggregate it.

What kind of data do we hold about you and how is your personal data collected?

Zepgrow holds the following data about you:

Name and surnames: pursuit of the contractual relationship.

Aaadhar Card / Pan Card : pursuit of the contractual relationship – billing and legal compliance.

Bank Passbook Photo: payment management and legal compliance.

Bank and billing information: information for billing purposes, current account or credit card numbers, if necessary to fulfil contractual obligations or manage purchases, or services.

Delivery Executive Photo: road safety, account fraud prevention and public safety.

Driving licence: road safety.

Vehicle Photo: road safety and legal compliance.

Own vehicle: pursuit of the contractual relationship.

Geolocation: management of the service provider’s location during the provision of services for road safety reasons and monitoring order process.

Phone number (Contact data): Pursuit of the contractual relationship and be able to communicate with the Delivery Executive by sending some communications through different channels such as: SMS, email, Whatsapp messages, etc.

Internet connection: pursuit of the contractual relationship.

What are the recipients of your data and why are we communicating it?

Your data may be disclosed to third parties only where necessary for the establishment, performance and termination of the contractual relationship with Zepgrow. The third-party recipients of the Data, designated as Data Processors, include:

advisers and consultants for the pursuit of accounting, labour, tax, insurance, legal and technical activities,
government bodies (tax authority, social security system, etc.),
state security forces, courts, mediation and arbitration bodies,
governments for regulatory matters.

During the performance of the relationship and to ensure that you can carry out your activity, the Data will be disclosed:

to those establishments with which Zepgrow has a commercial T&Cs,
those users who have placed an order which you have agreed to carry out,
external service providers that provide commercial offers with benefits and/or discounts for you.

Zepgrow hereby informs you that the Data may be disclosed to companies in the Zepgrow group in connection with the purposes described previously.

How long will we keep your data?

The said period may be shorter depending on the legal provision applicable to each purpose of data processing.

Useful information if you are a PARTNER:

1. What are the data processing purposes and the legitimate basis of the processing?

Zepgrow will process your personal data in order to:

i) grant you the possibility to create your own account and maintain the business relationship with Zepgrow to provide technology intermediation in the generation of leads and processing of payments and other services relating to in-store sales and the delivery of products, also to handle incidents arising in relation to orders,

ii) provide you with customer service to answer your questions or consultations.

** The above processing’s are always carried out under the contractual obligations arising from the Partner agreement.

2. What kind of data do we hold about you and how is your personal data collected?

Zepgrow holds the following data about you:

Information supplied directly by you:

1.1. Registration Data: the information provided by you when you create an account on the Zepgrow Platform: username and password.

1.2. User Profile Information phone number and email; phone number and email; pursuit of the business relationship and be able to communicate with the Partner or the Investor by sending some communications through different channels such as: SMS, email.

1.3. Product Information

1.4. Any additional information that you provide in your requests, comments or questions

3. How long will we keep your data?

Zepgrow shall retain your data for the duration of the contractual relationship and, after this has come to an end, for the period established by law for filing or defending the appropriate legal actions. This is established at a maximum of fifteen (15) years in order to comply with Zepgrow legal obligations – which include the duty to assist the security forces as necessary in the investigation and prosecution of crimes pursuant to the higher interest of public safety – and defend itself or take any action in relation to criminal, tax and social security matters.

The said period may be shorter depending on the legal provision applicable to each purpose of data processing.

SECURITY

We implement all technical and organizational measures to ensure the security and confidentiality of the processing of Personal Data.

As such, we take all necessary precautions, taking into account the nature of the Personal Data and the risks presented by the processing, in order to preserve the security of the data and, in particular, to prevent them from being distorted, damaged or that unauthorized third parties have access to it (physical protection of premises, authentication processes with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data, etc.).

UPDATING OUR PRIVACY POLICY

We may update or modify this policy from time to time in the event that our activities or our legal obligations evolve substantially. In the event that we make significant changes to this policy, we will publish an information notice on our Platform when the changes in question come into effect. Check this page regularly to monitor changes.

If you have any questions or comments regarding this policy, please do not hesitate to contact us at zepgrowdelivery@gmail.com

Last updated: October, 2024