Version 1.1 · Effective 15 June 2026 · Jurisdiction: India
1. Who we are
Certopact is operated by Perigeon Software Private Limited, a private limited company incorporated in India and based in Ahmedabad, Gujarat. This policy covers certopact.com and both Certopact products — Certopact Entry (identity verification) and Certopact Access (visit management: pre-registration, kiosk check-in, host approvals and badge printing) — together with their kiosks, admin consoles and integrations.
When a visitor checks in through Entry or Access, the enterprise using Certopact is the Data Fiduciary and Certopact acts as a Data Processor on its behalf.
2. Scope & our role
- Visitors checking in — the host enterprise decides what data is collected and for how long, under a Data Processing Agreement. Certopact processes it on their instructions.
- Enterprise customers & admins — Certopact is the Data Fiduciary for account, billing and product-communication data.
- Website visitors — Certopact is the Data Fiduciary for analytics, cookies and contact-form data.
In scope: certopact.com, the Entry kiosk and Access kiosk/check-in flows, the admin console, the API and related communications. Out of scope: third-party websites, UIDAI and DigiLocker's own practices, and customers' internal systems.
3. What data we collect
| Category | What we collect | From whom |
|---|---|---|
| Visitor identity (Entry) | Name, last 4 Aadhaar digits, date of birth, mobile for OTP, photograph | Visitor at kiosk |
| Verification responses (Entry) | UIDAI response, DigiLocker document references, name-match score | UIDAI, DigiLocker |
| Visit data (Access) | Pre-registration details, host name, visit purpose, approval status, badge details, check-in/out timestamps, visitor photo for badge | Host, visitor, receptionist, system |
| Account data | Name, email, phone, role, company, password hash | Enterprise admin |
| Website data | IP, browser type, pages viewed, referrer | Browser |
| Communications | Email, support tickets, recorded calls (with consent) | You |
Never collected: full Aadhaar number, raw biometric data, bank accounts or payment-card numbers.
4. Aadhaar, DigiLocker & offline verification (OVSE)
Identity verification is a feature of Certopact Entry. It also runs inside Access when an enterprise enables KYC Verification at check-in. Verification can be performed two ways:
Online (Aadhaar OTP)
- The visitor enters the last 4 Aadhaar digits and date of birth at the kiosk.
- UIDAI sends an OTP to the registered mobile; on success it returns limited demographics.
- Certopact calculates a name-match score and stores the masked result.
Offline (OVSE)
- As an Offline Verification Seeking Entity, Entry can verify Aadhaar without an online UIDAI call — by reading the secure QR code or a Aadhaar Paperless Offline e-KYC XML.
- Certopact validates UIDAI's digital signature before trusting any field. No OTP is collected and no online authentication is performed.
DigiLocker is opt-in; the visitor authenticates directly with DigiLocker and Certopact never sees their password. Live Face (match against the Aadhaar photo, in Entry) and Live Face Capture (photo-on-badge only, in Access) are used only where the enterprise enables them.
What we store: masked Aadhaar (last 4 digits), UIDAI/offline transaction reference, verification result, name-match score, e-KYC demographics where required, digitally-signed DigiLocker documents (if opted in), and the visitor photograph (where captured).
What we do not store: the full Aadhaar number, raw biometric data, the OTP, or any UIDAI data not returned to us.
Protection: AES-256 encryption at rest for Aadhaar-linked data, TLS 1.2+ in transit, India data residency (GCP Mumbai region only), role-based access with logging, and tenant isolation between customers. Certopact operates as a Sub-AUA under a licensed AUA/KUA. Aadhaar verification always requires explicit, informed consent, and a visitor may decline.
5. How we use it
Data is processed for specified, lawful purposes under the DPDP Act, 2023:
- Verify visitor identity at entry, on behalf of the enterprise (Entry).
- Manage the visit — pre-registration, kiosk check-in, host approvals and badge printing (Access).
- Produce visitor records for audit, compliance, evacuation and security.
- Generate analytics and reports (check-in trends, name-match distributions) and deliver Excel reports when an authorised admin requests them.
- Operate, secure and improve the service, and communicate about updates, security advisories and account matters.
- Comply with legal obligations.
Not used for marketing, profiling or advertising.
6. Sharing & processors
| Recipient | Purpose | Data shared |
|---|---|---|
| Enterprise customer | Manage visitor records | Visitor records under their account |
| UIDAI (via AUA/KUA) | Aadhaar OTP authentication | Aadhaar number, demographics, OTP |
| DigiLocker | Document fetch on consent | DigiLocker login redirect |
| Cloud providers (India only) | Hosting & operations | Encrypted production data |
| Email / SMS providers | OTP, reports, alerts | Mobile, email, message body |
| Law enforcement / regulators | Legal compliance | Only what a valid order requires |
All processors operate under written agreements with confidentiality, security, breach-notification and India data-residency clauses. We do not sell, rent or trade your personal data — not now, not ever.
7. Retention
Visitor & visit data: the enterprise (Data Fiduciary) sets the retention period in its DPA. Defaults are 180 days for active records and 3 years for masked audit logs.
Certopact's own records: account data for the life of the account plus 12 months; billing records for 8 years (Companies Act / tax); communications and support tickets for 24 months; website analytics for 14 months; security logs for 12 months. Backups are purged within 90 days of deletion.
8. Security
- AES-256 encryption at rest with regularly rotated keys; TLS 1.2+ in transit.
- Role-based access control with least privilege; MFA for admin and engineering accounts.
- Audit logging on all production access (12+ months).
- Quarterly security reviews, annual penetration testing and a vulnerability-disclosure programme.
- Incident response aligned with the DPDP Act, 2023 and CERT-In.
SOC 2 Type II and ISO 27001 audits are in progress for 2026.
9. Your rights
Under the DPDP Act, 2023 you may: access information about your data; correct or erase it; raise a grievance; nominate someone to exercise your rights; and withdraw consent for the future.
For visitor data, contact the host enterprise first. For account, website or communications data, write to our Grievance Officer (below). We acknowledge within 3 working days and respond substantively within 30 calendar days. You may escalate to the Data Protection Board of India.
10. Cookies & tracking
We use strictly-necessary cookies (session, security, preferences — always on) and analytics cookies (consent-based). We do not use advertising cookies, retargeting pixels or third-party tracking. Manage preferences via the cookie banner or your browser.
11. Children & minors
Certopact is a B2B service for adult workplace visitors. We do not knowingly collect personal data from anyone under the age of 18. If such data is collected accidentally, email us and we will delete it within 7 working days.
12. Changes to this policy
We announce updates by changing the “Effective” date above, emailing account holders at least 14 days before material changes take effect, posting a website notice and keeping a public changelog. Continued use after changes means acceptance of the updated policy.
13. Contact
Grievance Officer: [email protected]
Data Protection Officer: [email protected]
General: [email protected] · +91 63574 97151
Post: Perigeon Software Private Limited, Ahmedabad, Gujarat, India
Please include “Privacy / DPDP request” in the subject line.