Privacy Policy for DBH-Connect

1. Introduction

DBH-Connect ("the App") is a mobile application developed by Periscope Labs Limited for DBH Finance PLC, a Non-Banking Financial Institution (NBFI) operating in Bangladesh. This App is designed exclusively for use by DBH Finance PLC employees and authorized sales team members.

This Privacy Policy describes how we collect, use, store, and protect your personal information when you use the DBH-Connect mobile application.

2. Developer and Data Controller Information

DBH Finance PLC is the data controller responsible for the collection and processing of personal data through the App. Periscope Labs Limited acts as the data processor, developing and maintaining the App on behalf of DBH Finance PLC.

3. Scope and Applicability

This App is intended solely for use by:

• Employees of DBH Finance PLC
• Authorized sales team members of DBH Finance PLC
• Other authorized personnel designated by DBH Finance PLC

The App is not available for public download or use. Access is restricted to authorized DBH Finance PLC personnel only.

Jurisdiction: This App operates in Bangladesh and is subject to the laws of Bangladesh.

4. Information We Collect

4.1 Personal Information

We collect the following types of personal information:

• Authentication Data: Username, password, and employee identification information
• Profile Information: Name, employee ID, department, role, and contact information
• Location Data: Real-time GPS coordinates, location history, and geo-tagged visit locations
• Visit Information: Customer visit records, daily visit reports (DVR), visit timestamps, and visit-related forms
• Form Data: Dynamic form submissions including customer information, business data, and sales-related information
• Photos and Images: Photos captured through the device camera for visit documentation and business purposes
• Device Information: Device type, operating system version, unique device identifiers, and app version

4.2 Automatically Collected Information

• Usage Data: App features accessed, timestamps of activities, and interaction patterns
• Technical Data: IP address, network connection type, and app performance metrics
• Location Data: Continuous or periodic location tracking when the app is in use or running in the background for visit tracking purposes

5. How We Collect Information

We collect information through:

• Direct Input: Information you provide when completing forms, creating reports, or updating your profile
• Camera Access: Photos you capture using the in-app camera feature
• Location Services: GPS data collected through your device's location services and Google Maps API
• Automatic Collection: Technical and usage data collected automatically when you use the App
• External APIs: Data retrieved from client APIs and third-party systems integrated with the App

6. Purpose of Data Collection

We collect and process your information for the following purposes:

• Employee Management: Authenticate and manage employee access to the App
• Visit Tracking: Record and monitor customer visits, sales activities, and field operations
• Performance Reporting: Generate visit reports, analyze team performance, and create business analytics
• Geolocation Services: Verify visit locations, track field team movements, and ensure visit authenticity
• Documentation: Maintain records of customer interactions and business activities through photos and reports
• Business Operations: Support DBH Finance PLC's sales operations, customer relationship management, and business processes
• Communication: Facilitate internal communication between team members and management
• Compliance: Meet regulatory requirements and internal audit requirements of DBH Finance PLC

7. Device Information and Identifiers

To ensure app functionality, security, authentication, and proper operation, we automatically collect certain device information and identifiers from your mobile device. This collection is essential for maintaining app security and providing the services required for your job duties.

7.1 Types of Device Information Collected

• Device Identifiers: Android ID, device UUID (Universally Unique Identifier), and other device-specific identifiers that uniquely identify your device
• Device Information: Device model, manufacturer, operating system version, app version, screen resolution, and device language settings
• Network Information: IP address, mobile network operator, network connection type (WiFi/cellular), and mobile country code
• Technical Data: Device settings, time zone, and system configuration information

7.2 Purpose of Device Information Collection

Device identifiers and information are collected and used for the following critical purposes:

• Authentication and Security: Verify device identity during login and maintain secure session management across multiple login sessions
• Fraud Prevention: Detect and prevent unauthorized access, fraudulent activities, and security breaches by monitoring device patterns
• App Functionality: Ensure proper app operation, feature compatibility, and optimize performance based on device capabilities
• Technical Support: Diagnose technical issues, troubleshoot problems, and provide effective technical assistance
• Analytics and Improvements: Analyze app usage patterns, performance metrics, and crash reports to improve app quality and user experience
• Compliance: Meet security policies, audit requirements, and regulatory compliance obligations of DBH Finance PLC
• Session Management: Maintain active user sessions and synchronize data across app instances

7.3 Sharing of Device Information

Device identifiers and information may be shared with:

• Google Maps API: Device information is shared for proper integration of location services and map functionality
• Periscope Labs Limited: Technical service provider receives device data for app maintenance, technical support, troubleshooting, and performance optimization
• Cloud Infrastructure Providers: Device information is transmitted to secure hosting services for backend operations and data synchronization
• DBH Finance PLC IT Department: Device data is accessible to authorized IT personnel for security monitoring and compliance purposes

7.4 Data Security for Device Information

All device identifiers and information are:

• Transmitted securely using encrypted connections (HTTPS/TLS)
• Stored on secure servers with access controls
• Accessed only by authorized personnel for legitimate business purposes
• Protected in accordance with our security measures outlined in Section 10

7.5 Device Information Retention

Device identifiers and related information are retained:

• For the duration of your active employment and app usage
• For the period required for security audits and compliance purposes
• As mandated by DBH Finance PLC's record retention policies and Bangladesh law

8. Location Data Collection

8.1 Types of Location Data

The App collects precise location data (GPS coordinates) for:

• Visit check-in and check-out
• Geo-tagging of customer visits
• Route tracking for field activities
• Visit verification and validation

8.2 Location Collection Methods

• Foreground Collection: Location data is collected when the App is open and actively in use
• Background Collection: Location data may be collected when the App is running in the background during active visits to ensure accurate visit tracking

8.3 Location Data Usage

Location data is used exclusively for:

• Verifying employee presence at customer locations
• Generating visit reports and analytics
• Monitoring field team performance
• Ensuring visit authenticity and compliance

9. Camera and Photo Usage

The App requests access to your device camera to:

• Capture photos during customer visits
• Document business activities and meetings
• Provide visual evidence of field activities

Photo Storage: All photos captured through the App are:

• Uploaded to DBH Finance PLC's secure backend servers
• Stored in the App's database
• Associated with specific visit records and reports
• Not stored locally on your device permanently
• Accessible only to authorized DBH Finance PLC personnel

10. Data Sharing and Disclosure

10.1 Internal Sharing

Your information is shared internally within DBH Finance PLC with:

• Your supervisors and management team
• Relevant departments (Sales, Operations, HR, IT)
• Authorized personnel who need access for business purposes

10.2 Third-Party Service Providers

We share limited data with the following service providers:

• Google Maps API: For location services and mapping functionality (location coordinates only)
• Cloud Infrastructure Providers: For secure data storage and hosting
• Technical Service Providers: Periscope Labs Limited for app maintenance and technical support

10.3 External API Integrations

The App integrates with client APIs and third-party systems at customer premises for:

• Retrieving customer information
• Synchronizing business data
• Facilitating sales operations

Data shared through these integrations is limited to information necessary for business operations and is protected through secure connections.

10.4 Legal Disclosure

We may disclose your information if required by:

• Bangladesh law or regulation
• Court order or legal process
• Government or regulatory authorities
• Protection of DBH Finance PLC's rights and property

10.5 No External Sale or Marketing

We do not:

• Sell your personal information to third parties
• Share your information for marketing purposes
• Disclose your information to unauthorized external parties

11. Data Security

We implement appropriate technical and organizational security measures to protect your information:

11.1 Technical Measures

• Encryption: Data transmission is encrypted using industry-standard protocols (HTTPS/TLS)
• Authentication: Secure login with username and password protection
• Access Controls: Role-based access restrictions to limit data access
• Secure Storage: Data stored on secure servers with access controls
• Regular Backups: Regular data backups to prevent data loss

11.2 Organizational Measures

• Limited Access: Access restricted to authorized personnel only
• Confidentiality: Employees bound by confidentiality obligations
• Security Training: Regular security awareness training for staff
• Incident Response: Procedures for responding to security incidents

11.3 Data Retention

• Active Employment: Data retained for the duration of your employment with DBH Finance PLC
• Post-Employment: Data retained as required by Bangladesh law and DBH Finance PLC's record retention policies
• Business Records: Visit reports and business data retained as required for regulatory compliance and business purposes

12. Your Rights and Choices

As a user of the App, you have the following rights:

12.1 Access and Correction

• Right to access your personal information stored in the App
• Right to request correction of inaccurate information
• Contact your supervisor or IT administrator to exercise these rights

12.2 Location Services Control

You can control location permissions through your device settings:

• Android: Settings > Apps > DBH-Connect > Permissions > Location
• Note: Disabling location services may limit app functionality required for your job duties

12.3 Camera Permissions

You can control camera access through your device settings:

• Android: Settings > Apps > DBH-Connect > Permissions > Camera
• Note: Camera access is necessary for visit documentation requirements

12.4 Employment Context

Please note that as this App is provided by your employer (DBH Finance PLC) for work purposes:

• Use of the App is subject to your employment terms and conditions
• Some data collection is necessary for job performance and compliance
• Certain rights may be limited by legitimate business interests and legal requirements

13. Children's Privacy

The App is intended exclusively for use by DBH Finance PLC employees and is not directed to individuals under the age of 18. We do not knowingly collect information from minors.

14. Third-Party Services and Links

14.1 Google Maps

The App uses Google Maps API for location services. Use of Google Maps is subject to Google's Privacy Policy and Terms of Service:

• Google Privacy Policy: https://policies.google.com/privacy
• Google Maps Terms of Service: https://cloud.google.com/maps-platform/terms

14.2 External APIs

The App connects to customer premise APIs and third-party systems for business operations. These connections are made securely and data sharing is limited to business-necessary information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in data processing practices
• Changes in legal or regulatory requirements
• New features or functionality in the App
• Feedback from users or regulators

Notification of Changes:

• Updated Privacy Policy will be posted in the App
• Significant changes will be communicated via email or in-app notification
• Continued use of the App constitutes acceptance of the updated policy

16. Data Protection Officer / Privacy Contact

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

17. Compliance and Governing Law

This Privacy Policy and the App's data processing practices are governed by:

• The laws of Bangladesh
• Applicable data protection regulations in Bangladesh
• DBH Finance PLC's internal policies and procedures
• Industry best practices for data protection

18. Consent

By downloading, installing, and using the DBH-Connect App, you acknowledge that:

• You have read and understood this Privacy Policy
• You consent to the collection, use, and processing of your information as described
• You understand this App is for work purposes and subject to employer monitoring
• You agree to the terms outlined in this Privacy Policy