Staff App Privacy Policy

ZLTS LLP ("we", "us", "our", or the "Company") operates PureSect Staff (the "staff-app"), an Android mobile application designed exclusively for "Other Staff" engaged at residential societies, housing complexes, and commercial condominiums running on the PureSect ecosystem.

This Privacy Policy explains what information we collect through the staff-app, how we use and store it, who has access to operational records, and the rights and choices available to staff members as data principals under the Digital Personal Data Protection Act, 2023 (DPDP Act).

Scope boundaries of this Policy:

• Applies Exclusively to the staff-app: This document governs solely the staff-app mobile application downloaded on Android devices. No web-based portal is offered or made accessible to staff as part of this product.
• Covers "Other Staff" across all employment categories: Housekeeping, gardening, electrical, plumbing, driving, lift operations, facility maintenance, and supervisory personnel. This includes staff directly on society rolls (Direct Staff), staff deployed by facility vendors under the Contract Labour Act (Third-Party Staff), and independent gig technicians (Retainers).
• Explicit Statutory Exclusion of Security Guards: Security Guards and security personnel are engaged under separate statutory frameworks governed by the Private Security Agencies (Regulation) Act, 2005 (PSARA) and use separate operational gate modules. They are strictly excluded from the scope of this Policy and the staff-app.

By downloading, registering, or using the staff-app, you agree to the practices described in this Policy.

To ensure clarity across all legal and operational terms:

3.1 Identity & Profile Information

• Personal Identifiers: Full legal name, mobile phone number, and optional email address.
• Profile Photograph: Captured via camera or selected from photo gallery for badge identification within the Society.
• Employment Designation & Category: Designation (e.g. Electrician, Housekeeping Executive) and category (Direct Staff, Third-Party Staff, or Retainer).
• Vendor Affiliation: For Third-Party Staff, the legal name and identifier of the deployment agency.

3.2 Identity & Compliance Documents

• Verification Documents: Government-issued ID proof (e.g., Aadhaar, Voter ID, Driving Licence), address proof, or police verification certificates uploaded by the staff member where mandated by Society rules or statutory labor regulations for on-premises entry.

3.3 Gate QR Attendance & Operational Data

• Gate QR Punch Timestamps: When a staff member arrives at or departs the Society, they scan the on-premises Gate QR code using their device camera. The app records the timestamp, gate identifier (gateId), and punch action (IN / OUT).
• Zero Raw Video Storage: The camera is used solely to parse the QR barcode data. No photos, videos, or continuous image streams from the QR scan are stored or transmitted.
• Roster & Leaves: Shift allocations, duty schedules, leave applications, approval history, and accumulated leave balances.

3.4 Finance & Bank Account Information

• Bank Account Details: Account holder name, bank name, account number, and IFSC code provided by the staff member to facilitate direct payroll bank transfers by the Society or Vendor.
• Salary Slip Summaries: Informational view of past payment records, net pay amounts, pay periods (month/year), and disbursement status (PAID or PROCESSING) shared by the employing Society or Vendor.

3.5 Account, Session & Device Diagnostics

• Authentication Credentials: Secure JSON Web Tokens (JWT) and role permissions.
• Device Details: Device manufacturer, model, Android OS version, and app version for crash prevention and compatibility.
• Push Notification Tokens: Firebase Cloud Messaging (FCM) tokens to deliver leave approvals, shift changes, and society announcements.

3.6 Information We Strictly DO NOT Collect

• No Background Location: The app does not request or track continuous GPS or background location. Attendance verification relies solely on scanning the static physical QR code at the society gate.
• No Biometric Templates: We do not capture or store raw biometric fingerprint, iris, or facial recognition templates.
• No Payment Card Data: We do not collect debit/credit card numbers, CVVs, or payment PINs.

To deliver core operational functionality, the staff-app requests only essential Android device permissions. Each permission is tied directly to an active feature:

Zero Continuous Location Tracking: The staff-app does NOT request ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION, or ACCESS_BACKGROUND_LOCATION. On-site attendance presence is verified physically via gate QR scanning.

It is important to understand the role of PureSect regarding staff compensation:

• Not a Payment Processor or Escrow: PureSect and the staff-app do not operate as an escrow service, banking intermediary, payment gateway, or payroll disbursal engine for staff.
• Disbursement via Direct Banking Channels: Financial disbursements, wage payments, overtime allowances, and statutory benefits are executed directly between the employing entity (the Society Management Committee for Direct Staff, or the Vendor for Third-Party Staff) and the staff member through normal banking or NEFT/IMPS channels.
• Informational Display Only: The bank account details collected in the app are stored securely and transmitted to the employing Society or Vendor solely to facilitate accurate direct account transfers. Salary slips shown in the app are read-only summaries provided by the employer.
• Tax & Statutory Non-Applicability: PureSect does not withhold TDS under Section 192 (salary TDS) or Section 194C of the Income Tax Act, 1961. Statutory payroll obligations remain strictly between the employer of record and the staff member.

We process personal and operational data strictly for lawful, authorized purposes:

• Account Onboarding & Authentication: Verifying staff credentials, assigning role-based permissions, and issuing secure session tokens.
• Attendance Logging & Verification: Validating gate QR code scans to record accurate on-premises check-in and check-out times.
• Leave & Roster Management: Routing leave applications to designated society managers or supervisors, tracking approved leaves, and displaying duty shifts.
• Operational Oversight by Societies: Enabling Society Management Committees and facility administrators to monitor staffing levels, verify identity, and ensure uninterrupted community maintenance.
• Direct Payroll Facilitation: Making bank account numbers and IFSC details available to authorized society administrators or vendors for wage transfers.
• System Security & Auditability: Maintaining immutable audit logs of attendance punches and role changes to prevent identity fraud.

Our data collection and processing comply with prevailing statutory requirements in India:

• Digital Personal Data Protection Act, 2023 (DPDP Act): Personal data of Other Staff is collected and processed on the basis of consent granted during onboarding and registration, as well as legitimate uses necessary for the performance of the employment, service, or retainer arrangement.
• Contract Labour (Regulation and Abolition) Act, 1970 (CLRA): For Third-Party Staff, the Vendor remains the statutory employer of record, while the Society acts as the principal employer/service recipient. Operational attendance data collected via the app supports compliance with labor attendance and muster verification without creating direct employment liability for PureSect.
• Exclusion of PSARA 2005: The Private Security Agencies (Regulation) Act, 2005 does not apply to this Policy or the staff-app, as security guards are strictly excluded.

The Society Management Committee (or Resident Welfare Association / Condominium Board), as the entity responsible for premise safety and facility operations, holds administrative rights over operational data generated within its society boundary:

• Scope of Operational Data: Profile name, designation, contact number, uploaded compliance/ID documents, gate QR attendance records, leave requests, and shift allocations.
• Parity Across Staff Categories: The Management Committee has access to operational records for all Other Staff deployed at the premises, regardless of whether they are Direct Staff, Vendor-deployed Third-Party Staff, or Retainers.
• Strict Limit on Financial Data: The Society Management Committee does not have access to salary data of Third-Party Staff (which is governed between the Vendor and the worker). For Direct Staff, bank details are accessible solely to authorized committee treasurers for salary transfers.

We do not sell, rent, or trade staff personal data. Information is shared strictly under the following operational boundaries:

• With Society Management Committees: Operational profiles, gate QR punches, leave status, and compliance documents for staff servicing that Society.
• With Third-Party Vendors: For vendor-deployed staff, attendance hours, duty rosters, and leave approvals are shared with the respective Vendor to assist their workforce scheduling and statutory labor compliance.
• Between Internal Microservices: Operational data flows between PureSect's internal authentication, permission, and persistence services over encrypted cluster channels.
• Legal Mandate & Regulatory Authorities: Where disclosure is required by a valid court order, government agency, or statutory law enforcement authority.
• Business Transfers: In the event of a merger, acquisition, or restructuring, user data may be transferred subject to equivalent privacy covenants.

Many staff members (particularly Retainers and Vendor-deployed staff) service more than one residential society or commercial site. PureSect's unified tenancy architecture ensures complete data separation:

• Context Switching: Staff log in with a single phone number and can switch between assigned Societies (contextId).
• Cryptographic Isolation: Attendance punches, leaves, and shifts recorded in Society "A" are visible strictly to Society "A"'s administration. Unrelated societies (Society "B") have zero visibility into operational records logged outside their boundary.

We implement industry-standard technical and operational safeguards to protect staff personal data:

• Encryption in Transit: All communication between the staff-app and backend APIs is encrypted using Transport Layer Security (TLS 1.3 / HTTPS).
• Encryption at Rest: Database volumes and document storage are encrypted using industry-standard AES-256 encryption.
• Dynamic Policy Enforcement (PEP): API access requires verified cryptographic tokens with role-based permission checks before any data is returned.
• Domestic Data Hosting: All staff personal and operational data is stored on secure cloud servers located within India.
• Audit Logging: Administrative access and security events are logged for continuous monitoring and forensics.

We retain personal and operational records only for as long as necessary to satisfy operational, contractual, and statutory requirements:

• Active Engagement: Profile details and active login credentials remain active for the duration of the staff member's service at the Society or Vendor.
• Attendance & Muster Logs: In accordance with statutory labor record-keeping requirements under Indian law (such as the Contract Labour Act and Shops & Establishments Acts), attendance records, gate punches, and leave logs are retained for a statutory period of 3 (three) years.
• Archival & Deletion: After statutory retention obligations expire, personal data is permanently deleted or irreversibly anonymized.

As a data principal under the DPDP Act and in strict adherence to Google Play Store User Data and Account Deletion policies, you hold comprehensive rights regarding your personal information:

• Right of Access & Portability: You may request a summary of personal information held in your profile.
• Right to Correction: You may correct outdated mobile numbers, names, or bank account details directly in the app or via your society admin.
• Right to Withdraw Consent: You may withdraw consent for optional data processing at any time.

The staff-app is strictly intended for adult workers (18 years of age or older) engaged in professional employment, contractual labor, or facility maintenance services. We do not knowingly solicit or collect personal data from minors. If we discover that personal information of an individual under 18 has been submitted, it will be deleted immediately.

We may update this Privacy Policy periodically to reflect enhancements in product features, regulatory guidelines under the DPDP Act, or updates to Google Play Developer policies. When material updates occur, the "Last Updated" date at the top of this document will be revised, and active staff members will receive notification through the staff-app or through their Society Management Committee.

In accordance with Rule 3(2) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023, the details of our Grievance Officer are published below: