Privacy policy

Effective from Oct. 23, 2026. Last updated: Oct. 23, 2026.

This policy explains what personal data ClockWitness processes, why, on what legal basis, for how long and what rights you have over it. It applies worldwide: whatever country you live or work in, we give everyone the level of protection of the European Union's General Data Protection Regulation (GDPR).

Who we are and how to contact us

ClockWitness is provided by Espírito Rebelde Publicidade e Marketing Lda.

Address: Rua da Fábrica 222, Armazém 2, 4470-768 Maia, Portugal

Registration number: 509360378

Privacy and data protection contact (DPO): Bruna Teixeira, privacy@clockwitness.com. Use this address for any question about this policy or about your data.

Who decides about your data

ClockWitness is used by companies, our customers, to record their teams' working time. So, depending on the data, we have one of two roles:

  • Workspace data — the hours, screenshots, activity and location of a customer company's team members. The company (the employer) decides what data is collected, for what purpose and for how long: it is the controller. ClockWitness is the processor: it processes this data only on the company's behalf and on its instructions.
  • Account, billing and website data — here, ClockWitness is the controller.

If you work for a company that uses ClockWitness and have a question or request about your workspace data, contact your employer first: it decides about that data. If you contact us directly, we will forward the request to the company and help it respond.

What data we process and why

We use data for work purposes only: to provide the service, bill for it, keep it secure and comply with the law. We do not sell personal data, we do not use it for advertising and we do not build marketing profiles.

Account data

Name, email address, password (stored only as a hash, never in plain text), company, role (owner, manager or team member), language and time zone and, if you turn on two-factor authentication, that second factor's secret. We also record the devices linked to the account (computer name, operating system and agent version) and, in an audit log, important actions, with date, time and IP address. This is used to create and manage the account, authenticate whoever signs in and protect the service.

Hours and time records

Start and end of each work session, breaks, project and activity, task descriptions and corrections made to the records. If the company uses those features, also schedules, shifts, absences and leave, and hourly rates to calculate pay or bill its own clients.

Screen captures

While a session is recording on the computer, the desktop agent takes screenshots of every monitor, at the frequency the company sets (by default, about one every 2 minutes). The company can turn screenshots off for the whole team or for specific people. Every time someone views another person's screenshots, it is recorded in the audit log.

Activity

Per time interval: whether there was keyboard and mouse activity (never what is typed or which keys are pressed), periods of inactivity, and a statistical summary of the rhythm of mouse movements, used to flag patterns that look automated — a signal for review by a person, never an automated decision. If the company keeps it switched on, also the name of the applications and the title of the windows in the foreground and the time spent in each. ClockWitness is not a keylogger and does not record video of the screen.

Location (mobile app)

Only if the company requires it and the person grants location permission on the phone: the GPS coordinates at clock-in and clock-out and the workplace they correspond to. If the company turns on automatic clock-in and clock-out by zone, the app sends its position to detect arrival at or departure from a workplace. We do not store routes or continuous location throughout the day.

Billing

Company name, country, tax (VAT) number, account owner's email, plan, number of people, payment and credit history, and the customer and payment-method identifiers the payment provider returns to us. The billing address and card details are entered directly on the payment provider's page; card details never pass through our servers.

Website and communications

When you visit the website, our servers process your IP address and technical request data (browser, page requested) to serve the pages and prevent abuse. If you request an account or sign up, we process what you enter in the form (company, name, email, phone, team size, partner code). We send service emails (invitations, password recovery, notices about the trial period and payments, reports and alerts you set up) and, if you turn them on, browser notifications. If you write to us, we use your message to reply. To diagnose faults we collect technical error reports, configured to leave out personal data such as IP addresses and cookies.

Legal basis

  • Contract — to create and manage the account, provide the service the company signed up for, bill for it and send service communications.
  • Legitimate interest — to keep the website and the service secure, prevent abuse and fraud, keep the audit log and diagnose errors. We do so proportionately, and you can object (see “Your rights”).
  • Consent — when we ask for it, for example to turn on browser notifications. You can withdraw it at any time, without affecting what was done before.
  • Legal obligation — to keep billing records for the period the law requires and to respond to lawful requests from the authorities.

For workspace data, it is the company, as controller, that determines the legal basis (for example, the employment contract, a legal obligation to record working time or its legitimate interest) and that must inform its team. In any case, this data is used for work purposes only.

Who receives the data

We do not sell or rent personal data. We use only external hosting services, where the application, the database, screenshot storage and backups run, and which process the data only on our instructions; and a payment provider, which processes subscription payments. If you turn on browser notifications, they are delivered by your own browser's notification service, with the content encrypted. Within a customer company, each person sees only what their role allows. We disclose data to the authorities only when the law requires it.

International transfers

We host the personal data we process in data centres in the European Union, and we store our backups in the European Union in encrypted form.

Some of our authorised personnel, and some external service providers (for example external hosting, infrastructure, payment, email and technical support services), may access or process personal data from countries outside the European Economic Area (EEA). This includes countries that the European Commission has not recognised as providing an adequate level of data protection. Where this happens, we transfer or allow access to personal data only under one of the safeguards in Chapter V of the GDPR:

  • an adequacy decision of the European Commission for the country concerned, including, for the United States, the EU–U.S. Data Privacy Framework where the recipient is certified under it; or
  • the Standard Contractual Clauses adopted by the European Commission, together with a transfer impact assessment and any additional measures it shows are needed.

Everyone who accesses personal data from outside the EEA must protect it to the same standard we owe you under the GDPR, and must not give it less protection. In particular: they are bound by confidentiality obligations; they receive only the access their role needs; they access the data only through encrypted, authenticated connections, and access is logged; they must not keep copies outside our systems; they may use the data only on our instructions.

In exceptional cases where none of these safeguards applies, we rely only on a derogation in Article 49 of the GDPR, for example where the transfer is necessary to perform a contract with you or at your request.

You can ask for more information about these safeguards, or for a copy of them, by writing to privacy@clockwitness.com.

For customers: if you, or users you authorise in your workspace, access ClockWitness data from outside the EEA, that access is made on your instructions and under your responsibility as controller, and you are responsible for making sure it meets the data protection laws that apply to you.

How long we keep data

  • Screenshots: for the period each customer company sets, between 30 and 365 days (90 days by default). When the period ends, they are permanently deleted.
  • Hours, activity, applications and location: for as long as the company's account exists, until the company closes it.
  • Account data: for as long as the account exists. When a company closes its account, we give it an export of its records and then delete the organisation, its records and its stored screenshots.
  • Billing: for the period required by tax and accounting law.
  • Backups: daily database backups are kept for 30 days; the other backups rotate and are replaced periodically. Deleted data disappears from the backups as they expire.

Your rights

You have the right to access your data and obtain a copy; to rectify inaccurate data; to request erasure; to restrict processing; to receive your data in a structured, commonly used format (portability); to object to processing based on legitimate interest; and to withdraw consent at any time, where processing is based on it.

To exercise these rights, write to privacy@clockwitness.com. We reply within one month; in complex cases this period may be extended, and we will tell you if so. We may ask you to confirm your identity. For workspace data, address your request to your employer; if you send it to us, we will forward it and help the company respond.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular the one in the country where you live or work, or in the country where the alleged infringement took place.

Security

All connections are encrypted (HTTPS); passwords and device tokens are stored only as hashes; two-factor authentication is available to everyone and the company can make it mandatory; access to screenshots depends on each person's role and is logged; and backups are encrypted before they leave the server. More details on the Security and privacy page.

Cookies

The website uses only its own cookies, none for advertising or analytics. The full list, with the purpose and duration of each, is in the Cookie policy.

Automated decisions

We do not make solely automated decisions that produce legal or similarly significant effects on you.

Changes to this policy

We may update this policy. The date of the last update appears at the top of this page; if the changes are significant, we will notify account owners by email.