MetroFeeder — Privacy Policy

Last updated: 03 May 2026

DRAFT — REQUIRES LEGAL REVIEW BEFORE PUBLICATION. This draft is engineering-grade: every SDK and data category listed here reflects what the codebase actually does, but the legal phrasing, jurisdictional clauses and disclosure obligations should be confirmed by qualified Indian legal counsel before publishing at a public URL.

Effective date: [TO BE FILLED ON PUBLICATION]

Operator: [LEGAL ENTITY NAME], a company incorporated in India with its registered office at [REGISTERED ADDRESS], Hyderabad, Telangana, India (the "Company", "we", "us", "our").

Contact: privacy@metrofeeder.app · Grievance Officer: [NAME, EMAIL, PHONE] (per Rule 5(9), DPDP Act 2023 + IT Rules 2021).

This Privacy Policy explains how MetroFeeder ("the App") collects, uses, shares, retains, and protects your personal data when you use the MetroFeeder mobile application (iOS / Android) and the related driver, fleet, executive, and admin web portals.

This Policy is issued under the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. For users accessing the App from the European Union or the United Kingdom, the App also adheres to the principles of the GDPR / UK GDPR.

1. Personal data we collect

CategorySpecific fieldsSourceUsed for
IdentityFull name, gender, age, occupation, profile photoYou (during signup / profile edit)Account creation, ride matching, KYC
ContactMobile number, optional emailYouLogin, OTP verification, ride notifications, support
AuthenticationBcrypt-hashed PIN, biometric template (stored on-device only via expo-secure-store / iOS Keychain / Android Keystore)YouSign-in. Biometric data never leaves the device
LocationGPS coordinates, accuracy, timestamps; pickup, drop-off, and live ride locationsexpo-location (foreground only)Nearest-station detection, ride matching, ETA, live tracking, safety
Ride historyRide ID, route, fare, vehicle type, timestamps, ratings, driver/passenger IDGenerated server-sideRide history, dispute resolution, fraud prevention, regulatory reporting
PaymentWallet balance, transaction history, last-4 of saved card / masked UPI VPA, Razorpay/Stripe payment tokens. We do NOT store full card numbers, CVV, or UPI PINs.Razorpay / Stripe (PCI-DSS compliant processors)Wallet, ride payment, refunds, payout
KYC documents (drivers)Driving licence number, RC number, vehicle insurance, PAN, photographs of documentsYou (during driver onboarding)Driver onboarding aligned with the Motor Vehicles Aggregator Guidelines 2025; supports any subsequent verification by the Hyderabad RTA
Emergency contactsNames and phone numbers you addYouSOS escalation only
Device & technicalDevice model, OS version, app version, IP address, language, timezone, crash logs (without PII)Captured automaticallySecurity, crash reporting, fraud prevention
Usage analyticsScreens viewed, features used, performance metricsCaptured automatically (Sentry, Replit logs)Product improvement, crash diagnosis
CommunicationsSupport messages, in-app chat (passenger ↔ driver), grievance ticketsYouCustomer support, dispute resolution

We do not collect: contact list (we only show the system contact picker if you tap "Add Emergency Contact"), SMS contents, call logs, sensor or motion data, browsing history, or biometric raw data.

2. Why we process your data — lawful basis

Under DPDP Act § 4, we rely on the following grounds:

You may withdraw consent for any optional processing at any time — in-app at Profile → Privacy Center or by emailing privacy@metrofeeder.app.

3. Third-party SDKs & data processors

The following third parties may receive personal data only for the purposes listed and under contractual processing terms:

ServicePurposeData sharedPrivacy policy
Razorpay (Razorpay Software Pvt Ltd, India)UPI / cards / NetBanking checkout, wallet top-up, RazorpayX driver payoutsPayment amount, currency, tokenised payment instrument, your phone, your name, ride IDrazorpay.com/privacy
Stripe (Stripe Payments India Pvt Ltd)Legacy / fallback card processingSame as Razorpaystripe.com/in/privacy
Twilio (Twilio Inc, USA)OTP / SMS delivery, SOS escalation callsYour phone, OTP code, message bodytwilio.com/legal/privacy
Google Maps Platform (Google LLC, USA)Map tiles, Places autocomplete, Directions, GeocodingPickup / drop-off coordinates, search query stringpolicies.google.com/privacy
Apple (Apple Inc, USA)Sign in with Apple, Apple Push Notification service, App Store distributionUser-supplied Apple ID identifier (anonymous), device push tokenapple.com/legal/privacy
Google (Google LLC)Firebase Cloud Messaging push delivery, Play Store distributionDevice push tokenpolicies.google.com/privacy
Sentry (Functional Software Inc, USA)Crash & error reportingStack traces, app version, OS version, your internal database id only (no name/phone/email — automatically scrubbed by beforeSend filter)sentry.io/privacy
OpenAI (OpenAI L.L.C., USA)(a) Speech-to-text via the Whisper API for the voice-booking feature — the raw audio recording you make in the app is uploaded to https://api.openai.com/v1/audio/transcriptions. The audio may incidentally contain anything you spoke aloud (e.g. station names, a contact name, an address). We do not transmit your phone, account id, name, or location alongside the audio. After transcription the audio buffer is discarded server-side; only the resulting text is retained for matching against the metro-station list. (b) Text-only intent / help responses for the chatbot.Audio recording (voice booking); message text (chatbot)openai.com/policies/privacy-policy
Anthropic (Anthropic PBC, USA)In-app chatbot ("Help Assistant"). Text-only — the message you typed. We do not send phone, name, or location in the prompt.Message textanthropic.com/legal/privacy
Google Identity / OAuth (Google LLC, USA)Optional "Continue with Google" sign-in option on the login screen. If you tap it, the Google OAuth flow returns an access token; we then call https://www.googleapis.com/userinfo/v2/me once to read your Google profile name and email, which we store on your MetroFeeder account. We do not request Google contacts, calendar, drive, or any other scope.Google profile name & emailpolicies.google.com/privacy
Replit Hosting (Replit Inc, USA)Server hosting (Express + Postgres)All app data flows through Replit infrastructurereplit.com/site/privacy
Neon Database (Neon Inc, USA)Managed Postgres backing the APIAll app dataneon.tech/privacy-policy

We have no agreements with advertising networks or data brokers, and the App does not share your data for advertising or behavioural profiling.

4. Cross-border data transfers

Some of the third parties above (Stripe, Twilio, Google Maps, Google Identity, Apple, Sentry, OpenAI, Anthropic, Replit, Neon) process data outside India, primarily in the United States and the European Union. We rely on:

5. How long we keep your data

DataRetention
Active account profileUntil you request deletion (see § 8)
Ride records5 years from the date of the ride, per IT Rules 2021 + GST records retention
Payment / wallet transactions8 years, per Indian Income Tax Act, 1961
KYC documents (driver)5 years after the driver's last active ride
Crash & error logs90 days in Sentry
Server access logs30 days
Backups14 days rolling
Deleted account audit log3 years (only the user id, deletion timestamp, IP, optional reason — see deleted_users_log table)

6. Security

7. Children

The App is not directed at children under 13 and we do not knowingly collect data from them. If you believe a minor has provided us data, contact privacy@metrofeeder.app and we will delete it.

8. Your rights under DPDP Act 2023

You have the right to:

To exercise these rights: in-app at Profile → Help → Delete Account (passenger) or Profile → Support → Delete Account (driver) for erasure, or Profile → Privacy Center for access / correction / withdrawal. You can also email privacy@metrofeeder.app. See also the dedicated Account & Data Deletion page.

We respond within 30 days of receipt of a valid request.

Account deletion specifically

The "Delete Account" button performs a hard delete of your user record, with cascading deletes of your saved locations, wallet, emergency contacts, profile photo URL, ratings, notifications, and preferences. Ride records are retained in anonymised form (your user id is set to NULL) so that the driver's payment history, regulatory record, and dispute history remain intact. A single audit row in deleted_users_log (user id, timestamp, IP, optional reason) is kept for 3 years for fraud prevention.

9. Grievance Officer

In compliance with Rule 5(9) of the IT Rules 2021 and § 13 of the DPDP Act:

10. Changes to this Policy

We may update this Policy from time to time. The "Effective date" at the top reflects the latest revision. Material changes will be notified to you in-app and by email at least 7 days before they take effect.


Questions? privacy@metrofeeder.app