This privacy policy describes and determines how we, Government of Telangana handle and/or deal in your personal information and sensitive personal information, including biometric data collected through facial recognition technology, as defined under the applicable laws of India (hereinafter collectively referred to as Personal Information).

To provide you (“Your”, “User”, "Employee") with the Service (or Mee Pramanam App facial recognition attendance service as defined in the Terms and Conditions of Use ), Electronic Service Delivery, ITE&C Department, Government of Telangana (“We”, “Us”, “Our”, “ESD”, “ITE&C”, “GoT”) needs to collect some information about you, and this Privacy Policy is where we describe the information we collect, what we do with it, and how we protect it. By using or interacting with the Mee Pramanam App, you are entering into a binding contract with us and consenting to the use of your biometric information as explained in this Privacy Policy. If you don't agree with these terms, then please don't use the Mee Pramanam App.

This Privacy Policy inter alia determines, how we control the Personal Information provided by You to Us, how We handle and deal in the Personal Information, correction of inaccuracies in the Personal Information provided by You to Us, the purposes for which the Personal Information provided by You may be used by Us.

This Privacy Policy should be read in conjunction with the Terms of Use available at [Terms of Use]. This Privacy Policy will govern the use and access of the Mee Pramanam App by You. We collect, receive, possess, or store the Personal Information, to enable the App to function more effectively, and to enable Us to provide more efficient attendance management services to government employees. If the terms of this Privacy Policy are not acceptable to You, please do not use the Mee Pramanam App and/or the services provided by Us. If You refuse to accept the terms of this Privacy Policy, We may choose not to offer You the services for which the Personal Information was being collected.

  • 1.Facial Biometric Data

    The app collects:

    • Base Reference Photo captured during employee registration;
    • Live facial image captured during Check-In/Check-Out for real-time identity verification;
    The app does NOT collect or generate:
    • Facial geometry patterns or measurements
    • Facial landmarks or key feature points
    • Mathematical representations of facial characteristics
    • Any additional biometric templates beyond the base photo
  • 2. INFORMATION WE COLLECT

    2.1 Biometric Information Collection

    We collect the following categories of Personal Information from You when You access the Mee Pramanam App:

    (a) Facial Biometric Data:

    • Facial geometry patterns and measurements;
    • Facial landmarks and key feature points;
    • Mathematical representations of facial characteristics used for identification;
    • Facial images captured during the attendance marking process;

    (b) Personal Identification Information:

    • Employee ID number and government service details;
    • Full name as per official records;
    • Department and designation information;
    • Mobile number for authentication and notifications;
    • Aadhaar number for verification purposes (where applicable);

    (c) Technical and Usage Information:

    • Device information including mobile device type and operating system;
    • IP address and network information;
    • App usage patterns and attendance marking timestamps;
    • Location data when marking attendance (GPS coordinates of attendance location);
    • Camera permissions usage for facial scanning;

    2.2 Information That Does Not Qualify as Personal Information

    The following will not qualify as Personal Information for the purposes of this Privacy Policy:

    • Anonymous statistical data about attendance patterns that cannot identify individual employees;
    • Aggregated data used for administrative reporting purposes;
    • Information that is incapable of identifying You either individually or in combination with other information;

    2.3 Accuracy of Information

    You agree that We are not responsible for the accuracy, authenticity or verification of the Personal Information provided by You. However, we will take reasonable steps to ensure the accuracy of biometric matching and attendance records.

  • 3. CONSENT AND LEGAL BASIS FOR PROCESSING 3.1 Consent Requirements

    You hereby consent to the collection, storage, use, disclosure, and transfer of the Personal Information by Us for the purposes detailed in this Privacy Policy. Your consent is:

    • Free: Given without coercion or undue influence;
    • Specific: Related specifically to facial recognition attendance marking;
    • Informed: You are fully aware of how your biometric data will be used;
    • Unconditional: Not bundled with other unrelated consents;
    • Unambiguous: Demonstrated through clear affirmative action;

    3.2 Purpose Limitation

    You hereby acknowledge and agree that collection, storage, use, disclosure, and transfer by Us of the Personal Information is for the lawful purpose of:

    • Employee attendance tracking and monitoring;
    • Ensuring workplace punctuality and accountability;
    • Preventing fraudulent attendance marking and proxy attendance;
    • Administrative reporting and workforce management;
    • Compliance with government service regulations;
    3.3 Data Storage Location

    You acknowledge and agree that the Personal Information collected by Us, including biometric data, shall be stored by Us at our secure Data Centers (Server(s)) within India. By using our Mee Pramanam App and providing Personal Information to Us, You are consenting to the storage of the same by Us at Our Server(s) in compliance with data localization requirements.

  • 4. HOW WE USE YOUR INFORMATION

    4.1 Primary Uses

    The Personal Information collected by Us is used by Us, our affiliates, subsidiaries and authorized service providers, inter alia, for:

    (a) Attendance Management:

    • Recording daily attendance through facial recognition;
    • Maintaining accurate attendance records for payroll processing;
    • Generating attendance reports for administrative purposes;
    • Monitoring compliance with working hours and leave policies;

    (b) Security and Fraud Prevention:

    • Preventing unauthorized access to attendance systems;
    • Detecting and preventing proxy attendance;
    • Ensuring only authorized employees can mark attendance;
    • Maintaining the integrity of attendance data;

    (c) Administrative Functions:

    • Performance evaluation and monitoring;
    • Leave management and approval processes;
    • Compliance with government service regulations;
    • Generating statistical reports for workforce planning;

    4.2 Service Improvement

    You agree that We may use personal information about You to improve the Mee Pramanam App's services, analyze app usage, improve the app's content and service offerings, and customize the app's functionality. These uses improve the app to meet Your needs and provide You with a smooth, efficient, safe and customized experience while using the Mee Pramanam App.

    4.3 Data Sharing Restrictions

    We do not sell or rent Your personal information to third parties for their commercial purposes without Your explicit consent and we only use Your information as described in this Privacy Policy.

  • 5. INFORMATION SHARING AND DISCLOSURE

    5.1 Confidentiality Commitment

    We acknowledge that the Personal Information provided by You is important and confidential, and the contents of such Personal Information shall not be disclosed by Us to any Person, except to such third parties as are specified in this Privacy Policy. For the purposes of this Privacy Policy, the term "Person" shall mean any individual, corporation, partnership, limited liability partnership, joint venture, body corporate or other organization, association or entity.

    5.2 Authorized Disclosure Without Consent

    The Personal Information provided by You can be shared by Us at any time without obtaining explicit consent from You, with:

    (a) Government Agencies:

    • PAny government agencies mandated under the law to obtain Personal Information including sensitive Personal Information for the purpose of verification of identity;
    • For prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences;
    • Law enforcement agencies for legitimate security purposes;

    (b) Legal Requirements:

    • Any third party by an order under the applicable law for the time being in force;
    • Courts and tribunals pursuant to legal proceedings;
    • Regulatory authorities as required by law;

    (c) Administrative Purposes:

    • Department heads and supervisors for attendance monitoring;
    • HR departments for payroll and leave management;
    • IT support teams for technical maintenance (with appropriate safeguards);
    • Authorized audit teams for compliance verification;

    5.3 Third-Party Service Providers

    We may disclose Personal Information to authorized third-party service providers who assist us in operating the Mee Pramanam App, provided that:

    • They maintain the same level of data security practices as employed by Us;
    • They use the Personal Information only for purposes related to the Mee Pramanam App services;
    • They are bound by appropriate confidentiality agreements;

    5.4 Policy Enforcement

    We may also disclose the Personal Information to enforce Our policies, address concerns/complaints, and prevent any unethical/illegal practices/activity.

  • 6. DATA SECURITY AND PROTECTION

    6.1 Security Measures

    We employ commercially reasonable data security practices and procedures commensurate with the specifications under the applicable laws, including:

    (a) Technical Safeguards:

    • End-to-end encryption of biometric data using industry-standard AES-256 encryption;
    • Secure transmission protocols for data transfer;
    • Multi-factor authentication for administrative access;
    • Regular security audits and vulnerability assessments;

    (b) Physical Security:

    • Secured data centers with restricted access;
    • Environmental controls and monitoring;
    • Backup and disaster recovery procedures;
    • Physical security measures for devices and infrastructure;

    (c) Administrative Controls:

    • Role-based access control (RBAC) for system administrators;
    • Regular training for personnel handling biometric data;
    • Clear data handling procedures and protocols;
    • Incident response and breach notification procedures;

    6.2 Biometric Data Protection

    Given the sensitive nature of biometric data, we implement additional protections:

    • Biometric templates are stored in encrypted format and cannot be reverse-engineered to recreate original images;
    • Facial recognition processing occurs on secure servers within India;
    • Regular deletion of temporary biometric data after processing;
    • Strict access controls limiting who can view or process biometric information;

    6.3 Security Limitations

    In view of the functionality of the internet and provision of services over the internet, We cannot guarantee the complete security of Your Personal Information at any time. Given that the internet is a medium which is prone to several security hazards and other events/incidents which are beyond Our control, while we will strive to ensure full protection to Your Personal Information, We cannot guarantee the same at any given time. Any Personal Information provided by You must therefore be provided with full cognizance of this risk.

  • 7. DATA RETENTION AND DELETION

    7.1 Retention Period

    We will retain your biometric data and personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

    • Active employee data: Retained throughout the period of employment;
    • Attendance records: Retained as per government record-keeping requirements (typically 7 years);
    • Biometric templates: Retained for the duration of employment plus legal retention requirements;

    7.2 Data Deletion

    Upon termination of employment or withdrawal of consent (where applicable), we will:

    • Delete biometric templates within 30 days unless legally required to retain;
    • Archive attendance records as per government regulations;
    • Remove access permissions immediately upon employment termination;
    • Provide confirmation of data deletion upon request;
  • 8. YOUR RIGHTS AND CHOICES

    8.1 Access and Correction Rights

    You have the right to:

    • Access your personal information stored in our systems;
    • Request correction of inaccurate or incomplete information;
    • Receive information about how your biometric data is being processed;
    • Obtain copies of your attendance records;

    8.2 Consent Withdrawal

    While the use of Mee Pramanam App may be mandatory for government employees, you have the right to:

    • Understand the consequences of not using the facial recognition system;
    • Request alternative attendance marking methods where technically feasible;
    • Raise concerns about the processing of your biometric data through appropriate channels;

    8.3 Grievance Mechanism

    You have the right to raise concerns or complaints about the processing of your personal information through our grievance mechanism detailed in Section 10.

  • 9. CAMERA PERMISSIONS AND USAGE

    9.1 CCamera Access

    The Mee Pramanam App requires access to your device's camera specifically for:

    • Capturing facial images for attendance verification;
    • Real-time facial recognition processing;
    • Ensuring the person marking attendance is physically present;

    9.2 Camera Usage Limitations

    • Camera access is used only during attendance marking;
    • No unauthorized photography or recording;
    • Images are processed immediately and not stored permanently on the device;
    • Camera permissions can be managed through device settings, but this may affect app functionality;

    9.3 Location Services

    The app may use GPS technology to:

    • Verify that attendance is being marked from authorized locations;
    • Prevent remote or fraudulent attendance marking;
    • Ensure employees are physically present at their designated workplace;

    9.4 Background Notifications Permission

    The Mee Pramanam App may request permission to run in the background for the purpose of delivering important notifications related to attendance, system alerts, and service updates:

    • Notifications will be delivered only if you grant explicit permission to allow the app to run in the background;
    • If you deny this permission, you will not receive notifications from the app;
    • You may modify or withdraw this permission at any time through your device settings;
    • Background notification access is used strictly for service-related communication and not for any unrelated purposes;

    9.5 Storage Permissions and Usage

    The Mee Pramanam App may require access to your device’s storage in limited scenarios when using the Survisha functionality. This is necessary for:

    • Downloading required datasets during the initial setup of the app;
    • Reading and accessing these datasets from the device storage for facial recognition processing;
    • Ensuring the smooth functioning of attendance verification using Survisha technology;

    Limitations of Storage Access:

    • Storage permission is requested only for reading necessary datasets;
    • The App does not access or modify any personal files, photos, or documents stored on your device;
    • Storage access is strictly limited to datasets required for the functioning of the Mee Pramanam App;
    • You may revoke storage permission at any time through your device settings, but certain features (Survisha-based facial recognition) may not function properly without it;

    9.A) Additional App Permissions and Usage

    Apart from camera usage already described, the MeePramanam App may also request the following permissions:

    1. Internet Access

    • Permission: android.permission.INTERNET
    • Purpose: Required for secure communication with government servers and attendance synchronization.

    2. Storage Access

    • Permissions:
    • android.permission.READ_EXTERNAL_STORAGE
    • android.permission.READ_MEDIA_IMAGES / READ_MEDIA_VIDEO / READ_MEDIA_AUDIO (Android 13 and above)
    • Purpose: Used for accessing profile images or Aadhaar-related documents necessary for authentication and verification.

    3. Location Access

    • Permissions:
    • android.permission.ACCESS_FINE_LOCATION
    • android.permission.ACCESS_COARSE_LOCATION
    • Purpose: Capturing GPS coordinates during attendance marking to ensure employees are at designated workplaces.

    4. Notifications

    • Permission: android.permission.POST_NOTIFICATIONS (Android 13+)
    • Purpose: Sending attendance confirmations, reminders, and important system alerts.

    5. Background Services & Alarms

    • Permissions:
    • android.permission.WAKE_LOCK
    • android.permission.RECEIVE_BOOT_COMPLETED
    • android.permission.VIBRATE
    • android.permission.USE_EXACT_ALARM
    • android.permission.SCHEDULE_EXACT_ALARM
    • Purpose: Ensuring notifications, reminders, and alarms work reliably even when the app is not actively in use.

    6. Battery Optimization Exception

    • Permission: android.permission.REQUEST_IGNORE_BATTERY_OPTIMIZATIONS
    • Purpose: Preventing the app from being stopped by device battery optimizations so that attendance and notifications function without interruption.

    7. Overlay Permission

    • Permission: android.permission.SYSTEM_ALERT_WINDOW
    • Purpose: Displaying critical alerts or important system-level information, used only when essential.

  • 10. COOKIES AND TRACKING TECHNOLOGIES

    For mobile applications, We may use similar technologies for the following purposes:

    • Session management and user authentication;
    • Performance monitoring and error tracking;
    • Usage analytics for app improvement;
    • Security monitoring and fraud detection;

  • 11. THIRD-PARTY INTEGRATIONS

    11.1 Government Services Integration

    The Mee Pramanam App may integrate with:

    • Aadhaar authentication services for identity verification;
    • Government employee databases for validation;
    • Payroll and HR management systems;
    • Other authorized government applications;

    11.2 Third-Party Privacy Policies

    When the app integrates with third-party services, their respective privacy policies will apply to data processed by those services. We are not responsible for the privacy practices of third-party service providers.

  • 12. LEGAL COMPLIANCE

    12.1 Applicable Laws

    This Privacy Policy and our data processing activities comply with:

    • Digital Personal Data Protection Act, 2023 (DPDP Act);
    • Information Technology Act, 2000 and associated rules;
    • Aadhaar Act, 2016 (where applicable);
    • Constitutional right to privacy as established in K.S. Puttaswamy v. Union of India;
    • Other applicable central and state laws;

    12.2 Regulatory Oversight

    Our biometric data processing activities are subject to oversight by:

    • Data Protection Board under the DPDP Act;
    • Appropriate government authorities;
    • Internal audit and compliance teams;
  • 13. DATA BREACH NOTIFICATION

    13.1 Breach Response

    In the event of a data breach involving your personal information, we will:

    • Take immediate steps to contain and assess the breach;
    • Notify the Data Protection Board within 72 hours where required;
    • Inform affected employees without undue delay if the breach poses a high risk;
    • Implement corrective measures to prevent future breaches;

    13.2 Employee Notification

    We will notify you of any data breach that may affect your personal information through:

    • Official email communication;
    • SMS notification to registered mobile numbers;
    • Notice through the Mee Pramanam App interface;
    • Other appropriate communication channels;

    14. UPDATES TO THIS POLICY

    We may update/modify this Privacy Policy at any time due to changes in the applicable laws and/or changes in Our company policies. Your continued use of the services and the Mee Pramanam App shall be deemed acceptance of the updated/modified Privacy Policy by You. We will notify employees of material changes through appropriate channels.

    15. CHILDREN'S DATA

    The Mee Pramanam App is designed for use by government employees who are adults. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected personal information from a minor, we will take steps to delete such information.

    16. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

    16.1 Grievance Officer

    Deputy Director (Technical), ESD shall be the grievance officer for the purposes of this Privacy Policy. All of the following may be addressed to the grievance officer at:

    Level Officer Contact Details
    Level 1 Customer Support Center Phone: 1100, 18004251110
    Level 2 Deputy Director (Technical), ESD Email: Dydir_tech_eseva@telangana.gov.in,
    8-2-566, Road no. 7 Banjara Hills
    Level 3 Commissioner, ESD Email: Dir_eseva@telangana.gov.in

    16.2 Account Deletion Request

    Employees may request deletion of their MeeMee Pramanam App account and associated personal data through the following link:

    Request Account Deletion

    16.3 Response Timeline

    We will acknowledge your grievance within 48 hours and provide a resolution within 30 days of receipt of your complaint. For complex issues requiring technical investigation, we may extend this timeline with appropriate notification.

    17. CONCLUSION

    The Mee Pramanam App represents our commitment to modernizing government employee attendance management while protecting your privacy rights. We are dedicated to processing your biometric data responsibly, transparently, and in full compliance with applicable laws.

    Your privacy is important to us, and we will continue to enhance our security measures and privacy practices as technology and regulations evolve. If you have any questions about this Privacy Policy or our data practices, please contact us using the information provided above.