Privacy Policy

1. Overview

This Privacy Policy explains how ChronoSeal processes personal data when providing its time-recording and verification platform ("Service").

ChronoSeal is designed to ensure data integrity, transparency, and independent verifiability of time records, while minimising unnecessary exposure of personal data.

2. Roles Under GDPR

For employee data processed through the Service:

• The Customer (employer) is the Data Controller
• ChronoSeal acts as the Data Processor

ChronoSeal processes personal data only on behalf of the Customer, only for the purpose of delivering the Service, and in accordance with applicable data protection laws (including GDPR). ChronoSeal does not independently determine the legal basis for employee data processing.

3. Categories of Data Processed

Employee Identification Data

• Name
• Internal staff ID / user ID
• Work location

Time Event Data

• Clock-in / clock-out / break events
• Timestamps (client and server)
• Session date
• Device or kiosk identifier

Authentication Data

• Login email (for admin and employee access)
• PIN (stored as a secure hash, never in plain text)
• Authentication and access logs

System Integrity Data

• Cryptographic hashes
• Event chain references
• Seal data and timestamp proofs

ChronoSeal does not process special category data (e.g. biometric, health, or sensitive personal data) by default.

4. Purpose of Processing

Personal data is processed strictly to:

• Record employee working time
• Maintain an immutable, tamper-evident audit trail
• Provide verification of recorded time
• Enable employer oversight, reporting, and compliance workflows
• Provide employee access to their own records
• Ensure system security and prevent misuse

ChronoSeal does not use employee data for advertising, profiling, or independent commercial purposes.

5. Legal Basis

The legal basis for processing is determined by the Customer (Data Controller), typically:

• Compliance with legal obligations (e.g. labour law requirements)
• Legitimate interest in maintaining accurate work records
• Contractual necessity

ChronoSeal processes data solely under the Customer's instructions.

6. Data Integrity and Transparency

ChronoSeal is built around data integrity and full auditability:

• All events are stored in an append-only structure
• Records cannot be altered or deleted
• Corrections are recorded as new entries, preserving full history

Employees may access their own records via a secure self-service portal, view complete event history and sealed records, export their records and verification bundles, and independently verify the integrity of their records.

7. Public Verification

ChronoSeal provides optional public verification of sealed records using a cryptographic reference (hash). Public verification does not expose personal identity data. Only minimal, non-identifying information is displayed. The hash acts as an access key to verification.

8. Data Retention

ChronoSeal operates a non-destructive data model. Recorded events are not deleted. Records remain part of a continuous audit chain. ChronoSeal supports retention requirements under applicable labour laws, including retention of employee time records for a minimum of four (4) years where required. Customers are responsible for defining retention policies and ensuring compliance with applicable laws.

9. Data Security

ChronoSeal implements appropriate technical and organisational measures, including:

• Encryption in transit (TLS)
• Secure hashing of sensitive data (e.g. PINs)
• Role-based access controls
• Rate limiting and lockout mechanisms
• Logging of security-relevant events

10. Subprocessors

ChronoSeal may use trusted third-party providers to deliver the Service, including cloud infrastructure providers, authentication services, payment providers, and timestamping authorities. All subprocessors process data only as necessary and are subject to contractual data protection obligations. A list of subprocessors may be provided upon request.

11. Data Location and International Transfers

ChronoSeal processes and stores data within the European Union. All primary infrastructure — application hosting, databases, and cloud functions — is located in Western Europe (EU data centres). Where supporting services involve processing outside the EEA, appropriate safeguards are applied, including Standard Contractual Clauses (SCCs) and transfers to providers with adequacy decisions.

12. Data Subject Rights

Employees may exercise their rights via their employer (Data Controller), including access to their data, rectification (implemented via correction entries), restriction of processing, and data portability.

Due to the append-only nature of the system, records are not deleted or altered. Corrections are recorded as new events. This ensures preservation of the audit trail.

13. Data Minimisation

ChronoSeal is designed to store only necessary data, avoid unnecessary personal identifiers, and separate identity from verification wherever possible. Public verification systems do not expose personal data.

14. Changes to this Policy

ChronoSeal may update this Privacy Policy. Material changes will be communicated via email or in-app notification. Continued use of the Service constitutes acceptance of the updated policy.