Digital Vehicle Identity • Compliance • Assistance
PRIVACY POLICY DATA PROTECTION INFORMATION SECURITY GOVERNMENT PILOT READINESS

Privacy, Data Protection, Information Security & Government Data-Integration Policy

Effective Date: 29 September 2026   |   Version: 2.0

This Policy describes the privacy, data protection and information-security principles adopted for the VahanPass platform and related services. VahanPass is intended to provide a digital vehicle identity, compliance and assistance layer that can support vehicle owners, drivers, authorized organizations and, where formally approved, government departments and enforcement personnel.

This document is intentionally written to separate current platform principles from future/conditional government integrations. VahanPass will not represent itself as a Government of India or State Government service, and will not claim government approval, authorization or live government API access unless the relevant written authorization, agreement and technical access actually exist.

Legal status: This is a detailed policy draft for operational and government-pilot readiness. It must be finalized against the actual legal entity, technology architecture, contracts, data flows and applicable Indian law by qualified legal/privacy counsel before being relied upon as a final legal instrument.

Document Control

ItemDetails
Policy OwnerVahanPass (Legal Entity Name)
Version2.0
Effective Date29 September 2026
Review CycleAt least annually and whenever there is a material change in law, government agreement, architecture, data source or processing activity.
Privacy Contact[Insert Data Protection / Privacy Contact Name]
Registered Office[Insert Registered Office Address]

1. Scope & Applicability

This Policy applies to personal and vehicle-related information processed through VahanPass websites, mobile/web applications, QR-based vehicle identity services, verification interfaces, dashboards, administrative systems, support channels and assistance features.

2. Core Privacy & Data Protection Principles

Purpose LimitationCollect and use information for defined, legitimate and documented purposes.
Data MinimisationRequest only information reasonably required for the relevant service or authorized purpose.
TransparencyExplain what information is processed, why it is processed and how users can raise requests.
Security by DesignConsider security, privacy and access controls during product and architecture decisions.
Access ControlGive staff and officers only the access required for their approved role.
AccountabilityMaintain policies, records, logs and review processes appropriate to the service.
AccuracyWhere data is used for decisions or disclosures, appropriate processes will be used to maintain relevant accuracy and consistency.
Retention ControlDo not retain personal information indefinitely without a legitimate reason or applicable legal/contractual requirement.

3. Categories of Information We May Process

CategoryExamplesTypical Source
Identity & AccountName, mobile number, email, account ID, OTP/authentication records.User or authorized organization.
Vehicle IdentityRegistration number, vehicle type, QR identifier, activation status.User, authorized source or VahanPass record.
ComplianceRC, insurance, PUCC, fitness, permit, driving-licence or other relevant status.User-provided information or authorized external source, subject to access.
Document FilesDocument images/files where upload is enabled.User or authorized operator.
Verification EventDate/time, QR/vehicle identifier, result, officer/user identifier and audit information.VahanPass system.
LocationApproximate/precise location associated with an enabled feature or verification event.User device/system, subject to feature and notice.
Safety/AssistanceEmergency event, roadside request, mechanic request and related status.User/device/service provider.
Technical/SecurityIP address, browser/device data, login events, security logs and diagnostic information.System automatically.
CommunicationSupport tickets, complaints, messages and service interactions.User/support channel.

4. Purpose of Processing

PurposeExamples
Digital Vehicle IdentityAssociate a controlled QR identifier with a vehicle record and provide authorized vehicle information.
Compliance ManagementShow document/status information and provide expiry or maintenance reminders.
VerificationReturn information based on VahanPass records and, when authorized, approved external/government data sources.
Government Enforcement SupportSupport an approved field-verification workflow, audit trail, dashboard and compliance analytics.
Safety FeaturesSupport emergency/safety alerts and assistance features selected or enabled by the user.
Service DeliveryQR activation, replacements, orders, payments, support and service requests.
SecurityDetect unauthorized access, abuse, malicious activity and account compromise.
Legal/RegulatoryComply with applicable legal obligations, lawful orders and contractual requirements.

5. Legal/Operational Basis & Consent

VahanPass will determine the appropriate lawful basis and notice/consent mechanism for each processing activity under the law applicable to that activity. Where consent is the applicable basis, the consent request will be presented clearly and separately from unrelated information and users will be given an appropriate method to withdraw consent.

Processing may also be required or permitted for other lawful purposes, including performance of a service requested by a user, compliance with legal obligations, protection of security, or an applicable government/contractual arrangement. The precise basis will be documented for relevant processing activities.

Important: A privacy policy is not itself a substitute for a proper consent flow. The VahanPass product must implement the appropriate notice, consent, withdrawal and rights mechanisms in the actual UI wherever required.

6. Government & Authorized Data Integration

VahanPass may propose or implement integration with government or authorized data sources only through the applicable approval, agreement, API onboarding and security requirements of the competent authority/provider.

6.1 Potential Data Sources

6.2 Government Data Principles

Government approval status: This policy does not by itself create or imply government authorization. Any government pilot, API access or department deployment requires its own approval, agreement and technical onboarding.

7. Government Pilot Data Governance

Control AreaProposed Governance
PurposeDefined in the pilot proposal/agreement and limited to the approved operational use.
Data FieldsDocumented in an API/data-parameter matrix with purpose and justification.
AccessRole-based access for authorized officers/administrators.
AuditRelevant verification and administrative actions recorded for audit and evaluation.
RetentionBased on applicable law and the government/enterprise agreement.
SharingRestricted to approved departments/parties and approved purposes.
SecuritySecurity architecture, vulnerability assessment, penetration testing and remediation appropriate to the approved deployment.
ExitAt pilot closure, data return/deletion/retention will follow the agreement and applicable law.

8. QR Code, Token & Vehicle Identity Security

9. Information Security Framework

Identity & AccessMFA where appropriate, strong authentication, RBAC, least privilege and access reviews.
Network SecurityWAF/firewall controls, segmentation where appropriate, secure ingress/egress and monitoring.
Application SecurityInput validation, secure session management, authorization checks, secure coding and dependency management.
API SecurityAuthentication, authorization, rate limiting, validation, logging, credential protection and abuse detection.
Database SecurityRestricted network access, least-privilege database accounts, backups, monitoring and controlled administrative access.
EncryptionEncryption in transit and appropriate protection/encryption for sensitive information at rest.
LoggingSecurity-relevant events, administrative actions and operational events recorded according to documented requirements.
Backup/DRProtected backups, recovery procedures, restoration tests and disaster-recovery planning.

10. Security Architecture & Scalability Controls

For a larger deployment, VahanPass may use a layered architecture consisting of WAF, load balancing, stateless application servers, API gateway, queueing, caching where permitted, verification services, database infrastructure, backups and disaster recovery.

Capacity principle: registered vehicles and simultaneous requests are different workloads. Capacity, concurrency and API rate limits will be established through workload modelling and load testing rather than unsupported fixed server-count claims.

Illustrative Control Flow

User/Officer → WAF → Load Balancer → Application Layer → API Gateway → Verification Engine → Authorized Data Source → Result → Audit Log

11. Administrative & Officer Access

12. Data Accuracy & Verification Status

VahanPass may display data received from users, internal records or authorized external sources. The interface will distinguish between:

VerifiedUsed only where the relevant verification process successfully completed and the source/record supports the result.
PendingUsed where a verification request is still being processed.
UnavailableUsed where a required source/service cannot currently be reached.
User ProvidedUsed where information has been supplied by the user and has not been independently verified.

Where a result may affect an individual or enforcement action, the relevant authority/officer should use the applicable official process and source records required by law or department procedure.

13. Data Retention & Deletion

VahanPass will define retention periods by data category and purpose. Retention may be influenced by applicable law, government agreements, audit requirements, security requirements, contractual obligations and dispute/incident preservation requirements.

Data TypeRetention Approach
Account DataFor the active service relationship and thereafter as required by law, contract, security or legitimate record-keeping requirements.
Verification LogsAccording to the approved operational/audit requirement, pilot agreement and applicable law.
Uploaded DocumentsOnly as required for the service/purpose and applicable retention requirements.
Security LogsAccording to security, legal and applicable CERT-In requirements.
Government DataAccording to the applicable government data-sharing agreement, source requirements and law.
No indefinite retention: VahanPass will not use an open-ended retention period as a substitute for a documented retention schedule.

14. User Rights, Consent Withdrawal & Requests

Subject to the applicable law and the nature of the processing, VahanPass will provide appropriate mechanisms for users to:

Requests may be submitted to privacy@vahanpass.com. Reasonable identity verification may be required before responding to a request involving protected information.

15. Data Sharing & Third Parties

VahanPass may use technology providers, hosting providers, communication providers, payment providers, analytics/security providers and service/assistance partners where necessary to provide the service. Appropriate contractual, access-control and security measures should be used for relevant processors/service providers.

16. Payment & Commercial Information

Where VahanPass accepts payments for QR stickers, subscriptions or services, payment information will be processed through the applicable payment mechanism/provider. VahanPass should avoid storing sensitive payment credentials when the payment provider can securely process them directly.

17. Cookies, Sessions & Device Information

VahanPass may use essential cookies, sessions, local storage and similar technologies for authentication, security, preferences and service functionality. Device/browser information and technical logs may be collected for security, diagnostics and reliability. Any non-essential tracking introduced in the future should be covered by an appropriate notice and consent mechanism where required.

18. Location Data

Location data will be used only for features that require it, such as an authorized field-verification record, roadside assistance, nearby-service discovery or a safety feature. The actual product should request only the level of location precision needed for the selected feature and should clearly communicate the purpose to the user.

Important: VahanPass should not describe continuous location tracking as necessary unless the actual feature genuinely requires it and the applicable notice/permission has been implemented.

19. Safety & Emergency Features

Where VahanPass provides a safety-monitoring or emergency-alert feature, the feature may process technical events such as sound/impact indicators, device state, time and vehicle/user association as required by the implementation.

20. Security Incident & Personal Data Breach Response

VahanPass will maintain an incident-response process proportionate to the system and applicable requirements:

  1. Detect: Identify suspicious activity or a potential incident.
  2. Alert: Notify the responsible security/operations personnel.
  3. Assess: Determine affected systems, information and severity.
  4. Contain: Restrict compromised accounts, systems, tokens or access paths.
  5. Investigate: Preserve relevant logs and evidence.
  6. Mitigate: Remove the cause and address vulnerabilities.
  7. Recover: Restore services and verify system integrity.
  8. Notify: Make required notifications to authorities/affected individuals/contractual stakeholders as applicable.
  9. Review: Perform a post-incident review and implement corrective actions.
Security principle: An incident will not be hidden merely because disclosure is inconvenient. Reporting and notification will follow the requirements applicable to the incident, law and government/enterprise agreement.

21. Business Continuity, Backup & Disaster Recovery

22. Vulnerability Management & Security Testing

Before a government/enterprise production deployment, VahanPass should maintain a security assurance process that may include:

Architecture ReviewReview trust boundaries, data flows and privileged paths.
Threat ModellingIdentify abuse cases and security risks.
Secure Code ReviewReview authentication, authorization, input handling and secrets.
Vulnerability AssessmentIdentify known infrastructure/application weaknesses.
Penetration TestingTest approved application/infrastructure scope.
RemediationTrack, prioritize and resolve findings.
Re-testConfirm important findings have been addressed.
Security ReportMaintain appropriate evidence for the relevant customer/government review.

23. Government Pilot Security Documentation

For a government pilot, VahanPass may provide a security pack containing:

24. Government Pilot Governance

AreaProposed Pilot Control
Pilot ScopeDefined geography, department, vehicle population, duration and features.
Authorized UsersNamed roles/accounts with controlled permissions.
Data SourcesOnly data sources expressly approved for the pilot.
KPIsVerification time, successful scans, system availability, data accuracy, officer usage and operational outcomes as agreed.
SupportDefined technical and operational contacts and escalation procedure.
Incident ReportingIncident notification and escalation according to the pilot agreement and applicable requirements.
Data ExitReturn/deletion/retention at pilot closure according to the agreement and law.
Commercial DeploymentNo assumption of long-term deployment solely from a pilot; any production expansion requires the applicable approval/procurement/contractual route.

25. Government API Failure & Data Availability

Because VahanPass may depend on external/authorized systems, an unavailable external source must not result in a misleading verification.

SituationVahanPass Response
API AvailableProcess the approved request and show the permitted result.
API TimeoutRetry according to approved limits; show pending/unavailable status if not completed.
API Rate LimitRespect provider limits and queue/retry within the approved rules.
API DownShow "Verification temporarily unavailable" or equivalent.
Unexpected DataDo not silently transform it into a positive verification; log and investigate as appropriate.

26. Children & Vulnerable Persons

VahanPass is not intentionally designed to independently collect children's personal data. Where a service involves children or other situations requiring additional legal safeguards, the applicable legal requirements and authorization mechanisms will be followed.

27. Employee, Contractor & Vendor Confidentiality

Personnel with access to VahanPass information should be subject to appropriate confidentiality, access-control and security obligations. Access should be removed or reviewed when a person changes role or leaves the organization.

28. Data Processing by Service Providers

Where VahanPass uses a service provider to process personal data on its behalf, the relationship should be documented through an appropriate contract or terms addressing confidentiality, security, permitted processing, incident notification, assistance and deletion/return obligations as appropriate.

29. Grievance Management

Privacy and data-related complaints may be submitted through the designated grievance channel. VahanPass will maintain a process for recording the complaint, verifying relevant information, assigning responsibility, investigating, responding and documenting closure or escalation.

Grievance: grievance@vahanpass.com

30. Privacy, Security & Legal Contacts

Privacy / Data Requests: privacy@vahanpass.com

Grievance: grievance@vahanpass.com

Security Incident: security@vahanpass.com

Legal Entity: VahanPass (Legal Entity Name)

Registered Office: [Insert Registered Office Address]

31. Policy Review & Change Management

This Policy will be reviewed when there is a material change in the platform architecture, data sources, government agreement, security model, legal requirements or processing purposes. Material changes should be documented through version control and, where required, communicated to affected users or stakeholders.

32. Government Submission Checklist

Legal EntityCompany/LLP/proprietorship details
Data FlowWhat data enters, moves and leaves
SecurityArchitecture, access, encryption, logs
API MatrixParameter + purpose + justification

33. Important Legal Disclaimer

This document is a detailed operational and legal-policy draft. It is not a legal opinion and does not itself establish government authorization, API access, certification, procurement approval or regulatory compliance. Final wording must be reviewed against the actual VahanPass entity, technical implementation, contracts, data flows, government requirements and applicable Indian law before production or government submission.