Invernisoft LLC Privacy Policy

Information We Collect

Information we collect falls into one of two categories: "voluntarily provided" information and "automatically collected" information.

"Voluntarily provided" information refers to any information you knowingly and actively provide us when using our app and its associated services.

"Automatically collected" information refers to any information automatically sent by your device in the course of accessing our app and its associated services.

Device Data

Our app may access and collect data via your device's in-built tools, such as:

• Device/app history

When you install the app or use your device's tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.

Personal Information

We may ask for personal information - for example, when you submit content to us or when you contact us — which may include one or more of the following:

• Name
• Email
• Date of birth
• Phone/mobile number
• Home/mailing address

Biometric Information

Mintage Pulse is operated as a shared clock-in station on premises controlled by your employer. Where your employer has enabled facial verification, we may collect and process:

• A facial image captured by the device camera at the moment you clock in or out
• A mathematical representation (template) derived from that image, used solely to confirm that the person at the device matches the employee record selected
• The result of each verification attempt, recorded against the corresponding clock event

We collect this information only to verify identity at the point of clocking in or out. We do not use facial images or templates to identify you in any other context, to infer characteristics about you, for advertising, or for any purpose unrelated to attendance verification. Facial verification is configured by your employer and can be substituted with an employee PIN.

Facial templates are transmitted over an encrypted connection and stored on servers operated by Invernisoft LLC on behalf of your employer. They are held in the same secured environment as your employer's other Mintage Workforce records and are not shared with any third party.

Location Information

When you clock in or out, we may record the precise location of the device — the geographic coordinates of the device at that moment — so that your employer can confirm attendance was recorded at an expected worksite. For a fixed kiosk this is the site at which the device is installed. Where your employer has enabled clocking in for remote or field-based staff, the precise location of the device at the moment of the clock event is recorded and attached to that event.

We record location only at the moment you clock in or out. We do not track the location of the device between clock events, we do not collect location while the app is in the background, and we do not track your personal device outside the app.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Where we process biometric information, we do so on the basis of your employer's legitimate interest in accurately recording attendance and preventing time fraud, and, where required by applicable law, on the basis of consent obtained before enrolment. You may withdraw consent to facial verification and use an employee PIN instead; contact your employer or use the contact details below.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our app:

• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies
• When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our app's core features and services
• for internal record keeping and administrative purposes

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring you do not make your personal information publicly available via our platform.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information such as an email address when contacting us about a specific enquiry, we may retain this information for the duration of your enquiry remaining open as well as for our own records so we may effectively address similar enquiries in future. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Facial images captured for verification are discarded immediately after the verification attempt completes and are not retained. Facial templates are retained only for as long as necessary for the purpose for which they were collected: for as long as you remain an active employee in your employer's Mintage Workforce account, and no longer than 30 days after your employee record is deactivated or your enrolment is removed, after which they are permanently deleted. Location recorded with a clock event is retained as part of the attendance record, under your employer's own retention settings.

Children's Privacy

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary or affiliate of our company
• our employees, contractors, and/or related entities
• our existing or potential agents or business partners
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
• third parties, including agents or sub-contractors who assist us in providing information, products, services, or direct marketing to you
• third parties to collect and process data
• an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

• Stytch

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Downloading of Personal Information: We provide a means for you to download the personal information you have shared through our app. Please contact us for more information.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Biometric information: You may request access to, correction of, or deletion of the biometric information held about you. Because Mintage Pulse is provided to your employer, such requests are ordinarily made to your employer, who is the controller of your attendance records. You may also contact us directly using the details in the Contact Us section, and we will act on the request or direct it to your employer.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal information for their own purposes (known as "data controllers") and organizations that process personal information on behalf of other organizations (known as "data processors"). We, Invernisoft LLC, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian's consent to process your personal information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, you may consent to your name and email address being used so we can respond to your enquiry. While you may request that we delete your contact details at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance With the Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Biometric Data (Special Category Data)

Biometric data is a special category of personal data under Article 9 of the GDPR. Where the GDPR applies, we process it only where an Article 9(2) condition is met — ordinarily explicit consent obtained at enrolment, or where processing is necessary for the purposes of carrying out obligations in the field of employment law. A data protection impact assessment is available to employers on request.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that we restrict the processing of your personal information if:

1. you are concerned about the accuracy of your personal information;
2. you believe your personal information has been unlawfully processed;
3. you need us to maintain the personal information solely for the purpose of a legal claim; or
4. we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

Deon Thomas
support@invernisoft.com