Privacy Policy

Slash Limited ("we", "us", or "our") is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, and safeguard information across our workforce management platform, including the web platform, the iOS mobile application, and the Android mobile application (collectively, the "Service").

1. DATA COLLECTION AND ATTENDANCE METHODS

We collect data necessary to provide workforce management and attendance verification. This includes:

1. 1.1 Account & Identity Data: Names, employee IDs, and contact information.
2. 1.2
   Attendance & Verification Data: Depending on the methods selected by the Customer (the employer), we collect:

   • Biometric Data: Facial templates for Facial Recognition verification.
   • Visual Data: Photos captured at the time of clock-in/out.
   • Location & Proximity Data: GPS coordinates, Bluetooth Beacon proximity, NFC tag interactions, and Wi-Fi network identifiers (SSIDs).
   • Scanning Data: Data from QR Code scans.
3. 1.3 Technical Data: IP addresses, device models, and operating system versions.

2. HOW WE USE YOUR INFORMATION

We use the collected data for the following purposes:

1. 2.1 Attendance Verification: To confirm that an employee is present at the designated work location using the methods listed in Section 1.
2. 2.2 Service Optimization: To train and optimize our AI scheduling and verification algorithms using anonymized and aggregated data (data that cannot be traced back to an individual).
3. 2.3 Security & Troubleshooting: To detect fraudulent attendance logs and improve system reliability.

3. DATA SECURITY & ATTENDANCE IMAGES

We implement industry-standard security measures to protect all data processed within our Service. Regarding visual verification and facial recognition:

1. 3.1 Image Storage: We store photos captured during the attendance process to allow Employers to verify the identity of employees. These images are stored securely on our cloud infrastructure and are accessible only to authorized account administrators.
2. 3.2 Processing Purpose: Images and facial data are used solely for the purpose of workforce management, identity verification, and preventing attendance fraud. We do not sell or trade this visual data to any third party.

4. EMPLOYER (CUSTOMER) RESPONSIBILITIES

As our Service is a tool used by employers, the Customer (the employer) is the Data User under the Hong Kong PDPO. By using the Service, the Customer warrants that:

1. 4.1 They have obtained explicit, written consent from employees before collecting sensitive data, specifically Facial Recognition and GPS/Location data.
2. 4.2 They have provided employees with a Personal Information Collection Statement (PICS) explaining why these specific attendance methods are used.
3. 4.3 They will only use the collected data for legitimate employment-related purposes.

5. DATA SHARING AND DISCLOSURE

We do not sell personal data. Data is shared only with:

1. 5.1 The Customer (Employer): All attendance logs, photos, and verification data are shared with the account administrator.
2. 5.2 Service Providers: Infrastructure providers (e.g., AWS, Google Cloud) and payment processors (Stripe).
3. 5.3 Legal Necessity: If required by Hong Kong law enforcement or the PCPD.

6. DATA RETENTION

We retain data for the duration of the subscription. Upon termination of service, we will delete or anonymize personal data within a reasonable timeframe, unless retention is required for legal or tax purposes.

7. YOUR RIGHTS UNDER PDPO

In accordance with the Hong Kong Personal Data (Privacy) Ordinance, users have the right to:

1. 7.1 Inquire whether we hold their data and request access to it.
2. 7.2 Request the correction of inaccurate data.
3. 7.3 Withdraw consent for specific data collection (though this may result in the inability to use certain attendance features).

8. INTERNATIONAL TRANSFERS

Data may be processed on secure servers located outside of Hong Kong. By using the Service, you consent to the transfer of data across international borders for hosting and backup purposes.

9. CHANGES TO THIS POLICY

We reserve the right to update this policy to reflect changes in technology or Hong Kong law. Continued use of the Service after updates are posted constitutes acceptance of the revised policy.