Privacy Policy

Effective date: 1 July 2026 · Last updated: 1 July 2026

This Privacy Policy explains how TIMEmSYSTEM APS ("TIMEmSYSTEM", "we", "us", "our") processes personal data in connection with the mTIME Next Gen mobile application, its web application, the kiosk application, and related services (together, the "Service"). It is written to meet the requirements of the EU General Data Protection Regulation (GDPR) and the Danish Data Protection Act, and to satisfy the transparency requirements of the Apple App Store and Google Play.

1. Who we are and who controls your data

The Service Provider is:

TIMEmSYSTEM APS
Gærtorvet 3, 1799 København, Denmark
Company registration (CVR) no.: 32783899
Contact: contact@timemsystem.com

mTIME Next Gen is business software provided to organisations (employers) for the management of working time, attendance, and absence. This means two different roles apply, depending on the data:

• Your employer is the data controller for the employee and workplace data processed in the Service (for example your name, working-time records, clock-in/out entries, and absence records). Your employer decides which data is entered, for what purpose, and for how long it is kept. We process that data as a data processor, on your employer's documented instructions, under a data processing agreement. If your employer provided the Service to you, please also read your employer's own privacy notice, and direct requests about your employee records to your employer in the first instance (see "Your rights").
• We are the data controller for a limited set of data where we determine the purposes ourselves — principally account creation and sign-in, authentication and security, communications we send to you about the Service, and keeping the Service secure and operational.

2. What personal data we process

The exact data depends on how your organisation configures the Service and which features are used. The categories below reflect what the Service is capable of storing:

Identity and contact data

• Full name and preferred name
• Email address (work and, where provided by an integration, private email)
• Date of birth
• Phone and mobile number
• Postal/home address

National identifiers and payroll references

• National identification number (e.g. Danish CPR number / social-security number, and foreign SSN/TIN where supplied by a payroll integration)
• Payroll number and employment number

Account and authentication data

• Login email and a securely hashed password (hashed with Argon2id — we never store your password in readable form)
• Passkey / WebAuthn credentials (public-key data only) and single-sign-on identifiers where you use social or corporate sign-in
• Email-verification, password-reset, and invitation tokens (stored only as hashes)
• Session records (see "Technical and security data")

Employment and organisational data

• Job title, department / organisational unit, and manager
• Employment start and end dates and contract/working-time terms
• Working-time norm and full-time-equivalent (FTE) pattern

Time, attendance and work records

• Clock-in and clock-out timestamps and current "clocked-in" status
• Time registrations (hours worked, activities, projects) and any notes you add
• Timesheet statements, approvals, and the identity of approvers, together with an audit history of who submitted, approved, or amended a record and when
• Time-bank / flexitime balances and adjustments

Absence and leave data

• Planned, pending, and used leave and absence periods, including start/end dates and durations
• Absence categories (as defined by your employer) and any free-text reason or note recorded against an absence or clock entry

AI assistant interactions

• The messages you send to the in-app AI assistant, the assistant's responses, and limited context about the page you are on when you ask (which can include the time, absence, or configuration data shown on that page)
• Voice recordings, if you choose to use voice input — the audio is sent for transcription and is not retained as an audio file after transcription (see "Artificial intelligence")

Technical and security data

• IP address and browser/device user-agent string, recorded against each sign-in session for security purposes
• Session metadata (creation time, expiry). Sessions expire after up to 30 days for users and up to 1 year for shared kiosk devices.

3. Special-category and sensitive data

Some data processed in the Service may be "special category" data under Article 9 GDPR, or otherwise specially protected:

• Health-related data: where your employer records sickness absence, or where an absence reason or note describes a health-related matter, this constitutes health data.
• Gender, nationality and citizenship: these may be imported into an employee record where your employer enables a payroll/HR integration that supplies them.
• National identification numbers (e.g. CPR numbers), which are subject to specific legal protection.

Because your employer decides whether and how to record this data, your employer (as controller) is responsible for ensuring an appropriate lawful basis and Article 9 condition (typically the performance of obligations in the field of employment and social-security law). We process such data only on your employer's instructions and apply additional care to keep it secure and access-controlled.

4. How we use personal data and our legal bases

Where we act as processor, we process personal data only to provide the Service on your employer's instructions; your employer determines the purposes and legal bases. Where we act as controller, we rely on the following legal bases under Article 6(1) GDPR:

• Performance of a contract — to create and administer accounts, authenticate users, and make the Service available.
• Legitimate interests — to keep the Service secure, prevent and investigate fraud or abuse, maintain audit and diagnostic records, and operate and improve the Service. We record your IP address and user-agent against sessions to protect account security.
• Legal obligation — to comply with legal, accounting, and record-keeping requirements that apply to us.
• Consent — for any optional feature that specifically asks for it (for example, granting your device microphone access for voice input). You may withdraw consent at any time.

5. Artificial intelligence

The Service includes optional AI features: a conversational assistant that can help you register time, clock in/out, and request or approve leave; voice input; and an assistant-driven search of our help content. These features work as follows:

• Where processing happens. AI processing is performed by our cloud provider Scaleway using AI models hosted in the European Union (Paris, France). Your inputs are not sent outside the EU for AI processing.
• What is sent. When you use the assistant, the content of your messages, the assistant conversation history, and limited context from the page you are viewing are sent to the AI provider to generate a response. If you use voice input, your audio recording is sent for transcription. If you ask about the weather, the place name you provide is sent to a third-party weather service (Open-Meteo) to return a forecast.
• No training on your data. We do not use your data to train AI models, and under Scaleway's terms for its Generative APIs your inputs are not used to train its models.
• You stay in control. The assistant does not take any action (such as booking leave) automatically — proposed actions are shown to you and require your explicit confirmation. See also "Automated decision-making".
• Storage. Your conversations are stored within your organisation's workspace so you can revisit them, and are deleted in line with the retention rules below. Messages you mark as private notes are never sent to the AI provider.

6. Device permissions

The mobile app requests very few device capabilities:

• Microphone — used only if you choose to use voice input with the AI assistant, and only while you are actively recording. Audio is used to transcribe your request.
• Biometrics (Face ID / Touch ID / fingerprint) — if you sign in with a passkey, your device's biometric unlock is handled entirely by your device's operating system. Your biometric data never leaves your device and is never received or stored by us; we only receive a cryptographic confirmation that authentication succeeded.
• Internet access — required for the app to function.

The app does not request access to your location, camera, photos, contacts, or Bluetooth, and does not use push notifications.

7. Cookies and local storage

We use a strictly necessary, secure session cookie to keep you signed in; it is not accessible to scripts and is not used for tracking. The app also stores non-sensitive information on your device (such as your language, theme, and cached profile details) to make the app work and remember your preferences. We do not use advertising cookies, tracking pixels, or third-party analytics cookies, so no consent banner for non-essential tracking is required.

8. Third parties and sub-processors

We share personal data only with service providers who process it on our behalf ("sub-processors"), and with the third parties your organisation chooses to connect. We do not sell personal data. The main recipients are:

We may also disclose personal data where required to comply with a legal obligation, court order, or lawful request from a public authority, or where necessary to establish, exercise, or defend legal claims, or to protect the rights, safety, and security of our users, the public, or TIMEmSYSTEM.

9. International data transfers

Our core infrastructure and all AI processing are located in the European Union, so providing the Service does not routinely involve transferring your data outside the European Economic Area (EEA). Where an optional feature you or your organisation enables involves a provider that processes data outside the EEA (for example, certain single-sign-on providers), such transfers are protected by appropriate safeguards under Chapter V GDPR, such as an EU adequacy decision or the European Commission's Standard Contractual Clauses (SCCs).

10. Data retention

Where we act as processor, retention is primarily determined by your employer, including a configurable employee-data retention period. Our default retention behaviour is:

• Employee records are, by default, retained for 5 years after the end of employment and then automatically anonymised or deleted. Your organisation can adjust this period (including keeping records indefinitely where required by law).
• Deleted items are held in a recoverable state for 30 days (a "trash can") and then permanently purged.
• Data exports generated from the Service are automatically deleted after 30 days.
• Unverified sign-up accounts are automatically removed if the email address is never verified.
• Account, authentication, and security data are kept for as long as your account is active and for a limited period afterwards as needed for security and legal purposes.

When an organisation's workspace is deleted, we guarantee that all customer data is permanently deleted within 2 months, reflecting a 30-day recovery window followed by the expiry of encrypted backups. Full details are set out in our Data Deletion Policy.

11. Your rights

Under the GDPR you have the right to:

• Access the personal data we hold about you;
• Have inaccurate data corrected;
• Have your data erased ("right to be forgotten");
• Restrict or object to certain processing;
• Receive your data in a portable format and, where technically feasible, have it transmitted to another provider;
• Withdraw any consent you have given, without affecting processing carried out before withdrawal.

How to exercise your rights. Because most data in the Service is controlled by your employer, please direct requests concerning your employee records to your employer, who can also delete, export, or correct your data directly in the Service. We will assist our customers in responding to such requests. For data where we are the controller (for example your sign-in account), or if you are unsure who to contact, email us at contact@timemsystem.com.

Complaints. If you believe your data has been handled unlawfully, you have the right to lodge a complaint with a supervisory authority. In Denmark this is the Danish Data Protection Agency (Datatilsynet, www.datatilsynet.dk). You may also contact the supervisory authority in your country of residence.

12. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. The AI assistant may suggest actions or draft entries, but any resulting action requires human confirmation, and time and absence approvals are made by people (such as your manager).

13. Security

We take the security of personal data seriously and apply appropriate technical and organisational measures, including: encryption of data in transit (TLS) and of secrets at rest; strong password hashing (Argon2id) and support for passkeys; strict separation of each organisation's data; role-based access controls and audit logging of actions within the Service; mutual-TLS for sensitive public-sector integrations; and hosting on European cloud infrastructure with monitoring and access controls. No method of transmission or storage is completely secure, but we work continuously to protect your data.

14. Data breach notification

If a personal-data breach occurs, we will act in accordance with Articles 33 and 34 GDPR. Where we act as processor, we will notify the affected customer (controller) without undue delay so they can meet their obligations. Where we act as controller, we will notify the competent supervisory authority within 72 hours where required, and will inform affected individuals where the breach is likely to result in a high risk to their rights and freedoms.

15. Children

The Service is intended for use by employees and workers in a professional context and is not directed to children. We do not knowingly collect personal data from children under 16 (or the higher age of digital consent that may apply in your country). If you believe a child has provided personal data through the Service, please contact us at contact@timemsystem.com and we will take appropriate action.

16. Notice for California residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information is collected, to access and delete it, to correct inaccurate information, and to opt out of the "sale" or "sharing" of personal information. We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we do not use personal information for cross-context behavioural advertising. To exercise your rights, contact us at contact@timemsystem.com. We will not discriminate against you for exercising these rights.

17. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate, notify you within the Service. Previous versions are available on request.

18. Contact us

For any question about this Privacy Policy or how your data is handled, contact:

TIMEmSYSTEM APS
Gærtorvet 3, 1799 København, Denmark
Email: contact@timemsystem.com
Data protection / privacy enquiries: contact@timemsystem.com

You can also find more information about how we handle data at timemsystem.com/gdpr.

TIMEmSYSTEM APS · Copenhagen, Denmark. This Privacy Policy applies to the mTIME Next Gen application on the Apple App Store, Google Play, and the web.