Privacy Policy

1. Introduction

Khelo Tech and Strategy Pvt. Ltd. ("Khelotech," "we," "us," or "our") operates the Khelotech Attendance App (the "App"), an internal workforce attendance management application developed exclusively for use by employees and authorized personnel of organizations using Khelotech's services.

This Privacy Policy describes how we collect, use, store, and share information about employees and authorized users ("you") who use the App. By downloading or using the App, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you or your organization administrator provides, including:

• Full name, employee ID, role, department, and organization details
• Email address and phone number
• Login credentials and authentication data
• Attendance records including check-in and check-out times, shift schedules, and leave requests
• Any other information submitted through the App by you or your organization administrator

2.2 Information Collected Automatically

When you use the App, we may automatically collect:

• Device information such as device type, operating system version, and unique device identifiers
• IP address and network information
• App usage logs and interaction data
• Location data when you use geo-fenced or location-based attendance features
• Facial image data when you use the facial verification check-in feature
• QR code scan data when you use QR-based check-in features

2.3 Permissions the App Requests

The App requests access to certain device features only when you use the relevant functionality. You can manage all permissions at any time from your device Settings app. Below is a complete list of permissions the App may request and the specific reason for each:

• Location (Precise and Approximate): Used to verify your physical presence within an authorized work zone at the time of an attendance check-in. Location is accessed only during an active check-in action. The App does not track your location continuously or in the background.
• Camera: Used for facial verification during attendance check-in and for scanning QR codes. The camera is activated only when you initiate one of these specific actions.
• Microphone: Used only if your organization has enabled audio-based features within the App. If your organization has not activated such features, this permission will not be requested.
• Photo Library / Storage: Used only to allow you to upload a profile photo or required documents. The App does not scan, access, or collect any other content from your photo library or device storage.
• Face ID / Biometric Authentication: Where supported by your device and enabled by your organization, Face ID may be used for secure login to the App. Biometric data used for Face ID authentication is processed entirely by your device's operating system (iOS) and is never transmitted to or stored on our servers.
• Notifications: Used to send attendance reminders, shift alerts, leave status updates, and other operational notices relevant to your work schedule.

3. How We Use Your Information

We use the information we collect solely to operate and deliver the App's workforce attendance management functionality. Specifically, we use it to:

• Record and manage employee attendance, shifts, leave, and related workforce data
• Verify user identity and enable secure access to the App
• Support geo-fencing, facial verification, and QR code check-in features
• Send operational notifications and alerts relevant to your schedule and organization
• Monitor App performance, diagnose technical issues, and improve functionality
• Maintain the security and integrity of the App and its data
• Comply with your organization's internal policies and applicable legal requirements

We do not use your personal information for advertising, behavioural profiling, or any purpose unrelated to the workforce management functions described above. We do not sell or rent your personal information to any third party.

4. Facial Image Data and Face Recognition

Apple's App Store guidelines require that apps collecting face data provide complete and specific disclosures. This section addresses those requirements in full.

4.1 What Face Data the App Collects

When your organization enables facial verification for attendance, the App captures a still image of your face at the moment you perform a check-in action. This image is used to generate a facial map or template to verify that you are the authorized employee performing that check-in. Face data is collected only at the moment of an active check-in. No face data is collected passively, in the background, or at any other time.

4.2 How Face Data Is Used

Face data is used solely to verify your identity at the time of an attendance check-in event. It is not used for any other purpose, including advertising, analytics, profiling, identification outside the App, or any function unrelated to employee attendance verification.

4.3 Where Face Data Is Stored

Facial images and any derived facial templates are stored on secure servers operated by Khelotech or its contracted infrastructure service providers located in India. Face data is not stored on your device beyond the duration of the active check-in process. All stored face data is protected by access controls and encryption in transit.

4.4 Whether Face Data Is Shared With Third Parties

Face data is not sold, licensed, or shared with any third party for commercial purposes. Face data may be processed by contracted cloud infrastructure providers acting strictly on our behalf, who are bound by confidentiality obligations and are prohibited from using this data for any independent purpose. Face data is not shared with any other third party unless we are required to do so by law or legal process.

4.5 How Long Face Data Is Retained

Facial images and templates are retained only for as long as the employee's account remains active within the App, and for such additional period as required by your organization's HR record-keeping obligations or applicable law. When an employee's account is deactivated, or upon receipt of a verified deletion request, face data associated with that account is permanently deleted within 30 days.

4.6 Your Rights Regarding Face Data

You may request access to or deletion of your facial data at any time by contacting your organization administrator or by reaching us directly at info@allsports.in. All deletion requests will be processed within 30 days.

5. Location Data

We collect your location only when you actively perform a location-based check-in action within the App. We do not collect location data in the background, continuously track your movements, or share your precise location with third parties for any commercial purpose. Location data is used solely to confirm your presence within an authorized work zone at the moment of attendance check-in.

6. How We Share Your Information

We do not sell or rent your personal information. We may share your information only in the following limited circumstances:

• Within Your Organization: Attendance records and related data are accessible to authorized personnel within your organization based on their assigned role and access level, for example HR managers or department supervisors, as configured by your organization administrator.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, including operational record-keeping, organizational requirements, and applicable legal or regulatory obligations. When information is no longer needed for these purposes, we delete or permanently anonymize it in a secure manner.

8. Data Security

We implement reasonable and appropriate technical and organizational security measures to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include role-based access controls, encrypted data transmission (TLS), and secured server infrastructure. However, no system is completely secure, and we cannot guarantee the absolute security of information transmitted to or stored within the App. You are responsible for maintaining the confidentiality of your login credentials.

9. Children's Privacy

The App is intended solely for use by employees and authorized adult personnel of organizations using Khelotech's services. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take prompt steps to delete it. If you believe we have collected information from a minor, please contact us immediately at info@allsports.in.

10. Your Rights and Choices

Depending on your location and applicable law, you may have rights in relation to your personal information, including the right to access, correct, or request deletion of your data. To exercise any of these rights:

• Contact your organization's administrator, who manages your account and data within the App, or
• Contact us directly using the details provided in Section 12 below

You may manage App permissions including location, camera, microphone, and notifications at any time through the Settings app on your device. Please note that disabling certain permissions may prevent you from using specific features of the App.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, App features, or applicable legal requirements. When we make material changes, we will update the "Last Updated" date at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the App after any changes are posted constitutes your acceptance of the updated Policy.

12. Planned Features and Future Data Practices

The App is under active development. We are committed to being transparent about features we intend to introduce so that users and their organizations are informed before those features are deployed. The following modules are planned for future releases of the App. This Privacy Policy will be updated prior to the launch of each feature to describe in full the data collected, how it is used, and how it is protected.

12.1 Learning Management System (LMS) Module

We plan to introduce an integrated LMS module within the App. This module will allow organizations to assign training courses, learning materials, and assessments to employees directly through the App. When this module is launched, we will collect data related to course assignments, completion status, assessment scores, and learning progress. This data will be used solely to support employee training and development as directed by your organization. Full data practices for this module will be disclosed in an updated Privacy Policy prior to its release.

12.2 Grievance Management Module

We plan to introduce a Grievance Management module that will allow employees to formally raise workplace concerns, complaints, or disputes through the App. When this module is launched, information submitted through grievance forms - including the nature of the complaint, supporting details, and relevant parties - will be collected and made accessible only to authorized HR or management personnel within your organization as designated by your administrator. Submissions will be treated with confidentiality. Full data practices for this module will be disclosed in an updated Privacy Policy prior to its release.

12.3 Feedback Form Module

We plan to introduce a Feedback Form module that will allow employees to submit structured feedback regarding workplace experiences, processes, or management, as configured by their organization. When this module is launched, responses may be collected in identified or anonymous form depending on the configuration chosen by your organization administrator. Full data practices for this module, including anonymization options and data retention, will be disclosed in an updated Privacy Policy prior to its release.

12.4 Policy Update Commitment

Before any of the above features are made available to users, this Privacy Policy will be revised to include complete disclosures for each new module, covering what data is collected, how it is used, with whom it is shared, how long it is retained, and what rights users have in relation to that data. We will notify users and organizations of material policy updates in advance of any new feature going live.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact us: