SASPOLA EMPLOYEE — PRIVACY POLICY

Privacy, clearly handled.

This Privacy Policy explains how SASPOLA Employee handles personal and device data when authorized employees use the mobile application for activation, identity verification, location verification and attendance-related functions.

Effective date
24 September 2026
Application
SASPOLA Employee
Operator
IDG金融貿易株式会社 (D&B legal entity name: IDG KINYU BOUEKI K.K.; English business name: IDG Financial Trading Co., Ltd.)
01

Scope and role of SASPOLA Employee

SASPOLA Employee is a workforce application made available to authorized employees and other approved workforce users of organizations that use SASPOLA. It is not a public social network or consumer advertising application.

Your employer or the organization that provides your SASPOLA access may determine which attendance, identity, work-pattern and related workforce features are enabled for you. That organization may also be responsible for certain employment records and instructions concerning your use of the App.

02

Information we may process

The information processed depends on the features enabled by your organization and the actions you take in the App.

  • Identity and workforce information, such as your name, employee number or other workforce identifier, company or tenant association, account status and activation status.
  • Activation and authentication information, including activation tokens, enrollment status, verification results and security-related records used to protect access to the App.
  • Attendance information, such as clock-in and clock-out times, attendance events, attendance status and related work-schedule or leave information where those features are enabled.
  • Precise location information when location verification is required for an attendance or location-based feature. Location is used to validate the attendance action or permitted workplace area, not for advertising.
  • Camera and facial-verification information when identity verification is enabled, including images or facial-verification data necessary to enroll or verify an authorized employee.
  • Device and technical information, such as device type, operating-system and App version, device or installation identifiers, network information, security events, diagnostic information and error logs where necessary to operate, secure and troubleshoot the service.
  • Support and communications information you or your organization provide when requesting assistance.
03

How we use information

  • Activate the App and associate an installation with the correct organization.
  • Authenticate authorized employees and help prevent impersonation, unauthorized access and attendance fraud.
  • Verify location where location-based attendance controls are enabled.
  • Record and administer attendance events and related workforce workflows.
  • Operate, secure, maintain and improve SASPOLA Employee and its supporting services.
  • Investigate errors, misuse, security incidents and support requests.
  • Comply with applicable legal, regulatory, employment-record and audit requirements.
04

Location data

SASPOLA Employee may request precise device location when you use a feature that requires location verification, such as verifying your workplace location or submitting an attendance action. The App uses this information to determine whether the attendance action satisfies the location rules configured by your organization.

We do not use precise location data to serve targeted advertising. If a future version introduces a materially different location practice, this policy and any required in-app disclosure or consent will be updated before that practice is used.

05

Camera and facial verification

Where facial verification is enabled, SASPOLA Employee may use the device camera to capture an image for employee enrollment or verification. Facial-verification processing is used for identity and attendance-security purposes and is not used for advertising.

SASPOLA currently uses Luxand technology for facial-verification functions. Facial images or derived verification data may be transmitted to or processed by service providers acting on behalf of SASPOLA, depending on the configured verification flow. Authorized administrators may be able to enroll, re-enroll or revoke an employee's facial-verification enrollment.

06

Service providers and disclosure

We may provide data to service providers that process information on our behalf and only as necessary to provide, secure, host, support or maintain SASPOLA Employee. These may include facial-verification providers, cloud hosting and database providers, infrastructure providers and security or diagnostic service providers.

We may also disclose information where required by law, to protect the rights or security of users and the service, or in connection with a corporate transaction subject to appropriate safeguards. We do not sell employee personal data for advertising purposes.

07

Data security

We use technical and organizational safeguards designed to protect personal data, including access controls, authenticated access, encrypted network transport, role-based administration and security logging where appropriate. No system can be guaranteed to be completely secure, and users must protect their device and authentication credentials.

08

Retention and deletion

We retain information for as long as reasonably necessary to provide the App, maintain security and audit records, support the legitimate workforce and recordkeeping needs of the relevant organization, and satisfy applicable legal obligations.

Where permitted, employees may request access, correction or deletion of personal data through their employer or organization administrator, or by contacting us. Some attendance, security, audit or employment records may need to be retained where deletion is not legally or operationally permitted.

09

International processing

SASPOLA and its service providers may process information in countries other than the country where you are located. Where required, we use appropriate contractual, technical and organizational measures to protect personal data when it is processed internationally.

10

Children

SASPOLA Employee is intended for authorized workforce users and is not directed to children. Organizations using the App are responsible for ensuring that users are legally permitted to use the workforce service under applicable law.

11

Your choices and rights

Depending on your location and applicable law, you may have rights concerning your personal data, including rights to access, correct, restrict, object to certain processing, or request deletion. Because SASPOLA Employee is commonly provided through an employer or organization, some requests may need to be coordinated with that organization.

You can also control operating-system permissions such as camera and location permissions through your device settings. Disabling a permission that is necessary for an attendance-security feature may prevent that feature from working.

12

Changes to this policy

We may update this Privacy Policy to reflect changes to SASPOLA Employee, legal requirements or our data practices. The effective date shown above will be updated when this policy changes materially.

PRIVACY — CONTACT

Privacy contact

For privacy questions, data-rights requests or concerns about SASPOLA Employee, contact IDGFT. If your account is provided by an employer or another organization, you may also contact that organization's authorized administrator.

Privacy enquiries
info@idgft.com
Registered office
7-1-2-710 Motomachi-dori, Chuo-ku, Kobe, Hyogo 650-0022, Japan