Revision v1.02 | Updated on 16 October 2026 | Effective date 16 October 2026
1 Who we are and how to contact us
WorkLumi is operated by AJUBA LIMITED (NZBN: 9429047560567) trading as Ajuba Tech, at 15 Erson Avenue, Royal Oak, Auckland, 1061. In this policy, “we”, “us” and “our” mean that entity. Our Privacy Officer can be contacted at privacy@worklumi.com or at the postal address above, marked “Privacy Officer”.
This policy explains how we handle personal information through worklumi.com and its sub-domains, the WorkLumi application and related support. It covers business account owners, administrators, workers, contractors, website visitors and people who contact us. It is written for services supplied to New Zealand and Australian customers.
Our commitments to this policy apply to the covered service. We also comply with privacy laws that apply to our activities, including New Zealand’s Privacy Act 2020 and, where applicable, Australia’s Privacy Act 1988 and Australian Privacy Principles. This policy does not reduce anyone’s statutory rights.
2 Your employer and WorkLumi have different responsibilities
The organisation using WorkLumi decides why its workforce records are collected, which workers and managers can access them, and how they are used for employment administration. Its own employment and privacy notices also apply. A staffing agency and a host business may have separate responsibilities; access must reflect the actual authorised arrangement.
We process workforce information to provide the service on the customer’s instructions, subject to our legal obligations. We are separately responsible for information used for our own account administration, service security, support, billing and communications. In New Zealand, information held solely as an agent is treated differently from information used for our own purposes. We assess our role for each activity rather than treating all information alike.
An Australian employer’s employee-record exemption does not automatically extend to WorkLumi when we handle another organisation’s staff information. We do not rely on that exemption as a general permission to use worker records.
You may contact your employer about employment records and workplace decisions or contact us about our handling of your information. We will help identify the appropriate organisation and deal with any obligations that remain ours.
3 Information we collect
We collect information reasonably needed for the functions you or your organisation use. The initial timesheet service involves the following categories.
| Category | Examples and purpose |
|---|---|
| Account and identity | Name, username or email where supplied, organisation membership, roles, authentication identifiers and security settings, to identify users and manage access. |
| Business and employment | Company details, country, timezone, work locations, team, manager, employment type, start or end dates and worker identifiers supplied by the customer, to organise workforce records. |
| Time and approvals | Clock and break events, timesheets, submitted revisions, corrections, reasons, approvals, period locks and export records, to administer and evidence recorded time. |
| Security and technical information | Network address and request information, device and browser details, sign-in attempts, timestamps and audit events, to deliver and protect the service. Some identifiers may be stored in a keyed or pseudonymous form. |
| Support and commercial records | Enquiries, support correspondence, business contacts, agreed plan details and billing records where paid services are offered, to assist customers and administer our relationship. |
Only provide information that is relevant to the service. Do not put identity documents, tax numbers, bank details, medical records or other sensitive information into ordinary notes or support messages unless a specifically approved feature requires it and explains why. Payment-card collection, if offered, must use the payment provider identified at checkout.
Payroll calculations, tax filing, biometric matching, precise location attendance and advanced HR records require separately introduced features and appropriate notices. This policy does not authorise those forms of collection merely because they are on the roadmap. A device’s own face or fingerprint unlock is different from giving biometric information to WorkLumi.
4 Where information comes from and your choices
We receive information directly when you register, use the application, enter time, contact support or choose to receive marketing. We also receive workforce information from your employer, authorised managers or an authorised staffing agency, including through permitted imports and corrections. Technical information is generated when your device interacts with the service. An enabled integration may supply information within its stated permissions.
When personal information is collected indirectly, we and the customer will arrange appropriate notification of the collection, its purpose, intended recipients, the relevant collecting and holding organisations and access and correction rights. For New Zealand collections, we take the reasonable notification steps required by IPP3A as soon as reasonably practicable, unless an applicable exception has been assessed. Where an employer gives notice on our behalf, it must actually reach the affected people. A public link alone may not be enough.
Worker notice must be available even where a worker has no personal email address, for example through an employer-issued notice and the first-login screen. Accepting a business subscription is not consent on behalf of every worker for every optional use.
You can browse public information or make a general enquiry without identifying yourself where practicable. We need reliable identity and employment links for workforce accounts. If required information is not provided, the affected feature may not work; the employer should explain any alternative attendance process. Optional information and optional marketing choices are identified separately.
5 How we use information
We use information to create and administer accounts; record and display workforce information within authorised access; support submission, review, correction and export of time; communicate service and security notices; respond to requests; investigate failures and misuse; administer agreed charges; and meet applicable legal obligations.
We use technical information to maintain performance and security. Any optional analytics or advertising technologies are governed by our Cookie Policy and the choices presented for them. We do not sell personal information or use customer workforce records to advertise to workers. We do not use identifiable workforce records to train general-purpose AI models.
We will assess any new purpose before using information for it, provide updated notices and obtain consent where needed. Information that we receive but did not request is assessed and, where it cannot lawfully be retained, securely deleted or de-identified when lawful and practicable.
6 Calculations and automated processes
WorkLumi uses recorded events, selected timezones, break information, period settings and workflow status to calculate time summaries and determine whether a submission or export can proceed. Account status, permissions and security signals can allow, challenge or block access. These processes can affect your ability to enter or submit information.
Managers make employment and approval decisions. A recorded total or workflow restriction is not, by itself, a decision about lawful wages, disciplinary action or employment eligibility. Ask your manager to review an incorrect workforce outcome, and contact us about a technical restriction or our processing. We will investigate our part and assist with correction where appropriate.
Before introducing automated scheduling, profiling, biometric decisions or other materially different automation, we will identify the information involved, whether the computer makes or assists the decision, the likely effects and the available review route in the applicable notice.
7 Who can receive information
Information is available to the relevant customer and its authorised users according to their roles and scope. Group administrators may have access across businesses in their own organisation where authorised. Employment records for unrelated customers are not available merely because a worker uses the same identity in both.
We may provide necessary information to contracted hosting, authentication, database, email, payment, security and support providers. We require appropriate protections for the functions they perform. Our staff and contractors may access information where needed for authorised support, security or service operation, subject to confidentiality and access controls.
If a customer exports data or enables an integration, the selected recipient may receive it. The customer must check its authority, the recipient and the information included. Copies outside WorkLumi are subject to the recipient’s handling and cannot necessarily be recalled by us.
We may disclose necessary information to professional advisers, to comply with lawful requirements, to protect legal rights or safety, or as part of a business transfer with appropriate safeguards and required notices. A transfer of ownership does not automatically permit unrelated uses.
8 Providers and overseas processing
We use providers to operate the service. We give them information relevant to their functions and require appropriate privacy and security protections. Some providers also process information for their own legal, security or account-management purposes, as explained in their own privacy notices.
| Provider or feature | Purpose and information involved | Location information |
|---|---|---|
| Supabase | Database and authentication for accounts and business content, including account emails such as sign-up confirmation and password reset unless another email provider is listed below | Primary application database in Sydney, Australia; provider support and related operations may involve other countries |
| Vultr | Hosting of the WorkLumi application server and background worker, which process requests and workforce records to provide the service | Sydney, Australia |
| Vercel | Web hosting, content delivery and associated request and diagnostic information | Global infrastructure, including the United States; processing depends on deployment and delivery locations |
| Resend | Delivery of service emails, including recipient addresses, message content and delivery records | United States and supporting provider operations |
| Stripe | Subscription payments, billing and payment-related fraud prevention | International operations, including the United States; relevant Stripe entities and processing locations depend on the service and account |
| Google sign-in, if you choose it | Authentication and the account information authorised through the sign-in flow | Google's international infrastructure, including the United States |
| Google reCAPTCHA | Protection of the worklumi.com contact form against automated abuse, using device, browser, interaction and related technical signals | Google's international infrastructure, including the United States |
| Google Analytics, where enabled with consent | Website or product usage measurement | Google's international infrastructure, including the United States |
| Vercel Web Analytics, where enabled with consent | Website usage measurement, such as pages viewed, referring site, browser, device type and approximate country. It does not use cookies | Global infrastructure, including the United States |
| Cloudflare Turnstile | Protection of sign-in, sign-up and password reset in the WorkLumi application against automated abuse, using device, browser, network and interaction signals | Cloudflare's global network, including the United States |
| incident.io | Our public status page, including the email address or other contact details of people who choose to subscribe to status updates | International infrastructure does not take any data from the system (s) of worklumi, only carry status input by our technical team on services provided to our customers. |
Further information is available in the providers' notices: Supabase, Vercel, Resend, Stripe, Google, Cloudflare, Vultr - https://www.vultr.com/ and incident.io: https://app.incident.io. Provider location lists and subprocessors can change. Contact us for information about the arrangements relevant to your account.
We may also disclose information:
to authorised members or administrators of your business workspace;
to recipients when you or your business share a document or instruct us to send a message;
to professional advisers, insurers and auditors where needed and subject to appropriate confidentiality;
in connection with a proposed or completed business sale or restructure, subject to appropriate safeguards and any legally required notice;
where disclosure is required or permitted by law, necessary to establish or defend legal claims, or reasonably necessary to address fraud, security threats or a serious threat to someone's safety.
For New Zealand information, we assess whether a provider acts solely on our or the customer’s behalf or receives information for its own purposes. Where IPP12 applies to an overseas disclosure, we establish an applicable lawful basis and appropriate protection, including comparable contractual safeguards where relevant. Using an offshore processing agent does not remove responsibilities for security or proper handling.
Where Australian cross-border disclosure rules apply, we take the reasonable steps required to protect information and assess our accountability for overseas recipients. We do not treat general acceptance of this policy as a waiver of overseas-disclosure protections.
9 Security
We use reasonable technical and organisational safeguards appropriate to the information, including access restrictions, authentication, protected communications and operational procedures. We review provider arrangements and restrict support access to what is needed. No online service can guarantee absolute security.
Protect your credentials, change temporary passwords when prompted, use available stronger authentication and sign out on shared devices. Tell us promptly about suspected unauthorised access. We will not ask you to send your password or authentication recovery codes in a support message.
10 Retention and deletion
We keep personal information only for as long as needed for the stated purpose, an applicable record obligation, an agreed lawful service requirement or a documented legal hold. Ending a worker’s access or cancelling a subscription does not automatically erase employment evidence. Correction can require an amendment linked to the original record.
| Record class | Retention rule |
|---|---|
| Worker import preview rows | Eligible for deletion 30 days after the import is checked. Scheduled maintenance removes expired rows. Committed worker records and the import summary are separate records. |
| Sign-in protection counters | Eligible for deletion after 30 days without an update. Cleanup runs in bounded batches on subsequent attempts; this is not a guarantee of deletion at the exact 30-day mark. |
| Workforce records and audit evidence | The customer’s statutory recordkeeping needs and legal holds must be considered. |
| Account, support, billing and operational logs | Different purposes require different periods. |
| Website contact enquiries | Deleted 24 months after the enquiry is received. |
| Terms and privacy acceptance records | Kept while the account exists and for [TO CONFIRM: number of years] after it closes, as evidence of which version was accepted and when. |
| Closed accounts | To close your account, email privacy@worklumi.com from the email address on the account. After we verify that you are the account owner, we block access straight away. You have 30 days to ask us to restore it. After that we remove your data from live systems, except records we must keep by law or under a documented legal hold (see the paragraphs after this table). For a business account, the 30-day export window in our Terms of Service applies first. If you are a worker, records your employer keeps about you are handled as described in section 11. |
| Active accounts and business content | Retained while the account is open and the information is needed to provide the service. |
| Backups | Deleted information may persist in encrypted backups for up to 35 days before those backups are overwritten. Backups are restricted from ordinary use. If we restore backup, we reapply relevant deletion instructions. |
| Logs and analytics | Application and access logs are kept for up to 12 months for security, debugging and abuse prevention, then deleted or de-identified. |
Relevant New Zealand employer wage and time records generally require six years’ retention. Australian employers covered by the national workplace system generally need to keep time and wages records for seven years. These employer obligations do not require every browser identifier or security log to be kept for that period, and they do not promise indefinite storage by WorkLumi.
When retention ends, we securely delete or de-identify information where appropriate. Backups may expire on a different cycle and are restricted from ordinary use. Recovery procedures must reapply applicable deletions and restrictions before restored information returns to normal use. We retain a limited record of a legal hold and review it when the reason ends.
11 Access and correction
You can ask us to access or correct personal information we hold about you. Contact privacy@worklumi.com, describe the information and, if relevant, identify your employer. We may reasonably verify identity and authority. We will not require unnecessary identity documents.
For requests under New Zealand law, we normally communicate our decision within 20 working days. A lawful extension or transfer will be explained. Information we agree to provide is supplied without undue delay. For Australian requests, we respond within a reasonable period, generally within 30 calendar days.
We do not charge for making a request or correcting information. If a lawful, reasonable access charge is proposed, we explain it first. If we refuse access or correction, we explain the reason where permitted and how to complain. Where applicable, you may ask for a statement of correction to be attached to the disputed record.
Requests about employer-controlled records may need the employer’s involvement. We remain responsible for requests concerning our own processing and will assist with the relevant service records. Deletion is not an unrestricted right where information still has a lawful purpose or must be retained.
12 Marketing and browser technologies
We send optional product marketing only with appropriate permission. A workforce account or a manager’s invitation does not automatically subscribe a worker to marketing. You can unsubscribe through the message or contact us. We action marketing opt-outs promptly and within five working days; necessary service, security and account messages may continue.
Our Cookie Policy explains cookies, local storage, session storage and optional tracking choices. Removing browser storage does not delete server-held workforce records.
13 Privacy incidents and complaints
We assess suspected privacy incidents promptly, take reasonable containment and remedial steps, and notify affected customers without undue delay where their information is involved. We coordinate with the customer without postponing any notification obligation that applies to us.
For a notifiable New Zealand privacy breach, the required notifications are made as soon as practicable. For an eligible Australian data breach where the scheme applies, we notify the OAIC and affected individuals as required, subject to lawful exceptions. Assessment time is not permission to delay a notification once the relevant threshold is met.
Contact our Privacy Officer with your concern and the outcome you seek. We aim to acknowledge complaints within five working days and give a substantive response within 30 calendar days, or explain progress and an expected response date. These service targets do not extend a shorter legal deadline.
You may complain to New Zealand’s Office of the Privacy Commissioner at https://www.privacy.org.nz or Australia’s Office of the Australian Information Commissioner at https://www.oaic.gov.au. Each regulator applies its own jurisdiction and complaint process. Nothing here limits your right to seek independent advice or another available remedy.
14 Changes to this policy
We will publish the current version and effective date. For a material change affecting existing users, we provide an appropriate notice through the service or a relevant communication channel. If a new use requires consent, we obtain it before that use. Continued use is not treated as consent to unrelated collection or sensitive processing.
15 Contact
WorkLumi of AJUBA LIMITED
NZBN: 9429047560567
15 Erson Avenue, Royal Oak, Auckland, 1061.
Privacy: privacy@worklumi.com | Legal: legal@worklumi.com | Support: support@worklumi.com