CENTRUM HOUSING FINANCE LIMITED

EMPLOYEE FIELD ACTIVITY & LOCATION MONITORING PRIVACY NOTICE

Effective Date: August 2026
Version: 1.0
Owner: Human Resources / Legal & Compliance / IT

Centrum Housing Finance Limited (“CHFL”, “Company”, “we”, “us” or “our”) may use its authorised mobile application (“Application”) to record and monitor the official field activities of employees whose roles require customer visits, sourcing, verification, collections, business development or other field duties (“Field Employees”).

1. PURPOSE OF COLLECTION & MONITORING

CHFL may process employee information through the Application for legitimate employment, operational, business, security and compliance purposes, including to:

• record and verify official customer/business visits and field activities;
• verify attendance, movement and visit activity during authorised field-duty hours;
• improve productivity, resource allocation and operational efficiency;
• maintain accurate records of customer and business interactions;
• prevent or investigate misrepresentation, fraudulent activity, misuse of Company resources or other misconduct;
• protect CHFL from financial, operational, legal or reputational loss; and
• comply with applicable laws, regulatory requirements and internal policies.

2. INFORMATION THAT MAY BE COLLECTED

Depending on the employee’s role and the features enabled in the Application, CHFL may collect:

• employee name, employee ID and official contact details;
• GPS/location information, coordinates and location-related visit information;
• date and time of check-in, check-out and field activity;
• customer/business visit details entered by the employee;
• photographs, documents or other information submitted through the Application for official purposes; and
• device, application, authentication and technical information necessary for security and functioning of the Application.

CHFL’s location monitoring is intended to operate during the employee’s authorised working/field-duty hours and for official field activities. CHFL does not intend to use the Application for continuous monitoring of an employee’s private activities outside the scope of official duties.

3. HOW THE INFORMATION MAY BE USED

The information may be used by authorised CHFL personnel for field-force management, operational review, attendance/visit verification, productivity assessment, audit, investigation, compliance, risk management and other legitimate employment-related purposes.

Where necessary, information may also be shared with CHFL’s authorised technology service providers, application providers, auditors, professional advisers or other data processors strictly on a need-to-know basis and subject to appropriate confidentiality and data-protection obligations.

4. ACCESS, SECURITY & CONFIDENTIALITY

CHFL shall implement reasonable technical and organisational safeguards appropriate to protect employee information against unauthorised access, disclosure, alteration, misuse, loss or destruction.

Access to location and field-activity information shall be restricted to authorised personnel based on their functional requirements. Such information shall not ordinarily be disclosed to any person for purposes unrelated to the employee’s employment, CHFL’s business, legal/regulatory requirements or legitimate organisational interests.

5. RETENTION & DELETION

CHFL shall retain employee information, including location and field-activity records, only for the period reasonably necessary for the purposes stated in this Notice, or for such longer period as may be required under applicable law, regulatory requirements, Company policies, audit requirements or for establishing, exercising or defending legal claims.

Information that is no longer required shall be deleted, anonymised or otherwise disposed of in accordance with CHFL’s applicable retention and deletion practices.

6. EMPLOYEE RESPONSIBILITIES

Employees shall use the Application in accordance with CHFL’s applicable policies and shall provide accurate information while recording official field activities.

Employees shall not disable, manipulate, falsify, circumvent or otherwise interfere with the Application’s location, attendance or visit-recording functionality where such functionality is applicable to their role.

7. EMPLOYEE QUERIES & RIGHTS

Employees may contact chflr@centrum.co.in (HR / Data Protection / designated privacy contact) for queries or concerns regarding the collection or use of their personal data, or to exercise rights available to them under applicable law and CHFL’s policies.

Nothing in this Notice limits any right available to an employee under applicable law.

8. POLICY ACKNOWLEDGEMENT

By clicking “I Accept & Proceed”, I acknowledge that:

• I have read and understood this Employee Field Activity & Location Monitoring Privacy Notice;
• I understand that CHFL may collect and process my personal data, including location and field-activity information, for the purposes described above;
• I understand that location monitoring may be undertaken during my authorised working/field-duty hours for verification and management of official field activities;
• I understand that authorised CHFL personnel and authorised service providers may access such information on a need-to-know basis for legitimate purposes; and
• I agree to comply with CHFL’s applicable policies governing the use of the Application and field activities.