Privacy Policy
Staff — Effilearn sales team members with CallTrack on their work handset. Callers and recipients — anyone who speaks to a member of that team on a tracked line, including customers. Both are Data Principals under the Digital Personal Data Protection Act 2023 and both have the rights set out in section 8.
1. Who is responsible for your data
Effilearn is the Data Fiduciary for all personal data described here. It decides what is collected and why, and is accountable for it under the Digital Personal Data Protection Act 2023 ("DPDP Act").
| Data Fiduciary | Effilearn |
|---|---|
| Legal entity |
Tarun Entertainment, a sole proprietorship Proprietor: Radha Rakesh Mishra "Effilearn" is a registered trade name of this entity. |
| GSTIN | 27AWPPM6831L1ZT |
| Registered address |
Gala No. 102, Building No. 07, HDIL Industrial Park, Veer Savarkar Road, Chandansar, Vasai Virar, District Palghar, Maharashtra 401305, India |
| Contact for data protection | admin@effilearn.in |
2. What is collected
2.1 From a staff member's work handset
Only calls on the SIM the staff member nominates as their work SIM are collected. Calls on any other SIM in the same handset are filtered out on the device and never leave it.
| Data | Why |
|---|---|
| The other party's phone number, and a one-way hashed form of it | To identify who was called and to count distinct contacts without indexing raw numbers |
| The name saved for that number in the handset's contacts, if any | So the dashboard shows a name rather than a bare number |
| Direction (incoming, outgoing, missed, rejected) | Activity reporting |
| Start time and connected duration | Talk time, working-hours and idle-gap reporting |
| SIM slot and label | To confirm the call was on the work SIM |
| Call recording audio, where the handset's own dialler produces one | Quality review, coaching, and resolving disputes about what was said |
| Handset make, model, Android version, app version | To show which handsets can and cannot record, and to support them |
| Whether required permissions are granted and whether battery optimisation is disabled | To detect a handset that has silently stopped reporting |
| Integrity signals — call-log entries deleted from the handset, permissions withdrawn, an attempt to change the work SIM | To detect deliberate interference with activity records |
2.2 Not collected
CallTrack does not collect the contents of messages, email, photos, browsing history, keystrokes, app usage, or device location. It does not access the microphone except where a staff member has explicitly switched on the optional backup recorder described in 2.3. It does not upload the handset's address book.
2.3 The optional backup recorder
Some handsets have no built-in call recorder. On those, and only if the staff member switches it on, CallTrack can record through the handset microphone during a call. Because of restrictions Android places on all third-party apps, this captures the staff member's own side clearly and the other party only if the call is on speakerphone. Every such recording is marked "Rep only" everywhere it appears, and is not treated as a record of what the other party said.
2.4 From dashboard users
Managers and administrators sign in with an email address and password. A log is kept of every recording that is listened to — who listened, to which recording, and when.
3. Why it is collected, and on what legal basis
Personal data is processed only to measure and manage the sales team's work: reporting call activity, reviewing call quality and coaching, and confirming that activity records have not been interfered with.
For staff, the basis is the employment relationship, supported by a notice shown inside the app and acknowledged before any tracking starts. That acknowledgement is recorded with its version and the date.
For callers and recipients, the basis is Effilearn's legitimate business interest in keeping records of its own commercial calls. Staff are required to tell the other party when a call is being recorded.
Data is never used for advertising, profiling unrelated to work performance, automated decision-making about employment, or sale to any third party.
4. Where it is stored
| What | Where | Processor |
|---|---|---|
| Call records, device and account data, access logs | Managed PostgreSQL, Mumbai region, India | Supabase |
| Call recording audio | A private folder in an Effilearn-controlled Google Drive account |
Both are contracted Data Processors acting on Effilearn's instructions. The database is hosted in India. Google Drive storage may be located outside India; that transfer is permitted under section 16 of the DPDP Act to countries not restricted by the Central Government.
5. Who can see it
- A staff member can see their own calls and their own recordings, and nobody else's.
- A manager can see their own team members' calls and recordings.
- An administrator can see the whole organisation's.
These limits are enforced by the database itself rather than by the app, so they apply to every route into the data. Recordings are never made available through a public or shareable link; playback is authenticated each time and written to an access log.
6. How long it is kept
Call recordings are deleted automatically once they pass the retention window Effilearn has configured — currently 180 days. A scheduled job removes the audio from Google Drive and marks the record as deleted; the audio is not merely hidden.
Call records — number, time, duration, direction — are kept for as long as the staff member's employment record requires, and are erased on request under section 8 where no legal obligation requires Effilearn to keep them.
Access logs are retained so that Effilearn can demonstrate who accessed recordings, which the DPDP Act expects of a Data Fiduciary.
7. How it is protected
- All traffic between the app, the dashboard and the servers is encrypted in transit (HTTPS/TLS).
- Phone numbers are stored alongside a salted one-way hash, and it is the hash — not the raw number — that is indexed.
- Access rules are enforced at the database row level, not in application code.
- The credentials used to reach Google Drive are held server-side only and are never present in the mobile app.
- Recording filenames are masked so that a full customer number is not visible in the storage folder.
- Staff cannot alter the factual record of a call — time, duration, number or direction. They can add their own notes only.
If a personal data breach occurs, Effilearn will notify the Data Protection Board of India and every affected Data Principal, as required by section 8(6) of the DPDP Act.
8. Your rights
Under the DPDP Act you may:
- Access — obtain a summary of the personal data Effilearn holds about you and how it is processed.
- Correct or complete — have inaccurate or incomplete data corrected, updated or completed.
- Erase — have your personal data deleted, unless retention is required by law.
- Withdraw consent — where processing rests on consent, withdraw it as easily as it was given. Withdrawal does not undo processing already lawfully carried out.
- Nominate — nominate another individual to exercise these rights on your behalf in the event of death or incapacity.
- Grievance redressal — raise a complaint, and receive a response, before approaching the Board.
To exercise any of these, write to admin@effilearn.in with enough detail to identify the data — for a call recording, the approximate date, time and the number involved.
9. Grievance redressal
Tushar Mishra
Effilearn (Tarun Entertainment)
Gala No. 102, Building No. 07, HDIL Industrial Park,
Veer Savarkar Road, Chandansar, Vasai Virar,
District Palghar, Maharashtra 401305
Email: admin@effilearn.in
Complaints are acknowledged within 7 working days and answered within 30 days.
If you are not satisfied with the response, you may complain to the Data Protection Board of India under section 13 of the DPDP Act.
10. Children
CallTrack is a workplace tool issued to employed adults. It is not directed at children and Effilearn does not knowingly process the personal data of anyone under 18 through it. If a call recording is found to contain a child's personal data, it will be deleted on request.
11. Changes to this policy
Material changes are published here with a new version number and date. Where a change affects what staff are told, the in-app notice is updated to match and staff acknowledge the new version the next time they open the app.
12. Languages
This notice is available in English. As required by section 5(3) of the DPDP Act, a copy in any language listed in the Eighth Schedule to the Constitution of India will be provided on request to admin@effilearn.in.