PRIVACY POLICY

This privacy policy (“Policy”) describes how Codebell Technologies Pvt. Ltd. (herein and after referred to as “microHR”, “We”, “us”, “our”) collects, uses, and shares personal information of users of our Application, “microHR” and our website hosted at www.microhr.co set up for our customers (together, the “Site”), as well as associated products and services, (together, the “Services”), and applies to information that we collect through our Site and Services as well as information you provide to us directly. This Policy also applies to any of our other websites that post this Policy.

At microHR, your privacy is always a priority. This Privacy Policy explains (i) what information we collect through your access and use of our Service (ii) the use we make of such information; and (iii) the security level we provide for protecting such information. This Privacy Policy also sets out without limitation, how microHR, collects and uses information from customers and other individuals who access or use our Services. By downloading our mobile application and/or using our Services, you understand that we will collect and use your information as described in this Privacy Policy and accept the practices outlined in this Privacy Policy.

This Privacy Policy (“Policy”) does not apply to any third-party websites and apps that you may use, including any that are linked to in our Services. You should review the terms and policies for third-party websites and apps before clicking on any links.

If you do not agree to this Policy, please do not use our Sites or applications or Services.

1. WHO ARE WE

Codebell Technologies Private Limited is an Indian Company registered under the Companies Act, 2013, providing automated attendance, tracking, payroll and compliance services to small and micro businesses through its application microhR,

The Company is domiciled in India at the following address:
Codebell Technologies Private Limited 34, 3rd Floor, Corner Market, Malviya Nagar, New Delhi 110017, India.

All data storage infrastructure is located solely within India, and thus governed by the laws and regulations of India.

2. DATA WE COLLECT

Our company’s overriding policy is to collect as little user information as possible to ensure a completely private user experience when using the Service. Our data collection is limited to the following:

a.

Account Creation:

Any user signing up for a User Account on microHR is requested for the following personal information:

  • Name
  • Mobile Number
  • Email id
  • Gender
  • Complete Residential Address
  • Precise gelocation

b.

Information We Get From Other Parties:

We may get information about you from other sources. We may add this to information we get from this Site and/or through our Services. For example, you may also be able to access your microHR account by signing on through various sites such as Google. Your participation with the services provided on these platforms is voluntary. If you choose to sign on using this service, microHR will collect certain information from your account including your public profile, user name, email address, birthday, stated location city, contact lists, and other interactions on that platform (such as interests and likes). The information we may have access to will vary by platform and is controlled by privacy settings on that platform and your choices on that platform. Your use of services on third party platforms are governed by the privacy statement and other terms of use for that third party platform, until such information is shared with us, and then such information is also subject to this Policy.

c.

Information collected when you visit our Sites or use our Applications:

We automatically log information about you and your computer, phone, tablet, or other devices you use to access the Site and/or Services. For example, when visiting our Site or when using microHR mobile applications, we log your computer or device identification, operating system type, network information, geo location, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site or in microHR mobile application including tracking of background location during the office hours as defined by the organization you are associated with. How much of this information we collect depends on the type and settings of the device you use to access the Site and/or Services.

d.

Information collected from you:

If you choose to interact on the Site and/or through the Services, microhR will collect the personal information that you provide such as ad preferences.

e.

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Sites, and other information regarding your interactions with our Sites. For detailed information about the use of cookies in the Sites, please read and review our Cookie Policy.

We partner with third parties to either display advertising on the Sites or to manage our advertising on other sites. Our third-party partners may also use technologies such as cookies to gather information about your activities on our Sites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here.

Web beacons, tags and scripts may be used on our Sites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Sites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use LSOs such as HTML5 to collect and store information.

f.

Logs and Analytics Information:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Sites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Sites and Services. In such a case, we would treat the combined information in accordance with this Policy.

3. WHY IS THIS DATA REQUIRED AND/OR PROCESSED AND LEGAL BASIS OF PROCESSING

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you. We use your personal information as follows:

a.

General Uses:

The Legal basis for collecting your information is that we use the information to provide the Services to you. We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at hello@microhr.co or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Sites, Applications and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Sites, Applications and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

As an example, we require background location information throughout the office hours as defined by the organization associated with your user account, in order to track presence within the office premises during office hours.

b.

For research and development:

We are always looking for ways to make our Services smarter, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services; to analyze and improve our Site and/or Services (including developing new products and services); improving safety; managing our communications; analyzing our products; performing market research; for peer-reviewed and non-peer-reviewed clinical research; and performing data analytics.

c.

Account Opening Related Data:

In order to maintain integrity of the Service, microHR must take measures to avoid creation of accounts by spammers. Each User Account is unique and associated with an individual. Therefore, a unique identifier is generated and associated with each user. Contact number is used to facilitate messaging service between one or more users of the service. The legal basis for processing is User Consent. You are free to delete your User Account and remove that data in the account panel of your microHR User account.

d.

Verification:

Such data will only be used to contact you with important notifications about microHR, to send you information related to security, to send you an invitation link to create your User Account, to verify your User Account, or to send you password recovery links if you enable the option. We may also inform you about new microHR features in which you might have an interest. You are free, at any given time, to opt-out of those features through the account settings panel. In order to pursue our legitimate interest of preventing the creation of accounts by spam bots or human spammers, microHR uses a variety of human verification methods. You may be asked to verify using either reCaptcha, Email, or SMS. IP addresses, email addresses, and phone numbers provided are saved temporarily in order to send you a verification code and to determine if you are a spammer.

e.

Unauthorized Login:

In order to detect unusual activity from your User Account, geolocation and IP addresses are used to ascertain only genuine users are using the services, and any suspicious activity is reported to the user. The legal basis for processing is our legitimate interest to prevent unauthorized use of Service and protection of user’s interest, thereby maintaining integrity of the Service. Any personal information, so collected, is stored in encrypted form on microHR’s servers.

f.

Communicating with Codebell:

Your communications with the Company, such as support requests, bug reports, or feature requests may be saved by our staff. The legal basis for processing is our legitimate interest to troubleshoot more efficiently and improve the quality of the microHR service.

g.

Payment Information:

The Company relies on third parties to process credit card, PayPal, and other payment gateways and hence the Company necessarily must share payment information with third parties. Further, payment information shall also be used for processing of salary payments subject to compliance with local KYC norms. The legal basis of this processing is the necessity to the execution of the contract between you and us.

h.

With your consent:

We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured client stories to promote the Services, BUT ONLY with your permission.

i.

To protect our legitimate business interests and legal rights:

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, accounting, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Please do note that microHR will take reasonable precautions to protect your information from loss, misuse or alteration. Please be aware, however, that any text, email or other transmission you send unencrypted through the Internet cannot be completely protected against unauthorized interception.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

4. DATA USE

Any data that we do have will never be shared except under the circumstances described below in the SHARING OF PERSONAL INFORMATION. All personal information collected from You is solely used for delivering, and improving the Service.

5. SHARING OF PERSONAL INFORMATION

a.

Personally Identifiable Information:

We will not rent or sell your personally identifiable information to others without your consent, although we may share it with partners for the purposes described above under “Use of Personal Information”, such as the provision and personalization of Services. Such third parties are not authorized to use or disclose your information except as necessary to perform Services or comply with legal requirements, and are subject to agreements requiring them to maintain the confidentiality of any such information.

We may share your information with outside vendors that we use for a variety of purposes, such as to send you communications via emails, send push notifications to your mobile device on our behalf, help us analyse use of our services. Some of our products, services and databases are hosted by third party hosting services providers.

Any personally identifiable information you elect to make publicly available on our Sites or through the Services will be available to others. If you remove information that you have made public on our Sites or through the Services, copies may remain viewable in cached and archived pages of our Sites or through the Services, or if other users have copied or saved that information.

b.

Non-Personally Identifiable Information:

We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help us understand the usage patterns for certain Services and those of our partners.

c.

Instances Where We Are Required To Share Your Information:

We will only disclose the limited user data we possess if we are instructed to do so by a fully binding request coming from the competent authorities (legal obligation). While we may comply with electronically delivered notices (see exceptions below), the disclosed data can only be used in court after we have received an original copy of the court order by registered post or in person, and provide a formal response.

microHR may from time to time, contest requests if there is a public interest in doing so. In such situations, the Company will not comply with the request until all legal or other remedies have been exhausted.

6. DATA STORAGE

All servers used in connection with the provisioning of the Service are located in India and are rented by the Company from third party service providers. Only employees of the Company have physical or other access to the servers. Data is ALWAYS stored in encrypted format on our servers. Offline backups may be stored periodically, but these are also encrypted. We do not possess the ability to access any user encrypted message content on either the production servers or in the backups.

We are committed to protecting your privacy and data. We encrypt sensitive information during transmission and storage. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you, other involved parties, and any applicable regulator(s) of a breach where we are legally required to do so.

7. DATA RETENTION

All personal information collected is retained till You delete your user account or withdraw consent on the mobile app. You must appreciate that You may not continue to use our services even when you withdraw consent for personal information related to visual characteristics.

The data records are deleted automatically once You request account deletion. However, deleted data may be retained in our backups for up to 14 days.

8. RIGHT TO ACCESS, RECTIFICATION, ERASURE, PORTABILITY, AND RIGHT TO LODGE A COMPLAINT

Through the Service, you can directly access, edit, delete or export personal data processed by the Company in your use of the Service. A user may access such information through the profile section in our website or the mobile app.

Alternatively, any user may write an email/post-mail to Data Protection Officer for microHR and request a copy of their personal information, as held by the Company, or request modification or deletion of their personal data.

Communication Details:

Codebell Data Controller and Data Protection Officer

Name: Vikram Mali

Email: hello@microhr.co

Address: 34, 3rd floor, Corner Market, Malviya Nagar, New Delhi-110017, India.

The Company, on receiving such request from a user, shall attend to the request made by the user and do the needful within 7 days from date of such request.

If your User Account has been suspended for a breach of our terms and conditions, and you would like to exercise the rights related to your personal information, you can make a request to our support team.

In case of violation of your rights, you have the right to lodge a complaint to the competent supervisory authority.

9. MODIFICATIONS TO PRIVACY POLICY

The Company reserves the right to periodically review and change this policy from time to time and we will notify users who have enabled the notification preference about changes to our Privacy Policy Your continued use of microHR’s services constitutes your agreement to this Privacy Policy and any future revisions. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the Privacy Policy in effect when we receive that personal information.

For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing revisions with respect to such information.

This policy is effective as of 01/12/2023.