Privacy Policy

Effective Date: February 3, 2026

Last Updated: February 3, 2026

1. Introduction

This Privacy Policy governs the collection, processing, storage, disclosure, and transfer of personal data by Clar Aqua through the Clar Aqua mobile application. This policy is issued in compliance with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and applicable data protection regulations in India.

By installing, accessing, or using the Clar Aqua application, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the application.

2. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

• Data Principal: An individual to whom the personal data relates, including employees, sales personnel, managers, and operational staff using the Clar Aqua application.
• Data Fiduciary: Clar Aqua, the entity that determines the purpose and means of processing personal data.
• Data Processor: SDK Infinity Technologies, the technology service provider that processes personal data on behalf of and under instructions from Clar Aqua.
• Personal Data: Any data about an individual who is identifiable by or in relation to such data, including but not limited to name, contact information, employee identification, location data, and performance metrics.
• Sensitive Personal Data or Information (SPDI): Personal data consisting of information relating to passwords, financial information, biometric information, or any other data as defined under the SPDI Rules, 2011.
• Processing: Any operation or set of operations performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, or deletion.

3. Scope of Policy

This Privacy Policy applies to all personal data collected, processed, and stored through the Clar Aqua mobile application. The application is designed exclusively for use by authorized personnel of Clar Aqua, including employees, sales teams, managers, and operational staff, in the course of their employment and business operations.

This application is not intended for use by individuals below the age of 18 years. We do not knowingly collect personal data from minors.

4. Data Fiduciary and Data Processor

Data Fiduciary:

Clar Aqua

Data Processor / Technology Service Provider:

SDK Infinity Technologies
6, 2nd St, VOC Colony, Kodambakkam,
Chennai, Tamil Nadu 600024, India
Email: goalsplanner.sdk@gmail.com

SDK Infinity Technologies processes personal data solely on behalf of and under the instructions of Clar Aqua. SDK Infinity Technologies does not independently determine the purpose or means of processing personal data and acts strictly as a Data Processor under applicable law.

5. Categories of Personal Data Collected

The Clar Aqua application may collect and process the following categories of personal data:

5.1 Employee and User Data

• Full name
• Employee identification number
• Contact details (mobile number, email address)
• Attendance records
• Geo-location data (for attendance validation and field activity verification)
• Sales performance metrics and statistics
• Assigned sales targets and quotas
• Task assignments and workflow data
• Approvals and operational decisions

5.2 Customer and Sales Lead Data

• Customer or lead name
• Contact number
• Email address
• Business name and details
• Project information and requirements
• Sales pipeline status and updates
• Communication records and interaction history

5.3 Technical and Device Data

• Device type, model, and operating system
• IP address
• Application usage logs and analytics
• Device identifiers
• Network information
• Crash reports and diagnostic data

6. Purpose of Data Processing

Personal data collected through the Clar Aqua application is processed for the following legitimate purposes:

• Management of employee attendance and verification of physical presence at designated work locations through geo-location tracking
• Validation of field sales activities and client visits
• Project lifecycle management and operational workflow coordination
• Sales lead management and customer relationship management (CRM)
• Tracking and evaluation of sales performance against assigned targets
• Task assignment, monitoring, and completion tracking
• Facilitation of approvals and operational decision-making
• Internal reporting, analytics, and business intelligence
• Communication of task updates, approvals, and sales alerts through notifications
• Document management and record-keeping
• Compliance with employment contracts and legal obligations
• Security, fraud prevention, and system integrity maintenance
• Improvement and optimization of application functionality

7. Legal Basis for Processing

The processing of personal data through the Clar Aqua application is based on the following legal grounds:

• Consent: Users provide explicit consent to the collection and processing of personal data by accepting this Privacy Policy and granting necessary permissions on their devices.
• Contractual Necessity: Processing is necessary for the performance of employment contracts and service agreements between Clar Aqua and its personnel.
• Legitimate Business Interest: Processing is necessary for Clar Aqua's legitimate business interests, including workforce management, sales operations, project execution, and operational efficiency.
• Legal Obligation: Processing is required to comply with applicable laws, regulations, and legal obligations, including employment law, tax law, and corporate governance requirements.

8. Geo-Location Data Collection and Processing

Critical Disclosure: The Clar Aqua application collects and processes geo-location data for the following specific purposes:

• Verification and validation of employee attendance at designated work locations
• Authentication of field sales activities and client site visits
• Monitoring of operational workflow execution at specific geographic locations
• Compliance with attendance policies and employment terms

Geo-location data is collected only when the application is actively in use for attendance marking or field activity reporting. Location tracking is limited to employment-related purposes and is not used for continuous surveillance or monitoring outside of designated work activities.

Users may manage location permissions through their device settings. However, denial of location access may limit or prevent the use of attendance marking and field verification features, which may be required under employment policies.

9. Sales and CRM Data Processing

Critical Disclosure: The Clar Aqua application processes sales lead data and customer information as part of its customer relationship management (CRM) functionality. This data is processed for legitimate business purposes, including:

• Management of sales pipelines and lead tracking
• Recording and monitoring of customer interactions
• Analysis of sales performance and conversion metrics
• Allocation and tracking of sales targets
• Business development and revenue generation activities

Sales and customer data is processed in accordance with applicable data protection laws and is not sold, rented, or shared with third parties for marketing purposes without appropriate legal basis and consent.

10. Device Permissions

The Clar Aqua application may request the following permissions on your mobile device:

• Location Access: Required for geo-location based attendance validation and field sales activity verification. Location data is used strictly for operational and employment purposes and is not shared with third parties for advertising or unrelated commercial purposes.
• Camera Access: Required for uploading site photographs, client proof of visit, project documentation, and visual records related to work activities.
• Storage Access: Required for uploading, storing, and managing documents, images, and files related to projects, sales activities, and operational workflows.
• Notification Access: Required for delivering task updates, approval notifications, sales alerts, and system communications related to work activities.

You may revoke these permissions at any time through your device settings. However, revoking certain permissions may limit functionality and may affect your ability to perform required work-related tasks, subject to employment policies and contractual obligations.

11. Data Sharing and Disclosure

Personal data collected through the Clar Aqua application may be shared or disclosed under the following circumstances:

• Within Clar Aqua: Data may be shared with authorized personnel, managers, and departments within Clar Aqua on a need-to-know basis for legitimate business purposes.
• With Data Processor: Data is processed by SDK Infinity Technologies as the technology service provider, strictly under the instructions and control of Clar Aqua.
• Service Providers: Data may be shared with third-party service providers who assist in hosting, data storage, analytics, technical support, and other operational functions, subject to appropriate data protection agreements.
• Legal Requirements: Data may be disclosed to government authorities, law enforcement agencies, courts, or regulatory bodies when required by law, court order, or legal process.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, personal data may be transferred to the acquiring entity, subject to compliance with applicable data protection laws.

No Sale of Personal Data: Clar Aqua does not sell, rent, or trade personal data to third parties for monetary or other valuable consideration.

No Cross-App Tracking: The Clar Aqua application does not engage in cross-app tracking or share personal data with third parties for the purpose of tracking user activity across multiple applications or websites.

12. Third-Party Service Providers

Clar Aqua may engage third-party service providers to facilitate application functionality, data hosting, analytics, and technical support. These service providers are contractually obligated to:

• Process personal data only for the purposes specified by Clar Aqua
• Implement appropriate technical and organizational security measures
• Maintain confidentiality and data protection standards
• Not use personal data for their own purposes or share it with unauthorized parties
• Comply with applicable data protection laws and regulations

13. Data Retention Policy

Personal data collected through the Clar Aqua application is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specific retention periods include:

• Employee Data: Retained for the duration of employment and for such additional period as required by employment law, tax regulations, or legal obligations (typically up to seven years after termination).
• Sales and CRM Data: Retained for the duration of the business relationship and for such additional period as necessary for contractual, legal, or regulatory compliance (typically up to seven years).
• Attendance and Location Data: Retained for such period as required for payroll processing, compliance verification, and legal obligations (typically up to seven years).
• Technical and Usage Data: Retained for the duration necessary for system maintenance, security, and operational purposes (typically up to two years).

Upon expiry of the retention period, personal data will be securely deleted or anonymized in accordance with data protection standards, unless continued retention is required by law or legitimate business purposes.

14. Security Safeguards

Clar Aqua and SDK Infinity Technologies implement comprehensive technical, physical, and organizational security measures to protect personal data against unauthorized access, alteration, disclosure, destruction, loss, or misuse. These measures include:

• Encryption of data in transit and at rest using industry-standard protocols
• Access controls and authentication mechanisms to restrict access to authorized personnel only
• Regular security audits, vulnerability assessments, and penetration testing
• Firewall protection and intrusion detection systems
• Secure data storage infrastructure with backup and disaster recovery mechanisms
• Employee training on data protection and security best practices
• Incident response and breach notification procedures
• Compliance with IS/ISO/IEC 27001 information security standards or equivalent frameworks

While we implement robust security measures, no method of electronic transmission or storage is completely secure. Users are responsible for maintaining the confidentiality of their login credentials and for any activities conducted through their accounts.

15. Cross-Border Data Transfers

Personal data collected through the Clar Aqua application is primarily processed and stored within India. In certain circumstances, personal data may be transferred to, processed, or stored in jurisdictions outside India, including for purposes of data hosting, technical support, or service provision by third-party service providers.

Where cross-border data transfers occur, Clar Aqua ensures that:

• Adequate data protection safeguards are in place, including standard contractual clauses, binding corporate rules, or other lawful transfer mechanisms
• The recipient jurisdiction provides an adequate level of data protection as determined by applicable law
• Appropriate consents are obtained where required
• Transfers comply with the Digital Personal Data Protection Act, 2023, and other applicable regulations

16. Rights of Data Principals

Under the Digital Personal Data Protection Act, 2023, and applicable data protection laws, Data Principals have the following rights:

• Right to Access: The right to obtain confirmation of whether personal data is being processed and to access such data.
• Right to Correction: The right to request correction or completion of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of personal data, subject to legal and contractual obligations.
• Right to Data Portability: The right to receive personal data in a structured, commonly used, and machine-readable format, where applicable.
• Right to Nominate: The right to nominate another individual who may exercise rights on behalf of the Data Principal in the event of death or incapacity.
• Right to Grievance Redressal: The right to file grievances regarding personal data processing with the designated grievance officer or the Data Protection Board of India.

To exercise these rights, Data Principals may contact Clar Aqua through the contact information provided in Section 22 of this Privacy Policy. Requests will be processed in accordance with applicable law and within the timelines prescribed by regulation.

17. Grievance Redressal Mechanism

Clar Aqua has established a grievance redressal mechanism in compliance with the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000.

Grievance Officer:

SDK Infinity Technologies
Email: goalsplanner.sdk@gmail.com
Address: 6, 2nd St, VOC Colony, Kodambakkam, Chennai, Tamil Nadu 600024, India

Data Principals may submit grievances, complaints, or concerns regarding the processing of their personal data to the Grievance Officer. All grievances will be acknowledged within 24 hours of receipt and will be resolved within 30 days, or such other period as prescribed by law.

If you are not satisfied with the resolution of your grievance, you may escalate the matter to the Data Protection Board of India in accordance with the provisions of the Digital Personal Data Protection Act, 2023.

18. Withdrawal of Consent

Data Principals have the right to withdraw consent for the processing of their personal data at any time. Withdrawal of consent can be exercised by:

• Sending a written request to the Grievance Officer at the contact details provided in Section 17
• Adjusting device permissions to revoke access to location, camera, storage, or notifications
• Discontinuing use of the Clar Aqua application

Please note that withdrawal of consent may:

• Limit or prevent access to certain features or functionalities of the application
• Affect the ability to perform required work-related tasks and obligations under employment contracts
• Not affect the lawfulness of processing conducted prior to withdrawal
• Not apply to processing conducted on legal bases other than consent, such as contractual necessity or legal obligation

19. Account Termination and Data Deletion

Upon termination of employment, contract expiration, or cessation of authorized use, user accounts may be deactivated or deleted. Data Principals may request deletion of their personal data by submitting a written request to the Grievance Officer.

Upon receiving a deletion request, Clar Aqua will:

• Verify the identity of the requesting party
• Delete or anonymize personal data that is no longer required for legal, contractual, or legitimate business purposes
• Retain certain data as required by law, including for compliance with tax, employment, or regulatory obligations
• Complete the deletion process within a reasonable timeframe, typically within 90 days, subject to technical and legal constraints

Certain data may be retained in backup systems for a limited period and will be deleted in accordance with standard backup retention schedules.

20. Children's Privacy

The Clar Aqua application is intended exclusively for use by individuals who are 18 years of age or older. We do not knowingly collect, process, or solicit personal data from individuals below the age of 18.

If we become aware that personal data has been inadvertently collected from a minor, we will take immediate steps to delete such data from our systems. If you believe that we have collected personal data from a minor, please contact us immediately at the contact details provided in Section 22.

21. Compliance Statements

21.1 Google Play Store Compliance (2026)

The Clar Aqua application complies with the Google Play User Data Policy as updated for 2026. Specifically:

• We provide prominent disclosure of data collection, use, and sharing practices through this Privacy Policy
• We do not sell personal data to third parties
• We do not use personal data for advertising purposes unrelated to the core functionality of the application
• We do not engage in cross-app tracking or share data with third parties for tracking purposes
• Location data is collected solely for attendance validation and field activity verification, with explicit user consent
• We implement industry-standard security measures to protect user data
• We provide mechanisms for users to access, correct, and delete their personal data
• We handle sensitive permissions (location, camera, storage) in accordance with Google Play policy requirements

21.2 Apple App Store Privacy Compliance (2026)

The Clar Aqua application complies with the Apple App Store Privacy Guidelines as updated for 2026. Specifically:

• We provide clear and complete disclosure of data collection practices in this Privacy Policy and in the App Store privacy nutrition label
• We collect location data only when the application is in use, for purposes of attendance validation and field verification
• We do not use personal data for tracking across apps or websites owned by other companies
• We do not sell personal data or use it for advertising purposes unrelated to application functionality
• We obtain explicit user consent before collecting sensitive data such as location information
• We provide users with the ability to manage permissions and data access through device settings
• We implement security measures that comply with App Store security requirements
• We provide mechanisms for data access, correction, and deletion in accordance with user rights

22. Changes to This Privacy Policy

Clar Aqua reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in legal requirements, business practices, or application functionality. Any changes to this Privacy Policy will be effective immediately upon posting the revised policy within the application or on our website.

Users will be notified of material changes through:

• In-app notifications
• Email notifications to registered email addresses
• Prominent notice on the application interface

Continued use of the Clar Aqua application following the posting of changes constitutes acceptance of the revised Privacy Policy. We encourage users to review this Privacy Policy periodically to stay informed about how we protect personal data.

The current version of this Privacy Policy is always available within the application settings and can be accessed at any time.

23. Contact Information

For questions, concerns, requests, or complaints regarding this Privacy Policy or the processing of personal data, please contact:

Data Fiduciary:
Clar Aqua

Data Processor / Technology Service Provider:
SDK Infinity Technologies
6, 2nd St, VOC Colony, Kodambakkam,
Chennai, Tamil Nadu 600024, India
Email: goalsplanner.sdk@gmail.com

Grievance Officer:
SDK Infinity Technologies
Email: goalsplanner.sdk@gmail.com

We are committed to addressing your inquiries and resolving any concerns in a timely and transparent manner in accordance with applicable data protection laws.

24. Governing Law and Jurisdiction

This Privacy Policy and all matters relating to the processing of personal data through the Clar Aqua application shall be governed by and construed in accordance with the laws of India, including but not limited to:

• Digital Personal Data Protection Act, 2023
• Information Technology Act, 2000
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011

Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Chennai, Tamil Nadu, India.

25. Acknowledgment and Acceptance

By installing, accessing, or using the Clar Aqua application, you acknowledge that:

• You have read and understood this Privacy Policy in its entirety
• You consent to the collection, processing, storage, and disclosure of your personal data as described in this Privacy Policy
• You understand your rights as a Data Principal under applicable data protection laws
• You understand that certain features of the application require specific permissions (location, camera, storage, notifications) and that denial of such permissions may limit functionality
• You are 18 years of age or older and are authorized to use the application in accordance with your employment or contractual relationship with Clar Aqua

Last Updated: February 3, 2026

Version: 1.0