Privacy Policy & Workforce Data Governance Standards

1. Introduction & Overview#

AttendKH ("we", "our", "us", or "AttendKH") is committed to protecting the privacy, confidentiality, and fundamental data protection rights of organizations, employers, and their employees across Cambodia and international operating regions.

This Privacy Policy explains how AttendKH collects, uses, processes, stores, and safeguards personal data when you:

• Use our mobile applications for iOS (App Store) and Android (Google Play Store);
• Access our shared tablet QR Kiosk hardware modes;
• Log into our web applications, manager consoles, and administrative dashboards;
• Connect to our automated Telegram Bot notifications and webhook integrations;
• Visit our public website and marketing resources at attendkh.com.

By downloading, accessing, or using the AttendKH Attendance mobile application or web portal, you acknowledge that you have read and understood the practices described in this policy.

2. Roles & Responsibility: Data Controller vs. Data Processor#

To ensure transparency and compliance with global data protection standards (including GDPR principles and Cambodian personal data protections under the Civil Code and E-Commerce Law):

• Your Employer / Organization (Data Controller): The subscribing business or institution that employs you is the Data Controller. Your employer determines the personnel enrolled in AttendKH, sets authorized workplace geofences, configures shift rosters, approves attendance punches, and establishes compensation and payroll rules.
• AttendKH (Data Processor / Service Provider): AttendKH acts strictly as a Data Processor on behalf of and under the contractual instructions of your employer. We provide secure cloud infrastructure, cryptographic check-in verification algorithms, automated Cambodian labor law payroll calculation engines, and encrypted database storage.

If you are an individual employee with questions regarding why specific attendance rules or shift requirements apply to you, please contact your employer's human resources or operations department directly.

3. Categories of Data Collected by the Attendance App & Platform#

A. Employee Profile & Authentication Identifiers

When an employer registers an employee profile on AttendKH, or when you complete your employee mobile onboarding, we process:

• Full Legal Name & Display Name
• Employee Identification Number (Staff ID)
• Authentication Contact Identifiers (Phone Number or Email): At least ONE contact identifier (either a valid Phone Number for SMS/Telegram OTP verification OR a verified Email Address for magic links/OTP) is strictly required to authenticate your account and receive secure login codes. Providing both contact methods is optional.
• Workplace Branch Assignment: Department, operational team, role/title, and reporting manager
• Wage & Employment Structure: Base hourly or monthly salary parameters, overtime eligibility, standard shift templates, and statutory NSSF insurance classification (used exclusively for automated payslip generation)

B. Point-in-Time GPS Location Data & Geofencing

To verify that frontline staff are physically present at their assigned workplace branch (e.g. boutique store, restaurant, construction site, or office), AttendKH mobile apps query device location services under strict privacy rules:

• Point-in-Time Capture Only: Location coordinates (latitude, longitude, horizontal accuracy radius, and server timestamp) are captured ONLY at the exact millisecond you trigger an active punch event (Clock In, Clock Out, or Break Start/End).
• ZERO 24/7 Continuous Background Tracking: AttendKH NEVER monitors your continuous movement, travel routes, off-shift whereabouts, or location outside active clock-in events. When the mobile app is minimized or closed, GPS sensors remain completely inactive.
• Geofence Radius Verification: The instantaneous GPS coordinate is mathematically compared against the authorized branch perimeter set by your employer (typically 50 to 300 meters). The system records whether the punch occurred "Inside Radius" or "Outside Radius" along with accuracy confidence metrics.
• Mock Location & Anti-Spoofing Detection: The mobile app includes tamper-resistance algorithms that detect simulated GPS positions, third-party mock location apps, and developer-mode spoofing tools to maintain payroll fairness and fraud prevention.

C. Live Biometric / Selfie Photo Verification

To prevent fraudulent "buddy punching" (where one worker clocks in on behalf of an absent colleague) and verify identity at branch locations:

• Live Selfie Photo at Punch: When enabled by your employer, the mobile app or QR Kiosk captures a live front-camera photograph at the exact moment of clock-in.
• Watermarking & Cryptographic Binding: The photo is automatically stamped with cryptographic punch metadata (timestamp, branch ID, employee ID, and GPS coordinates) to prevent photo substitution.
• Restricted Access: Selfie photographs are accessible only to authorized managers and HR administrators of your specific organization for audit and attendance verification purposes.
• NO Third-Party AI Selling or Public Profiling: AttendKH does NOT sell, rent, monetize, or license your facial imagery to third parties, advertising networks, or external facial recognition training datasets.

D. Device Model, Hardware Authorization & Anti-Fraud Telemetry

To ensure mobile app security, authenticate authorized devices, and prevent multi-phone buddy punching or falsified check-ins, the mobile app collects:

• Device Model & Manufacturer (e.g., Apple iPhone 15 Pro, Samsung Galaxy S24, Xiaomi 13): Used to bind your employee profile to your authorized workplace device and prevent ghost clock-ins across unauthorized secondary phones.
• Operating System & Version (e.g., iOS 17.4, Android 14): Used for compatibility, security patching, and app stability.
• Unique App Instance Identifier (UUID) and hardware installation token.
• Network State & IP Address: Used to detect proxy evasion and ensure safe transmission.
• Crash Reports & Diagnostics: Non-identifying error stack traces used exclusively to resolve software bugs.

E. Offline Punch Queue & Local Device Storage

When employees work at remote project sites or provincial locations with unstable cellular connectivity (e.g., construction sites, agricultural facilities, or underground parking):

• Encrypted Local Cache: Attendance punches, timestamps, GPS coordinates, and selfie photos are stored within the mobile app's encrypted local sandbox storage (SQLite/Keychain).
• Automatic Background Synchronization: As soon as the mobile device reconnects to a cellular or Wi-Fi network, queued punches are cryptographically verified and uploaded to AttendKH cloud servers.

F. Payroll, Overtime & Time Records

As attendance data is collected, AttendKH generates and stores statutory workforce records:

• Clock-in and clock-out timestamps, total daily hours, and break durations
• Grace-period late arrivals and early departures calculated against employer shift rules
• Statutory overtime hours categorized into standard overtime (1.5× base rate) and Cambodian public holiday / weekly rest day overtime (2.0× double rate)
• Paid annual leave, sick leave, and special leave accruals and approvals
• Bilingual PDF payslips generated in US Dollars ($) and Khmer Riel (៛) with NSSF statutory contribution breakdowns

G. Messaging & Automated Notifications

• Telegram Bot Integration: If your organization connects AttendKH to Telegram, we store your Telegram User ID and Chat ID to transmit real-time manager alerts (e.g., late arrivals, missed shifts, overtime warnings) and daily attendance summaries.

H. Website Visitors & Sales Inquiries

• Marketing Inquiries: Information submitted through demo requests, pricing inquiries, or contact forms (name, company, business email, phone number, branch count).
• Cookie Consent: User preferences saved via our Cookie Consent banner (Necessary, Analytics, Functional, and Marketing cookies).

4. Mobile Device Permissions Matrix (Apple App Store & Google Play Disclosures)#

In compliance with Apple App Store Review Guidelines and Google Play Developer Policies, the table below outlines all mobile permissions requested by the AttendKH application and their exact operational justification:

5. How We Use Information (Purposes of Processing)#

We process attendance, location, biometric photo, and payroll data strictly for lawful operational purposes:

1. Accurate Attendance Verification: Confirming employee on-site arrival and departure within authorized geographic workplace perimeters.
2. Fraud Prevention & Integrity: Preventing buddy punching, time theft, and clock-in falsification through selfie verification and anti-spoofing checks.
3. Automated Cambodian Payroll Processing: Calculating exact gross wages, grace period deductions, overtime multipliers (1.5× and 2.0×), and bilingual payslip generation.
4. Labor Compliance & Audit Readiness: Maintaining statutory attendance registers required by the Ministry of Labour and Vocational Training (MoLVT) and the National Social Security Fund (NSSF).
5. Operational Team Communication: Delivering real-time Telegram and push notifications for shift swaps, roster schedules, and managerial approvals.
6. Platform Reliability & Security: Monitoring system performance, preventing denial-of-service attacks, and diagnosing technical issues.

6. Legal Bases for Processing#

Under applicable Cambodian regulations (including the E-Commerce Law 2019 and Cambodian Labour Law) as well as international data protection principles, we process personal data under the following legal bases:

• Contractual Necessity: Processing is necessary to fulfill the SaaS subscription contract with your employer and support the employment relationship between you and your employer.
• Compliance with Legal Obligations: Employers must maintain accurate records of working hours, overtime premiums, and social security contributions under Cambodian labor statutes.
• Legitimate Business Interests: Employers have a legitimate commercial interest in securing business facilities, verifying workforce presence, and ensuring payroll accuracy.
• Explicit Consent: Where required by mobile operating systems (iOS and Android), you provide explicit permission when granting camera, location, and notification access.

7. Data Security & Storage Architecture#

AttendKH implements enterprise-grade technical and organizational security measures to protect workforce and attendance data from unauthorized access, loss, or alteration:

• Encryption in Transit: All data transmitted between mobile devices, kiosk hardware, web browsers, and our cloud servers is encrypted using Transport Layer Security (TLS 1.3 / HTTPS) with modern cipher suites.
• Encryption at Rest: All database tables, selfie photo storage buckets, and automated backups are encrypted using AES-256 encryption.
• Credential Protection: User passwords are never stored in plaintext and are hashed using salted Argon2 / bcrypt algorithms.
• Role-Based Access Control (RBAC): System access is partitioned by role (Super Admin, Organization Owner, HR Manager, Branch Supervisor, Frontline Employee). Managers can view only the branches and staff under their direct operational scope.
• Audit Trails: All administrative modifications to punch logs, salary adjustments, and manual time overrides are permanently recorded in immutable audit logs.
• Isolated Multi-Tenant Databases: Organizational records are logically segmented to prevent cross-tenant data exposure.

8. Data Retention & Lifecycle Management#

We retain attendance logs and personal information only for as long as necessary to serve operational purposes and fulfill legal obligations:

• Active Organizational Subscription: Attendance logs, punch timestamps, and payroll archives are retained throughout the active duration of the employer's subscription to maintain continuity of employment records.
• Statutory Labor Law Retention: In compliance with MoLVT guidelines, payroll calculation archives and statutory records are typically retained for up to 3 years to support official labor inspections and tax compliance.
• Verification Selfie Photos: Verification photos are retained for an audit window determined by your employer's configuration (standard 90 to 365 days) and subsequently purged or anonymized.
• Post-Termination Purging: Upon cancellation or termination of an organization's subscription, all associated database records, photos, and employee profiles are permanently deleted from active systems within 60 days, subject to standard encrypted rolling backup lifecycles.

9. Account & Data Deletion Policy (Google Play & Apple App Store Compliance)#

AttendKH provides clear, accessible, and transparent mechanisms for both individual employees and organizational administrators to request the deletion of their accounts and associated personal data:

For Individual Employees:

• If you wish to delete your mobile account credentials, profile details, or personal data, you may submit a request directly to your employer's HR administrator (the Data Controller).
• Alternatively, you can submit an individual deletion request directly to our Data Protection Officer by emailing privacy@MPG_by_ongphaly.com with the subject line "Employee Data Deletion Request". Include your registered phone number, organization name, and Staff ID.
• Upon receiving verified confirmation from your employer or upon account deactivation, all personal authentication tokens, biometric selfie photos, and device identifiers associated with your profile will be permanently deleted from active databases within 30 calendar days.

For Organizations & Business Owners:

• Organization administrators can request complete deletion of their enterprise account, all branch geofences, staff profiles, attendance logs, and payroll records by emailing privacy@MPG_by_ongphaly.com from the verified owner's corporate email address or via the Admin Dashboard.
• All organizational data will be queued for permanent hard deletion across all production servers and storage buckets within 30 days.

10. Third-Party Sub-processors & Zero-Sale Guarantee#

AttendKH upholds a strict privacy standard regarding third-party disclosures:

WE DO NOT SELL, RENT, OR MONETIZE YOUR PERSONAL DATA OR VERIFICATION SELFIES TO ADVERTISERS, DATA BROKERS, OR THIRD PARTIES UNDER ANY CIRCUMSTANCES.

We engage a limited number of trusted enterprise sub-processors solely to deliver essential infrastructure and communications:

11. Your Rights as a Data Subject#

Subject to applicable Cambodian laws and international standards, you have specific rights regarding your personal information:

1. Right of Access & Transparency: You can view your real-time attendance history, punch timestamps, logged hours, leave balances, and generated payslips directly through the AttendKH mobile app.
2. Right to Rectification: If an attendance record is inaccurate (for example, due to a hardware failure or forgotten punch), you have the right to submit a manual punch adjustment request to your manager for review and correction.
3. Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data upon termination of employment or withdrawal of consent, subject to statutory labor record-keeping requirements.
4. Right to Restrict Processing: You may request restrictions on how your data is processed if you dispute its accuracy.
5. Right to Data Portability: Organizational administrators and employees can export attendance logs, overtime reports, and payslips in standardized formats (CSV, Excel, PDF).

To exercise any of these rights, please contact your employer's HR team or contact our privacy team at privacy@MPG_by_ongphaly.com.

12. Workplace Privacy & Anti-Surveillance Safeguards#

AttendKH is designed to balance operational workforce coordination with the fundamental privacy and dignity of frontline workers:

• No Continuous Audio / Video Recording: The mobile app NEVER records audio through device microphones or captures continuous video feeds.
• No Keystroke or Screen Monitoring: The app does NOT capture screenshots, monitor other installed mobile applications, or track browsing activity.
• Off-Duty Privacy: Outside active work hours, the mobile app performs zero monitoring and does not capture any location or status information.
• Kiosk Privacy: When using the shared tablet QR Kiosk mode, photos captured during punch-in are displayed only momentarily on-screen for user confirmation and are not publicly browsable on the physical device.

13. Children's Privacy#

AttendKH is an enterprise business-to-business workforce management platform. We do not knowingly collect, solicit, or maintain personal information from individuals under the legal employment age under the Cambodian Labour Law (under 15 years old for light work, or under 18 years old for general industrial labor). If we learn that personal data of an underage individual has been inadvertently collected without lawful parental or employer authorization, we will take immediate steps to delete the information.

14. Changes & Updates to this Privacy Policy#

We may update this Privacy Policy from time to time to reflect enhancements in our mobile applications, updates to Cambodian regulations, or evolving App Store and Google Play policies.

When material changes occur:

• We will update the "Last updated" date and increment the policy version number at the top of this document.
• We will notify registered employers and mobile users via an in-app notice, banner, or email notification before the updates take effect.
• Continued use of the AttendKH mobile app or web platform after the effective date of an updated policy constitutes acceptance of the revised terms.

15. Contact Us & Data Protection Officer (DPO)#

If you have questions, concerns, feedback, or complaints regarding this Privacy Policy, your personal data, or our mobile attendance security practices, please contact our Data Protection Office:

• Data Protection Officer (DPO): AttendKH Privacy & Security Compliance Team
• Email: privacy@MPG_by_ongphaly.com
• General Support: support@MPG_by_ongphaly.com
• Official Telegram Hotline: @MPG_by_ongphaly
• Phone Hotline: +855 23 999 888
• Operating Hours: Monday to Saturday, 8:00 AM – 6:00 PM (ICT / UTC+7)
• Physical Address: Phnom Penh, Kingdom of Cambodia