Privacy Policy - SmartFace Attendance
1. Introduction
SmartFace Attendance ("we," "our," or "us") is committed to protecting the privacy and security of personal information collected through our facial recognition-based attendance management system. This Privacy Policy explains how we collect, use, store, and protect your personal data.
By using the SmartFace Attendance system, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal information as described herein.
2. Information We Collect
2.1 Personal Information
We collect and process the following types of personal information:
Company/Organization Information:
- Company name
- Administrator name
- Business email address
- WhatsApp contact number
- Subscription and billing information
Employee Information:
- Full name
- Employee ID
- Email address
- Phone number
- Department and position
- Shift timings
- Basic salary information (for attendance-based salary calculations)
- Allowed leave entitlements
Biometric Information:
- Facial images (3-10 photos per person for enrollment)
- Facial recognition embeddings (mathematical representations of facial features)
- Face recognition confidence scores
Attendance Records:
- Check-in and check-out timestamps
- Attendance type (entry/exit)
- Device identification (terminal location)
- Attendance metadata (recognition method, confidence level)
- Working hours, overtime, and late arrival records
- Shift assignments and calendar data
Device Information:
- Face recognition terminal identifiers
- Device tokens for authentication
- Device location information
- Last activity timestamps
Technical Information:
- IP addresses (for security purposes)
- Authentication tokens
- API access logs
- System usage logs
2.2 Automatically Collected Information
- Server logs and error reports
- API request timestamps
- Face recognition processing metrics
- System performance data
3. How We Use Your Information
3.1 Primary Purposes
We use the collected information for the following purposes:
Attendance Management:
- Recording employee attendance through facial recognition
- Tracking working hours, overtime, and leave
- Generating attendance reports and summaries
- Calculating attendance-based salary components
Authentication and Security:
- Verifying user identity for system access
- Authenticating face recognition terminals
- Preventing unauthorized access
- Detecting and preventing duplicate attendance entries
System Operations:
- Managing employee profiles and assignments
- Organizing departments, shifts, and schedules
- Maintaining device and terminal registrations
- Providing subscription and account management
Analytics and Reporting:
- Generating attendance statistics and trends
- Creating monthly attendance calendars
- Calculating salary estimations based on attendance
- Providing dashboard analytics for administrators
Service Improvement:
- Improving face recognition accuracy
- Optimizing system performance
- Enhancing user experience
- Troubleshooting technical issues
3.2 Legal Basis for Processing
We process personal data based on:
- Consent: You provide explicit consent for biometric data collection and processing
- Contract Performance: Processing is necessary for employment and payroll management
- Legitimate Interests: System security, fraud prevention, and service improvement
- Legal Compliance: Meeting employment law and record-keeping requirements
4. Data Storage and Security
4.1 Storage Infrastructure
- All data is stored in MongoDB databases with encryption at rest
- Facial embeddings are stored as encrypted mathematical representations
- Data is hosted on secure servers with restricted access
- Regular backups are performed to prevent data loss
4.2 Data Location
- Data is stored on servers located in secure data centers
- We maintain data residency in accordance with applicable laws
- Cross-border data transfers (if any) comply with relevant regulations
4.3 Access Controls
- Multi-tenant architecture ensures data isolation between organizations
- Role-based access control (RBAC) limits data access
- Authentication required via Laravel Sanctum tokens
- Device-specific tokens for face recognition terminals
- All API access is logged and monitored
5. Data Sharing and Disclosure
5.1 Third-Party Sharing
We do not share, sell, rent, or disclose your personal data to third parties. All data processing occurs within our secure infrastructure.
5.2 Service Providers
We use the following internal components (not third-party services):
- MongoDB: For data storage (self-hosted)
- InsightFace: For face recognition processing (self-hosted, no external API calls)
- Internal Services: All processing occurs on our infrastructure
5.3 Legal Disclosures
We may disclose information only when:
- Required by law, court order, or legal process
- Necessary to protect our rights, property, or safety
- Required to prevent fraud or security threats
- Requested by law enforcement with proper authorization
6. Your Privacy Rights
You have the following rights regarding your personal data:
6.1 Access Rights
- View your personal information stored in the system
- Request copies of your attendance records
- Access your facial recognition enrollment status
6.2 Correction Rights
- Update your personal information (name, email, phone)
- Correct inaccurate attendance records (subject to administrator approval)
- Re-enroll facial data if recognition accuracy is poor
6.3 Deletion Rights
- Request deletion of your facial recognition data
- Request account deletion (subject to legal retention requirements)
- Withdraw consent for biometric data processing
6.4 Portability Rights
- Export your attendance records in standard formats (Excel)
- Receive copies of your personal data in a structured format
6.5 Objection Rights
- Object to certain data processing activities
- Opt-out of non-essential data collection
- Request human review of automated decisions
6.6 How to Exercise Rights
To exercise any of these rights, contact your organization's administrator or reach out to us at:
- Email: support@smartcodejunctioninfinity.com
- Support: Through the mobile application or system dashboard
7. Data Retention
We retain personal information only as long as necessary for the purposes outlined in this policy:
- Attendance Records: Retained for employment duration plus statutory requirements (typically 3-7 years)
- Biometric Data: Retained during active employment; deleted within 30 days of termination
- Account Information: Retained during subscription period; deleted according to retention policy
- Logs and Metadata: Retained for 90 days for security and troubleshooting purposes
For detailed retention periods, please refer to our separate Data Retention Policy.
8. Children's Privacy
SmartFace Attendance is designed for workplace use and is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors without parental consent as required by law.
9. Biometric Information Notice
9.1 Special Notice for Biometric Data
Facial recognition data is considered sensitive biometric information in many jurisdictions. We take extra precautions:
- Explicit Consent Required: Biometric enrollment requires explicit consent
- Purpose Limitation: Used only for attendance management, not for other purposes
- Secure Storage: Facial embeddings are encrypted and stored securely
- No Retention After Employment: Deleted within 30 days of employment termination
- No Sale or Trading: We never sell or trade biometric data
9.2 How Facial Recognition Works
- 3-10 facial photos are captured during enrollment
- Photos are converted to mathematical embeddings (numerical representations)
- Original photos are stored for re-enrollment purposes only
- Embeddings are compared during recognition; no photos are analyzed in real-time
- Recognition confidence scores determine match accuracy
10. Cookies and Tracking
The SmartFace Attendance mobile application does not use cookies. Our API uses:
- Authentication Tokens: Session tokens for secure API access
- Device Tokens: 8-character alphanumeric codes for terminal authentication
- These tokens are stored locally on devices and are not used for tracking
11. International Data Transfers
If your organization operates across multiple countries, data may be transferred internationally. We ensure:
- Compliance with applicable data protection laws (GDPR, CCPA, etc.)
- Adequate safeguards for international transfers
- Data processing agreements with all parties
- Notification to users of cross-border transfers
12. Security Measures
We implement comprehensive security measures including:
Technical Measures:
- Encryption in transit (HTTPS/TLS) and at rest
- Secure authentication (Laravel Sanctum with tokens)
- API rate limiting and request validation
- Regular security audits and penetration testing
- Intrusion detection and prevention systems
Organizational Measures:
- Access controls and role-based permissions
- Employee training on data protection
- Incident response and breach notification procedures
- Regular security policy reviews
Physical Measures:
- Secure data center facilities
- Restricted physical access to servers
- Environmental controls and monitoring
13. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will:
- Notify users of material changes via email or in-app notification
- Post the updated policy with a revised "Last Updated" date
- Provide at least 30 days' notice for significant changes
- Obtain renewed consent if required by law
14. Data Breach Notification
In the unlikely event of a data breach that affects your personal information:
- We will notify affected users within 72 hours of discovery
- Notifications will include the nature of the breach and affected data
- We will provide guidance on protective measures
- Authorities will be notified as required by law
15. Contact Information
For questions, concerns, or requests regarding this Privacy Policy or your personal data:
SmartFace Attendance Support
- Developer: Smart Code Junction Infinity
- Email: support@smartcodejunctioninfinity.com
- Website: https://smartfaceattendance.in
For data protection inquiries, contact your organization's Data Protection Officer or administrator.
16. Consent and Acknowledgment
By using SmartFace Attendance, you acknowledge:
- You have read and understood this Privacy Policy
- You consent to the collection and processing of your personal data as described
- You consent to biometric data processing for attendance management
- You understand your rights and how to exercise them
- You agree to comply with your organization's policies regarding system use
Note: This Privacy Policy should be read in conjunction with our Terms of Service, Data Retention Policy, and Security Policy. For employees, please also refer to your organization's internal data protection and biometric consent policies.
© Smart Code Junction Infinity Private Limited
All rights reserved. SmartFace Attendance is a registered platform of Smart Code Junction Infinity Pvt. Ltd. https://smartfaceattendance.in