Privacy Notice

1. Who we are and what this notice covers

This Privacy Notice is issued by Novaxion Systems LTD (“Novaxion”, “we”, “us” or “our”), a company registered in Nigeria (RC number to be inserted), with its registered office at [registered office address to be inserted].

It explains how personal data is handled in DutyMark (formerly StaffPass), an Android app that organizations use for verified staff check-in and check-out, attendance, shifts, leave and reports. It also covers the services behind the app: our servers, Help and support, and the Google Play subscriptions.

We process personal data in line with the Nigeria Data Protection Act 2023 (NDPA), administered by the Nigeria Data Protection Commission (NDPC).

2. Who is responsible for your data

Businesses, schools, hospitals, churches, NGOs, government bodies and other organizations use DutyMark.

• Your organization is the data controller for attendance records about its staff. It decides to record attendance, sets the rules (branches, shifts, verification level) and sees the reports.
• Novaxion is the data processor for those records. We run the service on the organization’s instructions.
• Novaxion is the data controller for your account itself (name, email, phone, password), for subscriptions and billing, for support conversations, and for the records we keep to prevent misuse of free trials.

If you have questions about why your employer records attendance, or how it uses the reports, please ask your employer first. We will help them answer.

3. Data we collect

4. Location

DutyMark asks for location permission only while the app is open. It reads one GPS position when you tap Check in or Check out, when an owner or admin sets a branch, or when an owner starts a free trial. It never tracks you in the background or between check-ins.

With each check-in we record:

• the position and how accurate it is;
• the distance from the branch, and whether it was inside the branch;
• whether a fake-location app was detected.

Your organization sees this information so that it can confirm attendance.

You can turn location off at any time in your phone’s settings. Without location, a check-in cannot be verified, and your organization may treat it as an exception.

5. Fingerprint and face

Every check-in and check-out needs your fingerprint or face unlock as well as your location. A phone PIN, pattern or password is not accepted, because those can be shared.

The fingerprint or face unlock happens entirely on your phone, in the Android security system. DutyMark never receives, stores or sees your fingerprint. Unlocking releases a private security key that stays on your phone; that key signs your check-in, so nobody else can check in for you. If you add a new fingerprint to your phone, the key is destroyed and the phone needs your organization’s approval again.

Face check (if your organization uses it)

Some organizations also ask for a short face check. You are told what it involves and asked to agree first. The app takes a few pictures with the front camera and turns them into a set of numbers (a face template) on your phone. The pictures are thrown away. The template is locked with a key held by your phone’s security system and is never sent to us or to your organization. We receive only a code (hash) that identifies it, so we can tell if it was replaced.

At check-in, the app asks for one or two simple actions (turn your head, smile or blink) and compares your face with the template, again entirely on your phone. We receive only the result: whether the actions were done, the picture quality and the match score. A failed face check is never decided by the app alone; a supervisor reviews it.

Face data is sensitive personal data under the NDPA. If you cannot or prefer not to use the face check, ask your organization for the alternative; your fingerprint and location are still checked. Signing out, uninstalling the app or clearing its data deletes your face templates from the phone.

6. Staff without a phone (assisted check-in)

An organization can add staff who have no smartphone. A trusted colleague (an admin, or someone the admin allows) then checks them in and out on the colleague’s own phone.

• The colleague confirms with their own fingerprint or face unlock, and the location of their phone is checked against the branch.
• The record shows who was checked in, who checked them in, when and where. Reports mark these records as assisted, so they are never mistaken for a self check-in.
• No fingerprint, face or location of the staff member without a phone is collected.

7. Free trials and preventing abuse

Each organization can have one free trial. So that the same person can’t start trial after trial, when an owner starts one we record:

• scrambled codes (salted hashes) of the owner’s email address, phone number and phone ID, and of the phone IDs of staff added during the trial. A hash can be compared with a new one, but it can’t be turned back into the email, number or ID;
• an approximate area (about 150 metres across) of where the trial was started. Location alone is never used to refuse a trial — many organizations share a building;
• if switched on, a Google Play Integrity result showing whether the app is genuine and running on a real, unmodified phone.

If these match an earlier trial, the new trial may be refused or reviewed by our team. You can always contact us, and a person will look at your case. This record is kept after an organization is deleted, because its purpose is to recognise a repeat trial.

8. How we use your data

• To provide DutyMark: accounts, check-in, attendance, shifts, leave, reports and notifications.
• To keep it secure: verifying devices, detecting fake locations and fraud, preventing repeat free trials, and locking accounts after repeated wrong passwords.
• To send service messages: sign-up and reset codes, invitations, trial reminders, receipts, replies to support messages and notices of important changes or maintenance. We send marketing only with your consent.
• To process subscriptions bought through Google Play.
• To fix problems and improve the service, using as little personal data as possible.
• To meet our legal obligations.

9. Our legal basis for processing

Under the NDPA, we rely on:

• performing our contract with you and with your organization;
• your organization’s legitimate interest in verified attendance;
• our legitimate interest in preventing fraud and misuse of free trials;
• compliance with our legal obligations;
• your consent, where consent is needed (for example the face check).

You can withdraw consent at any time, for example by turning off location permission.

10. Sharing your data

We share personal data only with:

• Your organization: the owner, admins and your supervisor see your attendance and requests, as their role allows. Colleagues do not see your records.
• Service providers who process data for us under contract:
  • our hosting provider (servers and database);
  • our email delivery provider (codes, invitations, reminders and receipts);
  • Google, for Google Play Billing and, if switched on, Play Integrity.
• Authorities, when the law requires it.

We never sell personal data, and we do not use it for advertising.

11. When Novaxion staff see your data

A small Novaxion team runs DutyMark: support, billing and security. They use a private console with strict safeguards:

• sign-in needs a password and a one-time code, and each person has only the access their role needs;
• emails and phone numbers are partly hidden, and showing one in full is recorded;
• to solve a problem you report, support may open a read-only view of your organization for up to 30 minutes; it can’t change anything;
• every action is written to a tamper-evident log, and serious actions (such as deleting an organization or changing its owner) need a second person’s approval.

12. International data transfers

Some of our service providers, including Google, may process data outside Nigeria. When that happens, we use the safeguards the NDPA requires, such as contractual protections, so your data stays protected to the same standard.

13. How long we keep data

• Attendance records are kept while your organization uses DutyMark, or for the period it sets. If a trial or plan ends, they stay viewable and exportable (read-only). We never delete an organization’s data without notice.
• Your account is kept until you ask us to delete it. If you leave an organization, your past attendance stays in that organization’s reports.
• Free-trial hashes are kept for as long as DutyMark offers free trials, because they exist to recognise repeat trials. They can’t be read back as emails or numbers.
• Purchase records are kept as long as tax and accounting law requires.
• Support conversations are kept while they help us support you, then deleted.
• Email codes expire after 10 minutes. Security logs are kept for a limited period, and backups are overwritten on a rolling basis.

14. How we protect your data

• Data travels between the app and our servers over encrypted (HTTPS) connections.
• Records saved on your phone are kept in an encrypted database.
• Passwords are stored only as salted hashes; email codes and sign-in tokens only as hashes.
• Access depends on each person’s role. Changes to settings, approvals and staff are recorded in an audit log.
• An admin can sign out a lost phone.

No system is perfectly secure. If a breach affects your data, we will notify your organization and the NDPC as the law requires and, where appropriate, you.

15. Your rights

Under the NDPA you can:

• ask what personal data we hold about you, and get a copy of it;
• have it corrected;
• ask for it to be deleted;
• restrict or object to its processing;
• move it to another service;
• withdraw your consent;
• ask for a person to review a decision, such as a refused free trial or a flagged check-in.

For attendance records, your organization decides on your request, because it is the controller. You can contact your organization directly, or contact us and we will pass your request on. You can correct your own profile in the app.

16. Deleting your account and data

To delete your DutyMark account and the data linked to it (the same steps are on novaxion.ng/accounts):

1. In the app, open Settings → Help and support → New message, choose “Something else” and write “Delete my account”; or
2. email support@novaxion.ng from the email address on your account, with the subject “Delete my DutyMark account”.

We confirm it is you, then delete your account within 30 days and tell you when it is done. If you own an organization, cancel its Google Play subscription first (Play Store → Payments and subscriptions), and tell us whether the organization and its records should be deleted too, or handed to another admin.

What is deleted, and what is kept:

• Deleted: your name, email, phone number, password, registered phones, face-check codes and support conversations.
• Kept by your organization: attendance records you made while you worked there, because they belong to the organization’s records. Ask your organization if you want them removed.
• Kept by us: purchase records for as long as tax law requires, and free-trial hashes (section 7), which can’t identify you on their own.

17. Children's privacy

DutyMark is a workplace tool for adults. It is not intended for anyone under 18, and we do not knowingly collect children’s data.

18. Changes to this notice

We may update this notice from time to time. When we do, we will change the “Effective date” above. For significant changes, we will tell you in the app or by email before they take effect.

19. Contact us and complaints

For any question about this notice, or to exercise your rights, contact us:

• Privacy email: privacy@novaxion.ng
• Support email: support@novaxion.ng
• In the app: Settings → Help and support
• Registered office: [registered office address to be inserted]

If you are not satisfied with our response, you can complain to the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.