1. Introduction & Acceptance

These Terms of Use ('Terms') govern your access to and use of the mobile application, website, APIs, AI systems, and all related services (collectively, 'Services') operated by Zylo Club Private Limited, a company incorporated under the Companies Act, 2013 ('Zylo', 'Company', 'we', 'us', 'our').

By downloading, installing, accessing, or using the Services in any manner, you:

• Agree to be legally bound by these Terms and all policies incorporated herein by reference, including the Privacy Policy in Part B
• Acknowledge and accept the terms governing Zylo Credits, Zylo Points, and promotional programmes as described in Section 4
• Consent to the collection, processing, and use of your data as described in Part B (Privacy Policy)
• Acknowledge that the Services incorporate AI-driven systems whose outputs are probabilistic in nature and do not constitute professional advice of any kind
• Confirm you are at least 18 years of age and legally competent to enter into a binding contract under the Indian Contract Act, 1872
• Accept that Zylo may update these Terms at any time with notice via the app or email; continued use constitutes irrevocable acceptance of the revised Terms

If you do not agree to these Terms in their entirety, you must immediately discontinue use of the Services and uninstall the application.

2. Eligibility

You may use the Services only if:

• You are 18 years of age or older. The Services are not intended for, and must not be used by, persons under 18.
• You are legally competent to enter into binding contracts under the Indian Contract Act, 1872
• Your use of the Services is not prohibited by any applicable law or regulation
• Your account has not been previously suspended or terminated by Zylo for any reason
• You are accessing the Services from within India, or voluntarily accessing them from outside India while accepting that Indian law exclusively governs your use

Zylo reserves the absolute right to deny access, verify eligibility, and suspend or terminate accounts at its sole and unfettered discretion without prior notice and without any obligation to provide reasons.

3. Nature & Scope of Services

Zylo Club™ is an AI-powered mobility commerce platform available to car and SUV owners (Zylo Gold™) and two-wheeler owners (Zylo Black™) in India. The Services include:

• Drive-to-Earn: Earning Zylo Credits based on kilometres driven or ridden using a verified vehicle
• Commerce — Eats: Ordering food and beverages from third-party restaurant partners via the partner network
• Commerce — Now: Hyperlocal delivery from Kirana stores and grocery merchants across India
• Commerce — Dine: A forthcoming dining reservation and experience service (not yet available)
• Commerce — Shop: Purchasing products from third-party partner merchants
• Garage: Vehicle management, document storage, and registration certificate services
• Joy AI™: Personalised AI-driven recommendations, insights, and conversational assistance
• Affiliate Programme: Earning Zylo Points by referring new users to Zylo
• My Rewards: A unified dashboard displaying your Zylo Credits balance and Zylo Points balance

Zylo is a technology platform and marketplace facilitator. Zylo does not manufacture, stock, own, or sell any product or service listed on the platform, and is not the seller, manufacturer, logistics provider, or direct service provider of partner seller offerings unless expressly stated. The contract for the sale of goods or services on the platform is between you and the relevant partner seller.

4. Zylo Credits & Points Programme

4.1 Zylo Credits — Nature & Regulatory Status

Zylo Credits are promotional discount instruments created and issued exclusively by Zylo Club Private Limited as part of its internal marketing, customer engagement, and promotional expenditure programmes. Zylo Credits are extended to users as a commercial decision by Zylo to offer promotional pricing on its platform — equivalent in nature to a promotional discount coupon or a marketing offer — and represent Zylo's marketing spend, not a monetary obligation to the user.

Zylo Credits carry no monetary value, are not redeemable for cash or cash equivalents under any circumstances, are non-transferable between users, create no monetary liability or legal entitlement on Zylo, and do not constitute a Prepaid Payment Instrument as defined under Section 2(1)(sa) of the Payment and Settlement Systems Act, 2007 or under any RBI Master Directions or guidelines issued thereunder.

Zylo Credits are not e-money, digital currency, prepaid vouchers, negotiable instruments, or any financial instrument regulated under any applicable Indian or international law. No user acquires any legal right, monetary claim, lien, or proprietary interest over Zylo Credits at any point.

4.2 Zylo Points — Nature & Regulatory Status

Zylo Points are promotional instruments created and issued exclusively by Zylo Club Private Limited as part of its affiliate marketing and customer referral programmes, accounted for internally as Zylo's marketing and promotional expenditure. Zylo Points represent Zylo's commercial decision to offer promotional pricing rewards to users who refer others to the platform.

Zylo Points carry no monetary value, are not redeemable for cash or cash equivalents under any circumstances, are non-transferable between users, create no monetary liability or legal entitlement on Zylo, and do not constitute a Prepaid Payment Instrument or any financial instrument of any kind under applicable Indian or international law.

Zylo Points are redeemable solely as promotional discounts against eligible purchases on the Zylo platform. No user acquires any legal right, monetary claim, lien, or proprietary interest over Zylo Points at any point.

4.3 What Zylo Credits and Points Are NOT

For the avoidance of any doubt, Zylo Credits and Zylo Points are NOT:

• A Prepaid Payment Instrument (PPI) under the Payment and Settlement Systems Act, 2007
• A wallet, digital wallet, or e-wallet regulated by the Reserve Bank of India
• E-money, digital currency, virtual currency, or cryptocurrency
• Negotiable instruments, securities, or financial products of any kind
• A cash equivalent or a substitute for legal tender
• An asset, property right, or investment of any nature
• Transferable, saleable, or exchangeable for any form of value outside the Zylo platform

Any characterisation, description, or representation by any third party suggesting that Zylo Credits or Points constitute a financial instrument, wallet, or regulated product is inaccurate and does not reflect Zylo's intent or the legal nature of these instruments.

4.4 Welcome Credit Bonus

• Zylo Gold™ users receive 5,000 Zylo Credits upon successful account verification and vehicle registration
• Zylo Black™ users receive 2,500 Zylo Credits upon successful account verification and vehicle registration
• Welcome Credits are a one-time promotional offer issued at Zylo's sole discretion and are subject to minimum usage and eligibility conditions as notified in the app
• Zylo reserves the right to modify, reduce, withdraw, or discontinue the Welcome Bonus at any time without notice and without any liability to users

4.5 Earning Zylo Credits (Drive-to-Earn)

• Zylo Gold™ (Car/SUV): Up to 10 Zylo Credits per kilometre driven
• Zylo Black™ (Two-Wheeler): Up to 5 Zylo Credits per kilometre ridden
• Credits are earned only during active Drive-to-Earn sessions on a verified vehicle with location services enabled
• Earning rates are promotional rates set by Zylo at its sole discretion and may be modified, reduced, or discontinued at any time with or without notice
• Credits are credited to the user's My Rewards balance only after Zylo's automated verification of the trip as legitimate and non-fraudulent

4.6 Redemption & Usage

• Zylo Credits and Zylo Points are redeemable exclusively against eligible purchases on the Zylo platform
• Zylo Credits and Zylo Points cannot be used simultaneously in a single transaction; only one type of promotional instrument may be applied per order
• The maximum percentage of any transaction value that may be covered by Zylo Credits or Points is determined by Zylo at its sole discretion and may vary by product category, merchant, or promotion
• Zylo reserves the right to restrict, modify, or withdraw redemption eligibility for specific product categories, sellers, or merchants at any time
• Credits and Points have no cash value and cannot under any circumstances be converted to, or exchanged for, cash or any equivalent

4.7 Expiry & Forfeiture

• Zylo Credits expire 12 months from the date of earning if not redeemed
• Zylo Points expire 24 months from the date of earning if not redeemed
• All Credits and Points are forfeited immediately and without compensation upon account suspension or termination for fraud, abuse, or policy violation
• Zylo reserves the right to withhold, cancel, reverse, reduce, or expire any Credits or Points at any time where Zylo determines, in its sole and final judgment, that they were earned fraudulently, through system manipulation, or in violation of these Terms

4.8 Anti-Fraud & Right to Reverse

Zylo employs automated and manual systems to detect fraudulent Credit or Points earning, including but not limited to: GPS spoofing, route simulation, emulator-based fake trips, device cloning, SIM swapping, multiple account creation, and referral manipulation.

Zylo reserves the right, without prior notice, to: reverse any Credits or Points earned fraudulently; permanently suspend or terminate the associated account; pursue civil or criminal remedies under the Information Technology Act, 2000, the Indian Penal Code, and any other applicable law.

Zylo's determination of fraud shall be final and binding. No user shall be entitled to dispute or appeal a fraud determination through any means other than the Grievance Redressal mechanism in Section 20.

4.9 Absolute Prohibition on Monetary Claims

No user, at any time and under any circumstances, shall have any right to demand, claim, or receive any cash payment, bank transfer, or monetary compensation in lieu of Zylo Credits or Zylo Points, whether upon account closure, programme discontinuation, legal proceedings, or any other event. Any such claim is expressly excluded and waived by the user upon acceptance of these Terms.

4.10 Programme Discontinuation & Modification Right

Zylo reserves the absolute right to modify, suspend, reduce, or permanently discontinue the Drive-to-Earn programme, the Affiliate & Referral Programme, or any other promotional programme, in whole or in part, at any time and with or without prior notice, at its sole and unfettered discretion.

Upon discontinuation of any programme, all unspent Credits and Points associated with that programme are immediately forfeited without compensation.

By accepting these Terms at the time of account registration or continued use of the Services, each user irrevocably and unconditionally acknowledges this right and waives any and all claims for compensation, damages, reimbursement, lost profits, or any other remedy arising from the modification, suspension, or discontinuation of any promotional programme, including any unspent Credits or Points held at the time of closure.

This waiver is a material inducement to Zylo's provision of these promotional programmes and cannot be revoked.

5. Account Registration & Security

• Accounts are created using a verified Indian mobile number (OTP-based authentication). Google Sign-In may be available as a secondary option.
• You are responsible for all activity conducted under your account. Any transaction completed through your account is deemed authorised by you.
• You must keep your login credentials confidential and must not share your account with any other person. Zylo shall not be liable for any loss arising from unauthorised access resulting from your failure to secure your credentials.
• Zylo reserves the absolute and unconditional right to admit, onboard, suspend, restrict, or permanently remove any user from the platform at its sole discretion, at any time, with or without prior notice, and without any obligation to provide a reason or justification. No user has a right or entitlement to access the Zylo platform. Removal or suspension does not entitle the user to any compensation, reimbursement, or recovery of Credits or Points.
• Each user may maintain only one active account. Multiple accounts created to circumvent bans, abuse promotional offers, or manipulate referrals will be permanently terminated and all associated Credits, Points, and balances will be forfeited.
• Zylo may use automated fraud detection systems, device fingerprinting, and behavioural analytics to identify suspicious account activity. Zylo's determination of suspicious activity is final.

6. Affiliate & Referral Programme

6.1 Programme Structure

Zylo operates an affiliate referral programme allowing registered users ('Referrers') to invite others ('Referred Users') to join the platform. Upon a Referred User completing qualifying transactions on Zylo, the Referrer earns Zylo Points as specified in the current programme terms published in the app. All Points earned through the Affiliate Programme are promotional instruments as described in Section 4.2 and are redeemable exclusively on the Zylo platform.

6.2 Earning Structure & Limits

• Referral earnings are credited to the Referrer's My Rewards balance as Zylo Points (not Credits)
• There are no cash payouts, bank transfers, or withdrawals under the Affiliate Programme. All earnings remain as Zylo Points redeemable exclusively on the platform.
• Earning rates, eligibility conditions, and qualifying transaction criteria are published in the app and may be modified with or without notice
• Zylo reserves the right to set, modify, or impose per-user annual Points earning and redemption limits at any time and at its sole discretion, with or without notice, for operational, commercial, legal, or regulatory compliance reasons
• Zylo reserves the right to require submission of PAN or other tax identity documentation from any user whose aggregate Points redemption value crosses a threshold determined by Zylo in its sole judgment, before permitting further redemption
• Zylo reserves the right to deduct applicable taxes, including but not limited to TDS under any applicable provision of the Income Tax Act, 1961, from a user's Points balance or from the transaction value prior to permitting redemption, in the event Zylo determines in its sole judgment that such deduction is legally required
• Zylo reserves the right to cancel, reduce, freeze, or permanently forfeit the Points balance of any user where required for legal, regulatory, or compliance reasons, without compensation

6.3 User Tax Responsibility

Zylo Points are promotional discount instruments accounted for as Zylo's marketing expenditure. Zylo makes no representation, warranty, or assurance about the tax treatment of Points under any individual user's personal tax circumstances.

Each user is solely and exclusively responsible for evaluating and fulfilling all personal income tax obligations that may arise in connection with promotional discounts, benefits, or perquisites received through the Zylo platform, including through the Affiliate Programme. Zylo is not a tax advisor and nothing in these Terms constitutes tax advice.

Zylo reserves the right to report user promotional benefit data to the Income Tax Department of India or any other competent authority as required by applicable law. Zylo's exercise of this right shall not entitle the user to any compensation or claim.

6.4 Programme Conditions & Prohibited Conduct

• Self-referrals and circular referrals are strictly prohibited and will result in immediate account termination and forfeiture of all Credits, Points, and benefits
• Referrals made through fake accounts, incentivised fraud, or any deceptive method are prohibited
• Zylo reserves the right to modify, suspend, or permanently terminate the Affiliate Programme at any time with or without notice, with no liability to any user
• Zylo reserves the right to withhold, reverse, or cancel any Points found to have been generated through fraud, system abuse, or violation of these Terms
• Users may not publicly claim to be 'Zylo affiliates' or 'Zylo representatives' or use the Zylo™ brand in promotional materials without prior written consent from Zylo

7. Data Collection, Processing & Product Development

7.1 Consent to Data Use

By using the Services, you consent to Zylo collecting and processing your data as described in Part B (Privacy Policy). This includes location data, driving behaviour data, AI interaction data, anonymised usage insights, and referral activity data.

7.2 Categories of Data

• Location & Driving Data: GPS data collected during active Drive-to-Earn sessions with your explicit consent
• AI Interaction Data: Conversations with Joy AI™, in-app preferences, and behavioural signals
• Vehicle Data: Registration details fetched via Vahan API with your explicit consent
• Device & Usage Data: Device identifiers, app usage patterns, session data, crash reports
• Contacts Data: Names and mobile numbers from your device phonebook, collected only upon your explicit grant of contacts permission for referral invitation purposes

7.3 Retention of Anonymised Insights

Zylo retains anonymised and aggregated insights derived from user data indefinitely for platform improvement, AI model training, and product development. Such aggregated data does not identify individual users and is not subject to deletion requests under the Digital Personal Data Protection Act, 2023.

8. User Consent & Controls

• You may withdraw consent for non-essential data processing at any time via the app's Privacy Settings
• Withdrawal of consent for location tracking will disable the Drive-to-Earn feature and prevent earning of Zylo Credits
• Withdrawal of consent for AI personalisation will switch Joy AI™ to a generic, non-personalised mode
• You may request account deletion at any time via the app or by emailing dev@zylo.club
• Account deletion will result in the immediate and permanent forfeiture of all Zylo Credits and Points with no right to compensation
• Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal, nor does it give rise to any claim for Credits or Points earned prior to withdrawal

9. AI Systems & Joy™

Zylo's Services incorporate AI-driven systems including Joy AI™. By using these features, you acknowledge and agree that:

• AI outputs are probabilistic and may not always be accurate, complete, current, or suitable for your specific circumstances
• AI-generated recommendations, insights, and responses do not constitute professional, medical, financial, legal, safety, or driving advice of any kind. You must not rely on Joy AI™ for decisions involving personal safety, vehicle operation, financial transactions, or legal matters.
• Zylo is not liable for any decision, action, or omission made in reliance on AI outputs, including decisions made while driving
• You will not use AI features to generate harmful, illegal, defamatory, fraudulent, or misleading content

9.1 AI Misuse — Strictly Prohibited

The following are strictly prohibited and will result in immediate account termination:

• Attempting to manipulate, jailbreak, prompt-inject, or extract training data or system prompts from Zylo's AI systems
• Using AI outputs to train, fine-tune, or benchmark external machine learning models
• Generating deepfakes, synthetic voices, or AI-fabricated content using or imitating the Zylo™ or Joy™ brand
• Generating content that is defamatory, obscene, threatening, promotes violence, or violates applicable law
• Using AI-generated content to deceive, defraud, impersonate, or harm third parties
• Systematic scraping, indexing, or harvesting of AI outputs for commercial purposes

10. Third-Party Partners & Marketplace

10.1 Zylo as Technology Platform Only

Zylo operates exclusively as a technology platform and marketplace facilitator. Zylo does not manufacture, stock, own, warehouse, or sell any product or service listed on the platform. Zylo does not employ delivery personnel, operate restaurants, or manage Kirana stores.

Zylo is not a party to any transaction, contract, or agreement between a user and any merchant, seller, restaurant partner, or service provider on the platform. The contract of sale for any product or service is solely between you and the relevant seller, merchant, or service provider.

Zylo's role is limited to providing the technology infrastructure that enables discovery, browsing, order placement, and communication between buyers and sellers.

10.2 Blanket Release — Merchant & Partner Claims

You hereby irrevocably release, discharge, and hold harmless Zylo Club Private Limited, its directors, officers, employees, affiliates, and agents from any and all claims, demands, damages, losses, costs, expenses, and liabilities of any nature whatsoever — whether known or unknown, foreseen or unforeseen, direct or indirect — arising out of or relating to: any product, service, quality, description, safety, freshness, packaging, non-delivery, delayed delivery, incorrect delivery, or any act, omission, fraud, negligence, or misconduct of any merchant, seller, restaurant partner, logistics provider, or any third-party service provider on the platform.

10.3 Partner Network — Eats & Now

For the 'Eats' (food delivery) and 'Now' (hyperlocal Kirana delivery) categories, Zylo operates as a buyer-side technology application on its partner commerce network. In this capacity, Zylo facilitates discovery, browsing, and order placement on the network only.

The contract of sale for any Eats or Now order is directly between you and the seller or merchant. Zylo is not a party to this contract.

All obligations regarding product quality, freshness, food safety, FSSAI licensing and compliance, accurate product description, packaging standards, and timely delivery rest solely and exclusively with the respective seller and their designated logistics or delivery partner.

Zylo shall not be liable for: defective, stale, or mislabelled products; wrong or incomplete orders; delayed or failed delivery; food safety violations or FSSAI non-compliance by sellers; or any act, omission, or misconduct of any network participant including sellers and logistics providers.

Disputes arising from Eats or Now orders must be raised directly with the seller in the first instance through the in-app dispute mechanism. Zylo's role in dispute resolution is limited to facilitating communication between the buyer and the seller.

10.4 Zylo Dine™ (Forthcoming)

Zylo Dine™ is a forthcoming dining and restaurant experience service and is not yet available. When launched, Zylo Dine™ will operate under a separate service model and its specific terms will be notified at the time of launch. Any references to Zylo Dine™ in the platform prior to launch are indicative only and create no obligation on Zylo.

10.5 Automobile Sales Facilitation

Zylo may facilitate connections between users and automobile dealers or manufacturers. Any such facilitation is a referral service only. Zylo is not a party to any vehicle purchase transaction and is not liable for the terms, financing, warranty, or fulfilment of any such transaction.

10.6 No Endorsement of Partners

The listing of any merchant, restaurant, seller, or service provider on the Zylo platform does not constitute an endorsement, recommendation, warranty, or guarantee by Zylo of the quality, safety, legality, or reliability of such party's products or services. Zylo does not independently verify all partner claims and makes no representation regarding the accuracy of seller listings, pricing, availability, or product descriptions.

11. Payments, Refunds & Settlements

• All payments on the Zylo platform are processed exclusively through RBI-licensed Payment Aggregators, currently Razorpay and PayU. Zylo does not process payments directly.
• Prices displayed on the platform are inclusive of applicable GST unless stated otherwise. GST-compliant receipts and invoices are issued for all completed transactions.
• Zylo does not store, retain, or have access to your full payment card numbers, CVV codes, or UPI PINs. Payment data is processed directly by the respective RBI-licensed Payment Aggregator in compliance with applicable PCI-DSS standards.
• UPI payments are processed through the National Payments Corporation of India (NPCI) infrastructure via the respective Payment Aggregator.
• All refunds for cancelled or undelivered orders shall be processed to the original payment method (card, UPI, or bank account) in the same manner as the original payment was received, within 5–7 business days of the approved refund.
• Zylo does not maintain a digital wallet. There are no refunds to any in-app balance. Refunds go exclusively to the original payment instrument.
• Zylo Credits or Points used in a transaction that is subsequently cancelled or refunded will be re-credited to the user's My Rewards balance.
• Disputed transactions must be raised within 7 days of the transaction date through the in-app Help & Support section. Zylo will endeavour to facilitate resolution with the relevant payment aggregator or seller.

12. User Obligations & Prohibited Conduct

You agree not to:

• Provide false, inaccurate, or misleading information during registration, vehicle verification, or any other interaction with the platform
• Use GPS spoofing, location simulation software, emulators, virtual machines, or any device or software manipulation to fake drive-to-earn trips or earn Credits fraudulently
• Create multiple accounts to abuse promotional offers, circumvent account bans, or manipulate referral programmes
• Use bots, scrapers, crawlers, automated scripts, or any non-human means to access, extract, or interact with the platform
• Reverse-engineer, decompile, disassemble, or attempt to extract source code, AI model weights, or proprietary logic from the platform or its systems
• Transmit viruses, malware, ransomware, or any other harmful or destructive code
• Circumvent, disable, or interfere with platform security, authentication mechanisms, fraud detection systems, or access controls
• Conduct fraudulent transactions, manipulate referrals, place fake orders, or abuse promotional offers in any manner
• Create, distribute, or use deepfakes, synthetic voice recordings, or AI-generated content that imitates or impersonates the Zylo™ or Joy™ brand
• Use the Services to send spam, unsolicited commercial communications, or phishing attempts
• Use the Services for any purpose that violates applicable Indian law or infringes the rights of any third party

Violations may result in: immediate and permanent account termination; forfeiture of all Credits, Points, and balances; financial penalties; civil proceedings; and/or criminal prosecution under the Information Technology Act, 2000, the Bharatiya Nyaya Sanhita, 2023, or other applicable laws.

13. Consumer Protection & E-Commerce Compliance

Zylo complies with the Consumer Protection Act, 2019 and the Consumer Protection (E-Commerce) Rules, 2020:

• Seller or partner information is displayed on product and service pages before purchase
• Return, refund, and exchange policies are accessible within the app before checkout completion
• For Eats and Now orders: FSSAI licensing, food safety compliance, and packaging standards are the sole and exclusive obligation of the respective seller. Zylo does not warrant the food safety or hygiene standards of any Eats or Now seller.
• Users may raise complaints through the in-app grievance mechanism or by contacting the Grievance Officer as described in Section 20
• Zylo does not engage in misleading advertising, dark patterns, or manipulative pricing practices
• For partner network orders, the relevant seller's return and refund policy governs. Zylo facilitates communication of these policies but does not independently warrant them.

14. Intellectual Property

All intellectual property comprising the Services — including software, source code, AI models and architectures, algorithms, data structures, databases, designs, user interfaces, trademarks, trade dress, and content — belongs exclusively to Zylo Club Private Limited or its licensors.

The names Zylo™, Zylo Club™, Zylo Gold™, Zylo Black™, Joy™, Zylo Dine™, Zylo Eats™, Zylo Now™, Zylo Shop™, and all associated logos, taglines, visual identities, and trade dress are proprietary trademarks and brand assets of Zylo Club Private Limited. No person or entity may use, reproduce, imitate, register, or create confusion with any Zylo trademark or brand element without prior written consent from Zylo.

Zylo's AI architectures, Drive-to-Earn earning algorithms, promotional discount engines, pricing models, referral mechanics, and platform logic constitute protectable trade secrets and confidential information under applicable Indian law. Any unauthorised access, extraction, reproduction, or use of such trade secrets is prohibited and actionable.

All AI-generated outputs, insights, recommendations, metadata, and system-generated content produced by Joy AI™ and all other Zylo AI systems are and shall remain the exclusive intellectual property of Zylo Club Private Limited. Users hold no ownership rights over AI outputs and may not reproduce, commercialise, transmit, or use AI outputs to train, fine-tune, or benchmark external machine learning models.

Use of the Zylo™ brand or any similar designation to imply partnership, affiliation, official endorsement, or association with Zylo is strictly prohibited and constitutes passing-off under the Trade Marks Act, 1999 and unfair competition under applicable Indian law.

Zylo may issue takedown notices under the Information Technology Act, 2000 and applicable intellectual property laws against any person or entity infringing Zylo's intellectual property rights.

15. User Content Licence

By submitting content to the platform (including reviews, feedback, ratings, or images), you grant Zylo Club Private Limited a worldwide, perpetual, royalty-free, non-exclusive, sublicensable licence to use, reproduce, modify, adapt, publish, translate, distribute, and display such content solely for the purposes of operating, improving, and promoting the Services, to the extent permitted by applicable law. You represent and warrant that you have all necessary rights to grant this licence and that your content does not infringe any third-party rights.

16. Disclaimer of Warranties

The Services are provided 'AS IS' and 'AS AVAILABLE' without any warranty of any kind. To the maximum extent permitted by applicable Indian law, Zylo disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, accuracy, completeness, availability, and uninterrupted service.

Zylo makes no warranty regarding: the quality, safety, freshness, accuracy of description, or fitness for purpose of any product or service offered by any merchant, seller, or partner on the platform; the reliability or availability of the partner network or any payment gateway; the accuracy or reliability of Joy AI™ outputs; or the uninterrupted availability of the Drive-to-Earn feature.

Nothing in this clause limits any mandatory statutory rights you may have under the Consumer Protection Act, 2019 in relation to Zylo's own services (as distinct from partner seller services).

17. Limitation of Liability

To the maximum extent permitted by applicable Indian law:

• Zylo's liability for any claim arising out of or in connection with a partner seller transaction ('Eats' or 'Now' orders) is expressly excluded and shall be zero. Zylo is not a party to any such transaction and assumes no liability for any seller's acts, omissions, or defaults.
• For claims relating to Zylo's own technology platform services, Zylo's total aggregate liability shall not exceed the greater of: (a) the total amount paid by the user to Zylo in the three months preceding the claim; or (b) INR 5,000.
• Zylo shall not be liable for any indirect, incidental, special, punitive, or consequential damages including loss of data, loss of profits, loss of Credits or Points, loss of revenue, or business interruption, arising from use of or inability to use the Services.
• Zylo shall not be liable for any loss of Zylo Credits or Points resulting from programme discontinuation, account termination, expiry, or system errors, as these are promotional instruments with no monetary value.
• This limitation does not apply to death or personal injury caused directly by Zylo's proven negligence or fraud.

Nothing in this clause limits any mandatory rights under the Consumer Protection Act, 2019 with respect to Zylo's own services.

18. Indemnification

You agree to indemnify, defend, and hold harmless Zylo Club Private Limited, its directors, officers, employees, affiliates, agents, successors, and licensors from and against any and all claims, losses, damages, liabilities, deficiencies, costs, and expenses (including reasonable legal fees and court costs) arising out of or relating to: (a) your use or misuse of the Services; (b) your violation of these Terms or any applicable law; (c) your infringement of any third-party intellectual property, privacy, or other rights; (d) any claim by a seller or logistics provider arising from your conduct as a buyer on the partner network; (e) your failure to fulfil any tax obligations arising from promotional benefits received; (f) your submission of fraudulent, false, or misleading information to the platform; or (g) any content you submit, post, or transmit through the Services.

19. Termination

• Zylo may suspend or permanently terminate your access to the Services at any time, with or without notice, at its sole discretion, for any reason including but not limited to: fraud, GPS spoofing, account multiplication, policy violation, legal requirements, or any operational reason
• Termination for fraud or policy violation: all Zylo Credits, Points, and any promotional balances are immediately forfeited without compensation
• User-initiated account closure: Credits and Points expire per their normal expiry terms (Section 4.7). No special payout or recovery is available.
• No termination, whether by Zylo or the user, entitles the user to any cash payment, bank transfer, or monetary compensation for any Credits, Points, or promotional benefits
• Upon termination for fraud, GPS manipulation, or systematic abuse, Zylo reserves the right to pursue civil and criminal remedies under applicable Indian law
• All licences granted under these Terms cease immediately upon termination
• Clauses relating to intellectual property, indemnification, limitation of liability, governing law, and warranty disclaimers survive termination

20. Grievance Redressal

In compliance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Consumer Protection (E-Commerce) Rules, 2020, Zylo has designated the following Grievance Officer:

• Grievance Officer: Aishwarya Sahni
• Designation: Grievance Officer — Zylo Club Private Limited
• Email: aishwarya@zylo.club
• Address: 218, Solus, Hiranandani Estate, Patlipada, Behind Bayer House, Thane West, Mumbai - 400607, Maharashtra
• Scope: The Grievance Officer handles all grievances relating to Terms of Use violations, Privacy Policy concerns, data rights requests, and general service complaints
• Resolution Timeline: Grievances acknowledged within 24 hours of receipt; resolved or escalated within 30 days

For disputes arising from partner network orders (Eats or Now), users must first raise the dispute through the in-app order dispute mechanism, which escalates to the relevant seller and logistics provider. The Grievance Officer handles escalated complaints only where the seller has failed to respond within the timeframe specified in the app.

21. Dispute Resolution & Arbitration

• Step 1 — Informal Resolution: Notify Zylo at aishwarya@zylo.club with full details of the dispute. Zylo and the user shall attempt resolution in good faith within 30 days.
• Step 2 — Arbitration: If informal resolution fails, the dispute shall be referred to and finally resolved by arbitration under the Arbitration and Conciliation Act, 1996, before a sole arbitrator appointed by mutual agreement or, failing agreement, by the relevant court. The seat and venue of arbitration shall be Thane, Maharashtra. The arbitration shall be conducted in English.
• Step 3 — Courts: If arbitration is inapplicable or fails, the courts at Thane, Maharashtra shall have exclusive jurisdiction.
• All disputes, regardless of the user's nationality, place of residence, or domicile, shall be resolved exclusively under Indian law and in Indian forums. No dispute shall be referred to any foreign court, tribunal, arbitral body, or regulatory authority.

22. Governing Law & Jurisdiction

These Terms are governed exclusively by and construed in accordance with the laws of the Republic of India, without regard to conflict of law principles.

The courts at Thane, Maharashtra shall have exclusive jurisdiction over all disputes arising from or related to these Terms or the use of the Services.

By accepting these Terms, all users — regardless of their nationality, country of residence, domicile, or place of access — irrevocably submit to the exclusive jurisdiction of Indian courts and expressly waive any right to invoke or rely upon foreign data protection, consumer protection, e-commerce, or any other laws, including but not limited to: the EU General Data Protection Regulation (EU) 2016/679, UK GDPR, California Consumer Privacy Act 2018, or any equivalent foreign legislation.

Zylo does not verify user nationality and provides its Services within India only. If you access the Services from outside India, you do so voluntarily at your own risk and initiative, and Indian law exclusively governs your access and use.

23. Force Majeure

Zylo shall not be liable for any failure or delay in the performance of its obligations caused by circumstances beyond its reasonable control, including but not limited to: outages or disruptions of partner commerce networks; downtime or technical failures of RBI-licensed Payment Aggregators or UPI infrastructure; failures or service interruptions by upstream AI or large language model service providers; telecommunications or internet infrastructure failures; cyber-attacks, distributed denial-of-service attacks, or security incidents beyond Zylo's reasonable control; natural disasters, floods, earthquakes, fires; epidemic, pandemic, or public health emergency; government orders, regulatory actions, or court-mandated service restrictions; or any other event of force majeure under applicable Indian law.

24. Tax Obligations

• All prices displayed on the Zylo platform are inclusive of applicable Goods and Services Tax (GST) unless stated otherwise. Zylo issues GST-compliant receipts and invoices for all completed purchase transactions.
• Zylo Credits and Zylo Points are promotional discount instruments accounted for internally as Zylo Club Private Limited's marketing and promotional expenditure. Zylo makes no representation, warranty, or assurance regarding the tax treatment of Credits, Points, or promotional discounts received through the platform under any individual user's personal income tax circumstances.
• Each user is solely and exclusively responsible for evaluating and fulfilling all personal income tax, TDS, and other statutory obligations that may arise from promotional discounts, benefits, or perquisites received through the Zylo platform. Zylo is not a tax advisor. Nothing in these Terms constitutes tax or financial advice.
• Zylo reserves the right, at any time and at its sole and absolute discretion, to: (a) impose per-user annual limits on Credits earning or Points earning and redemption for tax compliance purposes; (b) require submission of PAN Card or other tax identity documentation from any user before permitting redemption of Credits or Points above a value threshold determined by Zylo; (c) deduct applicable TDS or other statutory taxes from a user's Credits or Points balance or from the applicable transaction value prior to permitting redemption, where Zylo determines in its sole judgment that such deduction is legally required; and (d) report user benefit data, transaction records, and any other information to the Income Tax Department of India or any other competent statutory authority as required or permitted by applicable law.
• Zylo's exercise of any rights described in this Section shall be final and binding. Such exercise shall not entitle the user to any compensation, claim, or legal remedy of any kind.

25. Regulatory Compliance & Licensing

Zylo operates in compliance with applicable Indian regulatory frameworks:

• Payment Processing: All payment transactions on the platform are processed exclusively through Payment Aggregators holding valid authorisation from the Reserve Bank of India under the Payment and Settlement Systems Act, 2007. Currently, Zylo uses Razorpay and PayU as its licensed Payment Aggregators.
• Food Safety: All restaurant partners and grocery sellers on the Eats and Now categories are independently responsible for obtaining and maintaining valid FSSAI licences and complying with all applicable food safety regulations. Zylo does not hold or require FSSAI licensing for its marketplace technology operations.
• Data Protection: Zylo operates as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 and complies with the Information Technology Act, 2000 and applicable rules thereunder.
• E-Commerce: Zylo complies with the Consumer Protection (E-Commerce) Rules, 2020 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 in its capacity as an e-commerce marketplace entity.

26. Amendments to These Terms

Zylo reserves the right to modify, amend, or replace these Terms at any time. Users will be notified of material changes via in-app notification or email at least 7 days prior to the effective date of the change. Continued use of the Services after the effective date of any amendment constitutes irrevocable acceptance of the revised Terms. If you do not agree to any amendment, your sole remedy is to discontinue use of the Services and request account deletion.

27. Contact Information

• General Enquiries & Support: dev@zylo.club
• Legal, Compliance & Regulatory: dev@zylo.club
• Privacy & Data Rights Requests: dev@zylo.club
• Affiliate Programme Queries: dev@zylo.club
• Grievance Officer (Terms & Privacy): aishwarya@zylo.club
• Partner & Merchant Relations: gaurav@zylo.club
• Registered Address: 218, Solus, Hiranandani Estate, Patlipada, Behind Bayer House, Thane West, Mumbai - 400607, Maharashtra, India

Introduction

This Privacy Policy forms an integral part of the Terms of Use above and is governed exclusively by the laws of India. It describes how Zylo Club Private Limited ('Zylo', 'Data Fiduciary') collects, processes, stores, and protects the personal data of users ('Data Principals') in accordance with the Digital Personal Data Protection Act, 2023 ('DPDP Act'), the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ('SPDI Rules'), and all other applicable Indian laws. This Privacy Policy applies to all users of the Zylo mobile application and website, regardless of their nationality or location.

B1. Personal Data We Collect

• Identity Data: Full name, mobile number, email address
• Vehicle Data: Registration number (RC), make, model, year, fuel type — fetched from the Vahan API with your explicit consent
• Location Data: GPS coordinates, trip route, kilometres driven — collected only during active Drive-to-Earn sessions when the app is in use and location permission has been granted
• Financial & Transaction Data: Credits balance, Points balance, order history, payment method type (card/UPI — full card numbers and CVV are never stored by Zylo)
• Device Data: Device model, OS version, app version, IP address, device identifiers, session logs, crash reports
• AI Interaction Data: Conversations with Joy AI™ — inputs, outputs, and contextual signals
• Behavioural Data: In-app navigation, feature usage, click patterns, preference signals, time-spent data
• Contacts / Phonebook Data: Names and mobile numbers from your device phonebook — collected only upon your explicit grant of contacts permission, solely for the purpose of sending affiliate referral invitations. This data is not uploaded to or retained on Zylo's servers.
• Commercial Communication Preferences: Your opt-in or opt-out status for WhatsApp, SMS, and push notification communications
• Cookies & Analytics: Session data, visit frequency, referral source, feature engagement — for both the website and mobile app

B2. Lawful Basis for Processing

• Consent: For Drive-to-Earn location tracking, AI personalisation, marketing communications, and affiliate programme participation
• Contractual Necessity: For account creation, order processing, payment facilitation, and Service delivery
• Legal Obligation: For compliance with the IT Act 2000, DPDP Act 2023, tax obligations, regulatory reporting, and court orders
• Legitimate Interest: For fraud detection, security monitoring, platform improvement, and anonymised analytics

B3. How We Use Your Data

• Account creation, management, and authentication
• Verifying and crediting Zylo Credits based on kilometres driven
• Processing orders, payments, and refunds across all categories
• Personalising the Joy AI™ experience and platform recommendations
• Facilitating vehicle document management and RC verification through the Vahan API
• Detecting and preventing fraud, GPS spoofing, account manipulation, and security threats
• Complying with legal obligations including tax, regulatory reporting, and court orders
• Sending transactional notifications, operational alerts, and (where consented) promotional communications
• Improving platform features, AI model performance, and user experience through aggregated and anonymised insights
• Facilitating referral invitations through the Affiliate Programme (phonebook data, user-initiated only)

B4. Sharing & Disclosure of Data

Zylo does not sell, rent, or trade your personally identifiable data to third parties. Data may be shared in the following limited, specified circumstances:

• Sellers & Logistics Partners: Order fulfilment data (name, delivery address, contact number, order details) shared with the relevant seller and their logistics partner solely to complete Eats and Now orders
• Payment Aggregators: Payment-related data is shared with RBI-licensed Payment Aggregators (Razorpay, PayU) for transaction processing. Full card numbers and CVV are processed directly by these aggregators and are never transmitted to or stored by Zylo.
• Vahan API: Your RC number is transmitted to the National Informatics Centre's Vahan API solely for vehicle registration verification
• Analytics Processors — Google Analytics & Mixpanel: Zylo shares anonymised, pseudonymised behavioural and session data with Google Analytics and Mixpanel to understand platform usage, fix technical issues, and improve the product. These tools receive anonymised device identifiers and usage signals only. No personally identifiable information (name, phone number, email, financial data) is shared with these tools. Both operate under data processing agreements with Zylo and are bound to process data only per Zylo's instructions.
• Government & Law Enforcement: Personal data is disclosed when required by applicable Indian law, valid court order, or lawful government direction, including under the IT Act 2000, DPDP Act 2023, Income Tax Act 1961, or other applicable legislation
• Service Providers: Cloud hosting, infrastructure, and operational service providers operating under data processing agreements that restrict use of data to Zylo's specified purposes

All third-party service providers who process personal data on Zylo's behalf are contractually bound to comply with applicable data protection laws and Zylo's data handling standards.

B5. Data Retention

• Account & Identity Data: Duration of account + 3 years post-deletion (for legal compliance and dispute resolution)
• Vehicle & Vahan Data: Duration of account + 2 years
• GPS / Location / Driving Data: 90 days of raw trip data; anonymised aggregates retained indefinitely for AI model improvement
• Financial / Transaction Data: 7 years as required under the Income Tax Act, 1961
• Partner Network Order Data: 2 years from order date for dispute resolution purposes
• AI Interaction Logs: 12 months; anonymised thereafter for model improvement
• System & Security Logs: 180 days
• Marketing Consent Records: Until consent is withdrawn + 1 year

Upon account deletion request, Zylo will delete or anonymise all personal data within 30 days, subject to the mandatory retention periods specified above.

B6. Your Rights as a Data Principal

Under the Digital Personal Data Protection Act, 2023, you have the following rights:

• Right to Access: Request a summary of personal data Zylo holds about you
• Right to Correction: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data (subject to mandatory retention periods)
• Right to Withdraw Consent: Withdraw consent for non-essential data processing at any time via app settings
• Right to Grievance Redressal: Lodge a complaint with Zylo's Grievance Officer at aishwarya@zylo.club
• Right to Nominate: Nominate an individual to exercise your data rights in the event of your incapacity or death, as provided under the DPDP Act 2023

To exercise any of these rights, contact dev@zylo.club with your registered mobile number and a description of your request. Zylo will respond within 30 days.

B7. Location & Driving Data — Specific Disclosures

• Zylo collects GPS location data only during active Drive-to-Earn sessions when you have explicitly granted location permission and the feature is active
• Background location access may be used for Zylo Black™ two-wheeler users who operate in background mode, subject to your explicit grant of background location permission
• Raw GPS data is retained for 90 days for fraud detection and dispute resolution, then anonymised
• Your location data is not shared with advertisers, data brokers, or any third party other than as described in B4
• Disabling location access will disable Drive-to-Earn Credit tracking

B8. Phonebook & Contacts Data

Zylo requests access to your device phonebook solely to enable the Affiliate Referral Programme's contact-based invitation feature.

• Contacts permission is entirely optional. You may use the manual share link (via WhatsApp or SMS) without granting contacts access.
• Zylo reads contact names and mobile numbers solely in-session for the purpose of displaying them for your selection when sending a referral invitation.
• Zylo does not upload, store, retain, index, or analyse your contacts list on its servers.
• Contact data is not used for advertising, profiling, cross-referencing with other users, or any purpose other than sending the referral invitation at your explicit instruction.
• You may revoke contacts permission at any time via your device settings.

B9. Data Security

• End-to-end encryption (TLS 1.3) for all data in transit
• AES-256 encryption for sensitive data at rest
• Role-based access controls limiting data access to authorised personnel only
• Regular security audits and vulnerability assessments
• Multi-factor authentication for all administrative system access

B9.1 Data Breach Response

• Zylo will take immediate containment and remediation steps
• Affected Data Principals will be notified promptly in accordance with the DPDP Act 2023
• Zylo will document the incident, its cause, scope, and the remediation measures taken
• Disclosure to relevant authorities will be made as required under applicable Indian law

B10. Cookies & Analytics — Website & App

Website Cookies:

• Strictly Necessary Cookies: Required for the website to function correctly. Cannot be disabled.
• Analytical Cookies (Google Analytics): Help Zylo understand how visitors use the website — page views, session duration, traffic sources. Enabled only with your consent.
• You can manage website cookie preferences via the cookie banner or your browser settings.

Mobile App Analytics:

• Mixpanel: Zylo uses Mixpanel for in-app behavioural analytics — feature usage, user flows, crash reporting, and product improvement. Mixpanel receives anonymised device identifiers and usage events only. No personally identifiable information (name, phone, email) is transmitted to Mixpanel.
• Firebase / Google Analytics for Firebase: Used for app performance monitoring and crash reporting.
• Essential crash and performance analytics cannot be disabled as they are necessary to maintain app stability and security.
• Behavioural analytics may be opted out via app settings.

All analytics processors operate under data processing agreements with Zylo and are prohibited from using Zylo user data for their own purposes.

B11. Children's Privacy

The Services are not directed at persons under the age of 18. Zylo does not knowingly collect personal data from children. In accordance with the Digital Personal Data Protection Act, 2023, processing of data of persons under 18 requires verifiable parental or guardian consent.

If you become aware that a child under 18 has provided personal data without parental consent, please contact dev@zylo.club immediately. Zylo will delete such data promptly upon verification.

B12. Changes to This Privacy Policy

Zylo may update this Privacy Policy from time to time to reflect changes in applicable law, our practices, or our Services. When material changes are made, Zylo will notify users via in-app notification or email at least 7 days before the changes take effect. Continued use of the Services after the effective date of any update constitutes acceptance of the revised Privacy Policy.

B13. Final User Acknowledgement

By clicking 'I Agree', downloading the app, creating an account, or using the Services, you confirm that you have read, understood, and agree to be bound by these Terms of Use and this Privacy Policy in their entirety. You confirm that your personal data may be used to operate, deliver, secure, and improve the Zylo platform and its AI systems in accordance with the practices described herein and applicable Indian law. You irrevocably waive any right to claim compensation for the loss of Zylo Credits or Points arising from programme discontinuation, account action, or any other circumstance described in these Terms.

B14. India-Only Governing Law & Jurisdiction

This Privacy Policy is governed exclusively by the laws of the Republic of India, including the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000 and rules thereunder.

Zylo's Services are designed, operated, and intended for use within India. All personal data collected through the Services is processed and stored in India or in such countries as may be permitted under applicable Indian data localisation requirements.

Any person accessing the Zylo platform from outside India does so voluntarily, at their own initiative and risk, and is bound by this Privacy Policy and Indian law exclusively.

Zylo does not recognise, and expressly excludes, the applicability of any foreign privacy, data protection, or consumer protection regulations to its operations or to data processed through its Services, including but not limited to: the EU General Data Protection Regulation (GDPR) (EU) 2016/679, UK GDPR, California Consumer Privacy Act (CCPA) 2018, or any equivalent foreign legislation.

Zylo does not verify user nationality. All users, regardless of nationality or place of access, are treated as subject to Indian law for the purposes of this Privacy Policy.

B15. Commercial Communications Consent (TRAI)

• Transactional Communications: Order confirmations, payment receipts, delivery updates, account security alerts, and OTPs. These are sent as a necessary part of the Service and cannot be fully opted out of while the account remains active.
• Promotional & Marketing Communications: Offers, new feature announcements, Credits and Points programme updates, and promotional campaigns. These are sent only to users who have explicitly opted in.
• Referral Invitations via WhatsApp or SMS: Sent only upon your explicit initiation through the Affiliate Programme feature in the app.

Zylo complies with the Telecom Commercial Communications Customer Preference Regulations issued by TRAI.

You may opt out of promotional and marketing communications at any time via: (a) the notification preferences in the app; (b) replying STOP to any promotional SMS; or (c) contacting dev@zylo.club.

Opting out of promotional communications does not affect transactional communications necessary for Service delivery.