This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information?
We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe?
We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights?
To exercise your rights, you may contact us by email at legal@affixapi.com to submit a data subject access request.
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary.
We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at legal@affixapi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may approach your local data protection authority to submit a complaint. If you are in the EU, please see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html. If you are in the UK, you may contact the Information Commissioner's Office, or the relevant data protection authority in your jurisdiction to submit a complaint.
In Short: We aim to protect your personal information through a system of organisational and technical security measures and with a minimalistic approach to data storage and retention.
Our objective is to facilitate seamless interaction between Application developers and HR/Payroll Systems. We take no interest in the content of the data that we process, and as such adopt a minimalistic approach in storing it, keeping data retention as brief as possible, and only for the purpose of processing the data to facilitate the interactions between the Systems and the Applications that you use.
We do not engage in the sale of user data, nor do we process your data for our own purposes.
User data is shared exclusively with the Application (“Application”) and only the data explicitly authorised by the user is disclosed. For valid access tokens, we store cookies, usernames, and passwords to the Systems with which you hold an Account (“Accounts”) which you submit to us via our Services. Usernames and passwords undergo encryption using an AWS KMS symmetric key with key rotation enabled. The encrypted data (ciphertext only) is stored in an AWS DynamoDB table, which is encrypted at rest. The purpose of storing usernames and passwords is to enhance our service quality; without it, a token would only last two weeks. This information allows us to refresh cookies during storage, resulting in tokens with a longer lifespan.
We employ a cache system that temporarily retains the employment data we process for a duration of two hours. This cache is governed by a Time-to-Live (TTL) mechanism, ensuring automatic deletion upon expiration. It's important to note that we do not have direct access to this cached data. The purpose of this cache is twofold: first, to support the functioning of webhooks, and second, to enable us to regulate API requests during periods of high volume. This mechanism is solely in place to facilitate seamless processing and does not grant us the ability to query or access the cached data directly. Our database, AWS DynamoDB, is secured through AWS IAM, with internal systems granted access based on the principle of least privilege. The Customer Managed Key behind AWS KMS, serving as our encryption key, is also secured via AWS IAM with access restricted based on the principle of least privilege.
Logging is conducted using AWS Cloudwatch, and our log retention policy spans two weeks. Client requests and responses are logged, with usernames, passwords, and JWTs redacted from the logs.
To address errors related to user configurations, we may programmatically capture screenshots of errors on a customer account when attempting to fulfil API requests. These screenshots are generated only in the case of unexpected errors and are strictly used for debugging purposes. The retention policy for these screenshots is five days. The S3 bucket temporarily holding this data is encrypted at rest, not public, and additionally has public access block enabled. Upon a developer invoking our /disconnect endpoint, user cookies, usernames, and passwords are permanently wiped from our system.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you use our Services.
Personal Information Provided by You. The personal information that we process depends on the context of your interactions with us and the Services, the choices you make, and the Systems and Applications you use. We process the following categories of information with your consent:
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In Short: We process your information to provide and administer our Services, for security and fraud prevention, and to comply with law.
We process your information for a variety of reasons, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process personal information:
In legal terms, and for the purposes of this privacy policy, we are the 'data processor” under European data protection laws of the personal information described in this privacy notice, since we do not determine the purposes of the data processing we perform. This privacy notice only applies to the personal information we process as a 'data processor' on behalf of our customers. The customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them. If you want to know more about our privacy policy for our Developers and for visitors of our website in which circumstances we are the “data controller”, you may read our Developer Privacy Policy Here.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to process personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
In Short: We may share information with the following categories of third parties.
Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: www.affixapi.com/cookie-policy.
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). All cached data is automatically deleted via TTL after 2 hours. No purpose in this notice will require us keeping your username or password for longer than you are using our services.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@affixapi.com
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (") to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://affixapi.com/cookies.
If you have questions or comments about your privacy rights, you may email us at legal@affixapi.com.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? To exercise your rights, you may contact us by email at legal@affixapi.com to submit a data subject access request.
Verification process: We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary.
We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal: If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at legal@affixapi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may approach your local data protection authority to submit a complaint. If you are in the EU, please see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html. If you are in the UK, you may contact the Information Commissioner's Office, or the relevant data protection authority in your jurisdiction to submit a complaint.
How do you make a complaint? To make a complaint, you may contact us by email at legal@affixapi.com.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
To learn which categories of information we collect, please see the section entitled: WHAT INFORMATION DO WE COLLECT?
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
How do we use and share your personal information?
Learn about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'
Will your information be shared with anyone else?
We may disclose your personal information with our service providers, Systems, and Applications pursuant to a written contract between us and each service provider our Customers. Learn more about how we disclose personal information in the section, WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'
California Civil Code Section 1798.83, also known as the 'Shine The Light' law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a 'residents' as:
All other individuals are defined as 'non-residents'.
If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
We will not discriminate against you if you exercise your privacy rights.
If the business collects any of the following:
you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.
Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.
To exercise your right to limit use and disclosure of sensitive personal information, please email legal@affixapi.com to submit a data subject access request.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by submitting a data subject access request by email at legal@affixapi.com. If you have a complaint about how we handle your data, we would like to hear from you as well.
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
To submit a request to exercise these rights described above, please email legal@affixapi.com to submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at legal@affixapi.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
To submit a request to exercise these rights described above, please email legal@affixapi.com to submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at legal@affixapi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
To submit a request to exercise these rights described above, please email legal@affixapi.com to submit a data subject access request.
'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.
'Sale of personal data' means the exchange of personal data for monetary consideration.
If this definition of 'consumer' applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
You may contact us by email at legal@affixapi.com to submit a data subject access request.
If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary.
We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at legal@affixapi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), John Skilbeck, by email at legal@affixapi.com, by phone at +353 83 071 0944, or contact us by post at:
Affix API Inc.
John Skilbeck
DOGPATCH LABS, UNIT 1
THE CHQ BUILDING, NORTH WALL QUAY
Dublin, Dublin D01 Y6H7
Ireland
If you are a resident in the European Economic Area or Switzerland, we are the 'data processor” of your personal information. We have appointed John Skilbeck to be our representative in the EEA and Switzerland. You can contact them directly regarding our processing of your information, by email at legal@affixapi.com, by visiting http://www.affixapi.com, or by post to:
Affix API Limited
DOGPATCH LABS, UNIT 1
THE CHQ BUILDING, NORTH WALL QUAY
Dublin, Dublin D01 Y6H7
Ireland
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, submit a data subject access request by emailing us at legal@affixapi.com.