OneTap Data Processing Agreement

Version 2026-10

Draft for legal review. Not yet in force. This text sets out the structure and commitments OneTap is built to meet. Counsel must review and complete it, including every part in square brackets, before OneTap goes live.

1. Who does what

The company that signs up for OneTap (the "Company") decides why and how its employees' attendance data is processed. Under the Digital Personal Data Protection Act, 2023, the Company is the Data Fiduciary. Oltin [registered company name and number], of 431 Fen Street, Brooklands, Milton Keynes, MK10 7PE ("Oltin"), processes that data on the Company's behalf as its Data Processor, only to provide OneTap.

2. What OneTap processes

About Data
Employees Name, work email, employee ID, role, the offices they may check in at. If the Company gives them, the details attendance registers ask for: designation, gender, date of birth, father's or spouse's name, and date of joining.
Attendance Check-in and check-out times as recorded by the server, the office matched, which checks passed, the trust level, and any review decision with its reason.
Linked phones Model, operating system, app version, the phone's public keys, and the results of Apple App Attest or Google Play Integrity checks.
At the moment of a check-in or check-out only The office Wi-Fi router's hardware ID and name, and the public IP address of the request. At an office with an area set: whether the phone was inside it, how far it was from the office, and how accurate that reading was.
If the employee allows location all the time The time the phone left the office's area after a check-in, and the check-out it caused.
The Company's admins Name, work email, sign-in records and the audit trail of their changes.

OneTap keeps no location trails and stores no coordinates of people. At an office with an area set, the phone sends one position at each tap; OneTap compares it with the area and keeps only the results above, never the position. Face ID and fingerprint never leave the phone: OneTap receives only a signature made after the phone unlocked its key.

3. Purpose

Oltin processes the data only to record attendance for the Company, to keep the attendance and statutory registers the Company needs, and to secure and operate OneTap. Oltin does not sell the data, use it for advertising, or profile employees.

4. Instructions

Oltin processes the data only on the Company's documented instructions: this agreement and the settings the Company chooses in OneTap Admin. Oltin tells the Company if it believes an instruction breaks the law.

5. Security

Oltin keeps the data secure with measures that include encryption in transit (TLS 1.2 or newer) and at rest, isolation of each company's data in the database, keys held in phones' secure hardware, least-privilege access for Oltin staff, and logs of access. Oltin runs security controls aligned with ISO/IEC 27001. People at Oltin who can reach the data are bound by confidentiality.

5A. Support access

The Company instructs Oltin, under section 4, that Oltin's support staff may open the Company's account in OneTap Admin, as far as the Company's owner allows, only to help the Company: to answer its questions, and to find and fix faults.

6. Sub-processors

Sub-processor What it does Where
Google Cloud Hosting and the database Belgium, European Union
Cloudflare Network edge, DNS and protection from attacks Edge locations; data at rest stays in the European Union
Zoho (ZeptoMail) Sending sign-in codes, invites and notices by email Zoho's EU data centre
Apple and Google Checking that a phone and the OneTap app are genuine Their own services

Oltin gives the Company at least 30 days' notice before adding or replacing a sub-processor. The Company may object by writing to Oltin at the address in section 1 before the change takes effect. Each sub-processor is bound by data protection terms no less protective than these.

7. Where the data is kept

The data is stored and processed in the European Union (Belgium). It leaves the European Union only as needed for the phone checks run by Apple and Google, and in transit across the network edge.

8. Personal data breaches

Oltin tells the Company without undue delay, and within 24 hours of becoming aware of a personal data breach, with what is known and what is being done, so the Company can inform the Data Protection Board of India and affected employees within 72 hours. Where CERT-In rules require it, Oltin reports the incident to CERT-In within 6 hours.

9. Employees' rights

OneTap gives the Company the tools to answer employees' requests to see, correct or erase their data, and to name a grievance officer whom employees can reach in the app. Oltin helps the Company meet the timelines the law sets.

10. Keeping and deleting data

Oltin keeps the data while the Company uses OneTap, and keeps statutory records for at least five years as labour law requires. When the agreement ends, the Company can export all its data; Oltin then deletes it within 30 days and issues a certificate of deletion, except for records the law requires to be kept, which are deleted when that period ends.

11. Audits

Oltin gives the Company the information needed to show that this agreement is met, including summaries of independent security assessments. Further audits are agreed in writing.

12. Liability, law and disputes

[To be completed by counsel: limits of liability, governing law of India, and the courts of [city].]

13. Acceptance

The person who signs the Company up accepts this agreement on the Company's behalf. OneTap records the version accepted, the time, and who accepted it.