Privacy Notice

Last updated: June 25, 2026

1. Who We Are

FashionPay is operated by Elizabeth Esotor ("FashionPay", "we", "us"). For the personal data we collect about account holders and end users of the FashionPay service (the "Service"), we act as the data controller.

When you, as a business customer, upload information about your own staff into the Service, you act as the data controller for that staff data and we act as a data processor on your behalf.

2. Personal Data We Collect

• Account data: name, email address, sign-in credentials, role, company name.
• Staff records you upload: staff names, contact details, department, role, salary, payment method, attendance records, selfies captured at clock-in/out, uploaded documents.
• Location data: approximate location and the factory geofence coordinates used to verify attendance.
• Usage and device data: IP address, browser type, device identifiers, log files, pages visited, actions taken.
• Support data: messages you send us when requesting help.

3. How We Use Personal Data

• To create and manage your account, and provide the Service to you (legal basis: performance of contract).
• To process attendance, payroll calculations and reporting on your behalf (performance of contract).
• To secure the Service, prevent fraud and abuse, and maintain integrity of records (legitimate interests).
• To provide customer support (performance of contract / legitimate interests).
• To improve the Service and develop new features (legitimate interests).
• To comply with legal obligations (legal obligation).
• To send service-related communications and, where permitted, marketing (consent or legitimate interests).

4. Sharing Your Data

We share personal data only with the categories of recipients below:

• Service providers / subprocessors that host, secure and operate the Service (cloud hosting, database, file storage, analytics, email delivery).
• Paddle, our Merchant of Record, for processing subscription payments, subscription management, invoicing and sales-tax compliance. Paddle acts as an independent controller for payment data it collects directly from you at checkout.
• Professional advisers (legal, accounting) where necessary.
• Authorities where required by law or to protect our rights.

We do not sell your personal data.

5. Data Retention

We keep personal data only for as long as needed for the purposes set out above, to comply with legal obligations, or to resolve disputes. When data is no longer needed it is deleted or anonymised. Account and staff data are deleted or anonymised within a reasonable period after you terminate your subscription, subject to backup cycles and legal retention requirements.

6. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, role-based permissions, and private storage buckets for sensitive documents and selfies. No system is perfectly secure, but we work continuously to maintain a high standard.

7. Your Rights

Depending on the laws that apply to you, you may have the right to access, correct, delete, restrict or object to processing of your personal data, to withdraw consent, and to data portability. You also have the right to lodge a complaint with your local supervisory authority. To exercise any of these rights, contact us through the in-app support.

8. International Transfers

Personal data may be transferred to, and processed in, countries other than your own (including in connection with our cloud hosting providers and Paddle). Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.

9. Cookies

We use essential cookies and similar technologies to keep you signed in and to operate core features of the Service. We may also use analytics cookies to understand how the Service is used and improve it. You can manage cookie preferences through your browser settings; disabling essential cookies will prevent the Service from functioning correctly.

10. Children

The Service is intended for businesses and is not directed at children under 16. We do not knowingly collect personal data from children.

11. Changes to This Notice

We may update this Privacy Notice from time to time. We will update the "Last updated" date at the top and, where appropriate, notify you in-app.

12. Contact

For privacy questions or to exercise your rights, contact us via the in-app support channel. The data controller is Elizabeth Esotor, operating FashionPay.