Aadhaar & KYC Consent Notice

Issued by: Lazyfoxs Logistics Pvt Ltd (operating the "Delv Express" brand).
For: prospective and active Delivery Partners onboarded through the Delv Partner mobile application (com.delvexpress.partner).

Reference framework:

• Digital Personal Data Protection Act, 2023 ("DPDP Act"), sections 5 and 6, read with the Digital Personal Data Protection Rules, 2025, rule 3.
• Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 ("Aadhaar Act"), sections 8 and 8A, read with the Aadhaar (Authentication and Offline Verification) Regulations, 2021 (as amended by the 2024 Amendment and the 2025 Amendment Regulations).
• The judgment of the Hon'ble Supreme Court of India in Justice K.S. Puttaswamy (Retd.) & Anr. v. Union of India, (2019) 1 SCC 1 ("Puttaswamy II"), to the extent that it limits the use of Aadhaar by private entities to voluntary, informed-consent use cases.
• The Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2025.

This notice is required by the DPDP Act and the Aadhaar Act. Please read it carefully before you submit your Aadhaar number, your Permanent Account Number (PAN) or your Driving Licence to the Delv Partner app. Your submission of these documents is voluntary, and we cannot complete your onboarding without them. You may decline at any stage; if you do, you will not be able to use the Delv Partner platform but no other consequence will follow.

1. Who is asking for your consent

Lazyfoxs Logistics Pvt Ltd ("Delv Express", "we", "us"), a company incorporated under the Companies Act, 2013.

• Registered office: Haripur Siho, Muzaffarpur, Bihar 843119, India.
• Corporate office: Plot 63, Udyog Vihar Extension, Ecotech-II, Surajpur, Greater Noida, Uttar Pradesh 201306, India.
• Contact for this notice: admin@delvexpress.com / +91 80774 81613 (Mon–Sat, 10:00–19:00 IST).

We are the Data Fiduciary for the Personal Data described in this notice.

2. The Personal Data we are asking for

We do not perform Aadhaar biometric authentication. We do not read your Aadhaar OTP from UIDAI infrastructure. We do not call the Aadhaar Authentication User Agency or e-KYC User Agency systems. We perform offline visual verification only, supplemented (if you so consent on a separate screen) by a UIDAI-permitted offline e-KYC.

3. The specified purpose for which we are collecting

We collect this data for the following itemised purposes (DPDP Act, section 5(1)):

1. to verify your identity as a person at least eighteen (18) years of age, eligible to be onboarded as a Delivery Partner;
2. to verify your eligibility to drive or ride the vehicle category for which you wish to be assigned, by reference to your Driving Licence under the Motor Vehicles Act, 1988;
3. to comply with our obligations under the Income-tax Act, 1961, in particular the requirement to collect PAN before making payouts above the threshold prescribed under the Act and to deduct tax at source (TDS) where applicable;
4. to comply with our obligations under the Motor Vehicles Aggregator Guidelines, 2025, which require an aggregator to verify the credentials of every driver onboarded to its platform, to maintain records of identity, to enrol you in health and term insurance, and to conduct police verification, medical and (where applicable) psychological assessment;
5. to satisfy reasonable due-diligence, anti-fraud and safety-screening requirements applicable to a platform that engages individuals to handle Customers' goods and to interact with members of the public;
6. to procure on your behalf, for your benefit, the insurance cover described in section 9 of the Terms of Service and in the Delivery Partner Agreement;
7. to maintain records required under the Companies Act, 2013 and the Goods and Services Tax Act, 2017 for at least seven (7) years after your engagement with the platform ends; and
8. to defend or pursue any legal claim that may arise out of services performed by you through the platform.

We will not use this data for any other purpose without obtaining a fresh, specific consent or relying on another lawful basis under section 7 of the DPDP Act.

4. Your consent is voluntary

4.1 By tapping "I consent" on the KYC screen of the Delv Partner app, and by submitting the documents, you give us your free, specific, informed, unconditional consent with clear affirmative action to collect, store, retain, use and (in the limited manner described below) share these documents for the purposes above.

4.2 You are not required to give this consent. You may decline and the app will not proceed with onboarding. The only consequence of declining is that you cannot be engaged as a Delivery Partner. We will not penalise you, refuse to engage with you for any unrelated service, or share the fact of your declination with any third party.

4.3 The Aadhaar Act, section 8A, the Aadhaar Authentication and Offline Verification Regulations, 2021 (as amended in 2025) and Puttaswamy II all expressly limit private-entity use of Aadhaar to voluntary, informed-consent use. We affirm that we are an Offline Verification Seeking Entity to the extent we accept your Aadhaar in physical or image form.

5. What we do with your Aadhaar specifically

Because the Aadhaar number is treated as particularly sensitive both by statute and by judicial authority, we apply additional safeguards on top of those that apply to PAN and Driving Licence:

1. Display masking. Anywhere your Aadhaar number is displayed back to you in the app, in the dashboard or in any document we generate, the first eight (8) digits are masked (e.g., "XXXX XXXX 1234").
2. Storage encryption. The Aadhaar number and Aadhaar images are stored on encrypted infrastructure with access tightly restricted to specific KYC-reviewer and security roles. Access is logged for audit.
3. No biometric authentication. We do not perform fingerprint, iris or facial biometric Aadhaar authentication.
4. No core biometrics collected. We do not collect or store any "core biometric" within the meaning of the Aadhaar Act.
5. No transfer outside India. Aadhaar numbers and Aadhaar images are not transferred to any server outside India.
6. No third-party sharing for marketing. Your Aadhaar is shared only with the categories of recipients listed in section 7 below, and only for the purposes there stated.
7. No use to deny services that are not Aadhaar-conditional. If you withdraw Aadhaar consent, we will use any other identifier you provide for non-Aadhaar-mandatory purposes (e.g., payouts based on PAN alone if statute permits).

6. How long we will keep the data

After the relevant period the data is securely deleted or, where deletion is infeasible (e.g., backups already written), is anonymised and access-restricted until natural roll-off.

7. With whom we share this data

Sharing is limited to the categories described in section 6 of the Privacy Policy and, in respect of these documents specifically:

1. Authorised KYC-reviewer personnel within Delv Express;
2. Hub Managers to the extent necessary for hub-level onboarding (limited fields, on a need-to-know basis);
3. Identity-verification vendors engaged by us for PAN verification (Income-tax Department database), Aadhaar offline e-KYC (UIDAI-permitted OVSE workflow, with your separate consent on the relevant screen), and Driving Licence verification (Sarathi);
4. Insurers / insurance brokers / claims administrators in connection with the health and term insurance cover we procure on your behalf;
5. Auditors and professional advisers under confidentiality;
6. Regulatory and law-enforcement authorities in response to a valid legal request; and
7. Successors in interest in the event of a merger, acquisition, financing or sale of assets, subject to equivalent protections.

We do not sell or rent your KYC data to any third party.

8. Your rights under the DPDP Act

You have the rights set out in section 11 of the Privacy Policy, namely the rights to access, correction, completion, updating, erasure, withdrawal of consent, grievance redressal and nomination. Most importantly:

8.1 You may withdraw this consent at any time. Go to Profile → Privacy → Withdraw KYC consent in the Delv Partner app, or e-mail admin@delvexpress.com. Withdrawal is operationally equivalent to deactivating your Delivery Partner status, because we cannot lawfully continue to engage you without verified identity.

8.2 Withdrawal does not erase data we are required to retain under law. PAN / payout records retained under the Income-tax Act, accident-claim records retained under the Motor Vehicles Act, and Aadhaar disclosures required by a court or regulator are retained for the statutory minimum. Everything else is deleted within thirty (30) days of withdrawal taking effect.

8.3 Right to nominate. You may nominate another individual to exercise these rights on your behalf in the event of your death or incapacity. A simple nomination form is available from admin@delvexpress.com.

9. Grievance Officer

If you have a question, complaint or grievance about this notice or how we handle your KYC data:

• Name: The Grievance Officer
• Designation: Grievance Officer & Data-Protection Contact Person
• E-mail: admin@delvexpress.com
• Phone: +91 80774 81613 (Mon–Sat, 10:00–19:00 IST)
• Postal address: Grievance Officer, Lazyfoxs Logistics Pvt Ltd, Plot 63, Udyog Vihar Extension, Ecotech-II, Surajpur, Greater Noida, Uttar Pradesh 201306, India.

We acknowledge grievances within forty-eight (48) hours, respond to substantive requests within seven (7) days, and resolve grievances within ninety (90) days, in line with rule 14 of the DPDP Rules, 2025.

If you are not satisfied with our response, you may escalate to the Data Protection Board of India established under section 18 of the DPDP Act through the Board's portal.

10. Confirmation of consent

By tapping "I consent" and submitting the KYC form in the Delv Partner app, you confirm that:

1. you have read and understood this notice;
2. you are at least 18 years of age;
3. you are the lawful holder of the Aadhaar, PAN and Driving Licence you have submitted, and the documents are genuine;
4. the consent is freely given, specific, informed, unconditional and unambiguous, signified by clear affirmative action;
5. you understand that you may withdraw this consent at any time and that withdrawal will deactivate your Delivery Partner status;
6. you understand the categories of recipients with whom we share this data and the purposes;
7. you have been informed of your right to grievance redressal and the contact details of our Grievance Officer; and
8. where applicable, you separately consent to the Aadhaar offline e-KYC workflow described on the relevant screen.

A timestamped record of your consent is preserved by us for as long as we hold the underlying data.

Related documents

• Terms of Service
• Privacy Policy
• Cookie Policy
• Delivery Partner Agreement
• Contact / Grievance

© 2026 Lazyfoxs Logistics Pvt Ltd. All rights reserved.