1. Who is responsible for the data
Our role depends on whose data it is.
- Account data of customers and web users, such as owners, admins and payroll staff: we are the data controller.
- Worker data, such as photos, faces, working hours and wages: the company using TrongTime (the employer) is the data controller, and we process the data on its behalf and on its instructions.
2. Data we collect
Web users (owners, admins, payroll staff)
- Name, email address and profile picture from your Google account, if you sign in with Google
- Company name, site names, phone number and the approximate number of workers entered at sign-up
- Sign-in records: date and time, IP address and browser type
- Proof of accepting the terms of use: who accepted, the version, date and time, IP address and browser type
- Plan and payment history. Card numbers are held by Stripe; we never see or store them
Supervisors using LINE
- LINE user ID, display name, the LINE groups linked to sites, command messages and photos sent to the group
Workers (processed on behalf of the employer)
- Group photos sent by supervisors, and face images cropped from them
- Facial data used to recognize individuals. This is biometric data, a sensitive category under Section 26 of the PDPA
- The name given by the employer, clock-in, clock-out and break times, work sites, wage rates and calculated wages
- Whether consent to collect their face has been given
Visitors to this website
- This website uses no cookies and no tracking. Our hosting provider may log IP addresses briefly for security
3. How we use data
| Purpose | Legal basis |
|---|---|
| Record time, recognize faces, and calculate hours and wages as the customer has set them up | Contract with the customer (Section 24(3)), and for faces, the explicit consent the employer obtains from each worker (Section 26) |
| Create accounts, sign users in and email sign-in codes | Contract (Section 24(3)) |
| Keep proof that the company accepted the terms of use | Contract (Section 24(3)) and legitimate interests (Section 24(5)) |
| Collect fees and issue payment documents | Contract (Section 24(3)) and accounting and tax obligations (Section 24(6)) |
| Prevent repeat free trials, keeping email addresses, phone numbers and LINE IDs only in a form that cannot be reversed | Legitimate interests (Section 24(5)) |
| Keep the service secure, prevent misuse and fix problems | Legitimate interests (Section 24(5)) |
| Tell you about important account matters, such as a trial about to end | Contract (Section 24(3)) |
We do not sell data or use it for advertising, and we use faces only to record time for the company concerned. We do not use photos, faces or any other customer data to train or improve AI models, ours or anyone else's, and we have told the face recognition provider not to use the data to improve its own services.
4. How long we keep data
| Data | Period |
|---|---|
| Photos sent by supervisors | Deleted automatically after 90 days, or as the company has set |
| Faces of workers who have not given consent | Deleted within 14 days |
| Faces of workers the company removes | Deleted immediately everywhere they are stored |
| Working hours and wages | As long as the service is used, as the employer's record of payment |
| Proof of accepting the terms of use | As long as the company's account exists. Nobody can change or delete it; it goes with the company account |
| Trial accounts that do not buy a plan | Everything is deleted 60 days after the trial ends, with 7 days' notice |
| Cancelled accounts | Kept for 90 days after the end of the paid period so data can be exported, then deleted with 7 days' notice |
| System backups | Deleted data may remain in backups for up to 30 days |
| Data that prevents repeat trials (transformed) | As long as it is needed to prevent repeat sign-ups |
| Payment documents | For the period required by accounting and tax law |
5. Service providers
We use the following providers to run the service. Each one uses the data only to provide its service to us.
| Provider | Used for | Data location |
|---|---|---|
| Amazon Web Services | Server, and face recognition (Amazon Rekognition) with the facial data it uses | Australia (Sydney) |
| Supabase | Database | Australia (Sydney) |
| Cloudflare | Photo storage and serving this website | Asia-Pacific (photos) and a worldwide network (website) |
| LY Corporation (LINE) | Messages and photos in LINE groups | Japan and other countries LINE uses |
| Resend | Sign-in code and account emails | United States |
| Stripe | Payments | United States |
| Sign-in with a Google account (only for those who choose it) | United States and other countries Google uses | |
| Sentry | Recording system errors so we can fix them | United States |
Apart from these providers, we may disclose data when the law requires it, for example under a court order.
6. Transfers outside Thailand
Most data is stored outside Thailand. The server, the database, and face recognition with the data it uses to recognize faces are in Australia (Sydney). Photos and the face images cropped from them are stored with Cloudflare in Asia-Pacific.
Some providers process data in Japan or the United States, as listed in section 5. We transfer only what the service needs under the contract, and choose providers with suitable data protection agreements and security standards, in line with Sections 28 and 29 of the PDPA.
7. Security
- All data is encrypted in transit
- Each company's data is kept apart at the database level; one company cannot see another's
- Photos are kept in private storage, opened only through short-lived links by people allowed to see them, with a record of who opened them
- Access within a company follows roles: owner, admin, payroll and viewer
- If a data breach happens, we will tell the affected companies without delay and, where we are the controller, notify the Office of the Personal Data Protection Committee within the time the law requires
8. Your rights
Under the PDPA, data subjects have the right to
- access and get a copy of their data, and ask for it to be sent or transferred
- have their data corrected
- have their data deleted, restrict its use, or object to its use
- withdraw consent at any time, without affecting what was done before
- complain to the Office of the Personal Data Protection Committee
Web users can contact us at support@trongtime.com. We reply within 30 days.
Workers should contact their employer first. The employer can delete your face and data from the workers page. If you withdraw consent to keeping your face, the employer will delete it and record your time another way. If you cannot reach your employer, contact us and we will pass the request on and help.
9. How to delete data
- Delete one worker: an owner or admin deletes them on the workers page. Their face is deleted at once everywhere it is stored; working hours and wages stay as the record of payment.
- Stop collecting from a LINE group: unlink the group on the sites page. The bot no longer records photos from that group.
- Delete the whole company account: the account owner asks at support@trongtime.com. We confirm who you are, then delete all data, faces included, within 30 days.
- Cancelling, or not buying after the trial: the system deletes the data on its own after the periods in section 4, with 7 days' notice.
- Delete your own web user account: ask at support@trongtime.com.
Backups expire on their own within 30 days of a deletion. Payment documents are kept for the period required by accounting and tax law.
10. Cookies
This website uses no cookies. The web app uses only the cookies needed to keep you signed in. There are no advertising or tracking cookies.
11. Changes to this policy
For significant changes, we will tell you by email or in the web app at least 30 days before they take effect, and show the date of the last update at the top of this page.
12. Contact us
TrongTime, email support@trongtime.com