Privacy Policy

Effective date: 10 October 2026 · imbeddeX Technologies Pvt. Ltd.

1. Who we are and what this policy covers

This Privacy Policy explains how imbeddeX Technologies Private Limited (“imbeddeX”, “we”, “us”), CIN U26204MH2024PTC429399, with its registered office at 147/292, Powai Chowk, Mulund Colony, Mulund (W), Mumbai – 400 082, India, collects, uses, shares and protects personal data in connection with:

• this website, imbeddex.com (the “Website”); and
• TAMS — True Attendance Management System, including the TAMS device, the TAMS Attendance App, the TAMS Teachers App, the TAMS Students App and the TAMS admin web panel (together, the “TAMS Services”).

We process personal data in accordance with the Information Technology Act, 2000 and the rules made under it, and the Digital Personal Data Protection Act, 2023 (“DPDP Act”), as applicable.

2. Our role and your institution’s role

TAMS is provided to educational institutions (“Institutions”). When you use TAMS as a student, teacher or staff member, your Institution decides what data is collected and why, and acts as the Data Fiduciary for that data. imbeddeX processes that data on behalf of, and on the instructions of, the Institution as its Data Processor, under our agreement with the Institution.

For the Website (for example, when you send us an enquiry), imbeddeX decides how your data is used and is the Data Fiduciary.

3. Information we collect

a) Through the TAMS Services

• Identity and academic details provided by the Institution: name, roll number, enrolment or employee number, class, course, subjects, academic year and a profile photo, where used.
• Contact details: email address and mobile number of the student, teacher and, where the Institution provides it, the parent or guardian.
• Account details: the email address and password used to sign in to the Teachers or Students App. Passwords are handled by our authentication provider and are never visible to us or to the Institution.
• Biometric data:
  • Fingerprints — the TAMS device stores only a fingerprint template (a numerical representation) on its sensor. Fingerprint images are never stored anywhere in the system, and a fingerprint image cannot be recreated from the template.
  • Face — where the Institution enables face matching, a registered face photo and a numerical face template derived from it are used solely to verify identity when attendance is marked. Face detection runs on the user’s phone.
• Attendance records: lecture, date and time, the method used to mark attendance (fingerprint, RFID card, face, code, Bluetooth, manual or admin), the fingerprint match score, and the device used.
• Location: the location of the lecture and of an app-based attendance punch, captured only at the moment a lecture is started or attendance is marked, to confirm the user is in the classroom. Location is never tracked in the background.
• RFID and Bluetooth identifiers: the number of an RFID ID card registered by the Institution, and, where Bluetooth attendance is enabled, the Bluetooth identifier registered for a student.
• Messages: queries, replies and announcements exchanged through TAMS Connect.
• Technical data: app version, device type, push-notification token and error logs needed to deliver notifications and keep the service working.

b) Through the Website

• Enquiry details you choose to send through our contact form: your name, designation, institution, city, mobile number, email address, approximate student count and message.
• Spam protection: to keep automated spam out, the form checks how it was filled in (for example, the time taken) and may use Cloudflare Turnstile, which checks that the visitor is human. Suspected spam is discarded.
• Server logs: our hosting and security providers automatically record your IP address, browser type and the pages requested, for security and to keep the Website available.

The Website does not use advertising or tracking cookies, and we do not use third-party analytics. The embedded Google Map on our contact page is provided by Google and is governed by Google’s privacy policy.

4. App permissions

The TAMS apps ask for the following permissions, only for the purposes described:

• Camera — to capture a face for face-match attendance or a profile photo.
• Location — to confirm that attendance is marked, or a lecture is started, in the classroom.
• Bluetooth and nearby devices — for the Attendance App to connect to the TAMS device.
• Notifications — to deliver attendance alerts, announcements and replies to queries.

You can withdraw a permission at any time in your phone’s settings; features that depend on it will then stop working.

5. How we use information

• To record, verify and report attendance for the Institution, and to prevent proxy or fraudulent attendance.
• To show students, teachers and the Institution dashboards and reports.
• To send attendance alerts and summaries to students and parents by app notification, email, SMS or WhatsApp, as configured by the Institution.
• To synchronise data with the Institution’s ERP system, where the Institution has enabled this.
• To provide technical support, maintain security, keep audit logs and improve the reliability of the TAMS Services.
• To respond to enquiries sent through the Website and to arrange demonstrations or quotations.

We do not sell personal data, use it for advertising, or use biometric data for any purpose other than verifying attendance.

6. How information is shared

We share personal data only as needed to provide the TAMS Services, and only with:

• The Institution and its authorised staff, according to the roles and permissions the Institution assigns.
• Hosting providers chosen by the Institution, such as the Institution’s own server, Google Firebase (Google Cloud), Amazon Web Services or another cloud provider.
• Messaging providers used to deliver notifications, emails, SMS and WhatsApp messages.
• The Institution’s ERP provider, where ERP integration is enabled by the Institution.
• Authorities, where disclosure is required by law, court order or a lawful request of a government agency.

All service providers are bound to use the data only to provide their service to us or to the Institution.

7. Where data is stored and how long it is kept

Each Institution has its own separate TAMS instance. Data is stored on the platform and in the region chosen for the Institution’s instance. Biometric fingerprint templates remain on the TAMS device sensor.

TAMS data is kept for as long as the Institution requires it for its academic and regulatory purposes. When the Institution’s subscription ends, or on the Institution’s written instruction, we delete or return the Institution’s data, except where we must keep it to comply with law. Website enquiries are kept for up to three years to follow up on and service the enquiry.

8. How we protect information

• Encrypted connections (HTTPS/TLS) between the apps, the web panel and the servers on cloud deployments, and wherever the Institution’s own server supports them.
• Role-based access control, so that each user sees only what their role allows.
• Access logs that record every change to attendance and settings, with the user and time.
• Tamper protections: device marks cannot be edited, and older lectures can be locked against editing.
• No storage of fingerprint images anywhere in the system.

No method of transmission or storage is completely secure, but we take reasonable security practices and procedures to protect personal data, and we will notify affected Institutions and authorities of a personal data breach as required by law.

9. Students under 18

TAMS is used by colleges and universities. Where a student is under 18 years of age, the Institution is responsible for obtaining verifiable consent from the student’s parent or lawful guardian as required by the DPDP Act. The TAMS apps are not intended for children under 13, and we do not knowingly collect their personal data.

10. Your rights

Subject to applicable law, you have the right to access a summary of your personal data, to request correction, completion, updating or erasure of it, to withdraw consent, to nominate another person to exercise your rights, and to have your grievances addressed.

Students, teachers and staff should make these requests to their Institution, which controls the TAMS data. For Website enquiries, write to us directly. We respond to requests within a reasonable time and in any case within the period required by law.

11. Grievance Officer and contact

If you have any question or complaint about this policy or about how your data is handled, please contact our Grievance Officer:

We will acknowledge your complaint within 48 hours and work to resolve it within 30 days. If you are not satisfied with our response, you may approach the Data Protection Board of India.

12. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our services or in the law. The updated policy will be posted on this page with a new effective date, and significant changes will be communicated to Institutions.