Legal & Compliance

Privacy Policy – NoBadge

GDPR-compliant data processing for employee time tracking. EU servers, transparent data handling, full accountability.

NoBadge is an EU-hosted employee time tracking platform that processes personal data strictly in accordance with the General Data Protection Regulation (GDPR). All data is stored on servers located within the European Union. We collect only the minimum data necessary to provide attendance tracking services to SMEs with 5–100 employees.

EU Servers Only GDPR Compliant No Data Selling 100% Uptime
EU

Data Residency

GDPR

Full Compliance

72h

Breach Notification

30d

Data Deletion on Request

Data Controller

1. Data Controller

The data controller for all personal data processed through the NoBadge platform is:

  • Company: Innovazione su misura di Catana Petronela
  • VAT Number: IT 12533670019
  • Address: Via Val Della Torre, 81 – Torino (TO) – Italy
  • Email: info@nobadge.it
  • Support: support@nobadge.it

For any privacy-related enquiry or data subject request, please contact us at the email addresses above or via WhatsApp.

Data We Collect

2. Personal Data We Collect

NoBadge processes only the minimum personal data required to deliver employee attendance tracking services. The following categories of data are collected depending on your role (employer/admin or employee):

2.1 Account Holders (Employers / Admins)

  • Identity data: first name, last name, company name
  • Contact data: email address, phone number (optional)
  • Billing data: VAT number, billing address, payment method (processed via secure third-party payment processor)
  • Usage data: login timestamps, IP address, browser/device type, platform activity logs

2.2 Employees (End Users)

  • Identity data: first name, last name (entered by employer)
  • Contact data: email address or phone number (for platform access invitation)
  • Location data (GPS): GPS coordinates at the time of clock-in/clock-out events — collected only when the employee actively initiates a time stamp via the app
  • Attendance data: clock-in/clock-out timestamps, total hours worked, overtime, absences, approved leave
  • Device data: device type, operating system version, app version (for technical support purposes)

2.3 Website Visitors

  • Technical data: IP address, browser type, referral source, pages visited, session duration
  • Cookie data: as described in our Cookie Policy
Legal Basis

3. Legal Basis for Processing

NoBadge processes personal data under the following legal bases as established by GDPR Article 6:

Contractual Necessity

Processing your account and billing data is necessary to provide the NoBadge service under our Terms and Conditions.

Legitimate Interest

Processing usage and technical data to ensure platform security, stability, and improvement of our employee time tracking service.

Legal Obligation

Retaining billing and tax records as required by Italian and EU fiscal regulations. Compliance with Working Time Directive obligations for employers.

Consent

Where required (e.g. marketing communications, non-essential cookies), we obtain explicit consent which can be withdrawn at any time without penalty.

GPS Data & Employee Tracking

4. GPS Location Data – Special Considerations

NoBadge collects GPS location data only at the moment an employee actively triggers a clock-in or clock-out event. We do not track employee location continuously.

This is a fundamental design principle of our GPS time tracking feature. Specifically:

  • GPS coordinates are recorded as a point-in-time snapshot, not a continuous track
  • Location data is used solely to verify the employee was within a configured geofence at the time of stamping
  • Employees are clearly informed by the app UI before each GPS-enabled stamp
  • Employers can configure a tolerance radius — location data outside working hours is never collected
  • Anti-spoofing measures are in place to prevent falsification of location data

Employer Responsibility: When using NoBadge for GPS attendance tracking, the employer acts as a data controller for their employees' personal data. Employers are responsible for informing their employees about GPS data collection in accordance with applicable labour law and GDPR requirements in their jurisdiction (e.g. Working Time Regulations UK, ArbZG Germany, RDL 8/2019 Spain).

Retention

5. Data Retention Periods

NoBadge retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law.

Data Category Retention Period Basis
Account data (employer) Duration of contract + 2 years Contractual
Attendance records (employees) As set by employer (min. 2 years recommended) Legal obligation (varies by country)
Billing & invoicing data 10 years Italian fiscal law (D.P.R. 633/1972)
GPS location snapshots Same as attendance records Contractual / Legal
Website analytics / logs 13 months Legitimate interest
Marketing consent records Until consent withdrawn + 1 year Consent

Upon account deletion or termination of service, personal data is anonymised or securely deleted within 30 days, except where retention is required by law.

Data Sharing

6. Data Sharing and Third Parties

NoBadge does not sell, rent or trade personal data to third parties. We share data only in the following limited circumstances:

Infrastructure & Hosting Providers

We use EU-based cloud infrastructure providers to host the NoBadge platform. All providers are GDPR-compliant and bound by data processing agreements (DPAs).

Payment Processors

Billing information is processed by our certified payment processor. NoBadge does not store full payment card details on its servers. Transactions are encrypted and PCI-DSS compliant.

Communication Services

Transactional emails (account invitations, password reset, notifications) are sent via a GDPR-compliant email delivery service. Only necessary data (email address, name) is shared.

Legal Requirements

We may disclose personal data if required by law, court order or regulatory authority. We will notify affected users where legally permitted to do so.

"NoBadge processes employee attendance data exclusively within the European Union. No personal data is transferred to countries outside the EEA without appropriate safeguards in place."

Your Rights

7. Your Data Subject Rights

Under GDPR, you have the following rights regarding your personal data. These rights apply to both employers/admins and employees whose data is processed through the NoBadge platform:

Right of Access

Request a copy of all personal data we hold about you.

Right to Rectification

Request correction of inaccurate or incomplete personal data.

Right to Erasure

Request deletion of your personal data where there is no overriding legal basis for retention.

Right to Restriction

Request that we restrict processing of your data in certain circumstances.

Right to Portability

Receive your personal data in a structured, machine-readable format (CSV/Excel export available directly from the platform).

Right to Object

Object to processing based on legitimate interest, including direct marketing communications.

How to exercise your rights: Send your request to info@nobadge.it or via WhatsApp. We will respond within 30 days. No fee is charged for standard requests.

You also have the right to lodge a complaint with your national data protection authority. In Italy: Garante per la Protezione dei Dati Personali (garante.it). In the UK: Information Commissioner's Office (ico.org.uk).

Security

8. Data Security Measures

NoBadge implements industry-standard technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction. Key measures include:

🔐

Encryption in Transit

All data transmitted between your device and our servers is encrypted using TLS 1.2+.

🗄️

Encryption at Rest

Personal data stored in our EU databases is encrypted at rest using AES-256.

🔑

Access Controls

Role-based access control (Admin / Manager / Employee). Principle of least privilege enforced throughout.

🛡️

Anti-Spoofing

GPS anti-spoofing layer and dynamic QR codes (regenerated every second) prevent fraudulent time entries.

📊

Audit Logs

All administrative actions are logged with timestamp and user identity for accountability.

100% Uptime SLA

Redundant EU infrastructure ensures continuous availability of your attendance data.

In the event of a personal data breach that poses a risk to individuals' rights and freedoms, NoBadge will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33.

Employer Obligations

9. Employer Responsibilities (Data Controller)

When an employer (company or individual) uses NoBadge to track employee attendance, the employer acts as a data controller for their employees' personal data. NoBadge acts as a data processor on behalf of the employer.

This means employers are responsible for:

  • Informing employees about the use of NoBadge for attendance tracking before deployment
  • Ensuring a valid legal basis exists for processing employee attendance and location data under applicable national law
  • Complying with local labour law requirements (e.g. Working Time Regulations UK, ArbZG Germany, RDL 8/2019 Spain)
  • Responding to employee data subject requests relating to their attendance records
  • Configuring data retention settings within the platform in accordance with applicable legal requirements

Data Processing Agreement (DPA): A Data Processing Agreement between NoBadge (as processor) and the employer (as controller) is available upon request. Contact info@nobadge.it to obtain a signed DPA.

Cookies

10. Cookies and Tracking Technologies

The NoBadge website uses cookies and similar technologies. We use:

Strictly Necessary

Session cookies required for platform login and security. Cannot be disabled.

Functional

Cookies that remember your preferences (language, display settings). Enabled by default but can be disabled.

Analytics

Anonymised analytics to understand how visitors use the website and improve our service. Requires consent.

For full details, see our Cookie Policy. You can manage your cookie preferences at any time via the cookie settings banner.

International Transfers

11. International Data Transfers

NoBadge's infrastructure is hosted exclusively within the European Economic Area (EEA). We do not routinely transfer personal data outside the EEA.

In the limited cases where a third-party service provider may process data outside the EEA (e.g. certain analytics or communication tools), we ensure that appropriate safeguards are in place, including:

  • European Commission Standard Contractual Clauses (SCCs)
  • Adequacy decisions by the European Commission
  • Binding Corporate Rules where applicable

For UK users: following Brexit, NoBadge treats UK data subjects with the same protections as EEA data subjects. The UK GDPR applies in full to all processing of UK residents' personal data.

Policy Updates

12. Changes to This Privacy Policy

NoBadge may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. When we make material changes, we will:

  • Update the "Last updated" date at the top of this page
  • Notify registered account holders by email for significant changes
  • Display a notice on the platform dashboard for 30 days following material changes

Continued use of the NoBadge platform after the effective date of any changes constitutes acceptance of the revised Privacy Policy.

Last updated: January 2025  |  Version: 2.0  |  Applies to: nobadge.eu and nobadge.it and all associated subdomains

FAQ

Frequently Asked Questions – Privacy & GDPR

Common questions about how NoBadge handles personal data and GDPR compliance for employee time tracking.

Yes. NoBadge is fully GDPR compliant. All data is stored on EU servers, we collect only the minimum data necessary, we have a 72-hour breach notification procedure, and we support all data subject rights (access, erasure, portability). A Data Processing Agreement is available for employers who require one.

No. NoBadge only captures a GPS coordinate at the precise moment an employee actively triggers a clock-in or clock-out. There is no continuous background tracking. This design minimises data collection and keeps the system proportionate and GDPR-compliant. Employees are always informed before each GPS stamp.

All NoBadge data is stored exclusively on servers located within the European Union. No personal data is transferred to countries outside the EEA without appropriate GDPR safeguards. UK users benefit from the same protections under the UK GDPR framework.

Yes. Under GDPR, employees have the right to erasure. Requests should be directed to the employer (as data controller) or to NoBadge at support@nobadge.it. Data is deleted within 30 days where there is no overriding legal obligation to retain it (e.g. labour law retention requirements in your country).

Yes. Employers acting as data controllers must inform employees about the use of NoBadge for attendance tracking before deployment. This includes informing them about GPS data collection, the purpose of processing, and their data subject rights. NoBadge provides a template employee information notice upon request.

Yes. A signed Data Processing Agreement between NoBadge (processor) and the employer (controller) is available upon request. Contact info@nobadge.it to obtain a DPA. This is recommended for all business customers and required under GDPR Article 28 when a controller engages a processor.

GDPR-Compliant Time Tracking

Track attendance with confidence.
Zero compliance risk.

NoBadge gives SMEs a legally compliant, EU-hosted employee time tracking solution — no hardware, no complexity, no hidden costs. Start your 15-day free trial today.

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