Legal

Privacy Policy

Effective Date: January 26, 2026 • Last Updated: April 12, 2026

1. Introduction

D Advaya FM Pvt Ltd (“we,” “our,” or “us”) operates the FM NaipuNya mobile application and web platform (collectively, the “Service”). We are committed to protecting your privacy in compliance with the Digital Personal Data Protection (DPDP) Act, 2023 of India and applicable data protection laws.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our Service.

2. Information We Collect

We collect the following categories of data to provide our training and certification services:

  • Identity Data: Name, Employee ID, and profile photo (for identity verification via the Vajra system).
  • Contact Data: Mobile phone number (for OTP-based authentication via MSG91).
  • Device Data: Device ID, operating system version, and app version (for session management and security).
  • Training Data: Module completion records, quiz scores, assessment results, and training progress.
  • Camera & Microphone: Used only during active liveness verification checks and WebXR simulations. Data is processed locally and not stored on servers.
  • Location Data: Collected only during active Emergency Mode (SOS) to coordinate with emergency services. Not collected during normal training.

3. How We Use Your Data

  • To authenticate your identity and maintain secure sessions.
  • To track and verify completion of mandatory training modules.
  • To generate compliance reports for your employer or facility manager (Pass/Fail status only).
  • To improve our training content based on aggregated, anonymized performance data.
  • To facilitate the zero-reprisal POSH (Prevention of Sexual Harassment) reporting system.
  • To provide emergency services coordination when SOS is activated.

4. Zero-Reprisal POSH Guarantee

For users reporting harassment through our POSH module:

  • All reports are end-to-end encrypted.
  • Reports are routed directly to the Internal Complaints Committee (ICC), bypassing local supervisors and managers.
  • Your identity is protected unless you voluntarily choose to disclose it.
  • We maintain a strict zero-reprisal policy — no adverse action will be taken against a reporter.

5. Data Sharing

  • With Your Employer: We share training compliance status (module completion, pass/fail) with your employer or facility manager as required for site access and regulatory compliance.
  • No Third-Party Advertising: We do NOT sell, rent, or share your personal data with advertisers or third-party marketing platforms.
  • Service Providers: We use cloud infrastructure (AWS) and authentication services (MSG91) that process data on our behalf under strict data processing agreements.
  • Legal Obligations: We may disclose data if required by law, court order, or government regulation.

6. Data Storage & Security

  • All data is stored on servers located in India (AWS ap-south-1, Mumbai).
  • Data is encrypted in transit (TLS 1.3) and at rest (AES-256).
  • Liveness verification telemetry is retained for a maximum of 30 seconds and then permanently deleted.
  • Training records are retained for the duration of your employment plus 3 years for audit purposes.

7. Your Rights Under the DPDP Act

As a data principal under the DPDP Act 2023, you have the right to:

  • Access: Request a copy of your personal data we hold.
  • Correction: Request correction of inaccurate data.
  • Erasure: Request deletion of your data (see our Data Deletion page).
  • Portability: Export your training score card and certification records.
  • Grievance Redressal: Contact our Data Protection Officer for any privacy concerns.

8. Children's Privacy

Our Service is not intended for users under 18 years of age. We do not knowingly collect personal data from children. If you believe a minor has provided us with personal data, please contact us immediately.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated through the app or via email. Continued use of the Service after changes constitutes acceptance.

10. Contact Us

For privacy concerns, data requests, or to exercise your rights under the DPDP Act:

  • Email: admin@advayafm.com
  • Phone: +91 79890 02661
  • Address: D Advaya FM Pvt Ltd, 502B Sadhguru Capital Park, Madhapur, Hyderabad, Telangana 500081, India