Internal Apps — Authorized Personnel Only

Privacy Policy — DEC Mobile and DEC Operators

Effective Date: 8 November 2026 Last Updated: 8 November 2026

Contents

  1. 01 Introduction
  2. 02 Data Controller
  3. 03 Information We Collect
  4. 04 Face Data
  5. 05 How We Use Your Information
  6. 06 Legal Basis
  7. 07 How We Share Information
  8. 08 Data Retention
  9. 09 Security
  10. 10 Your Rights & Choices
  11. 11 Account & Data Deletion
  12. 12 Children's Privacy
  13. 13 International Data Transfers
  14. 14 Permissions (iOS & Android)
  15. 15 Third-Party Links
  16. 16 Changes to This Policy
  17. 17 Contact Us

1 Introduction

This Privacy Policy applies to the DEC Mobile app (for site engineers) and the DEC Operators app (for operators, security, mess and site staff) on iOS and Android (together, the "Apps").

These Apps are internal work tools provided by DEC Infrastructure and Projects (India) Private Limited ("DEC", "Company", "we", "us"), Dabla Sadan, 2-1-434/1, Street No. 4, Nallakunta, Hyderabad – 500 044, Telangana, India, to its employees and to the staff of its contractors working on DEC sites.

The Apps are developed, implemented, managed, published and run for DEC by Nutrinium Technologies Private Limited ("Nutrinium"). They support construction site operations such as attendance, gate and mess entry, reporting, leave, travel, claims, and internal requests and approvals.

This Privacy Policy explains how information is collected, used, shared, and protected when you use the Apps. If you do not agree with this Privacy Policy, do not use the Apps.
The Apps do not contain advertising, do not sell data, and do not use analytics or tracking SDKs.

2 Who Controls Your Data (Data Controller)

For employment and worksite operations data, DEC is the Data Controller — the entity that determines the purposes and means of processing. Nutrinium acts as Data Processor and processes personal data only on DEC's documented instructions.

Data Controller
DEC Infrastructure and Projects (India) Private Limited

Dabla Sadan, 2-1-434/1, Street No. 4,
Nallakunta, Hyderabad – 500 044,
Telangana, India

info@decinfra.com

Data Processor (App Developer)
Nutrinium Technologies Private Limited

Acts as Data Processor under a written contract with DEC. Processes personal data only on DEC's documented instructions — including for hosting, maintenance, support, face-recognition infrastructure, and feature updates.

Privacy contact: dec@nutrinium.in

3 Information We Collect

We collect information to provide, secure, and operate the Apps. The table below summarises the main categories; further detail on face data is in Section 4.

Data When Why
Account details: employee number, name, work email / username, mobile number, role, project and site When HR sets up your account; when you sign in To sign you in and show the work and approvals that belong to you
A sign-in PIN (stored only as a one-way hash) and a device ID When you set a PIN; when you sign in Security; one device per account
Location (GPS), only while the app is open When you check in / out, and on reports that need a site location To confirm attendance is marked at the site and to tag reports with where they were made. The Apps do not track location in the background.
Face data — see Section 4 Face registration, attendance face check, gate / mess face scan, labour attendance Identity checks at attendance, the gate and the mess
Photos, videos and voice notes you take or attach When you add them to a report, request, claim or pass Evidence for the work record (progress, safety, deliveries, bills, gate passes)
Work records: reports, requests, approvals, attendance, leave, travel, claims, gate and meal entries When you use those screens To run the site and HR processes they belong to

3.1 Account & Authentication Information

3.2 Attendance & Time Tracking Data

3.3 Location Information

Location is collected only when the feature is enabled by DEC and you grant permission. Location is captured only while the App is open and in active use — not in the background.

3.4 Camera, Photos & Media

We do not access your gallery or photos unless you explicitly choose media for upload and grant the relevant permission. Face-related camera use is described separately in Section 4.

3.5 Work-Related Operational Data

3.6 Device & Technical Information

We do not collect contacts, SMS, call logs, or other unrelated personal data for the Apps' core functions. The Apps do not use advertising, analytics or tracking SDKs.

3.7 Audio/Video (Optional, Feature-Dependent)

4 Face Data

Face recognition is used for identity checks at attendance, the site gate and the mess. The Apps use the ordinary device camera for this purpose. They do not use Face ID / TrueDepth sensor data for face recognition.

4.1 What Face Data Is Collected

4.2 How Face Data Is Used

Face data is used only to confirm who a person is:

Face data is not used for any other purpose, not used to train models, and not used for marketing.

4.3 Where Face Data Is Stored and Who Can See It

Who can see the photos

4.4 How Long Face Data Is Kept

Face data Kept for
Registration photo and face template While you work on DEC sites. A replaced photo / template is deleted when you register again.
Photos taken at a gate or mess face scan 90 days, then deleted automatically
Photo of a failed attendance face check 90 days, then deleted automatically (HR's record that the check failed is kept, without the photo)
Photos of successful attendance face checks Not kept — only the result (matched / not matched) is stored
Labour attendance photos on the daily labour report Kept with the labour report as the record for the contractor's labour bill

A daily job carries out the time limits described above.

4.5 How Face Data Is Deleted

5 How We Use Your Information

6 Legal Basis (Where Applicable)

Depending on jurisdiction, processing may rely on:

7 How We Share Your Information

We do not sell personal information and do not share it for advertising.

We may share information only in the following circumstances:

Face data is not sent to any outside face-recognition or cloud AI service (see Section 4).

8 Data Retention

We retain data only for as long as necessary to provide the Apps and for legitimate business purposes, including compliance with legal, safety, payroll, and audit requirements. Retention periods may vary by data type and project, and are defined by DEC's internal policies.

Work records (attendance, leave, payroll-related, safety and project records) are kept as long as DEC needs them for the work and as long as Indian law requires them to be kept. Photos and documents attached to a work record are kept with that record.

Face data retention and deletion timelines are set out in Sections 4.4 and 4.5.

Certain payroll, safety, and audit records may be retained after an employee or contractor staff member leaves where required or permitted by law. When data is no longer required, it is deleted or anonymized where feasible and in accordance with applicable laws.

9 Security

We use reasonable safeguards to protect data, including:

9.1 Security Incidents

If a security incident affects personal data, DEC will take reasonable steps to investigate, mitigate, and provide notices where required by applicable law and Company policy.

10 Your Choices, Controls, and Rights

The Apps are provided for employment/worksite operations. Certain requests may be routed through DEC's authorized HR/IT administrators for identity verification and operational continuity.

11 Account Deletion & Data Deletion Requests

Because the Apps are provided for employment/worksite operations, account deactivation is handled by DEC (HR/IT) or by Nutrinium on behalf of DEC.

You can request deletion of your account and associated personal data (subject to legal retention) by contacting HR or emailing dec@nutrinium.in with the following details:

Face registration deletion follows the process in Section 4.5 (including the option to use QR or phone number at the gate and mess instead of face).

We may retain certain records where required for legal, payroll, safety, audit, or compliance obligations even after an account deletion request.

12 Children's Privacy

The Apps are for adults employed on DEC sites. They are not intended for individuals under 18 and are meant only for authorized personnel. They are not meant for children.

13 International Data Transfers

Data may be stored and processed in India and, where service providers operate globally (for example Apple / Google / Expo push notification infrastructure), may be processed in other regions with appropriate protections — including contracts, Data Processing Agreements (DPAs), and security controls — as required by applicable law.

Face recognition itself runs on DEC's own face-recognition server operated by Nutrinium for DEC and is not sent to outside face-recognition or cloud AI services.

14 Permissions Explained (iOS & Android)

Common permissions requested by the Apps (actual permissions depend on features enabled by DEC and on which App you use):

Location (Precise/Approximate)
Attendance and site-tagged reports while the App is open — not background tracking
Camera
Face registration/checks, reports, labour attendance photos, QR scanning (if used)
Photos/Media
Upload attachments you choose
Microphone (Optional)
Voice notes, if feature is enabled
Notifications
Send operational alerts and communications

15 Third-Party Links

If the Apps link to external sites, their own privacy practices apply. Please review their policies before submitting personal data to them.

16 Changes to This Policy

If this policy changes, the new version is shown in the Apps and on this page with a new effective date. We may also notify users through internal channels for material changes.

17 Contact Us

For any privacy question, request or complaint:

Privacy Inquiries
Nutrinium Technologies Pvt. Ltd.

dec@nutrinium.in

You may also complain to the Data Protection Board of India.

Registered Address
DEC Infrastructure and Projects (India) Pvt. Ltd.

Dabla Sadan, 2-1-434/1, Street No. 4,
Nallakunta, Hyderabad – 500 044,
Telangana, India