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INTRODUCTION:

This Privacy Policy ("Policy") outlines how Transport Corporation of India Ltd. ("TCIL/the Company") collects, uses, and protects information obtained through mobile devices that are owned by the Company and provided to its employees. This Policy is supplementary to the Privacy Policy available on the website and mobile application of TCIL. It specifically relates to the use of GPS technology to track Company-owned Mobile Devices during working hours, with the prior and informed consent of the employees concerned. The purpose of such tracking is to improve attendance management, provide accurate route guidance, monitor employee safety, optimize field operation, and ensure timely delivery of customer services.

1. TO WHOM THIS POLICY APPLIES:

This policy applies to only those employees, who are using the company-owned mobile devices and have given their specific written consent for tracking. The tracking will start once an employee log-in to the company’s mobile application and will immediately stop once the said employee logged out of the mobile application.

2. HOW WE TAKE THE CONSENT:

Before collecting any personal or sensitive data (including location), the application displays a clear in-app disclosure to the user explaining what data is collected, how it is used, and whether it is collected in the background.

Users are required to provide explicit consent within the application by accepting this disclosure before any permissions are requested. In addition to in-app consent, the Company may also obtain written consent from employees as per internal policies. Employees can withdraw their consent at any time by logging out of the application or by notifying their supervisors and the HR department.

3. WHY WE TRACK THE COMPANY-OWNED MOBILE DEVICE:

Our primary objective for tracking of the mobile device are:

To accurately record attendance of the employees.
To assist employees in visiting customer premises efficiently.
Allocate and assign customer visits to employees.
Set customer area perimeter and route.
Ensure safety and security of employees.

4. WHAT PRIMARY DATA WE COLLECT DURING THE TRACKING

During the tracking we collect following data:

Location data during working hours.
Login time and log out time.
Time spent on customer location.
Route data for optimizing travel to customer locations.
The app tracks the employee's location while it is logged in and running in the background. Location tracking stops immediately upon logout.
Location data is collected only after the user grants permission within the app.

5. WHAT ADDITIONAL DATA AND PERMISSION WE TAKE:

CAMERA ACCESS:
The App may request access to the camera of the device to verify the identity of the Employee. The employee may be asked to take a selfie to verify his/her identity, which is crucial for ensuring the security of the account and preventing unauthorized access.
PHOTO GALLERY ACCESS:
The App may request access to the photo gallery for the uploading of any document related to the customer or photos. If necessary, the Employee can select and upload images from the gallery to address any issues or provide additional information related to their customer visit.
DEVICE ID:
The App collects the device’s unique identifier (Device ID) to ensure that the account is linked to the specific device. This helps in preventing unauthorized access to the employees account and maintaining the integrity of the data. The Device ID is also used to deliver personalized experiences and customize the App’s functionality to the needs of the employees.
VIRTUAL IMEI NUMBER:
We do not collect actual IMEI number of the device. We collect Virtual Identifier to prevent unauthorized access to the Employees account and maintaining the integrity of the data.

6. HOW WE USE THE DATA COLLECTED DURING TRACKING:

We may use the data collected during the tracking for following purpose:

To verify employee attendance.
To confirm the identity of the employee and provide personalized support.
To assist in scheduling and managing customer visits.
To provide optimal routes for customer visits.
To analyse and improve the customer experiences.
To enhance the security of the account and protect against unauthorized access.
The Company may disclose the Personal Information provided by Employees to third-party service providers engaged by it (“Service Providers”) for the purpose of enabling such Service Providers to perform services on its behalf and in furtherance of the purposes for which such Personal Information has been collected. All such Service Providers shall process the Personal Information strictly in accordance with the documented instructions of the Company, solely for the purposes for which they have been engaged and shall be bound by contractual obligations to maintain confidentiality, implement reasonable security safeguards and ensure compliance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023.
The Company does not sell, rent, lease, or otherwise disclose Personal Information to any third parties for their own marketing or commercial purpose.
The Application utilizes certain third-party services, for the purposes of providing notifications and backend support. Such third-party service providers may collect and process limited technical data (including device and usage information) in connection with the provision of such services, in accordance with their respective privacy policies.

7. HOW WE ENSURE SECURITY OF THE DATA COLLECTED

We are committed to protecting the privacy and confidentiality of the collected data. Measures include:

Encryption of location data.
Restricted access to authorized personnel only.
Regular audits to ensure compliance with this policy.

8. HOW LONG THE DATA WILL BE RETAINED:

We shall not retain the data collected for longer than necessary to fulfil the purposes for which it was collected, unless otherwise required by law.

9. WHAT ARE THE RIGHTS OF EMPLOYEES:

Subject to applicable law, Employees can request for deletion or correction of their data shared with the Company.

Employees have the right to revoke their consent for mobile phone tracking at any time by providing written notice to the Human Resources department/IT department. However, revocation of consent may impact the employee's ability to perform certain work-related tasks efficiently.

For revocation, deletion or cancellation, Employees can contact at the following ID:

Email: app2.crpo@tcil.com

10. MISCELLANEOUS:

This Application is not intended for use by individuals under the age of eighteen (18) years. The Company does not knowingly collect or process personal data from children. In the event the Company becomes aware that personal data of a child has been inadvertently collected, it shall take appropriate steps to delete such data in accordance with applicable law, including the Digital Personal Data Protection Act, 2023.

We may review and update this Privacy Policy periodically. Employees will be notified of any significant changes.

For questions or concerns about this policy, please reach out us at: app2.crpo@tcil.com

By clicking the below Accept option, you hereby confirm that, you have read and understood the policy and consent to the tracking of the company-owned mobile device being used by you during working hours for the purposes outlined in this policy.