Privacy Policy

1. Introduction & Overview

This Privacy Policy explains how Keel Info Solution Private Limited (registered office: 3rd Floor, Temple Tower, No. 672, Anna Salai, CIT Nagar East, Nandanam, Chennai, Tamil Nadu 600035, India; phone: +91 44 2229 9222; HR/privacy contact: support@keelis.com) ("Company", "we", "us", or "our") collects, uses, processes, stores, discloses, and protects personal information obtained through our Human Resource Management System mobile application ("HRMS Application" or "App"), distributed through the Google Play Store and Apple App Store.

The HRMS Application is a publicly available mobile application distributed through the Google Play Store and Apple App Store. Anyone may download and install the App. However, its employee registration process, HRMS services, and employee-related information are restricted to authorized employees, contractors, team leaders, managers, and human resource personnel of the Company and its affiliated operating entities (including Keel Info Solution, KeelXpert, EverGuard Insurance, EG Tech, and KeelCyber).

2. Organization & Data Controller Details

For the purposes of applicable data protection laws, including the Digital Personal Data Protection Act, 2023 (DPDPA 2023, India) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011:

If you access this platform as an employee of an affiliated operating entity or corporate client, your employing organization acts as the primary Data Fiduciary for your personnel records, and our organization operates as the technical Data Processor maintaining the platform infrastructure.

3. Scope of this Policy

This Privacy Policy applies to all personal, employment, statutory, financial, and attendance data processed by the HRMS Mobile Application on Android and iOS devices, as well as data exchanged with our secure backend GraphQL servers. It does not apply to external websites or third-party portals that may be referenced outside the Application.

4. Information We Collect

We collect and process only personal information that is directly necessary for workforce administration, attendance verification, payroll execution, and statutory compliance. The data categories processed include:

A. Employee Identity & Profile Information

• Full Legal Name: First name, last name, father's name, and salutation.
• Corporate Identifiers: Employee ID (empid), internal user ID, and username.
• Contact Details: Official work email, personal email, primary mobile contact number, secondary contact number, and emergency contact details.
• Demographic Information: Date of birth, gender, and marital status.
• Residential Address: Street address, city, state, country, and postal/ZIP code.
• Profile Photograph: Optional employee profile picture displayed within the user profile.

B. Indian Statutory & Tax Identifiers (High Sensitivity)

To fulfill statutory labor, social security, and tax compliance obligations under Indian law:

• Aadhaar Number: Maintained securely in accordance with applicable statutory standards.
• Permanent Account Number (PAN): Used for income tax assessment, Form 16 issuance, and Tax Deducted at Source (TDS) reporting.
• Universal Account Number (UAN) & Member ID: For Employees' Provident Fund Organisation (EPFO) compliance.
• ESIC Number: For Employee State Insurance Corporation healthcare coverage.

C. Financial, Compensation & Banking Information

• Bank Account Details: Bank name, account number, IFSC code, branch name, and CIF number.
• Salary & Compensation: Gross earnings, net payable salary, Cost to Company (CTC), allowance breakdown, loss of pay (LOP) deductions, overtime calculations, tax deductions, and monthly payslips.
• Expense Reimbursements: Invoice dates, reference numbers, claim amounts, TDS percentages, payment currency, description of expense, and attached receipts.

D. Attendance, Time-Tracking & Absence Records

• Attendance Punch Times: Daily check-in timestamps, check-out timestamps, recorded working hours, overtime hours, and resume times.
• Workplace Biometric Hardware Sync: Punch times recorded at physical corporate biometric attendance terminals are synchronized to the central database and mirrored in the App.
• Attendance Regularization: Requests submitted to rectify missed punches with employee-provided justifications.
• Leave Applications: Casual, sick, earned, or unpaid leave requests, date ranges, half-day indicators, reasons for absence, leave balance counts, and delegation of responsibility (primary/secondary DOR).
• Work From Home (WFH): Applications for remote work days, task descriptions, and managerial approval queues.
• Permission Passes: Applications for short work-hour permissions and remaining balance hours.

E. Performance & Recruitment Information

• Performance Evaluations: Periodic review scores across multiple attributes (technical delivery, teamwork, multitasking, professional conduct, communication), review periods, and managerial feedback notes.
• Staff Requisitions: Internal job requisition requests submitted by team leads including role definitions, required experience, candidate evaluation panels, and job descriptions.

F. Security, Device & Diagnostic Data

• Session Data: Encrypted user authentication tokens and encoded user IDs stored in on-device hardware-backed secure storage.
• Biometric Lock Setting: Local preference flag indicating whether on-device biometric lock is enabled.
• Technical Diagnostics: Installed application version (via package_info_plus) and active network connectivity state (via connectivity_plus).

5. How Information is Collected

Personal information is collected through the following mechanisms:

1. Pre-Registration by Management: Before an employee can register through the App, the Company's management or authorized HR administrators create and assign an official company email address for that employee and maintain the address in the Company's authorized employee records.
2. Sign-Up Email Eligibility Check: When a person opens the sign-up flow, the App checks the entered email address against the Company's authorized employee email records. If the email address is found, the person may proceed to enter the required registration details. If it is not found, the sign-up process cannot continue. This check is intended to prevent unauthorized public registration; it does not, by itself, establish that every other registration detail is accurate.
3. Direct Employee Input: Information entered during the sign-up process and when submitting leave requests, applying for WFH, filing expense reimbursement claims, submitting regularization requests, or updating passwords.
4. Employer & HR Provisioning: Core identity, department, shift, statutory identifiers, and salary structures configured directly by corporate HR administrators.
5. Workplace Biometric Attendance Terminals: Synchronized punch timestamps from physical biometric access readers installed at corporate office facilities.
6. Automated Device Checks: Application version verification and network reachability checks executed locally on the device.

6. Purposes of Data Processing

We process your personal information strictly for legitimate workforce management, organizational operations, and statutory compliance:

• Checking sign-up email addresses against management-maintained authorized employee records, allowing eligible personnel to proceed with registration, authenticating authorized personnel, and securing access to internal enterprise systems.
• Managing employee personnel files, departmental allocations, and reporting hierarchies.
• Tracking attendance, computing working hours, and administering leave, WFH, and permission requests.
• Executing monthly payroll, computing tax withholdings, issuing payslips, and reimbursing business expenses.
• Complying with statutory labor and tax regulations in India (including the Employees' Provident Funds Act, ESI Act, Income Tax Act, and state Shops and Establishments Acts).
• Facilitating periodic employee performance reviews and internal talent requisition.
• Maintaining administrative audit trails and application security.

7. Attendance

The HRMS Application allows authorized employees to record and manage their daily attendance through check-in and check-out functionality. Attendance information, including check-in timestamps, check-out timestamps, recorded working hours, overtime hours, and attendance history, is processed and maintained in the Company's HRMS system.

Attendance records may also be synchronized from physical office biometric attendance terminals and displayed in the Application.

8. Biometrics & Local Device Authentication

It is important to distinguish between on-device application locking and workplace biometric attendance:

A. On-Device Local Biometric Lock

Employees may activate an optional "Biometric Lock" to unlock the App using their device's native fingerprint scanner, Touch ID, or Face ID (via local_auth). The App never accesses, receives, or stores your raw biometric templates. Authentication occurs entirely within your device's isolated hardware enclave (Secure Enclave on iOS, TrustZone on Android), returning only a cryptographic success or failure status to the App.

B. Workplace Biometric Hardware

Physical biometric access readers installed at corporate offices record attendance punches. The HRMS Application receives and displays only the resulting timestamp data (e.g., check-in time, check-out time). Raw biometric templates remain secured within physical facility access control systems and are not transmitted to or stored by the mobile application.

9. Device Permissions & System Access

The Application requests only the minimal operating system permissions necessary for functionality:

The App does not access device contacts, microphone, SMS messages, call logs, calendar events, or advertising identifiers.

10. Document Access, File Uploads & Payslips

When you attach bills, invoices, or medical certificates for expense claims or leave requests, the App uses the native system document picker (via file_picker). Selected files (PDF, JPG, PNG, JPEG formats up to 2MB) are transmitted securely to our backend server using standard multipart upload specifications. When viewing payslips, generated PDF documents are stored in private application sandbox directories and opened using your device's default document viewer.

11. Data Storage & Security Controls

We implement comprehensive administrative, physical, and technical safeguards to protect your personal information:

• Hardware-Backed Secure Storage: Authentication session tokens and user identifiers are encrypted locally using FlutterSecureStorage, backed by the Android KeyStore and iOS Keychain.
• Encrypted Transport: All data transmissions between the App and backend servers are protected using Transport Layer Security (TLS 1.2/1.3) over HTTPS and secure WebSockets (WSS).
• SSL Certificate Validation: The mobile client strictly validates SSL certificates and terminates connections if an untrusted or self-signed certificate is detected.
• Role-Based Access Control (RBAC): Backend data access is segregated. Employees access only their own records, while team leaders and HR administrators hold restricted access commensurate with their managerial roles.
• No Local Credential Caching: Passwords are not permanently stored in plain text on the device.

12. Data Sharing & Disclosure

Employee information is maintained as confidential corporate records. We do not sell, rent, trade, or commercially monetize employee personal data. Information is disclosed solely in the following controlled scenarios:

• Internal Management: Team leaders and HR administrators access relevant attendance, leave, WFH, performance, and reimbursement records for operational management.
• Affiliated Operating Entities: For employees belonging to affiliated corporate entities (Keel Info Solution, KeelXpert, EverGuard Insurance, EG Tech, KeelCyber), requests are securely routed to the designated organizational database based on your corporate email domain.
• Statutory Authorities: Disclosed to Indian government bodies (such as the EPFO, ESIC, Income Tax Department, or labor authorities) strictly as mandated by applicable law.
• Cloud Infrastructure Providers: Secure enterprise cloud hosting providers host backend servers and databases under confidentiality agreements and strict data processing terms.

13. Third-Party Services & SDKs

The mobile application integrates no third-party advertising SDKs, commercial trackers, or behavioral analytics frameworks (e.g., no Firebase Analytics, Google Analytics, Facebook SDK, or AdMob). Fonts (Roboto) are bundled locally within the App asset bundle. When document attachments are viewed externally, standard browser intents are launched via url_launcher.

14. Data Retention

Personal data is retained based on the nature of the information, employment status, and applicable statutory requirements:

• Active Employment: Personal, attendance, leave, performance, and payroll records are maintained throughout your active tenure with the organization to facilitate human resource management.
• Post-Separation Retention: Following employee separation, the retention period is not universal across all data types. Specific records (such as tax deduction statements, provident fund contributions, social security records, wage sheets, and attendance registers) are retained for specific statutory durations prescribed by applicable Indian tax and labor laws or as mandated by the employer's confirmed record retention schedule (Applicable statutory requirements and the employer’s documented record-retention schedule). Non-statutory data is retained only as long as necessary for legitimate business auditing and operational purposes.
• Local Device Cache: Tapping Logout immediately purges all locally stored session tokens, credentials, and profile records from the device's secure storage.

15. Account Deactivation, Data Deletion & Store Policy Disclosures

A. Technical & Operational Distinctions: Logout vs. Deactivation vs. Deletion

To ensure clarity regarding how data is handled across different states:

• 1. Logging Out (Local Device Cache Purge): When an employee taps Logout within the Application (via the navigation drawer), all locally stored session tokens, encoded user IDs, and cached profile data are immediately purged from the device's hardware-backed encrypted storage (FlutterSecureStorage), and in-memory attendance tracking timers are reset. Logging out terminates the local mobile session but does not deactivate the employee's account on the backend server or delete historical employment records.
• 2. Account Deactivation (Administrative Offboarding): Because the mobile app does not provide self-service account termination, account deactivation is an administrative process managed by the employer's HR or IT administration in accordance with internal corporate offboarding policies and operational procedures. Deactivating an account typically revokes active mobile credentials and terminates access to the platform, while maintaining historical records required for organizational operations and auditing.
• 3. Backend Personal Data Deletion / Erasure: The mobile application does not have an API endpoint to permanently delete employee accounts from backend databases. Where an employee submits a formal data deletion or erasure request, the employer reviews the request against legal and operational needs. Where permissible under law and internal policies, non-statutory personal identifiers may be removed or anonymized.
• 4. Statutory Record Retention (Legal Non-Erasure): Immediate or permanent deletion of all employee records cannot be granted where preservation is mandated by law. Applicable legal frameworks—including taxation laws, social security regulations, and state labor legislation—require employers to retain specific payroll, attendance, and contribution registers for legally specified retention periods.

B. How Employees Can Request Account Deactivation & Data Deletion

Employees and former personnel seeking the deactivation of their account or the deletion of non-statutory personal data may initiate a formal request through the following process:

1. Submit a Formal Request: Send an official written request from your registered corporate or personal email address to the employer's Human Resources Department or Privacy Contact at support@keelis.com, or submit an internal HR request if active on company systems.
2. Provide Verification Details: To prevent unauthorized modifications, provide your full legal name, Employee ID (empid), and official email address.
3. Administrative Review & Response: The employer's HR administration and privacy contact review the request (within the applicable statutory timeline) to verify employment status and differentiate between records that can be modified or removed and records that must be retained under applicable statutory obligations.
4. Outcome Notification: The employee receives written confirmation outlining the deactivation of access credentials, the status of personal data deletion, and any statutory records that must remain archived pursuant to specific legal requirements.

C. Apple App Store & Google Play Store Review Disclosures

This policy provides disclosures relevant to mobile platform operator guidelines:

• Apple App Store (Review Guideline 5.1.1(v)): The App supports in-app sign-up, but registration is restricted to people whose official company email address has already been created and authorized by the Company's management or HR administrators. The email eligibility check does not make the App available for unrestricted public registration. The Company handles account deactivation and applicable data deletion requests through the administrative process described in this section. Store declarations and review notes should accurately describe this restricted in-app registration flow.
• Google Play Store (User Data & Account Deletion Policy): The App supports in-app account registration after the entered email address is matched against the Company's authorized employee email records. Because users can create an account through the App after passing this check, the developer should declare account creation accurately in Google Play Console and provide the applicable in-app and public web account deletion mechanisms required by Google Play. This policy describes the Company's administrative request process and provides the contact information (support@keelis.com) for employees seeking account deactivation or data deletion. This policy text alone does not replace any separate in-app deletion functionality or Play Console declarations that may be required.
• Compliance Note: The inclusion of these disclosures supports transparency and store review requirements, but does not alone guarantee application approval, which remains subject to the full review evaluation and developer configuration in App Store Connect and Google Play Console.

16. Employee Privacy Rights

In accordance with applicable data protection legislation (including the Digital Personal Data Protection Act, 2023), employees enjoy the following rights regarding their personal data:

• Right to Access: View personal profile, attendance records, and payslip data directly within the Application.
• Right to Correction: Request the correction or updating of inaccurate or incomplete personal records.
• Right to Grievance Redressal: Submit privacy-related concerns or complaints to the designated Grievance Officer.
• Right to Nominate: Nominate an individual to handle data privacy rights in case of death or incapacity, as provided under law.

17. International Data Transfers

The HRMS Application primarily serves employees based in India. Backend server infrastructure and databases are hosted in secure enterprise facilities located in India. Any cross-border data transfer complies with applicable data protection requirements.

18. Children's Privacy

The Application is strictly an employment tool designed for working adults aged 18 and older. We do not knowingly collect or maintain data relating to minors.

19. Changes to this Privacy Policy

We may revise this Privacy Policy periodically to reflect technological updates, operational adjustments, or legal requirements. Updated policies will be posted on this page with an updated "Last Updated" date. Employees will be notified of material changes through internal communication channels or in-app notices.

20. Contact & Grievance Redressal

For questions, privacy inquiries, or formal grievances, please contact our designated Data Protection & Grievance Officer: