Privacy Policy

This Privacy Policy explains how Smart Solution Labz LLC ("Smart Solution Labz", "we", "us") collects, uses, shares and protects personal data when you use the Clocker application, websites and related services (the "Service"). It also explains your rights under the EU General Data Protection Regulation (GDPR) and Croatian data-protection law.

1. Who is responsible for your data

The data controller for the Service is:

Smart Solution Labz LLC
30 N Gould St, Ste R, Sheridan, WY 82801, USA
Register: Wyoming Secretary of State, filing ID 2024-001386276
Privacy contact: info@s-labz.com

EU representative (Article 27 GDPR). Because we are established outside the European Union, we have designated Smartyn d.o.o., Vladimira Nazora 1b, 40317 Podturen, Croatia (email: info@s-labz.com), as our representative in the EU. You and supervisory authorities may contact the representative on all matters related to the processing of your personal data, in addition to or instead of contacting us directly. This is a separate mandate: the representative does not process personal data on our behalf and is not our processor; support for the Service is our own work.

The seller. Smartyn d.o.o. is also the company that sells paid Clocker subscriptions to customers whose billing country is Croatia, another EU member state, the United States, Bosnia and Herzegovina, or Serbia (businesses registered for VAT there). For those purchases it is a controller in its own right of the data it needs to sell, invoice, collect and account for the purchase - your billing name and address, tax number, contact e-mail, the subscription and its price, invoices and payment records - which it keeps under Croatian tax and accounting law and describes in its Subscription Terms. It does not receive the data your Workspace holds about your staff and clients. Customers in every other country buy from Stripe, as merchant of record, through Link (Section 6).

2. Controller and processor roles

Clocker is a business tool. It matters in what role we process data:

• We are the controller for data about your account, billing and payments, your use of the Service, and our communications with you.
• We are a processor (you are the controller) for personal data that you or your Members enter into a Workspace about identifiable people - for example, employee time records, location check-ins, client (CRM) contact details, bookings, notes and attachments. We process that data on your documented instructions to provide the Service. As the controller of that data, you are responsible for having a valid legal basis and for informing the individuals concerned (for example, your employees about location tracking).

Who to ask for what. If you want your Clocker account itself deleted, or you have a question about sign-in, your subscription status or the app, ask us - see Sections 9 and 10; a question about an invoice or a charge goes to the seller that issued it (Section 1). If you want something changed or removed from the work records your employer keeps in Clocker - working hours, payroll figures, personnel documents, or the entries that record your name as the person who did or approved something - ask your employer. They decide what happens to those records; we act only on their instruction, and we will not delete or alter them because a Member asks us to. The Article 28 GDPR terms of that relationship are set out in our Data Processing Addendum.

3. Personal data we collect

You give us:

• Account data - name, email address, password (stored hashed), company/Workspace details, language and settings, and an optional home/postal address (country, city, postal code and street) that a Member may provide, and that their employer's Administrators may view and maintain, for the employer's payroll and work records. Your account also carries a record of the legal texts you accepted and the privacy choices you made: the time, your answer, the version of the text and the language you saw it in (see Sections 4 and 9).
• Content you submit ("Customer Data") - time records, work hours, work orders, reservations and events, client (CRM) records, notes, tasks, and any files or attachments you upload.
• Payment data - the billing details you enter at checkout (billing name, address, country, tax number) go to the seller for your country. Card payments are processed by Stripe on the seller's account, or by Stripe itself where it is the merchant of record; we receive limited data such as the fact of payment, the amount, the period it covers and a payment reference, so that we can keep your Workspace in step with your subscription. We never see or store card numbers.
• Support and communications - messages you send us, including through the in-app chat with the developer (the text you write, any screenshots or documents you attach, our replies, and, so that we can answer, your email address, the Workspace you were in, your device platform and app language).

We collect automatically:

• Location data - if you use location-based check-in, the Service uses your device location to confirm you are within the allowed radius of a workplace. Location is used for this purpose and related records. On mobile devices you can control location permission in your device settings; disabling it may limit location check-in.
• Device and usage data - device type, operating system, app version, identifiers, log data, the date of your last activity and the platform you used, and, only with your consent, how you interact with the Service (see Section 4, Analytics).
• Push notification tokens - to deliver notifications (for example, invitations or reminders), if enabled.
• Cookies and similar technologies - see our Cookie Notice.

4. Why we use your data and our legal bases

Purpose	Legal basis (GDPR Art. 6)
Provide, operate and secure the Service and your account	Performance of a contract
Keep your Workspace in step with your subscription (the payment result and the period the seller reports to us)	Performance of a contract; legal obligation
Provide support and respond to you	Performance of a contract; legitimate interests
Location check-in (confirming presence at a workplace)	Performance of a contract with the account holder; where you are a Member, the controller (your employer) is responsible for the legal basis, which may be legitimate interests, legal obligation or consent
Maintain security, prevent fraud and abuse	Legitimate interests; legal obligation
Diagnose crashes and keep the app stable (crash reporting)	Legitimate interests (you can opt out in the app)
Understand usage to improve the Service (analytics, in the app and on the website)	Consent (off by default; one question per account in the app, asked again six months after a refusal, and the cookie banner on the website; withdraw at any time)
Keep aggregate service statistics (how many workspaces, invitations or records are created per day, how many devices of each platform are active)	Legitimate interests (counts only, no identifiers)
Send service and, where permitted, marketing messages	Legitimate interests or consent; you can opt out of marketing
Comply with legal, tax and accounting obligations	Legal obligation

Where we rely on legitimate interests, we balance those against your rights. Where we rely on consent, you can withdraw it at any time without affecting prior processing.

Analytics, crash reporting and your in-app controls

We use Google Firebase for optional, non-essential processing, and you control it in the app under Settings > Data & privacy:

• Analytics (Google Analytics for Firebase) helps us understand how the app is used so we can improve it: which screens are opened, which features are used, where people get stuck. It is off by default. We ask you when you first sign in, with two equal choices. Your answer, yes or no, belongs to your account: it applies in the app on every device where you sign in, and the app sends no analytics from a device where nobody is signed in. You can change your answer at any time in Settings; the change reaches your other devices the next time you open Clocker on them. If you say yes, we do not ask again unless the analytics change materially: a new purpose, a new recipient, or a wider reach. If you decline, we leave the question alone for six months and then ask again; declining changes nothing about how the app works for you. When it is on, the app sends a random app-instance identifier (in a browser, the analytics cookie described in the Cookie Notice and the address of the page you are on), the names of the actions we measure, the device model, operating system, app version, language and an approximate country, plus four general facts about your context: your role in the Workspace (owner, manager or employee), the size band of your team, the language you use the app in, and the trade your Workspace works in (one of a short fixed list). It never sends your name, e-mail address, phone number, your company's name, or the content you put into the app - your working hours, clients, notes and files. Everything it does send is a fixed label or a number from a short, predefined list, so no free text can reach it. We never use it for advertising and we do not collect the device's advertising identifier. We keep a record of your answer: when you answered, what you chose, which version of the question and of this Policy you saw, and in which language, so that we can show that consent was given or refused and honour a withdrawal.
• Website analytics (Google Analytics) on clocker.cloud runs only after you choose "Accept all" in the cookie banner. It records the addresses of the pages you open (which also tells us which language version you read), how far you scroll, which links into the app and which trade categories you click, and which questions you open in the frequently asked questions, together with a random visitor identifier stored in a cookie, your browser and device type, and an approximate country. It never contains your name, e-mail address or anything you type. See the Cookie Notice. The website and the web app at /app share one analytics stream and one visitor cookie, so a visit to the site and a later session in the web app count as the same visitor, still without your name or account. Your answer to the banner governs the website; when you are signed in at /app, your account's answer governs the app.
• Crash reporting (Firebase Crashlytics) sends diagnostic reports when the app crashes so we can fix problems. It is on by default as a legitimate interest in keeping the app stable and secure, and you can turn it off at any time in Settings.
• Service statistics. We keep daily counts of how many accounts, workspaces, invitations, time records, reservations, notes and clients are created, how quickly invitations are accepted, which answer new workspaces gave to "how did you hear about us", and how many devices of each platform are active. These are aggregate numbers with no identifiers, kept to run and plan the Service, and unlike analytics they are counted whether or not you consent. To count active devices, your profile stores the date of your last activity and the platform you used; nothing else about your activity is recorded for this purpose.

5. Location data

Because Clocker offers location-based check-in, we want to be clear: location is collected to verify that a check-in happens within a workplace radius configured for a Member. If you are an employer using this feature, you are the controller of your Members' location data and must have a lawful basis and inform your Members. If you are a Member, your employer decides whether location check-in applies to you; direct questions about it to your employer.

6. Who we share data with

We do not sell your personal data. We share it only with:

• Service providers (processors) who help us run the Service under contract, including Google (Firebase Authentication, Cloud Firestore, Cloud Functions, Cloud Storage, Cloud Messaging, App Check with reCAPTCHA on the web, Crashlytics and, only with your consent, Google Analytics) for hosting, infrastructure and diagnostics, and Scaleway S.A.S. (France) for sending email from the Service (reminders, subscription notices). The email provider receives data only once email from the Service is live.
• The seller of your subscription, Smartyn d.o.o. (Croatia), if your billing country is Croatia, another EU member state, the United States, Bosnia and Herzegovina, or Serbia (businesses registered for VAT there): it receives your billing name and address, tax number, contact e-mail, the subscription and its price, and the payment result, and uses them as a controller in its own right to sell, invoice, collect and account for the purchase. It issues its invoices through E-RAČUNI d.o.o. (Croatia), its certified e-invoicing intermediary and processor, which receives the billing details and the invoice lines, and it takes card payments through Stripe on its own account: its agreement is with Stripe Payments Europe, Limited (an Irish company), and the payment itself is carried out by Stripe Technology Europe, Limited, an electronic money institution authorised by the Central Bank of Ireland. The seller receives no data your Workspace holds about your staff and clients, and it does not act on our behalf. E-RAČUNI and Stripe receive data only once paid subscriptions are live.
• Stripe, as merchant of record through Link, if your billing country is any other country, or Serbia without a VAT registration: Stripe sells you the subscription. At its checkout you give Stripe your name, e-mail address, billing address and country, any tax number and your card details directly; Stripe uses them as a controller in its own right to sell, charge, add and remit the tax of your country where it covers it, issue receipts and tax invoices, handle refunds and provide purchase support, and it sends the receipts and notices to you itself, from Link; where Stripe does not cover the tax of your country, the invoice carries our name and details. It decides the purposes itself, as a controller, also for fraud monitoring and detection, preventing financial loss and security risks, its own internal billing, legal compliance including anti-money-laundering and know-your-customer checks, and developing its own products, and its own privacy policy applies to all of that. Our agreement for those purchases is with Stripe, LLC in the United States, which is self-certified under the EU-US Data Privacy Framework and receives personal data under it; if that certification is withdrawn, terminated, revoked or otherwise invalidated, the European Commission's Standard Contractual Clauses apply instead. We receive from Stripe the fact of payment, the amount, the period and a reference.
• Google Maps Platform (Google), which acts as a controller in its own right for that service, not as our service provider: when you open a map or pick a workplace location, Google receives your IP address and the map request, and when you type an address, the text you type goes to Google Places to offer suggestions. Google's own Privacy Policy applies to that service. We do not send it your work records or your team's personal details.
• Apple, if you sign in with Apple (Apple gives us a unique identifier and, unless you hide it, your email address) and for delivering push notifications to iPhones and iPads (Apple's push service receives a device token and the text of the notification). On iPhone, the address of a workplace is looked up by Apple's geocoder.
• Your Workspace - Customer Data you submit is visible to the Administrators and Members of your Workspace according to the permissions you set.
• Authorities or third parties where required by law, to protect our rights, or in connection with a merger, acquisition or sale of assets (with continued protection of your data).

Our current sub-processors are listed in the Data Processing Addendum, section 11; you can also ask at info@s-labz.com.

7. Where your data is stored

The Service's primary data storage is hosted in the European Union (Google Cloud region europe-west3, Frankfurt): the database that holds Customer Data and the file storage that holds your uploads are both in that region. Backups and processing take place under appropriate safeguards.

Sign-in data is the exception. Firebase Authentication - the Google service that holds your email address, your password hash, your telephone number if you sign in with one, your Google or Apple sign-in identifier, and the IP addresses and timestamps of your sign-in events - is operated only in the United States, whatever region the database is in. Push notification delivery, crash diagnostics and usage analytics (Google Analytics, only with your consent) may also be processed outside the European Economic Area. Section 8 explains the safeguards we rely on for those transfers.

8. International transfers

We are a company established in the United States, and some of our providers (for example, Google) and the sellers' payment providers (Stripe, including Stripe, LLC in the United States for purchases through Link) may also process personal data outside the European Economic Area. Customer Data is stored in the European Union (see Section 7); where personal data is accessed from or transferred to the United States or another third country, we rely on appropriate safeguards under Chapter V of the GDPR: where the recipient is certified under the EU-US Data Privacy Framework, the transfer takes place under that adequacy decision, and if a certification is withdrawn, terminated, revoked or otherwise invalidated, the European Commission's Standard Contractual Clauses apply instead. You can request more information about these safeguards at info@s-labz.com.

9. How long we keep data

• Account and Customer Data - for as long as your account is active. When a Free Trial expires or a Subscription ends, we keep your Workspace and its Customer Data for 80 days, so that you can subscribe (or resubscribe) within that window and continue exactly where you left off. If the Workspace owner asked for erasure when cancelling, we delete the Workspace at termination instead (Data Processing Addendum, Section 15.2). After those 80 days we delete or anonymise Customer Data, subject to backups that are overwritten on a rolling basis. You can also ask us to delete it sooner (see Section 10).
• Billing and tax records - held by the seller of your subscription: Smartyn d.o.o. keeps its invoices and accounting records for as long as Croatian tax and accounting law requires; Stripe keeps the records of purchases through Link under its own rules. On our side, the subscription status and payment references are kept for as long as your account exists and as the law requires.
• Support communications - for as long as needed to handle your request and for our records.
• Usage analytics (only with your consent) - event-level data is kept in Google Analytics for 14 months; crash reports for 90 days. The aggregate service statistics described in Section 4 contain no identifiers and are kept for as long as the Service exists.
• Consent and acceptance records - the time, answer, text version and language of your acceptance of the Terms and this Policy, of your analytics choice, of the notice shown to you when you accept an invitation to a Workspace and, for Administrators, of the acknowledgement of the Data Processing Addendum. Kept for as long as your account exists and deleted with it. The record of a customer's consent to automatic renewal, given at checkout, is kept by the seller together with the terms consented to for at least three years for customers in the United States, separately from the Clocker account.
• Server logs - the technical logs of our servers and functions (request metadata, technical identifiers such as an account id, storage paths), including the record that a deletion was carried out, are kept for up to 30 days.

You (or your Administrator) can delete much of your data directly in the Service, and you can request deletion as described below.

Deleting your Clocker account

You can delete your account in the app, or on our account deletion page, which accepts the request itself after you sign in.

Deletion is not instant. Your account is first deactivated and enters a grace period of 40 days: you immediately lose access to every Workspace you belonged to, and during that window you can change your mind and restore the account simply by signing in again. When the window expires, a scheduled job permanently deletes your sign-in credentials, the Clocker account behind them and your personal profile. The deletion does not reach what an employer keeps about you inside its own Workspace. Your employee card stays there, marked in the Service as the card of a deleted account, and everything on it stays with it. That means your first and last name and the details your employer entered: your role, your rate of pay and travel allowance, your national identification or tax number where it entered one, and the personnel documents it put on your card. It also means the contact details that were copied onto the card from your own profile: your email address, telephone number, date of birth and gender, and the home address taken from your profile when you joined. Your employer decides what happens to the card and the data on it: when it removes you from its Workspace, it chooses whether your data there is erased, as described below.

What stays after that, and why. Your employee card stays in each Workspace you were a member of, with everything on it. The records each employer keeps about your work stay too: working-hours records, payroll and payment data, the personnel documents it uploaded, the notes its managers wrote about you, and the operational records that name you as the person who created, edited or approved something. None of that is deleted when you delete your Clocker account. Those are your employer's records, not ours: your employer is the controller, we are only its processor, and in most cases your employer is legally required to keep them for years after your employment ends. We are therefore neither entitled nor able to delete them because you ask us to. Section 10 explains where to take such a request.

When your employer removes you from a Workspace

An Administrator can remove you from a Workspace in one of two ways. Archiving withdraws your access and changes nothing else; the membership can be restored at any time. Deleting your data withdraws your access immediately and starts a cancellable window of 40 days, after which your personnel record in that Workspace is permanently deleted: profile fields, manager notes, uploaded personnel documents and the files behind them, and your own absence and leave requests. Your working-hours and payroll records are kept unless the Administrator explicitly switches that on as a separate, separately confirmed instruction.

After that deletion completes, a minimal record holding only your first and last name and technical flags remains in the Workspace, so that historical entries still display correctly. Your name also remains on the employer's operational records, shown in a muted style. Every removal, cancellation and permanent deletion is written to a log inside the Workspace that records who ordered it and when; that log is kept as evidence of the instruction and is deleted with the Workspace itself.

Removal from a Workspace does not delete your personal Clocker account. It stays yours, with your profile intact, and you can create your own Workspace or accept another invitation with it.

10. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• rectify inaccurate or incomplete data;
• erase your data ("right to be forgotten") in certain circumstances;
• restrict or object to processing in certain circumstances, including objecting to processing based on legitimate interests and to direct marketing;
• data portability - receive your data in a structured, commonly used, machine-readable format;
• withdraw consent at any time where we rely on consent; and
• lodge a complaint with a supervisory authority, in Croatia the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka - AZOP).

To exercise your rights, contact info@s-labz.com. If your request concerns data where your employer or another organisation is the controller (for example, Member or client data in their Workspace), we will direct you to, or notify, that controller. We respond within the time limits required by law (generally one month).

Requests about your work data. If you ask us to erase, correct or hand over the records an employer keeps about you in Clocker, we will confirm we received the request, tell you which organisation is the controller, and refer you to them; where we consider it appropriate we will also let them know that you asked. We will not act on the request ourselves, for two independent reasons: we process that data only as the employer's processor and may not act against the controller's instructions, and the right to erasure does not apply where processing is necessary for compliance with a legal obligation of the controller (Article 17(3)(b) GDPR) - which is usually the case for working-time, payroll and personnel records. This does not limit your rights against your employer, or your right to complain to a supervisory authority. It also does not stop you deleting your Clocker account itself at any time (Section 9).

11. Security

We use technical and organisational measures to protect personal data, including encryption in transit, access controls, authentication, and hosting on reputable cloud infrastructure. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a personal data breach is likely to result in a risk to your rights, we will notify the relevant authority and, where required, affected individuals in line with the GDPR.

12. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. Features such as automatic classification of hours are calculation tools; they do not by themselves make decisions about individuals.

13. Children

The Service is intended for business use by people aged 18 or over and is not directed at children. We do not knowingly collect personal data from children.

14. Cookies

Our websites and the Service use cookies and similar technologies as described in our Cookie Notice.

15. Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes we will provide notice (for example, by email or in the Service) before they take effect. The "Last updated" date at the top shows the latest revision.

16. Contact

For any privacy question or to exercise your rights:

Smart Solution Labz LLC
30 N Gould St, Ste R, Sheridan, WY 82801, USA
Register: Wyoming Secretary of State, filing ID 2024-001386276
Email: info@s-labz.com

EU representative (Art. 27 GDPR): Smartyn d.o.o., Vladimira Nazora 1b, 40317 Podturen, Croatia, email: info@s-labz.com