This Policy explains how Gapsmiths handles personal data in the Bandobast platform. Bandobast is supplied to organisations — typically police and law-enforcement bodies. For the operational data held in the system, your organisation is the Data Fiduciary (the entity that decides why and how the data is processed) and Gapsmiths acts as a Data Processor on its instructions. If you are an officer whose details are in Bandobast, please raise requests with your own organisation in the first instance.
1. Who we are
Bandobast is operated by Gapsmiths, B 14 Munjal Nagar, Off Eastern Express Highway, Chembur, Mumbai 400071, Maharashtra, India (GSTIN 27AAPFG1889E1Z0). This Policy covers the website at bandobast.online, the web application at app.bandobast.online, the Bandobast mobile applications, and our backend services.
2. Our role in your data
Where an organisation uses Bandobast to plan deployments and manage its personnel, that organisation determines what data is entered and why. It is the Data Fiduciary. We process that data on its behalf and under its instructions, as its Data Processor, in line with our Terms of Use and the service agreement with it.
We are the Data Fiduciary for a limited set of data we control directly — for example enquiries sent to us through this website or by email, and our own billing and business records.
3. Data we process
3.1 Account and identity data
- name, official email address and mobile number;
- badge or belt number, rank, designation and posting;
- the organisation, station and unit to which the account belongs;
- role and permission assignments within the Service; and
- authentication data — a password stored as a salted hash (never in plain text), and where sign-in through Firebase is used, the associated identifier.
3.2 Personnel records
Records the organisation maintains about its personnel for deployment purposes: name, badge and belt number, rank and designation, force type and unit, contact number, email, address, reporting officer, parent unit, and where uploaded, a photograph.
3.3 Operational data
- events, sanction details, jurisdiction, and the deployment hierarchy;
- locations and posts, including their geographic coordinates, and the assessments recorded against them;
- allocations, duty rosters, shift assignments and attendance or duty register entries;
- external force units, accommodation, catering, vehicle passes and equipment records; and
- issues, instructions and notes recorded against a deployment.
3.4 Technical and usage data
- IP address, device and browser characteristics, and application version;
- server and application logs, including timestamps and requested endpoints; and
- push notification tokens, where the mobile application is used and notifications are enabled.
3.5 Audit records
The Service maintains an audit trail of significant actions — who created, changed, approved or deleted a record, when, from which IP address, and what the values were before and after. Audit entries are hash-chained so that tampering can be detected. These records exist to make deployments accountable and cannot be edited by users.
3.6 Enquiries
If you contact us, we process your name, contact details and the content of your message so that we can respond and keep a record of the exchange.
4. Biometric and location data
Two categories warrant specific mention because they are more sensitive than ordinary records.
4.1 Facial recognition data
Where an organisation enables the optional face enrolment feature, the Service derives a mathematical representation (an “embedding”) from a personnel photograph, to assist with verifying identity at deployment. In relation to that feature:
- the embedding is biometric data and is treated as such;
- it is stored in the organisation’s own database record for that person, is not shared with other customers, and is not used to train any model;
- it is derived from the stored photograph and can be recomputed, so it is not the sole copy of anything;
- it is deleted automatically when the person’s photograph is removed or when the feature is switched off for their organisation; and
- the feature is off unless the organisation deliberately enables it, and the organisation is responsible for having a lawful basis and for informing the personnel concerned.
4.2 Location and vehicle tracking
The Service records coordinates for deployment locations, and — where an organisation uses the vehicle tracking feature — the position, speed and heading of tracked vehicles over time, together with the call sign, registration number and, where entered, the driver’s name and phone number. This is operational tracking of duty vehicles during an event. It is visible to authorised users within that organisation and is retained under the organisation’s retention settings.
5. Why we process it
| Purpose | Data involved |
|---|---|
| Providing the Service — planning events, assessing locations, allocating personnel, running rosters | Account, personnel and operational data |
| Authentication and access control | Account and authentication data |
| Notifying personnel of duty and roster allocations, including over WhatsApp and push notifications | Name, mobile number, allocation details, push tokens |
| Accountability and audit | Audit records, IP address, timestamps |
| Security, fraud and abuse prevention, and diagnosing faults | Technical and usage data, logs |
| Support, and communicating about the Service | Account data, enquiry content |
| Billing, taxation and statutory records | Customer contact and billing details |
We do not sell personal data. We do not use Customer Data for advertising, and we do not use it to train machine-learning models for other customers.
6. Lawful basis
Where we act as a Processor, the lawful basis is determined by the organisation. Typically this is the performance of its statutory and public functions, its legitimate interests in managing its workforce and operations, compliance with legal obligations, or — where required — consent obtained by it.
Where we act as a Data Fiduciary in our own right, we rely on the performance of our contract with the customer, our legitimate business interests in operating and securing the Service, compliance with legal obligations, and consent where consent is the applicable basis.
7. Sharing and disclosure
We disclose personal data only in these circumstances:
- Within the customer organisation — to users authorised by it, subject to their role and permissions.
- To sub-processors that help us operate the Service, as listed in section 8, under contracts that restrict their use of the data to providing services to us.
- Where required by law — to comply with a valid legal obligation, court order or lawful request from a competent authority. Where we are legally permitted to do so, we will inform the customer before disclosing its data.
- To protect rights and safety — where necessary to investigate or prevent fraud, a security incident, or a threat to the safety of any person.
- In a business transfer — if our business is merged, acquired or reorganised, subject to the acquirer being bound by commitments no less protective than this Policy.
8. Sub-processors
We use the following categories of sub-processor. Each is engaged under contract and receives only the data necessary for its function.
| Provider | Function | Data involved |
|---|---|---|
| Microsoft Azure | Cloud hosting of the application and database | All hosted data |
| Amazon Web Services (CloudFront) | Content delivery for static assets and uploads | Stored files and images |
| Mapbox | Maps, geocoding and map tiles | Coordinates and search terms sent to render maps |
| Google Firebase | Authentication and push notification delivery | Identifiers, device tokens, notification content |
| Meta Platforms (WhatsApp Business) | Delivery of duty and roster messages over WhatsApp | Recipient number and message content |
A current list is available on request from info@gapsmiths.com. We will give customers notice of a material change to this list so that they may object.
9. International transfers
We host the Service on infrastructure located in India wherever we reasonably can. Some sub-processors listed above operate globally, and limited data — such as push notification payloads, WhatsApp message delivery and map requests — may be processed outside India by them. Where that occurs, we rely on contractual protections with those providers and on transfers to jurisdictions not restricted under applicable Indian law.
10. Retention
Where we act as a Processor, we retain Customer Data for as long as the customer’s subscription is active and as instructed by the customer.
On termination, and on written request made within thirty (30) days, we will make Customer Data available for export. After that window we delete or irreversibly anonymise it within a further ninety (90) days, except where retention is required by law or is necessary to establish, exercise or defend a legal claim.
Backups are retained on a rolling cycle and are overwritten in the ordinary course, typically within thirty-five (35) days. Face embeddings are deleted as described in section 4.1. Audit records are retained for the period the customer specifies, because their purpose is accountability over time. Invoices and tax records are retained for the period required by Indian taxation law.
11. Security
We apply safeguards appropriate to the sensitivity of the data, including:
- encryption in transit using TLS across all endpoints;
- encryption at rest for the database and stored files;
- passwords stored only as salted hashes, never recoverable in plain text;
- role-based access control, so users see only what their role and posting permit;
- a tamper-evident, hash-chained audit trail of significant actions;
- restricted administrative access on a need-to-know basis, with access logged; and
- regular patching, backups and monitoring.
No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to protect data using measures proportionate to the risk.
12. Your rights
Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you may have the right to:
- obtain confirmation of, and access to, your personal data;
- have inaccurate or incomplete data corrected or completed;
- have data erased where it is no longer needed;
- withdraw consent where processing is based on consent;
- nominate another person to exercise your rights in the event of death or incapacity; and
- have a grievance addressed, and to complain to the Data Protection Board of India.
How to exercise them. If your data is in Bandobast because of your employment or posting, your organisation controls that record — please contact its administrator or nodal officer. If you approach us directly, we will refer your request to the relevant organisation and assist it in responding. For data we hold as Data Fiduciary — such as an enquiry you sent us — write to info@gapsmiths.com. We respond to requests within thirty (30) days, and will verify your identity before acting.
13. Children’s data
The Service is intended for use by adults acting in a professional capacity. It is not directed at children, and we do not knowingly collect personal data of children. If we learn that such data has been provided, we will delete it.
14. Cookies and local storage
This website uses no analytics, advertising or third-party tracking cookies.
The application at app.bandobast.online uses cookies and browser storage that are strictly necessary for it to work — to keep you signed in, to hold your session and authentication token, and to remember interface preferences such as language and selected filters. These are not used to track you across other websites. Blocking them will prevent the application from functioning.
15. Breach notification
If we become aware of a personal data breach affecting Customer Data, we will notify the affected customer without undue delay, with the information available to us about the nature of the breach, the data involved, its likely consequences and the steps taken. We will assist the customer with its own notification obligations to the Data Protection Board of India and to affected individuals.
16. Changes to this Policy
We may update this Policy from time to time. We will revise the “Last updated” date above and, where the change is material, notify customers by email or through the Service before it takes effect.
17. Grievance officer & contact
In accordance with the Information Technology Act, 2000 and the rules made under it, and the Digital Personal Data Protection Act, 2023, our grievance contact is:
- Entity Gapsmiths
- Address B 14 Munjal Nagar, Off Eastern Express Highway, Chembur, Mumbai 400071, Maharashtra, India
- Email info@gapsmiths.com
- Phone +91 99805 32789
- GSTIN 27AAPFG1889E1Z0
- Response Acknowledged within 48 hours; resolved within 30 days
If you are not satisfied with our response, you may complain to the Data Protection Board of India.