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Privacy Policy Agreement

Last Updated: 31 October 2026


1. Introduction

AiroHR Technologies Private Limited (“we,” “us,” or “our”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our software applications.

We process personal data on the basis of consent where the law requires it (for example face attendance or WhatsApp messages), or for legitimate uses permitted under the Digital Personal Data Protection Act, 2023, such as employment and legal obligations.

Who is responsible for your data. When a company uses AiroHR to manage its employees, that company (the employer) decides why and how employee data is processed and is the Data Fiduciary for that data. AiroHR processes it on the employer’s behalf as a data processor. For information you give us directly — for example a demo request, a signup or contact form, or your account as a customer’s administrator — AiroHR Technologies Private Limited is the Data Fiduciary.

2. Data We Collect

We may collect information in several ways:

  • Personal Data: Name, email address, phone number, and professional details provided during registration.
  • Employee Data: Attendance logs, salary structures, and KYC documents uploaded by employers/employees.
  • Device Information: IP address, browser type, and location data (if GPS attendance is enabled).
  • Attendance Selfie Photos: if your employer uses selfie attendance, one photo taken when you tap Punch In or Punch Out in the AiroHR app, kept with that attendance record.
  • Selfie Face Verification Data: if your employer uses Selfie + Location attendance, a face template and one face photo you register in the AiroHR app with your consent, and a face template made from each punch selfie so it can be compared with the registered one (see section 10).
  • Face Attendance Data (Airo Lens): if your employer uses the Airo Lens kiosk, a face template and one face photo captured at enrolment (see section 10).

3. How We Use Data

Your information allows us to provide a seamless HR experience, including:

  • Calculating accurate payroll and attendance.
  • Generating statutory compliance reports (PF/ESI).
  • Sending automated notifications and payslips.
  • Improving our software performance and security.

4. Data Security

We implement industry-standard security measures, including SSL encryption and secure cloud storage, to protect your data from unauthorized access, alteration, or disclosure. However, no method of transmission over the internet is 100% secure.

5. Data Sharing

We do not sell your personal data, and we do not share it for advertising. We may share information with:

  • Service providers who run AiroHR for us, only for that purpose: cloud hosting; email delivery (Amazon Web Services – Amazon SES); SMS and WhatsApp messaging providers (including Gupshup, and Meta Platforms for WhatsApp); push notifications (Google Firebase Cloud Messaging); payment gateways for subscription payments; and, where your employer enables the optional AI letter-drafting assistant, an AI service provider that receives the letter text to draft it. We require each of them to protect personal data.
  • Salary payouts go only through the customer’s own payout account (for example Cashfree Payouts) when the customer enables it.
  • Government authorities (when required for statutory filings). EPFO, ESIC, the Income Tax Department and state PT portals receive data only when the customer uploads the files AiroHR prepares.
  • Legal entities (if required by law).

Where data is stored. Your data is stored on secure servers operated by our hosting provider. If any data is stored or processed outside India, we do so only as permitted under Indian law.

6. Cookies

Our website and apps use essential cookies — for your login session and for security (such as protection against forged requests). We do not use advertising cookies or third-party analytics. On our public website, one first-party cookie (airohr_ft, kept for 90 days) notes how you first reached us: the website or search engine you came from, the first page you saw and any campaign tag in the link. It stays in your browser unless you send us an enquiry, download from a free tool or sign up for alerts. It is then saved with that request, so we can see which pages help people. You can disable cookies through your browser settings, but you will then not be able to log in.

7. Data Retention

We retain your information for as long as your account is active or as needed to provide you services and comply with legal obligations.

  • Customer account and employee records: kept while the customer’s subscription is active. After it ends, the customer can ask us for an export; the workspace data is then deleted or anonymised, except records we must keep by law.
  • Payroll, PF/ESI, TDS and wage records: kept for the periods that the law requires the employer to keep them, or as the customer instructs.
  • Demo and signup enquiries: kept only as long as needed to respond to and follow up on the enquiry.
  • Attendance selfie photos: kept with the attendance record they belong to while your employer’s subscription is active, and deleted with the workspace data when it ends. You can ask your employer’s HR team or admin@airohr.com to delete them sooner.
  • Face data (selfie face verification and Airo Lens): as described in section 10.

8. Your Rights

Users have the right to access, correct, or request the deletion of their personal data. Employers are responsible for the data of their respective employees as the primary data controllers.

You can ask to access, correct, update or delete your personal data, and withdraw consent you have given (for example for face attendance or WhatsApp messages), by contacting your employer’s HR team or our Grievance Officer (section 13). Withdrawing consent does not affect processing already done, or processing the law requires (for example statutory payroll records). You may nominate another person to exercise your rights if you die or become incapacitated. If you are not satisfied with our response, you can complain to the Data Protection Board of India.

Deleting your account or data: see Delete your account or data for how to ask, what is deleted and what the law requires us to keep.

9. Mobile App Permissions

The AiroHR apps (Android, and iOS where available) request the following device permissions. Each is used only for the purpose stated and never for advertising, profiling, or background tracking.

  • Camera. Used only when you tap a photo upload field (profile photo, KYC document), register your face photo, or tap Punch In / Punch Out when your employer uses selfie attendance. Photos are never accessed in the background.
  • Face ID (iOS). Optional app unlock. The face check is done entirely by Apple’s Face ID on your iPhone or iPad. The app receives only “unlocked” or “not unlocked”. No face data ever reaches the app or our servers.
  • Storage. Used to save documents you download (payslips, reports) to your device’s public Download/AiroHR folder. On Android 10 and above no storage permission is required.
  • Notifications. Used to alert you about leave approvals, attendance reminders, and other workflow events. You can disable notifications in Android settings without affecting other app functionality.
  • Location. Captured only at the moment of an attendance punch when your employer has enabled geofencing. No continuous or background location tracking.
  • Internet. Required to communicate with airohr.com servers.

Face data in the AiroHR apps. The AiroHR employee app uses face data only when your employer puts you on Selfie + Location attendance: you register a face photo once, with your consent, and each Punch In / Punch Out selfie is checked against it so nobody else can punch with your login. How this works, what is stored and how to delete it is explained in section 10 (“Selfie face verification”). For every other attendance mode the app makes no face data: the punch selfie, if any, is an ordinary photo stored with that attendance record. The AiroHR HR manager app collects no face data; it only displays attendance records, including the face photo and match result of a punch, to authorised HR administrators.

The apps do not keep your data on the device beyond your sign-in session. What you enter or capture in them (details, photos, punch location, and face data for selfie face verification) is sent securely to your employer’s AiroHR account and handled as described in sections 2–8 and 10.

10. Face Data & Biometric Information

AiroHR uses face data in two features, each only when your employer turns it on: selfie face verification in the AiroHR employee app, and the Airo Lens kiosk.

Selfie face verification (AiroHR employee app)

When your employer puts you on Selfie + Location attendance, each punch selfie is checked against a face photo you registered, so that only you can punch with your login.

  • Explicit consent first. Before your first selfie punch the app shows the “Register Face Photo” screen, explains how your face data is used and asks you to tick “I agree”. Nothing is saved without it. We record the consent version, time and IP address.
  • What is made and stored. At registration the app takes a live photo with the front camera (gallery images cannot be used) and converts your face into a face template: a list of 128 numbers that describes your face. The template is stored encrypted on our servers together with that one face photo. Your employer’s HR administrator checks the photo once and approves it; once approved it also becomes your employee profile photo (unless you use Airo Lens, whose photo stays your profile photo).
  • At each selfie punch. The app makes a face template from the punch selfie and sends it with the photo over an encrypted (HTTPS) connection. Our server compares it with your registered template and records the match score with that attendance record. If the face does not match, the punch is not saved. The registered template never leaves our servers.
  • Live-person check. When you register, the app asks you to turn your head to one side and then the other, so that a photo or screen held up to the camera cannot be registered as your face. It does this on your phone by following points on your face (such as the nose and jaw line) during the check; these points are not stored. Only the result of the check and two numbers measuring how far you turned are sent; our server checks them and does not keep them. Selfie punches do not include this check: you only look at the camera. Punch records from before 30 October 2026 still hold those two numbers.
  • Who can see it. Only you and your employer’s authorised HR administrators can see your face photo, punch selfies and match scores. The face template itself is not shown to anyone.
  • Purpose limitation. Used only to verify it is you who punches and to prevent proxy (“buddy”) punching. Never used for advertising, profiling, surveillance or any other purpose, and never sold or shared with third parties.
  • Withdrawal & erasure. You can withdraw consent at any time on the Register Face Photo screen (“Withdraw consent and delete my face data”), which deletes your face template immediately; selfie punches then need a new registration or another attendance mode from your employer. A template is also deleted when HR rejects or resets your face photo, and with the rest of your employer’s workspace data when its subscription ends. You can also ask your employer’s HR team or admin@airohr.com to delete it.
  • Your rights (DPDP Act 2023). You may access, correct, or request deletion of your face data, and raise a grievance with our Grievance Officer in section 13.

Airo Lens kiosk

When your employer enables Airo Lens, your attendance can be marked by face recognition on your employer’s Airo Lens kiosk (an Android tablet installed at the workplace). This section explains exactly how that face data is handled.

  • Explicit consent first. Enrolment is done on the kiosk by your employer’s administrator. Your face data is saved only after the consent notice is shown on the kiosk and “I agree” is tapped. You can withdraw consent at any time by asking your employer’s HR team or emailing admin@airohr.com.
  • What is stored. At enrolment the kiosk converts your face into a mathematical template (a numeric “embedding”) used only to verify it is you. The kiosk also uploads one face photo captured at enrolment, which is saved as your employee profile photo so HR can recognise your record. Each re-enrolment replaces that photo.
  • Where matching happens. Face matching runs on your employer’s Airo Lens kiosk, not on your personal phone.
  • Purpose limitation. Face data is used only to mark your attendance and to prevent proxy (“buddy”) punching, and the enrolment photo only as your profile photo. It is never used for advertising, profiling, surveillance, or any other purpose.
  • Liveness / anti-spoofing. When your employer turns on liveness detection, the kiosk checks for a real, live person (for example a blink) before marking attendance.
  • Security. Your face template is encrypted in transit and at rest on our servers, stored only against your employee record, and enrolment and deletion actions are logged.
  • No sharing or sale. Face templates and photos are never sold or shared with third parties or advertisers.
  • Retention & erasure. There is no self-service “delete my face data” option in the app. To delete your face data, ask your employer’s HR administrator (who can delete your face enrolment from the kiosk) or email admin@airohr.com. We delete your face template when you withdraw consent. It should be kept only while it is needed for attendance, so when you leave the organisation your employer can delete your enrolment from the kiosk, or you can ask for it. If you also want your profile photo removed, say so in your request.
  • Your rights (DPDP Act 2023). You may access, correct, or request deletion of your face data, and raise a grievance with our Grievance Officer in section 13.

The kiosk camera is used only for enrolment and when attendance is marked at the kiosk.

Compliance alert emails

If you sign up for compliance alerts on our website, we keep your email address, company name if you give it, and the time and IP address of your sign-up and confirmation as a record of your consent. AiroHR Technologies Private Limited is the Data Fiduciary for this data. We use it only to send these alerts. We send nothing until you confirm by email, and each email has an unsubscribe link. After you unsubscribe we keep your address marked as unsubscribed, so that you are not emailed again. To have it deleted, email admin@airohr.com.

AI HR assistant on WhatsApp

If your employer turns this on and you message AiroHR’s WhatsApp number, questions the simple commands cannot answer are sent to our AI provider, Anthropic, to create a reply. So are the HR details needed to answer, such as your leave, attendance, pay and job details. Your bank details, PAN and Aadhaar are not sent. We keep your messages and the replies in our logs, as with other WhatsApp messages. Your employer is the Data Fiduciary for this data. AI replies can be wrong, so check anything important with HR. Send stop to mute the assistant.

AI Agent for HR teams

If your employer turns this on, HR users can ask an AI agent to look up staff information, prepare reports and letters, and propose changes. Their requests, and the HR details needed to carry them out, go to our AI provider, Anthropic. These can include staff names, job details, leave, attendance, requests, pay and the reasons staff give in requests. Bank details, PAN, Aadhaar, UAN, phone numbers and personal email are not sent. An HR user must approve every change. The chats are stored encrypted and are deleted after 30 days without use. Your employer is the Data Fiduciary for this data.

11. Children

AiroHR is a workplace tool and is not meant for children under 18. We do not knowingly collect children’s data, except where an employer records a dependant’s or nominee’s details (for example for ESI or PF nomination) in the course of employment.

12. Changes to this Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top shows when it was last changed.

13. Grievance Officer and Contact

If you have a question, complaint or request about your personal data, including access, correction, deletion or withdrawing consent, contact our Grievance Officer. We acknowledge complaints within 24 hours and resolve them within 15 days. If you are an employee of one of our customers, you can also contact your employer’s HR team, because your employer decides how your employment data is used. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

For any other question about this Privacy Policy, please contact us:

AiroHR Technologies Private Limited

admin@airohr.com

+91 63634 63737

First Floor, No 02, Basaveshwara Complex, 40 Feet Road, Srinivasa Nagar, Sunkadakatte, Bengaluru, Karnataka 560091