Privacy Policy
Construct Manager — Attendance & Performance Management
1. Who we are and what this policy covers
This policy explains what personal data we collect through the platform, why we collect it, who we share it with, how long we keep it, and the rights you have over it. It is written to meet the requirements of the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Roles. Where you are our employee or a worker engaged directly by us, we act as the Data Fiduciary. Where the platform is deployed for a client organisation (a builder, principal employer or contractor), that organisation is the Data Fiduciary for its own workforce data and we act as a Data Processor on its written instructions. In that case, this policy describes our practices; your employer's own notice governs the purposes for which your data is used.
2. Personal data we collect
2.1 Identity and contact details
Name, worker or employee code, date of birth, gender, father's or husband's name, photograph, phone number, email address, permanent and local address (state, city, area, pincode), and emergency contact name and phone number.
2.2 Employment and engagement details
Contractor or department, assigned project and site, job category, skills, date of joining, employment type, employment status, and the history of changes to those assignments.
2.3 Financial and statutory details
Wage rate (daily, monthly or hourly), overtime rate, salary, PF and other deductions, salary advances, payroll records and payslips, ESI/PF identification number, and the history of wage changes and approvals.
2.4 Government identifiers
Aadhaar number, collected only with your separate, explicit and recorded consent. We store the timestamp at which consent was given. The Aadhaar number is stored in encrypted form and is never displayed in full in reports or exports. You may refuse to provide it; where Aadhaar is legally required for a statutory filing, we will tell you before collecting it.
2.5 Biometric and authentication data
Face data. When you register your face in the mobile app, the app uses the camera on your phone to capture your face. The image is converted on the phone itself into a set of numbers (a mathematical "face template") by an on-device model. Only that set of numbers is sent to our servers — the photograph is not uploaded during registration and is not stored by us. The template cannot be turned back into a recognisable photograph of you. It is used only to confirm that the person marking attendance is you.
Biometric attendance devices. Where your site uses a fingerprint or face recognition terminal (for example a Hikvision access control device), the biometric template used by that terminal is created and stored inside the device itself by its manufacturer's software. Our platform receives only the punch event — your worker ID, the time and the device — not your biometric template.
PIN. If you use a PIN to mark attendance, we store only a one-way cryptographic hash of it. We cannot read your PIN.
RFID card number / QR code, where your site issues them.
Biometric data is treated as sensitive personal data. We collect it only for attendance verification and payroll accuracy, and never for surveillance, emotion analysis, performance profiling or any purpose not listed in Section 3.
2.6 Attendance and location data
Check-in and check-out date and time; the method used (face, PIN, QR, RFID, device punch or manual entry); GPS latitude and longitude captured at the moment you check in or check out; whether that location fell inside the site's geofence; the attendance photograph captured at the punch, where your site has enabled photo capture; the device that recorded the punch; working hours, overtime hours and their approval status; and leave, time-off and attendance correction requests.
We capture location only at the moment of a check-in or check-out. We do not track your location continuously, in the background, or after working hours.
2.7 Site operations content
Daily task and progress entries, activity photographs and media you upload, incident and safety reports, training records, permits, safety checklists and performance reviews.
2.8 Technical and security data
Login history (username, IP address, device description, success or failure and timestamp); audit logs recording who created, updated or deleted a record, what changed, and from which IP address; mobile push notification tokens; and app preference settings.
2.9 Data stored on your phone
The mobile app stores attendance records, your face template and reference data in a local database on your device so that you can mark attendance when the site has no network coverage. This data is synchronised to our servers when connectivity returns, and is deleted when you log out or uninstall the app.
3. Why we process your data, and on what basis
Purpose
Data used
Lawful basis under the DPDP Act
Recording attendance and verifying identity at the site
Biometric template, PIN, attendance timestamps, location, photo
Consent; and employment-related legitimate use
Calculating wages, overtime, advances and payroll
Employment, attendance and financial data
Performance of the employment relationship
Statutory compliance — PF, ESI, labour and welfare board filings, muster rolls, wage registers
Identity, Aadhaar, employment and payroll data
Compliance with law
Site safety, incident management and access control
Identity, attendance, incident, training and permit records
Legitimate use for employment purposes and safety of persons
Workforce planning, supervision and reporting to the principal employer
Attendance and project assignment data
Legitimate use for employment purposes
Preventing proxy attendance ("buddy punching") and fraud
Biometric template, location, geofence result, audit logs
Legitimate use for employment purposes
Securing the platform and investigating misuse
Login history, audit logs, IP address
Legitimate use; compliance with law
Sending you operational notifications
Push token, phone number
Consent
We do not sell your personal data, and we do not use it for advertising, credit scoring, or automated decisions that produce legal effects on you without human review.
4. Consent
Where we rely on your consent — in particular for face registration, biometric attendance and Aadhaar collection — we will:
ask for it separately, in clear language, before collecting the data;
tell you the specific purpose, and collect only what that purpose needs;
record the fact and time of your consent;
offer this notice in English and Hindi, and on request in any other language listed in the Eighth Schedule to the Constitution of India;
allow you to withdraw consent at any time, as easily as you gave it, by contacting the Grievance Officer in Section 10 or through your site supervisor.
Withdrawing consent for biometric attendance does not affect your employment. Your site will provide an alternative method — PIN, card or supervisor-marked manual attendance. Withdrawal does not undo processing that already happened lawfully, and we may continue to retain records we are legally required to keep (for example, wage registers).
5. Who we share your data with
Your employer, contractor and the principal employer at your site, to the extent needed to supervise work, verify attendance and pay you.
Statutory authorities — EPFO, ESIC, labour departments, welfare boards, tax authorities, and law enforcement or courts where we are legally required to disclose.
Service providers acting on our instructions, under written contracts that restrict them to our purposes and require equivalent security: our cloud hosting and database provider [Provider name, region], and our push notification provider (Google Firebase Cloud Messaging).
Biometric device manufacturers. Where your site uses a third-party attendance terminal, that device is operated by your employer and is governed by the manufacturer's own terms. Biometric templates held inside such a device are not transferred to us.
A successor entity, in the event of a merger, acquisition or restructuring, subject to this policy continuing to apply.
We do not share your data with anyone else without your consent, unless required by law.
6. Where your data is stored
Your personal data is stored on servers located in [India / specify region]. Where any processing occurs outside India, it will be limited to countries not restricted by the Central Government under Section 16 of the DPDP Act, and will be covered by contractual safeguards.
7. How long we keep your data
Category
Retention period
Face templates and PIN hashes
Deleted within [30] days of your exit, or immediately on withdrawal of consent
Attendance records, muster rolls and wage registers
[3] years after the relevant financial year, or as required under applicable labour legislation, whichever is longer
Payroll, PF and ESI records
[8] years, as required by tax and statutory rules
Aadhaar number (encrypted)
Only while required for a statutory filing; deleted thereafter
Attendance photographs and site media
[12] months, unless attached to an open incident or dispute
Login history and audit logs
[24] months
Local data on your phone
Until you log out or uninstall the app
When a retention period ends, we delete the data or irreversibly anonymise it so it can no longer identify you. Records under an active legal claim, audit or investigation are retained until that matter closes.
8. How we protect your data
Encrypted transmission (HTTPS/TLS) between the apps and our servers.
Aadhaar numbers encrypted at rest; PINs and passwords stored only as one-way hashes.
Face templates stored as numeric vectors, not as images.
Role-based access control: every screen and action is governed by module-level permissions, and users can see only the organisations, projects and sites they are assigned to.
Audit logging of every create, update and delete, with the user and IP address recorded.
Time-limited authentication sessions and recorded login history.
Access to production data restricted to authorised personnel on a need-to-know basis.
No system is perfectly secure. In the event of a personal data breach, we will notify the Data Protection Board of India and every affected person, in the form and within the time required by the DPDP Act and its rules.
9. Your rights
Under the DPDP Act, you have the right to:
Access — obtain a summary of the personal data we process about you, the processing activities undertaken, and the identities of other Data Fiduciaries and Processors with whom it has been shared.
Correction and completion — have inaccurate or incomplete data corrected or updated.
Erasure — have your data deleted where it is no longer needed for the purpose it was collected for, and where we are not legally required to keep it.
Withdraw consent — at any time, as described in Section 4.
Grievance redressal — a readily available means of raising a complaint with us, which we will respond to within [30] days.
Nomination — nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.
To exercise any of these rights, contact the Grievance Officer below, or ask your site supervisor to raise the request on your behalf. We may ask you to verify your identity before we act. If you are not satisfied with our response, you may complain to the Data Protection Board of India.
11. Children and persons with disabilities
The platform is not intended for anyone under 18 years of age, and we do not knowingly register minors as workers. Where the law requires it, processing of a child's data, or the data of a person with a lawful guardian, will be carried out only with verifiable consent from the parent or guardian, and never for tracking, behavioural monitoring or advertising. If you believe a minor has been registered, contact the Grievance Officer and we will remove the record.
12. Permissions the mobile app requests
Permission
Why it is needed
Camera
To capture your face for registration and attendance verification, and to attach photographs to site activity and incident reports
Location (precise)
To record where a check-in or check-out took place and confirm it is within the site boundary. Captured only at the moment of a punch, never in the background
Storage
To save photographs and offline attendance records on your device until they sync
Internet / network access
To sync data with our servers
Notifications
To alert you about approvals, shifts and requests
You can refuse or revoke any of these in your phone's settings. Refusing camera or location permission will prevent face-based or geofenced attendance; your site will provide an alternative method.
13. Changes to this policy
We may update this policy as the platform or the law changes. We will post the revised version in the app and on [website URL], update the "Last updated" date, and where the change is significant, notify you in the app before it takes effect. Where a change requires it, we will ask for fresh consent.
This document reflects how the Construct Manager platform actually handles data, based on its database schema, API and mobile app permissions. It is not legal advice. Have it reviewed by qualified legal counsel, and complete every field marked in [brackets], before publishing it.