Privacy Policy
Last updated: [DATE OF PUBLICATION]
1. Who we are
The Face Attendance System (the "Service") is operated by [REGISTERED LEGAL NAME OF COMPANY], [REGISTERED ADDRESS] ("we", "us"). The Service lets schools mark student attendance using face recognition on a browser camera, restrict attendance to the school campus using device location, and manage student fees.
2. Schools and our role
Each school that uses the Service decides which students to register and what data to enter. The school is responsible for that data and for having a lawful basis to collect it, including any consent required from parents or guardians. Under India's Digital Personal Data Protection Act, 2023, the school acts as the Data Fiduciary for student data, and we process that data on the school's behalf.
If you are a student, parent or guardian and have a question about your data, please contact your school first. You can also contact us using the details in section 13.
3. What we collect and where it is stored
The Service is designed so that most student data stays with the school: in the browser on the school's own devices and in the school's own Google Drive. Some data is stored on our servers, as listed below.
| Data | Where it is stored | Why |
|---|---|---|
| School account: Google account email address, school name, username, password, registration status and dates, student limit, number of registered students | Our server | To verify the school, approve or suspend its account, enforce the student limit, and let staff sign in |
| Student details: name, class, section, roll number, registration date | Browser storage on school devices and the school's Google Drive | To identify students and record their attendance |
| Student face photos uploaded or taken with the camera during registration | The school's Google Drive | To create and later rebuild the face recognition template |
| Face recognition templates (a list of numbers calculated from the photos) | Browser storage on school devices and the school's Google Drive | To recognise a student in front of the camera |
| Attendance records: who was marked present, date and time | Browser storage on school devices and the school's Google Drive | Attendance registers and reports |
| Campus locations set by the school: name, address, coordinates, allowed radius | Our server | To check that attendance is marked on campus |
| Blocked attendance attempts: student name, class, section, roll number, location description, distance from campus, reason | Our server (only the most recent 1,000 entries are kept) | So school administrators can review attempts made outside the campus |
| Fee data: fee structures, concessions, payments, receipts, dues, contact details entered by the school, and an audit log of changes | Our server | To calculate dues, record payments and produce fee reports |
We do not sell personal data. We do not use student data for advertising.
4. Face recognition data
When a school registers a student, staff upload several photos of the student or take them with the device camera. The software, running in the browser, calculates a face recognition template from those photos. During attendance, the camera image is compared with these templates in the browser. Camera frames used for recognition are not uploaded to our servers.
Registration photos are uploaded to the school's own Google Drive, not to our servers. Face templates are stored in the browser on school devices and backed up to the school's Google Drive.
Face recognition can make mistakes. Schools should review attendance records and correct errors.
5. Location data
If the school turns on location verification, the device marking attendance reads its location (GPS or network location) when attendance is marked. The software compares this location with the campus locations the school has set. To turn coordinates into a readable address, the device may send coordinates to a map service listed in section 7.
We do not track students continuously. Location is read only from the school's attendance device, and only when attendance is being marked or a campus location is being set up. When an attempt is blocked for being outside the campus, a log entry is stored as described in section 3.
6. Children's data
Most students are under 18. The school must obtain verifiable consent from a parent or guardian before registering a child's face or other personal data, as required by applicable law. We rely on the school to do this. If a parent or guardian withdraws consent, the school should delete the student from the Service.
[LEGAL REVIEW: confirm parental consent wording and process under the DPDP Act, 2023 and its Rules.]
7. Third-party services
The Service relies on the following providers. Each handles data under its own privacy policy.
- Google: Google sign-in to verify the school's account, Google Drive to store the school's student data, photos and backups, and Google Sheets if the school chooses to connect one.
- Map and address services: Geoapify, Photon (Komoot), Nominatim (OpenStreetMap) and OpenRouteService may receive coordinates in order to look up addresses, nearby schools or walking distance.
- Content delivery networks: software libraries and fonts are loaded from jsDelivr, cdnjs (Cloudflare) and Google Fonts. These services receive your IP address and browser details when the app loads.
- Hosting: our servers are hosted by [HOSTING PROVIDER AND COUNTRY].
8. Cookies and browser storage
We use a session cookie to keep staff signed in. The app stores student, attendance and settings data in the browser (IndexedDB and local storage) so it can work offline. We do not use advertising or tracking cookies.
Clearing the browser's site data removes the local copy. The school can restore it from its Google Drive backup.
9. How long we keep data
- Data in the school's Google Drive and browsers stays under the school's control until the school deletes it.
- Blocked attendance logs: only the most recent 1,000 entries are kept. Older entries are deleted automatically.
- School account and fee data on our servers: [RETENTION PERIOD, e.g. kept while the account is active and deleted within N days of a written request or account closure, subject to legal record-keeping duties].
10. Security
We use access controls, separate logins for the fees section, and an audit log of fee changes. No system is completely secure, and we cannot guarantee that data will never be accessed without permission. If we become aware of a personal data breach affecting our servers, we will notify affected schools and the authorities as required by law.
Schools are responsible for securing their own devices and Google accounts.
11. Your rights
Depending on applicable law, you may have the right to access, correct or erase your personal data, to withdraw consent, and to raise a grievance. Because the school controls student data, requests about students are best sent to the school, which can update or delete records directly. We will help schools respond to these requests.
12. Changes to this policy
We may update this policy when the Service changes. We will change the date at the top of this page and, for significant changes, notify school administrators before the change takes effect.
13. Contact and grievances
Grievance Officer: [NAME]
Email: [EMAIL ADDRESS]
Address: [POSTAL ADDRESS]
We aim to respond within [NUMBER] days.