Draft for legal review. This text has not yet been approved. Code Genie Technologies Private Limited will replace this draft before accounts can be created by the public.
Last updated: [date of approval]
This notice explains how Code Genie Technologies Private Limited ("Code Genie", "we", "us") handles personal data in CodeHR, our app for employee records, leave and attendance at https://hr.codegenie.co.in. It sets out what we collect and why, and your rights under the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the Digital Personal Data Protection Rules, 2025. Please read it with our Terms of service.
You can ask for this notice in English or in any language listed in the Eighth Schedule to the Constitution of India by writing to [grievance email].
The short version
- We collect only what we need to run your account and keep it safe.
- Your employer decides what is kept about you as an employee. We keep it for them, and use it for nothing else.
- We do not store Aadhaar numbers, fingerprints or face images. PAN and bank account numbers are encrypted.
- We do not sell personal data, show advertising, or use advertising or analytics cookies.
- CodeHR's server, database, files and backups are in Mumbai, India.
- You can ask to see, correct or erase your data, and complain to us and then to the Data Protection Board of India.
Who is responsible for your data
Data about you as an account holder: Code Genie decides
When you create an account and use CodeHR, we decide why and how your account data is used: your name, email address, password and sign-in. For that data, Code Genie is the Data Fiduciary under the DPDP Act. Most of this notice is about that data.
Data a business keeps about its employees: the business decides
Businesses use CodeHR to keep records of their employees, such as names, contact details, dates of birth, job details, PAN, bank accounts, documents, leave and attendance. The business decides why and how it uses those records, so the business is the Data Fiduciary for them. Code Genie processes them only on the business's behalf, as its Data Processor.
If you are an employee of a business that uses CodeHR and want to see, correct or erase your records, please contact that business. Where your business has given you access, you can also see and download your own records in CodeHR. If you write to us instead, we will pass your request on where we can identify the business.
What we collect and why
We collect the following personal data about you as an account holder, and use each item only for the purposes listed.
| Personal data | What we use it for | How long we keep it |
|---|---|---|
| Your name and email address | To create your account, sign you in, send you service emails, and show the people in your businesses who you are | While your account exists |
| Your password, if you choose one | To sign you in. We store only a bcrypt hash of it, so nobody at Code Genie can read it | While your account exists |
| If you continue with Google: your Google account ID, and the name and email address Google shares | To connect your Google account to your CodeHR account and sign you in with it | While your account exists, or until you ask us to disconnect it |
| Your sign-in session | To keep you signed in, using one essential cookie | Until you sign out, or 30 days after your last visit |
| The IP address and email address used to sign up, sign in or reset a password | To limit repeated attempts and protect accounts from abuse | A short time, usually about two days |
| A record of the changes you make in a business (its audit log) | To show the business's owners who changed what and when | While the business exists |
| When you accepted the Terms of service and this notice, and which version | To show what you agreed to | While your account exists, and [period] after it closes |
| Messages you send us | To answer you | [period] |
We process this data on the basis of the consent you give when you create your account. We may also process it without consent where the DPDP Act allows, for example to comply with a law or a court order.
Business data. Each business also enters its own records: its profile (legal and trade name, address, state, PAN and logo), its locations and departments, and its employees' records, documents, leave and attendance. We use business data only to provide CodeHR to that business.
Attendance devices. A business may upload the files its attendance devices export. CodeHR reads only each punch's device ID, date, time and direction. Fingerprints and face images stay on the device and never reach CodeHR.
Emails. We send only service emails: to verify your email address, reset your password, tell you about requests waiting for you, and give notices about your account or our terms. We will not send you marketing emails unless you separately agree.
Cookies
CodeHR uses only essential cookies:
codehr_sessionkeeps you signed in, for up to 30 days after your last visit.- If you continue with Google,
codehr_googleandcodehr_google_promptprotect the sign-in from forgery for up to 10 minutes, andcodehr_google_sign_upremembers a sign-up in progress for up to an hour.
We do not use advertising or analytics cookies, or any other trackers.
Where your data is stored
CodeHR runs on Amazon Web Services (AWS) in Mumbai, India (the ap-south-1 region). The application server (Amazon Lightsail), the database and uploaded files (Amazon S3) are there. Encrypted backups are made every night and stored in Amazon S3, also in Mumbai.
The exceptions are the bot check and Google sign-in described below, which Cloudflare and Google may carry out outside India. The DPDP Act allows personal data to be processed outside India, except in countries the Government of India restricts.
Who we share it with
We do not sell personal data. We share it only with the service providers that help us run CodeHR:
- Amazon Web Services: hosts the app, database, files and backups, and sends our emails through Amazon Simple Email Service (SES), all in Mumbai.
- Google: if you press Continue with Google, you sign in on Google's own page; if your browser is signed in to Google, the sign-in page may instead offer your Google accounts in the browser's own prompt. Either way, Google tells us your name, email address and Google account ID. We ask Google for nothing else. Google's privacy policy covers what Google does with your Google account.
- Cloudflare: runs the Turnstile bot check on the sign-up and forgot-password forms. It processes signals from your browser and device to tell people from bots, and may do so outside India. We receive only the result of the check.
Other people in a business you belong to can see who you are and, depending on their role, the changes you have made there. An employee's records are open only to the business's owners and HR, to the employee, and, for leave and attendance, to the people the employee reports to. We may also disclose personal data where the law requires it, such as under a court order.
How we protect it
- Traffic to and from CodeHR is encrypted in transit (TLS), and backups are encrypted.
- Passwords are stored only as bcrypt hashes.
- PAN and bank account numbers are encrypted by the app before they are stored, and shown masked except to those who need them.
- Each business's data is kept apart in the database by row-level security.
- Sign-up, sign-in and password-reset attempts are rate-limited.
- CodeHR support (our platform administrators) can see a business's profile, its people and the number of its employees, and can switch a business off. They cannot see employees' records through the app, and they cannot sign in with Google.
- A small number of Code Genie engineers can access the database directly, only when needed to run and fix the service.
If a personal data breach affects you, we will tell you and the Data Protection Board of India, as the law requires.
How long we keep it
- Your account data: while your account exists. If you ask us to close your account, we delete or anonymise it within [number] days.
- Business records: while the business exists. If an owner asks us to delete a business, we delete or anonymise its data within [number] days.
- Employees who have left: the business keeps their records for the periods labour and tax laws require, then CodeHR erases them. [Retention periods to be set before payroll.]
- When you leave a business: records you created there, and audit log entries showing your changes, are part of that business's records. They stay with the business, with your name, after you leave or close your account.
- Backups: kept for 7 days on the server, and in Amazon S3 as 30 daily and 12 monthly copies. Deleted data can stay in backups for up to about 12 months before the last copy ages out. We use backups only to recover from failures or mistakes.
We keep data longer only where the law requires it. For example, the DPDP Rules, 2025 require certain logs of processing to be kept for at least one year.
Your rights
Under the DPDP Act, you have the right to:
- Access: get a summary of the personal data we process about you, what we do with it, and who we have shared it with.
- Correction and completion: have inaccurate or incomplete data corrected, completed or updated.
- Erasure: have your personal data erased once it is no longer needed, unless the law requires us to keep it.
- Grievance redressal: complain to us and get a response.
- Nomination: name someone to exercise your rights for you if you die or become unable to act.
- Withdraw consent: at any time, as easily as you gave it, by writing to [grievance email]. This does not affect what we did before. We need your account data to provide CodeHR, so withdrawing consent means closing your account.
For your records as an employee, make these requests to your employer, who decides what is kept.
How to make a request
Email [grievance email] from the address on your account and tell us what you would like. We may ask you to confirm your identity first. We will reply within [number] days.
Complaints
If you are unhappy with how we handle your personal data, contact our Grievance Officer (see Contact us). We will respond within [number] days, and in any case within the 90 days the DPDP Rules, 2025 allow. If you are not satisfied, you can then complain to the Data Protection Board of India.
Children
You must be 18 or older to create an account. We do not knowingly collect personal data about children as account holders. A business may record an employee's family members, such as a child named as a nominee, as its own records; it is responsible for that data.
Changes to this notice
If we change this notice in a way that matters, we will tell you in the app or by email before the change takes effect, and ask for your consent again where the law requires. The date at the top shows when it last changed.
Contact us
- Grievance Officer: [grievance officer name]
- Email: [grievance email]
- Company: Code Genie Technologies Private Limited, [registered office address]
- CIN: [CIN]
- General support: [support email]