Privacy Policy for Mobile App
1. Introduction and Scope
This Privacy Policy ("Policy") describes how Vensar Constructions Company Limited ("Vensar", "Company", "we", "us", or "our") collects, uses, stores, and discloses personal data through the Vensar mobile application ("App") in connection with attendance, verification, and workforce management.
This Policy applies to all employees, contractors, and other authorised users ("you", "User") who are required or permitted to use the App as part of their engagement with the Company.
This Policy should be read together with the Company's IT Policy and HR Policy applicable to your employment, which govern your obligation to use the App as a condition of your role.
2. Data Fiduciary and Grievance Officer
Vensar Constructions Company Limited is the Data Fiduciary responsible for determining the purpose and means of processing personal data collected through the App, for the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable law.
a. Grievance Officer: RAVI KUMAR GUBBALA
b. Email: it@vensar.com
c. Phone: +91 97017 87444
d. Address: 8-2-12/76/1/B, 3rd Floor, Ashoka Hitech Chambers,
Road No 2, Banjara Hills, Hyderabad - 500034
Any User may raise a grievance regarding the processing of their personal data with the Grievance Officer, who shall endeavour to resolve it within a reasonable time and in any event with in the period prescribed under applicable law.
3. Personal Data We Collect
The App collects the following categories of personal data, each strictly limited to the stated purpose:
a. Camera: Facial images for face verification, face registration, QR/barcode scanning, and image capture required by app workflows.
b. Location: Precise device location at the time of check-in/check-out, used to validate attendance.
c. Photo Library: Images or documents uploaded by you, such as leave applications or verification attachments.
d. Notifications: Device token used to deliver attendance reminders and app alerts.
e. Face ID: Device-level biometric authentication used to unlock or access your saved session.
f. Account and usage data: Employee ID, attendance logs, timestamps, and app usage data necessary for workforce administration.
4. Purpose and Lawful Basis of Processing
• Personal data is processed for the following purposes only:
(a) Verifying employee identity for attendance and access control;
(b) Validating on-site presence for attendance and payroll accuracy;
(c) Enabling secure app access through device-level biometric authentication;
(d) Sending operational alerts and reminders;
(e) Processing leave and verification-related document submissions;
(f) Complying with statutory, audit, and record-keeping obligations.
Processing is carried out based on your consent provided within the App, read together with the Company's IT/HR policy applicable to your employment, which constitutes a legitimate purpose for processing in the context of your employment relationship.
5. Camera and Facial Verification Data
The App collects facial images through the device camera during employee face registration, login identity verification, and attendance check-in and check-out. These images are collected solely to register an employee’s face, verify the identity of the person accessing the App, and prevent unauthorised or fraudulent attendance submissions.
To enable repeat verification, a facial is generated from the captured image and stored in encrypted form on Vensar's own servers located in India. No third-party service provider, SDK, or vendor is involved in the capture, processing, generation, or storage of this facial template; the entire process is carried out on Vensar's own infrastructure.
The facial template is retained only for the duration of the employee's employment with the Company, for the sole purpose of attendance verification, and is not used for any other purpose, including tracking, profiling, or analytics. On cessation of employment, the facial template and any associated facial data shall be deleted or anonymised within three months, save for any attendance or payroll record that the Company is required to retain for a longer period under applicable labour, tax, or statutory record-keeping laws.
Access to stored facial templates is restricted to authorised personnel who administer attendance records, and is protected through encryption and access controls as set out in Clause 9.
6. Location Data
Location data is accessed only at the time of a relevant action (such as check-in or check-out) and is not tracked continuously or in the background.
Location logs are retained for a period of [90 days / specify period] from the date of the relevant check-in or check-out, and are used exclusively for attendance validation and record-keeping. Location data is not used for any other purpose, including performance monitoring or route-tracking, and is deleted upon expiry of the retention period stated above, save for any record the Company is required to retain for a longer period under applicable law.
7. Face ID
The App's Face ID feature relies solely on the native biometric authentication provided by the device operating system (Apple/Google).
No separate facial-recognition layer is applied by Vensar for this purpose.
8. Data Sharing and Disclosure
Vensar does not sell or rent personal data. Personal data may be shared only:
(a) with authorised service providers strictly for app hosting, cloud storage, or technical support, under contractual confidentiality and data-processing obligations;
(b) where required by law, regulation, court order, or governmental authority;
(c) with the Company's HR and administrative functions, strictly for workforce management purposes.
9. Data Storage, Security, and Localisation
Personal data collected through the App is stored on servers located within India.
The Company employs industry-standard technical and organisational measures, including encryption in transit and at rest, access controls, and audit logging, to protect personal data against unauthorised access, alteration, or disclosure.
10. Data Retention and Deletion
Personal data is retained only for as long as necessary to fulfil the purposes stated in this Policy, or as required under applicable labour, tax, or statutory record-keeping laws, whichever is longer.
Biometric and facial data is retained and deleted in accordance with Clause 5 above. Location data is retained and deleted in accordance with Clause 6 above. All other categories of personal data collected through the App shall be retained only for the duration of the employee's employment, and deleted or anonymised within three months of cessation of employment, save for any record required to be retained for a longer period by law.
Users may request deletion of eligible biometric and facial data, including facial images and facial templates, by selecting Profile → Privacy & Support → Request Face Data Deletion in the App, or by emailing it@vensar.com with their employee ID and registered mobile number. Vensar will verify the requester’s identity and process an eligible request, subject to any data that must be retained under applicable law. Deletion of facial data may restrict or disable App functionality that requires facial identity verification.
11. Permission Management
You may manage or revoke Camera, Location, Photo Library, Notification, or Face ID permissions at any time through your device settings.
Revoking certain permissions may limit or disable corresponding app functionality, including attendance validation.
12. Children's Data
The App is intended solely for use by employees and authorised personnel of the Company and is not directed at, nor knowingly used by, children.
13. Changes to this Policy
The Company may update this Policy from time to time. Material changes will be notified to Users through the App or by other reasonable means prior to the change becoming effective.
Continued use of the App after such notice constitutes acceptance of the revised Policy.
14. Governing Law and Jurisdiction
This Policy shall be governed by the laws of India, and the courts at Hyderabad shall have exclusive jurisdiction over any disputes arising in connection with this Policy.
15. Contact
For any questions regarding this Policy, please contact the Grievance Officer at the details set out in Clause 2 above.