Privacy Policy

IV. Sensitive Information

We may collect sensitive information, a subset of personal data that includes biometric identifiers (for example, facial recognition templates or biometric verification data) used exclusively for automated authentication or identification.

• Minimised collection: While we aim to limit the amount of sensitive data gathered, our biometric features inherently require collection of such information from you and, where applicable, your employees.
• Consent-based: We collect sensitive information only with the explicit consent of the individual (you or your employees). By using our services, you confirm that consent has been obtained.
• Strict usage: Sensitive information is used solely to enable and secure access to our services. We never use it for direct marketing, and we do not share it with third parties except to the extent necessary to deliver our services (for example, with service providers who support our authentication processes).

V. Cross Border Disclosure

We store and process all personal information and personal data within New Zealand and Australia to ensure it is subject to the protections of the New Zealand Privacy Act 2020 and the Australian Privacy Act 1988. Our primary data storage and processing environment is hosted on AWS servers in Australia.

When we engage reputable third-party service providers—such as cloud infrastructure hosts, data backup services, or platform partners—to support the delivery of CleverTime’s platform and related services, we require them to process and retain your data within New Zealand, Australia, or in other jurisdictions offering equivalent data protection standards.

Before establishing any cross-border arrangement, we perform due diligence to confirm that these providers implement robust security, confidentiality, and privacy controls. We also enter contractual agreements requiring them to uphold the same level of data protection as we do under this Policy.

VI. Verifying and Updating Your Personal Details (As Applicable)

We implement reasonable technical and organisational safeguards—such as encryption, secure backups, and access controls—to protect your data from misuse, loss, unauthorised access, or modification. To ensure this, we recommend that you notify us of errors, omissions or changes in your Personal Information or Personal Data (as applicable). This is especially important for information required for us to communicate with you, such as a change in name, email, phone number or address.

VII. Protecting Your Information and Personal Data (As Applicable)

At CleverTime, we implement comprehensive technical and organisational safeguards to protect your personal information or personal data from misuse, loss, unauthorised access, modification, or disclosure. Key measures include:

• Encrypting data both in transit and at rest, and performing regular backups of our databases;
• Maintaining rigorous procedures to ensure that the personal information or personal data we collect, use, or disclose remains accurate, complete, and up to date;
• Securing personal information or personal data with physical protections, network security controls, access restrictions, and continuous monitoring;
• Permanently deleting or irreversibly anonymising personal information or personal data when it is no longer required for its original purpose.

While we strive to uphold industry-standard security practices, no system can guarantee absolute protection against all risks—such as human error or deliberate attacks by third parties. We also rely on customers to safeguard their login credentials and prevent unauthorised use.

VIII. Your Right to Accessing Your Personal Information or Personal Data and Requesting Corrections (as applicable)

You have the right to access any of your Personal Information or Personal Data (as applicable) that we hold, with some exceptions as allowed by law. To obtain a copy of this information, contact us and we will provide it to you. CleverTime reserves the right to charge a reasonable fee for the provision of this information.

If you would like to correct any records of Personal Information or Personal Data (as applicable) we have about you, you are able to access and update that information (subject to the above exceptions) by contacting us via the details set out below. support@clevertime.com

IX. Your Consent to Our Data Practices

By continuing to use our products, services, or websites, you affirm your consent to CleverTime’s collection, use, and disclosure of your Personal Information or Personal Data as described in this Policy. All such data held in connection with our cloud-based SaaS products and services will be erased or irreversibly anonymised no later than 60 days following the termination of your service agreement.

X. Resolving Privacy Complaints

We have established formal procedures to address any privacy-related concerns you may have. When you raise a complaint, we will:

• Engage with you to clarify the nature and details of the issue;
• Request a written description of your complaint, if needed, to ensure we fully understand the matter;
• Provide an estimated timeline for our investigation and response;
• Explain the legal or policy basis for any decisions we make in resolving your complaint.

We maintain a register of all privacy complaints and the actions taken in response. Our goal is to resolve issues promptly, thoroughly, and transparently.

To submit a complaint, please contact us at support@clevertime.com.