UBCC HRM Privacy Policy

This Privacy Policy explains how UBCC HRM, LLC (“UBCC HRM,” “we,” “us”) collects, uses, discloses, and protects personal information in connection with the UBCC HRM platform (the “Platform”). It applies to our customers (employers), their employees and contractors who use the Platform (“Workers”), job applicants, and visitors to our websites. Where we process Worker personal data on behalf of an employer-customer, that customer is the data controller and we act as its service provider/processor, subject to our agreement with that customer; individual Workers with questions about their data should generally start with their employer.

1. Information We Collect

We collect the following categories of information:

• Identity and contact information: name, address, phone number, email, date of birth, and government identifiers such as Social Security number or other national ID, where required for payroll and tax purposes.
• Financial information: bank account and routing numbers for direct deposit and tax remittance, and wage, salary, and compensation details.
• Employment information: job title, department, employment status, work history, timekeeping records, and benefits elections.
• Sensitive information provided voluntarily or as required by law: health or benefits-plan information (e.g., for enrollment in employer-sponsored benefits).
• Location information: where an employer-customer enables it, the geolocation of a Worker’s clock-in at the time-and-attendance kiosk.
• Usage and device information collected automatically: IP address, browser and device identifiers, log data, and cookies or similar technologies (see Section 8).
• Information from third parties: identity-verification providers, background-check providers (where used and authorized), payroll tax agencies, and benefits carriers.

Biometric data. UBCC HRM does not currently collect biometric identifiers (such as fingerprint or facial geometry scans) as part of its time-and-attendance features; clock-ins are verified by account credentials and, where enabled, geolocation only (see “Location information” above). If UBCC HRM adds biometric verification in the future, we will update this Policy, obtain a Worker’s prior written consent before collecting any biometric identifier or biometric information, publish a written retention and destruction schedule, and will not sell, lease, trade, or otherwise profit from biometric data.

2. How We Use Information

We use personal information to provide and maintain the Platform (including payroll processing, tax filing, benefits administration, and time tracking); to verify identity and prevent fraud; to communicate with you about your account and the Platform; to comply with tax, labor, and other legal obligations; to verify the location of a time-and-attendance clock-in where your employer enables that feature; to improve and secure the Platform, including through aggregated or de-identified analysis; and, for prospective customers and business contacts, for marketing communications you can opt out of at any time. We do not use Worker personal data to train externally shared AI models without the applicable employer-customer’s authorization, and we do not sell personal information.

3. How We Share Information

We share personal information with: (a) infrastructure and application service providers who perform specific technical functions on our behalf — including application hosting and document storage, our primary database, caching, background-job coordination, real-time in-product notifications, and address look-up for work locations — each of which is contractually restricted to the specific data and purpose described for it in the subprocessor table in Section 10 of the Security Policy; (b) an email delivery provider, to send and receive payroll-related correspondence such as paystubs and reports; (c) a product-analytics provider, which receives internal usage identifiers and usage events but not Social Security numbers, bank account information, or other payroll record content; (d) banks and payment networks as necessary to process direct deposits and tax payments; (e) government agencies, including tax authorities, as required for payroll tax filing and legal compliance; (f) benefits carriers and insurers you or your employer selects; (g) professional advisors and, in the event of a merger, financing, or acquisition, a successor entity, subject to confidentiality obligations; and (h) law enforcement or regulators where required by law or to protect the rights, safety, or property of UBCC HRM, our customers, or others. The current subprocessor list is set out in Section 10 of the Security Policy and will also be published at https://ubcc.com/subprocessors; customers will be notified of material changes to that list as described in their Data Processing Addendum.

Where your employer-customer invites a bookkeeper, accountant, or other professional as an Administrator of its account under Section 2 of the Terms of Service, that Administrator will have access to Worker personal information to the same extent as any other administrator your employer-customer designates; that access is governed by your employer-customer’s own agreement with UBCC HRM, not by a separate disclosure under this Policy.

4. Data Retention

We retain personal information for as long as needed to provide the Platform and for the periods required by applicable tax, labor, and recordkeeping laws (which, for payroll and employment tax records, commonly range from three to seven years depending on jurisdiction and record type). Post-termination retention and deletion of Customer Data is further described in Section 14 of the Terms of Service. We retain biometric data, where collected, only as long as necessary for its collection purpose and delete it no later than one (1) year after the purpose is satisfied or the Worker’s relationship with the employer-customer ends, consistent with applicable biometric privacy laws.

5. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, as described in our Security Policy. No system is completely secure, and we encourage you to use strong, unique passwords and multi-factor authentication where available.

6. Your Rights and Choices

Depending on your location and relationship to UBCC HRM, you may have the right to access, correct, delete, or receive a copy of your personal information, to opt out of the “sale” or “sharing” of personal information (we do not currently engage in either as those terms are defined under U.S. state privacy laws) and of targeted advertising, and to limit the use of sensitive personal information, which includes the precise geolocation data described in Section 1. Employer-customers and their Workers may generally exercise these rights through the Platform or by directing requests to their employer as the data controller; where we receive a request directly from a Worker, we will refer it to the relevant employer-customer unless we are legally required to respond directly. We honor the Global Privacy Control signal where legally required. To submit a request, contact info@ubcc.com.

7. U.S. State Privacy Law Notices

Residents of California, and of other states with comprehensive privacy laws in effect, have rights that may include those described in Section 6, as well as the right to non-discrimination for exercising these rights and, where applicable, the right to appeal a denied request. The categories of personal information UBCC HRM collects and discloses are described in Sections 1 and 3 of this Policy, covering the preceding twelve months; contact info@ubcc.com for a copy specific to your account. Precise geolocation, collected only where an employer enables clock-in location verification, is treated as sensitive personal information under the CCPA/CPRA and other applicable state laws.

8. Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies to operate the Platform, remember preferences, and, on our marketing website, measure and improve performance. You can control cookies through your browser settings; disabling some cookies may affect Platform functionality.

9. International Data Transfers

UBCC HRM currently operates only in the United States and does not knowingly collect or process personal data of individuals located outside the United States. If that changes, we will update this Policy — and, where required, rely on legally recognized transfer mechanisms such as Standard Contractual Clauses — before serving any customer or Worker outside the United States.

10. Children’s Privacy

The Platform is intended for business use by adults and is not directed to children. We do not knowingly collect personal information from children under 13 (or the relevant minimum age under local law) other than dependent information a Worker voluntarily provides for benefits enrollment purposes.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new effective date and, for material changes, provide additional notice (such as email or an in-Platform banner).

12. Contact Us

Questions about this Privacy Policy can be directed to info@ubcc.com or UBCC HRM, LLC, 919 North Market Street, Suite 950, Wilmington, DE 19801.

Version 1 · published 2026-10-07