BVSM CONNECT – PRIVACY POLICY Effective Date: [Insert Date] Application Name: BVSM Connect Data Controller / Data Fiduciary: [Full Legal Name of Company] Contact Email: [Official Email Address] 1. Introduction BVSM Connect is a private mobile application developed exclusively for authorised employees and field personnel of the Company. The application facilitates field visit reporting, GPS-based travel monitoring, workshop information collection, photographic documentation, and audio recording of business discussions. The Company recognises the importance of protecting the personal information of its employees, workshop representatives, and other individuals whose information may be collected through the application. This Privacy Policy explains how information is collected, used, stored, shared, protected, and deleted. The Company intends to process personal information in accordance with applicable Indian data protection and privacy laws, including the Digital Personal Data Protection Act, 2023, and rules to the extent they are in force and applicable, as well as other relevant laws. 2. Information Collected BVSM Connect may collect the following categories of information. A. Employee Information - Employee name. - Employee identification number. - Mobile number. - Official email address. - Assigned department or field territory. - Login and authentication information. - Application usage and activity records. B. GPS and Travel Information - Device location during authorised field-duty sessions. - Starting and ending points of field visits. - Routes travelled. - Total distance covered. - Date and time of movement. - Locations and duration of stoppages. - Workshop arrival and departure information. C. Workshop Information - Workshop name and address. - Business category, including mechanic, denter, painter, garage, or allied business. - Name and business contact information of the workshop representative. - GPS location of the workshop. - Visit history and business discussion details. - Follow-up and business development information. D. Photographs The application may collect photographs of workshop premises, signage, and other relevant business locations. Photographs may also contain location information, timestamps, or identifiable individuals. E. Audio Recordings When the authorised recording feature is activated, the application may capture audio discussions between field employees and workshop representatives. Such recordings may include voices, business-related statements, and other information disclosed during the conversation. F. Technical Information The application may collect limited technical information necessary for security and operation, including: - Device type and operating system. - Application version. - Login timestamps. - Technical error reports. - Device identifiers where necessary and permitted. - Network and synchronisation information. 3. Purpose of Data Collection The Company collects and processes information for legitimate and disclosed business purposes, including: 1. Monitoring and coordinating authorised field activities. 2. Measuring distances travelled during official duties. 3. Maintaining accurate records of workshop visits. 4. Building and managing a workshop contact database. 5. Documenting discussions and business opportunities. 6. Planning follow-up visits and business development activities. 7. Verifying field reports and operational performance. 8. Supporting employee safety and operational accountability. 9. Investigating reported discrepancies or misuse. 10. Maintaining application security and complying with applicable legal obligations. The Company shall not use personal information for unrelated purposes without an appropriate lawful basis. 4. Location Tracking BVSM Connect uses GPS or other permitted location services to document employee travel during authorised field-duty activities. Location information may be collected while the application is actively used and, if the relevant feature is implemented and permissions are granted, while the application operates in the background during an active duty session. The Company shall clearly disclose whether tracking continues when the screen is locked or the application is minimised. Location tracking is intended for official field-duty activities and not for continuous personal surveillance outside authorised working activities. Employees should have a clearly identifiable method of ending a field-duty tracking session. Where location permission is denied or withdrawn, relevant tracking functions may become unavailable. Any employment-related consequences shall be handled separately under applicable Company policy and law. 5. Audio Recording and Consent BVSM Connect may record business discussions when the employee activates the designated recording feature. Before starting a recording, the employee must inform the other participant and obtain the consent required under applicable law. A suggested disclosure is: "This discussion is being recorded through our Company's BVSM Connect application for maintaining business visit records. Do you agree to the recording?" If the participant declines, the employee must not record the discussion and should use an approved alternative method of documenting the visit. Recordings shall be accessible only to authorised personnel and used for disclosed business purposes. 6. Use of Photographs Photographs collected through the application are intended to document genuine workshop visits and support operational records. Employees should avoid photographing individuals, private documents, residential areas, or unrelated activities unless necessary and lawfully permitted. Photographs shall not be publicly published or used for marketing without the required authorisation or consent. 7. Employee Monitoring and Transparency The Company may review location histories, workshop visit records, photographs, and authorised audio recordings to supervise official field operations. Monitoring shall be carried out for defined business purposes and shall not be excessive or unnecessarily intrusive. Employees shall be informed about the categories of information collected, the purpose of monitoring, and the personnel authorised to access their records. 8. Data Storage and Security Information collected through BVSM Connect may be stored on secure servers or approved cloud infrastructure operated by the Company or its authorised service providers. The Company shall implement reasonable technical and organisational safeguards, including as appropriate: - Secure employee authentication. - Role-based access controls. - Encryption during transmission. - Encryption of stored sensitive records where appropriate. - Restricted access to audio and location histories. - Security logging and monitoring. - Appropriate backup and recovery arrangements. - Procedures for identifying and responding to data breaches. No electronic system can be guaranteed to be completely secure. The Company shall take reasonable steps to reduce security risks. 9. Sharing of Information Information collected through BVSM Connect may be shared with: - Authorised Company management. - Designated field supervisors. - Approved system administrators. - Contracted application developers, hosting providers, or technical support providers where necessary. - Government authorities or law enforcement agencies when legally required. The Company shall not sell employees' personal information or workshop representatives' personal information to third parties. Service providers shall be subject to appropriate confidentiality, security, and contractual safeguards. 10. Data Retention The Company shall retain personal information only for as long as reasonably necessary for the disclosed business purpose or applicable legal obligations. The approved retention periods shall be documented before the application is deployed. Retention Schedule: - Employee account information: [Insert retention period]. - GPS and route history: [Insert retention period]. - Workshop visit records: [Insert retention period]. - Workshop photographs: [Insert retention period]. - Audio recordings: [Insert retention period]. - Security and technical logs: [Insert retention period]. Records may be retained longer where reasonably necessary for a legal claim, investigation, regulatory obligation, or other lawful requirement. At the end of the applicable retention period, information shall be securely deleted or anonymised unless further retention is legally justified. 11. Employee Rights and Requests Subject to applicable law, employees and other individuals whose personal data is processed may have rights to: - Obtain information about their personal data. - Request correction of inaccurate information. - Request deletion where legally applicable. - Withdraw consent where processing depends on consent. - Raise privacy grievances. - Exercise other rights provided under applicable data protection law. Requests may be submitted to the Company's designated privacy contact. Withdrawal of consent may affect application features that require the relevant information. Processing permitted on another lawful basis may continue where applicable. 12. Third-Party Workshop Representatives The application may collect business contact details, photographs, and recordings relating to workshop owners, mechanics, denters, painters, and other representatives. The Company shall ensure that such individuals receive appropriate information about relevant data collection. Where legally required, their consent shall be obtained. Workshop representatives may contact the Company regarding their personal information using the contact details provided below. 13. Application Permissions BVSM Connect may request access to: Location: To record official field travel, workshop visits, routes, and distances. Microphone: To record authorised business discussions. Camera: To photograph workshops and relevant business locations. Internet / Network: To transmit and synchronise authorised business records. Notifications: To provide relevant work-related alerts, where enabled. Permissions shall be requested only when necessary for implemented application features. The application shall not access unrelated personal files, private messages, personal calls, or other information outside its disclosed functions. 14. Data Breaches If a personal data breach occurs, the Company shall assess the incident, take appropriate containment and remedial measures, and provide notifications to affected individuals and competent authorities where required by applicable law. 15. International Data Transfers If the Company's approved service providers store or process information outside India, such processing shall be subject to applicable Indian legal requirements and appropriate contractual and security safeguards. The Company shall disclose material changes to its data-hosting arrangements where required. 16. Changes to This Privacy Policy The Company may update this Privacy Policy to reflect changes in application features, operational requirements, or applicable law. Material changes shall be communicated appropriately to affected users. The latest version shall be accessible within BVSM Connect. 17. Contact and Grievance Redressal For privacy-related questions, correction requests, complaints, or grievances, please contact: Company: [Full Legal Name] Privacy / Grievance Contact: [Name or Designation] Email: [Official Email Address] Office Address: [Company Address] The Company shall respond to requests and grievances in accordance with applicable legal requirements. --- PRIVACY ACKNOWLEDGEMENT I acknowledge that I have read and understood the BVSM Connect Privacy Policy. I understand that the application may process my official-duty location information, field visit details, workshop photographs, and authorised audio recordings for the business purposes described above. I understand how to contact the Company regarding privacy-related questions and requests. Button: I HAVE READ AND UNDERSTOOD