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Legal

Privacy Policy

Last updated: June 18, 2026

1. Data Controller

Avos is the controller of personal data collected through the platform, in accordance with applicable data protection laws.

2. Data Collected

We collect the following data:

  • Account data: name, email, password (hashed)
  • Company data: legal name, tax identifiers, address
  • Employee data: name, documents, banking details, salary
  • Usage data: access logs, IP address and user-agent (browser/device), and platform actions — retained for security and fraud prevention
  • Selfie at time-clock punch (when enabled by the employer) — used only to validate who recorded the punch

Selfie at time-clock punch

When the employer enables photo validation, a selfie is captured at punch time for the EXCLUSIVE purpose of confirming who recorded the time entry (fraud prevention), based on the employer’s legitimate interest and legal working-time obligations. The image is not used for facial recognition or any other purpose, is linked to the corresponding immutable record, is accessible only to authorized company managers, and is kept for the same legal retention period as the time records, being deleted afterwards. Data subjects can exercise their rights through the channels in this policy.

3. Purpose of Processing

Data is used exclusively for: (a) providing the contracted Service; (b) payroll calculation; (c) service communications; (d) legal compliance; (e) fraud prevention.

4. Legal Basis

Data processing is based on contract performance, legal obligation, and legitimate interest, in accordance with applicable data protection legislation.

5. Data Sharing

We do not sell personal data. We share only with essential infrastructure providers, public authorities when required by law, and payment processors for billing.

6. Data Retention

We retain data for the period necessary to provide the Service and for at least 5 years after account closure to comply with legal obligations.

7. Your Rights

As a data subject, you have the right to:

  • Confirmation and access to your data
  • Correction of incomplete or incorrect data
  • Data portability
  • Deletion of data, where applicable
  • Information about data sharing

8. Security

We employ encryption at rest and in transit (TLS 1.3), role-based access control (RBAC), daily backups, and continuous security monitoring.

9. Contact — DPO

Data Protection Officer (DPO): privacy@useavos.app