Legal • Privacy Policy

Privacy Policy

This Privacy Policy explains how MetaGuard Mobitech Pvt. Ltd. and MemoFaceAI collect, use, store, share and protect personal data, including sensitive and biometric information.

Version 3.1 Last Updated: 11 March 2026 Effective From: 01 April 2026 India · MENA

This policy explains how MetaGuard Mobitech Pvt. Ltd. ("MetaGuard", "we", "us", or "our") and MemoFaceAI collect, use, store and protect personal information, including sensitive personal data and biometric data, across our products and services.

In most deployments, MemoFaceAI acts as a data processor on behalf of the customer organisation, which acts as the data controller. The employer or institution determines the purposes for which employee or student data is used.

Important distinction
MetaGuard processes customer-controlled data only on the customer's instructions and in accordance with the applicable Data Processing Agreement (DPA).
01

Introduction

MetaGuard Mobitech Pvt. Ltd. ("MetaGuard", "we", "us", or "our") operates the MemoFaceAI platform, including the web application, Android and iOS/iPad applications, on-premise hardware integrations, APIs and associated services.

This Privacy Policy describes how we collect, use, disclose and safeguard personal information when you or your organisation uses our Services.

The policy applies to:

  • Employees and workers whose attendance is recorded by MemoFaceAI on behalf of an employer.
  • Administrators, HR managers and authorised personnel who access the MemoFaceAI dashboard.
  • Students, faculty and institutional staff using MemoFaceAI in educational settings.
  • Visitors to our website and individuals who contact us for sales or support.

Please read this policy carefully. If you do not agree with our practices, discontinue use of the Services and contact your employer or institution to understand their applicable data practices.

02

Who We Are

MetaGuard Mobitech Pvt. Ltd. is a company incorporated under the Companies Act, 2013 in India, with its registered office in Gurgaon, Haryana. MemoFaceAI is our AI-powered workforce intelligence product.

Company MetaGuard Mobitech Pvt. Ltd.
Product MemoFaceAI
Registered Office Gurgaon, Haryana, India
CIN Available on request
Data Controller Contact privacy@metaguard.in
DPO Loveneesh Bansal — loveneesh@metaguard.in
03

Data We Collect

We collect different categories of personal data depending on the individual's role and the Services being used.

3.1 Data provided by customer organisations

  • Full name, employee or student ID, department and designation.
  • Contact details including email address and mobile number.
  • Employment or enrolment status, shift assignments and leave records.
  • Payroll-relevant information such as working hours, overtime and deductions.

3.2 Data collected automatically

  • Attendance records, including check-in and check-out timestamps.
  • Approximate GPS coordinates when mobile check-in or geo-fencing features are enabled.
  • Device model, operating system version and application version.
  • Server logs, IP addresses, access timestamps and API usage information.

3.3 Data collected from website visitors

  • Contact form submissions including name, email, company and message.
  • Demo booking information.
  • Newsletter subscription information.
  • Analytics information collected through cookies.
We do not sell personal data.
MemoFaceAI does not sell personal data of employees, students or end users to third parties for advertising, profiling or unrelated commercial purposes.
04

Biometric Data — Special Category

Biometric data requires additional protection.
Facial recognition templates and liveness-detection data are treated as sensitive personal data and are protected using additional safeguards.

What biometric data we collect

  • Facial geometry templates: Mathematical representations of unique geometric facial features generated from an enrolment photograph or video frame.
  • Liveness signals: Infrared or depth signals used to distinguish a live person from a photograph or mask.

How biometric data is stored

  • Facial templates are stored as encrypted mathematical vectors rather than photographs.
  • Templates cannot be used to reconstruct a recognisable image of the individual.
  • Data is encrypted at rest using AES-256 and in transit using TLS 1.3.
  • In on-premise deployments, biometric templates remain on the customer's hardware.
  • Cloud-hosted templates are stored in isolated, access-controlled storage.

Consent for biometric data

Under India's Digital Personal Data Protection Act, 2023 (DPDPA) and applicable regulations, the data controller is responsible for obtaining appropriate informed consent before biometric enrolment where required by law.

Biometric data retention

Biometric templates are deleted within 30 days of termination of a customer's contract, or immediately upon a verified deletion request from the data controller. Templates for individuals who leave an organisation are deleted within 7 days of de-enrolment unless the customer organisation is legally required to retain them.

05

How We Use Personal Data

Purpose Data Used Legal Basis
Attendance verification and recording Biometric template, timestamp, device data Contract / Legitimate interest
Payroll processing and HRMS sync Attendance records, working hours, OT data Contract
Workforce analytics and reporting Aggregated attendance data Legitimate interest
Compliance reporting Attendance records, shift logs Legal obligation
Security and fraud prevention Liveness data, IP logs, access logs Legitimate interest
Product improvement De-identified usage data and model performance metrics Legitimate interest
Customer support and onboarding Contact details, support ticket content Contract
Marketing communications Email address, name, industry Consent

We do not use biometric data to train general-purpose AI models or for purposes beyond the attendance, security and compliance functions described in this policy.

07

Data Sharing and Disclosure

We do not share personal data with third parties except where necessary for the circumstances described below.

7.1 With your employer or institution

Attendance records, reports and analytics are shared with the customer organisation as the primary purpose of the Services. The organisation controls what authorised users can access.

7.2 With integrated HRMS and payroll providers

Where enabled by the customer organisation, attendance data may be transmitted to integrated systems such as GreytHR, Keka, Zoho People, SAP HCM, Darwinbox and BambooHR.

7.3 With sub-processors and infrastructure providers

  • Cloud infrastructure, servers, databases and storage.
  • Email delivery and notification services.
  • Analytics and monitoring tools using anonymised or aggregated information.
  • Security and DDoS protection services.

A full list of sub-processors is available on request at privacy@metaguard.in .

7.4 Legal requirements

Personal data may be disclosed where required by law, court order or government authority.

7.5 Business transfers

In the event of a merger, acquisition or sale of substantially all assets, personal data may be transferred as part of that transaction, subject to applicable requirements.

08

Data Retention

Data Type Retention Period Basis
Biometric templates Until de-enrolment or contract termination + 30 days DPDPA / Contractual
Attendance records As configured by customer; default 5 years Labour law compliance
Payroll-sync logs 7 years Legal obligation
Access and security logs 12 months rolling Security / Legitimate interest
Support tickets 3 years from resolution Contractual
Marketing contacts Until unsubscribe or 3 years of inactivity Consent
Website analytics 26 months, anonymised Legitimate interest

Where a customer deletes an account or terminates a contract, personal data is deleted within 30 days unless applicable law requires longer retention.

09

Security Measures

We implement technical and organisational security measures appropriate to the sensitivity of the data processed.

  • Encryption at rest: AES-256 encryption.
  • Encryption in transit: TLS 1.3.
  • Access control: Role-based access control and least-privilege principles.
  • Network security: Firewall, intrusion detection and DDoS protection.
  • Vulnerability management: Regular security assessments and penetration testing.
  • Incident response: Documented incident response procedures.
  • Staff training: Mandatory data protection and security training.
Security vulnerability reporting
To report a security vulnerability or suspected data breach, contact: security@metaguard.in
10

Your Data Rights

Subject to applicable law and MetaGuard's role as data processor or controller, individuals may have rights regarding their personal data.

👁

Right of Access

Request a copy of personal data held about you, including the existence of biometric templates.

✎

Right to Rectification

Request correction of inaccurate personal information.

⌫

Right to Erasure

Request deletion of personal data, subject to applicable legal retention requirements.

⊘

Right to Object

Object to processing based on legitimate interests where applicable.

⇩

Right to Portability

Request attendance records in a structured, machine-readable format where available.

Ⅱ

Right to Restrict Processing

Request restriction of processing while a complaint or correction request is assessed.

Because MemoFaceAI typically acts as a data processor for an employer or institution, employment-related attendance requests should generally first be directed to the relevant HR department.

Requests concerning data collected directly by MetaGuard, such as website visitor information or marketing data, can be sent to privacy@metaguard.in .

11

Cookies and Tracking

The MemoFaceAI and MetaGuard websites use cookies and similar technologies. The MemoFaceAI application platform uses strictly necessary session cookies to maintain authenticated sessions.

Cookie Type Purpose Opt-Out?
Strictly necessary Session authentication, CSRF protection and load balancing No
Analytics Anonymised page views and navigation patterns Yes
Preferences Language, region and theme preferences Yes
Marketing No retargeting pixels or advertising cookies N/A

Cookie preferences can be managed through the website cookie settings or through browser settings.

12

Children's Privacy

MemoFaceAI may be used in school and educational environments where individuals under 18 may be enrolled.

  • The educational institution acts as the data controller and is responsible for obtaining appropriate parental or guardian consent where required.
  • Student data receives the protections described in this policy and additional restrictions.
  • Student data is not used for commercial purposes.
  • Parents or guardians may request access, correction or deletion of their child's data through the relevant school or institution.
  • MetaGuard does not knowingly collect personal data from children under 13 through direct-to-consumer website channels.
13

International Data Transfers

MetaGuard's primary data infrastructure is hosted in India. For customers in the MENA region, data may be hosted in regional cloud infrastructure to support data residency requirements.

Where personal data is transferred internationally, appropriate safeguards may include:

  • Standard contractual clauses where required.
  • Adequacy decisions or equivalent safeguards.
  • Data Processing Agreements with applicable sub-processors.

Customers requiring specific data residency guarantees, including data that must remain within India, may opt for an on-premise deployment or discuss dedicated regional hosting arrangements.

14

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, legal requirements or industry practices.

For material changes, we may:

  • Update the "Last Updated" date.
  • Notify customer organisations by email where applicable.
  • Display a notice in the MemoFaceAI dashboard.
  • Seek renewed consent where required for changes involving biometric processing.

Previous versions of this policy may be requested by contacting privacy@metaguard.in .

15

Contact Us

If you have questions, concerns or requests regarding this Privacy Policy or our data practices, please contact us through the channels below.

Get in touch about privacy

Our Data Protection Officer is available for privacy enquiries, data rights requests and concerns about personal data processing.

Privacy enquiries privacy@metaguard.in
Security / breach reports security@metaguard.in
Data Protection Officer Loveneesh Bansal
Phone +91-85888 27540
Registered Address MetaGuard Mobitech Pvt. Ltd.
Gurgaon, Haryana, India