Sileo Technologies Private Limited ("Sileo Technologies", "Sileo", "we", "our", or "us") respects the privacy of individuals and is committed to protecting personal information processed through *VetanWala*, our AI-enabled Human Resource Management System (HRMS), payroll and workforce management platform.

This Privacy Policy explains how personal information may be collected, accessed, used, stored, processed, protected and disclosed when organisations, administrators, employees or other authorised users use VetanWala.

By accessing or using VetanWala, you acknowledge that you have read and understood this Privacy Policy.

1. About VetanWala

VetanWala is an HRMS platform designed to support organisations in managing workforce-related processes, which may include:

- Employee information management

- Attendance and shift management

- Leave management

- Payroll and payslips

- Statutory and payroll-related information

- Performance management

- Employee onboarding and offboarding

- Assets and related records

- HR reports and analytics

- AI-enabled insights and reports

- Customised and conversational reporting

- Other HR and workforce management functions

The specific features available to an organisation may depend on its subscription, configuration and contractual arrangement with Sileo Technologies.

2. Roles and Responsibilities

For organisational deployments of VetanWala, the organisation subscribing to or using the platform generally determines what employee or workforce information is collected and how it is used.

Accordingly:

- The *customer organisation* is generally responsible for determining the purposes and means of processing employee data within its VetanWala account.

- *Sileo Technologies* provides, operates and supports the VetanWala platform and processes information as necessary to provide the contracted services and related support.

- Employees and other individuals whose information is entered into VetanWala should contact their respective organisation for questions regarding organisation-specific HR policies, employment decisions or the use of their personal information.

The exact allocation of responsibilities may be governed by the applicable customer agreement, data-processing terms or other contractual documentation.

3. Information We May Collect

Depending on the features enabled by the customer organisation, VetanWala may process the following categories of information.

### 3.1 Employee and Profile Information

This may include:

- Name

- Employee ID

- Date of birth

- Gender, where collected by the organisation

- Contact details

- Address

- Department

- Designation

- Joining and employment details

- Emergency contact details

- Bank/payment information

- Identification and statutory information

- Employment documents and records

### 3.2 Attendance and Workforce Information

This may include:

- Attendance records

- Check-in and check-out information

- Working hours

- Shift information

- Leave records

- Holidays

- Overtime and compensatory-off information

- Attendance regularisation records

- Location information where a customer-enabled feature requires it

### 3.3 Payroll Information

Depending on the services configured by the organisation, this may include:

- Salary and compensation information

- Payroll calculations

- Allowances and deductions

- Tax-related information

- Provident Fund and other statutory information

- Payslip information

- Reimbursement information

- Payment-related information

- Full and final settlement information

### 3.4 Performance and HR Information

Where enabled, VetanWala may process:

- Performance objectives

- Appraisal information

- Manager assessments

- Employee self-assessments

- Key performance indicators

- Training information

- Feedback and HR records

- Confirmation and employment-related records

### 3.5 Technical and Usage Information

We may also process:

- Login information

- IP address

- Browser and device information

- Operating system

- Access timestamps

- Audit logs

- Application activity

- Security and diagnostic information

- Information required to maintain system integrity and security

4. How We Use Personal Information

Personal information processed through VetanWala may be used to:

- Provide and operate HRMS and payroll services

- Authenticate users and manage access

- Maintain employee and organisational records

- Process attendance, leave and payroll activities

- Generate payslips and HR reports

- Provide analytics and dashboards

- Support performance-management processes

- Provide customer and technical support

- Maintain audit trails

- Detect, investigate and prevent security incidents, fraud or misuse

- Maintain and improve the reliability and functionality of the platform

- Comply with applicable legal, regulatory and contractual requirements

- Perform other activities authorised by the customer organisation or permitted by applicable law

5. AI-Enabled Features

VetanWala may include artificial intelligence (AI), machine-learning, natural-language processing, analytics or generative-AI capabilities.

Depending on the features enabled, AI may be used to assist with:

- HR analytics

- Workforce insights

- Attendance and leave analysis

- Performance-related insights

- Payroll-related analytics

- Automated summaries

- Report generation

- Customised or conversational reports

- Data analysis and trend identification

- Alerts, recommendations or other decision-support outputs

AI processing will be limited to the functionality made available within the platform and the purposes authorised by the applicable customer organisation.

6. AI Outputs and Human Oversight

AI-generated information, recommendations, summaries, reports or insights may contain errors, omissions or inaccuracies.

AI-generated outputs are intended to *assist authorised users and support decision-making* and should be appropriately reviewed and validated by authorised personnel before being relied upon for material or consequential HR decisions.

Unless expressly configured, authorised and legally permitted, AI-generated outputs should not be treated as the sole basis for decisions relating to:

- Hiring

- Promotion

- Compensation

- Performance evaluation

- Disciplinary action

- Termination

- Benefits

- Other significant employment decisions

The customer organisation remains responsible for employment decisions made using information available through VetanWala.

This human-review approach is consistent with recognised AI governance principles that emphasise defined human responsibilities, transparency and appropriate oversight of AI systems.

7. AI Training and Model Improvement

Where AI or machine-learning technologies are used, information may be processed to provide the requested AI-enabled functionality, subject to the applicable product configuration, customer agreement and technical architecture.

*VetanWala customer data will not be represented as being used for general-purpose AI model training unless such processing is specifically authorised, disclosed and permitted under the applicable contractual and privacy terms.*

Where third-party AI or technology providers are used, applicable data-processing arrangements and technical safeguards may apply.

8. Data Access and Role-Based Permissions

VetanWala is designed to support role-based access to information.

Depending on the customer's configuration, access may be provided to:

- Employees

- HR personnel

- Managers

- Payroll administrators

- Finance personnel

- System administrators

- Other authorised users

Access permissions should be configured by the customer organisation according to job responsibilities and business requirements.

Users must not attempt to access information beyond the permissions assigned to them.

9. Data Security

Sileo Technologies takes reasonable technical and organisational measures to protect information processed through VetanWala against unauthorised access, disclosure, alteration, loss, misuse or destruction.

Depending on the applicable deployment and service configuration, security measures may include:

- Authentication and access controls

- Role-based access controls

- Encryption where appropriate

- Secure application and infrastructure practices

- Audit logging

- Monitoring and security controls

- Backup and recovery mechanisms

- Vulnerability and security management

- Administrative controls and operational safeguards

No electronic system or method of data transmission can be guaranteed to be completely secure.

10. Data Isolation and Customer Environment

Where VetanWala is provided as a multi-tenant service, appropriate logical controls are implemented to help prevent unauthorised access between customer environments.

Customer data is processed according to the applicable service architecture, configuration and contractual requirements.

11. Sharing and Disclosure of Information

Sileo Technologies does not sell personal information processed through VetanWala.

Information may be disclosed or made accessible where necessary to:

- Provide VetanWala services

- Provide hosting and infrastructure services

- Provide technical and customer support

- Provide security, monitoring and maintenance services

- Provide authorised AI or technology services

- Comply with legal or regulatory requirements

- Respond to lawful requests from government or law-enforcement authorities

- Protect the rights, security and property of Sileo Technologies, its customers or users

- Facilitate a merger, acquisition, restructuring or transfer of business assets

Third-party service providers may process information only to the extent necessary to provide their contracted services and subject to appropriate contractual and security requirements.

12. Third-Party Service Providers

VetanWala may integrate with or rely upon third-party services for functions such as:

- Cloud hosting

- Database and infrastructure services

- Email and communication

- Authentication

- Payment processing

- Analytics

- Security

- AI and machine-learning services

- Backup and disaster recovery

Where third-party services process personal information on our behalf, we seek to use appropriate contractual, technical and organisational safeguards.

13. Data Retention

Personal information will generally be retained for as long as reasonably necessary to:

- Provide the requested services

- Maintain customer and employee records

- Meet contractual requirements

- Fulfil legal, regulatory, tax and accounting obligations

- Maintain security and audit records

- Resolve disputes

- Prevent fraud or misuse

The applicable customer organisation may have its own retention requirements for employee and HR records.

Following termination of services, customer data may be retained, returned or deleted in accordance with the applicable agreement, technical procedures and legal requirements.

14. Data Accuracy

Customers and authorised users are responsible for ensuring that information entered into VetanWala is accurate, complete and appropriately updated.

Where permitted by the platform, authorised users may correct or update information through the relevant HRMS functionality.

15. Employee and Individual Rights

Subject to applicable law, individuals may have rights concerning their personal information, including the ability to:

- Request access to their personal information

- Request correction of inaccurate information

- Request deletion where legally applicable

- Raise concerns regarding processing

- Withdraw consent where processing is based on consent

- Exercise other applicable privacy rights

For information processed on behalf of an organisation, individuals should generally first contact their employer or the relevant customer organisation.

Requests may be subject to applicable legal, contractual and security requirements.

16. Cookies and Similar Technologies

The VetanWala website or web application may use cookies, session technologies and similar mechanisms for purposes including:

- Authentication

- Security

- Session management

- User preferences

- Performance monitoring

- Analytics

- Improving user experience

Users may manage certain cookies through their browser or device settings. Disabling essential technologies may affect the functionality of the platform.

17. International Data Processing

Depending on the hosting architecture, service providers and customer configuration, information may be processed or stored in locations outside the user's state or country.

Where applicable, such processing will be carried out subject to contractual, technical and legal requirements.

18. Children's Privacy

VetanWala is designed primarily for organisations, employees, HR professionals, administrators and other authorised adult users.

We do not knowingly collect personal information directly from children for purposes unrelated to the services.

Where an organisation is responsible for information entered into the platform, the organisation remains responsible for ensuring that its collection and use of such information complies with applicable law.

19. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

- Changes to VetanWala functionality

- Changes in technology

- Changes in our business practices

- Changes in applicable laws or regulations

- Changes in AI capabilities or processing practices

The updated version will be published with a revised *"Last Updated"* date.

20. Contact Us

For questions, privacy requests or concerns relating to VetanWala or this Privacy Policy, please contact:

*Sileo Technologies Private Limited*

*Email:* info@thesileo.com

*Website:* www.thesileo.com

For privacy-related requests, please mention *"Privacy Request – VetanWala"* in the subject line.

Where the information is processed on behalf of an organisation, we may direct the request to the relevant customer organisation where appropriate.