Welcome to SmartClocker! We are committed to protecting your privacy and handling your data in an open and transparent manner. This privacy policy explains how we collect, use, disclose, and safeguard your information when you use our SmartClocker services, including our website and mobile applications (collectively, the "Services").

1. Information We Collect

We may collect information about you in a variety of ways. The information we may collect via the Services includes:

1.1. Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Company name and job title

• Face images (used solely for time tracking verification with your explicit consent and your employer's agreement)

1.2. Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

1.3. Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

2. Face Images Policy

This section outlines our practices specifically concerning the collection, use, disclosure, sharing, and retention of face images ("Face Images") processed by SmartClocker for employee verification purposes.

2.1. Collection of Face Images

SmartClocker collects Face Images strictly for employer-mandated employee verification. This collection occurs when an employee uses the facial recognition feature for time tracking, as agreed upon by their employer. The collection is solely for the purpose of verifying the employee's identity for attendance and work-related activities.

2.2. Use of Face Images

The Face Images collected are used exclusively to verify the identity of the employee during clock-in and clock-out events. This ensures accurate time tracking and helps prevent time theft, aligning with the employer's operational requirements. We do not use Face Images for any other purpose, such as employee monitoring beyond verification, marketing, or profiling.

2.3. Disclosure and Sharing of Face Images

SmartClocker does not share, sell, lease, trade, or otherwise disclose your Face Images with any third parties whatsoever. The Face Images remain within the SmartClocker application and are used strictly for the internal verification purposes outlined above. Access to this data is restricted to authorized personnel and systems directly involved in providing the verification service to your employer.

2.4. Retention and Deletion of Face Images

Face Images are retained for a period of ninety (90) days from the date of collection. After this 90-day period, the Face Images are permanently deleted from our systems. This retention period is established to support employer requirements for record-keeping and dispute resolution related to time tracking. Upon termination of an employee's account or at the request of the employer (in accordance with applicable laws and agreements), Face Images associated with that employee may be deleted sooner.

3. How We Use Your Information

Having accurate information permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Services to:

• Create and manage your account.

• Provide and maintain our Service, including to monitor the usage of our Service.

• Process your transactions and send you related information, including purchase confirmations and invoices.

• Communicate with you about products, services, offers, promotions, and events offered by SmartClocker and others, and provide news and information we think will be of interest to you.

• Improve our Services and develop new products, services, features, and functionality.

• Ensure the security of our Services, including preventing and detecting fraud, and enforcing our terms of service.

• Comply with legal obligations.

Regarding face images, they are used exclusively for verifying employee identity during clock-in/out events as part of the time tracking service subscribed to by your employer. We do not use this data for any other purpose.

4. Disclosure of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

• By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

• Service Providers: We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• With Your Consent or at Your Direction: We may share your information with third parties when you provide consent to do so, or at your direction (e.g., if your employer directs us to share time tracking data with a payroll provider).

5. Data Security

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

Face images are stored securely and protected with strong encryption and access controls. For verification, these images may be converted into encrypted mathematical representations (vectors), and not stored as raw image files in all instances, to enhance privacy and security.

6. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

• The right to access – You have the right to request copies of your personal data.

• The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our contact information below.

7. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Last Modified" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

9. How to Contact Us

If you have any questions about this Privacy Policy, You can contact us: By email: privacy@smartclocker.com