Privacy Policy

Who we are and how this policy applies

Radius Workforce Management ("Radius WFM", "we", "us", "our") operates the workforce management platform available at radiuswm.app and its tenant subdomains. We are a multi-tenant SaaS provider headquartered and registered in Zimbabwe, operating in South Africa and Zimbabwe.

Data controller vs data processor

Your employer or organisation (the "Tenant") who subscribes to Radius WFM is the responsible party / data controller in relation to your personal information. Radius WFM acts as the operator / data processor, processing personal information only on the Tenant's instructions and on its behalf.

This policy applies to:

• Employees and workers whose employers use Radius WFM to manage attendance, scheduling and payroll;
• Administrators and managers who access the Radius WFM admin console;
• Visitors to radiuswm.app who enquire about our services.

Applicable law

This policy is drafted to comply with:

• South Africa — Protection of Personal Information Act 4 of 2013 (POPIA) POPIA
• Zimbabwe — Cyber and Data Protection Act (Chapter 12:07), 2021 (CDPA) CDPA

Where both laws apply, we comply with the more stringent requirement.

Personal information we collect

We collect only the personal information that is necessary to deliver the Radius WFM platform. The categories below apply to employees and workers whose employers use our platform.

We do not collect or store special categories of personal information beyond biometric data (described in Section 3) and, where payroll is active, tax and banking data. We do not process racial or ethnic origin, political opinions, religious beliefs, trade union membership, or health data as part of normal platform operation.

Biometric data — face embeddings

What we capture and what we store

During enrolment, a short video or series of frames is captured through your device camera solely to generate a face embedding — a mathematical representation of your facial geometry (512 numerical values). This embedding is used only to verify your identity at each clock-in event.

• Raw images and video are never persisted — they are processed in memory and discarded immediately after the embedding is extracted.
• The embedding itself cannot be used to reconstruct a photograph of your face.
• Embeddings are stored encrypted within your employer's isolated database partition on Radius WFM infrastructure.
• Embeddings are never sold, licensed, or shared with third parties for any purpose other than providing the clock-in service to your employer.

Liveness detection

To prevent spoofing, our system verifies that a live person is present (blink detection at enrolment; head-turn detection at clock-in). No additional biometric data is retained from these checks beyond confirming a pass or fail result.

Consent and withdrawal

Your employer must obtain your written consent before activating biometric enrolment. You may withdraw consent at any time by notifying your employer. Upon withdrawal, your face embedding will be deleted from the system. Note that withdrawal may affect your ability to clock in using the platform's face-recognition feature; your employer is responsible for making alternative arrangements.

Location data and GPS geofencing

Radius WFM uses GPS coordinates only at the moment a clock-in or clock-out action is initiated. We do not continuously track your location or build a movement history beyond the discrete events listed below.

• Clock-in / clock-out events — a single GPS coordinate is recorded to verify that the employee is within an approved geofence zone.
• Trip departures and returns — a GPS coordinate is recorded when an employee logs leaving or returning to a site during a shift.

Location data is not transmitted to third-party advertising or analytics services. It is used solely for the operational purpose of attendance verification and is retained as part of the attendance record subject to the retention periods in Section 9.

Lawful basis for processing

South Africa — POPIA POPIA

Under POPIA, processing must satisfy at least one condition set out in Section 11. The conditions we rely on are:

• Consent (s11(1)(a)) — for biometric data (face embeddings) and, where applicable, sensitive personal information.
• Contractual necessity (s11(1)(b)) — processing necessary for the performance of the employment contract, including attendance verification, payroll calculation and shift scheduling.
• Legitimate interest (s11(1)(f)) — for security monitoring, fraud prevention, and service improvement, where our interest does not unduly prejudice the data subject.
• Legal obligation (s11(1)(c)) — where processing is required to comply with applicable labour law, tax law (Income Tax Act, UIF Act), or other statutory obligations.

For special personal information (biometric data), processing is further authorised by explicit consent under Section 27(1)(a) of POPIA.

Zimbabwe — CDPA CDPA

Under the Cyber and Data Protection Act, we rely on the following lawful grounds:

• Consent — for biometric data and any processing not covered by the grounds below.
• Contractual performance — processing necessary to give effect to the employment relationship.
• Legal obligation — compliance with the Labour Act (Chapter 28:01), ZIMRA obligations, NSSA Act, and related statutory requirements.
• Legitimate interests — fraud prevention and platform security, subject to a balancing test against data subject rights.

How we use your information

• Attendance verification — matching clock-in selfies against enrolled face embeddings; verifying GPS location against configured geofence zones.
• Shift and scheduling management — assigning shifts, tracking attendance against scheduled hours, flagging absences and late arrivals.
• Leave administration — processing leave requests, managing leave balances, cancelling conflicting shifts upon approval.
• Payroll calculation — computing gross pay, statutory deductions (PAYE, UIF, SDL for South Africa; PAYE, NSSA, ZIMDEF for Zimbabwe), and net pay from verified attendance hours.
• Reporting — generating attendance, overtime, and statutory compliance reports for employer administrators and relevant regulators.
• Platform security — detecting and preventing fraudulent clock-in attempts, unauthorised access, and abuse of the platform.
• Service delivery and support — troubleshooting, system maintenance, and responding to support requests from employer administrators.
• Legal and regulatory compliance — retaining records as required by labour, tax, and data protection legislation.

We do not use personal information for marketing profiling, sale to third parties, or any purpose incompatible with the purposes listed above.

Sharing and disclosure

We share personal information only as follows:

• Your employer (Tenant) — administrators and managers at your employer's organisation have access to your attendance, scheduling, leave and payroll records within their isolated platform environment.
• Service providers (sub-processors) — we engage third-party providers for hosting infrastructure (servers and databases), email delivery (transactional emails such as payslips), and cloud build services for our mobile application. All sub-processors are bound by data processing agreements that restrict use to the provision of services to us and prohibit independent use of personal data.
• Statutory authorities — where required by law, we may disclose information to SARS, ZIMRA, the South African Information Regulator, POTRAZ, labour authorities, or a court of competent jurisdiction. We will notify the relevant Tenant where legally permitted to do so before making such disclosure.
• Business transfers — in the event of a merger, acquisition or sale of substantially all assets, personal information may be transferred to the successor entity, subject to equivalent privacy protections.

We do not sell, rent, or trade personal information to any third party for commercial or marketing purposes.

International transfers

Radius WFM's primary infrastructure is hosted in cloud data centres located in the Africa region. Where data is processed or stored outside the country of origin of the data subject, we ensure that adequate safeguards are in place as required by POPIA (Section 72) and the CDPA.

Safeguards include:

• Contractual clauses with sub-processors that impose data protection obligations equivalent to those required by applicable law;
• Transfers only to jurisdictions that have been assessed to provide an adequate level of protection, or where specific contractual protections apply;
• Encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256).

Upon request, we will provide information about the specific safeguards applicable to any cross-border transfer of your personal information.

Retention periods

Upon expiry of the applicable retention period, personal information is securely deleted or anonymised. Employers (Tenants) may request earlier deletion of employee data subject to applicable statutory retention requirements that take precedence.

Security safeguards

We implement appropriate technical and organisational measures to protect personal information against loss, unauthorised access, disclosure, alteration or destruction, as required by POPIA (Section 19) and the CDPA.

• Encryption at rest — all database data is encrypted using AES-256. Face embeddings are stored in encrypted form with access restricted to the verification service.
• Encryption in transit — all communications between client applications and our servers use TLS 1.2 or higher. HTTP connections are automatically redirected to HTTPS.
• Data isolation — each Tenant's data is stored in a dedicated PostgreSQL schema, preventing any cross-tenant access at the database level.
• Access controls — role-based access control (RBAC) limits administrator access to the minimum necessary for their function. Platform operator access is separately authenticated and logged.
• Audit logging — all clock-in attempts, administrative actions, and access events are logged with timestamp and actor identity.
• Secure development — we follow secure software development practices including regular dependency updates, input validation, and protection against common web vulnerabilities (OWASP Top 10).
• Incident response — we maintain an incident response procedure. In the event of a security breach affecting personal information, we will notify affected Tenants and, where required, the relevant supervisory authority, within the timeframes prescribed by applicable law (72 hours under POPIA Regulations).

Your rights under POPIA (South Africa) POPIA

If your employer is a South African company or you are a South African data subject, you have the following rights under POPIA:

To exercise these rights, contact your employer's Information Officer in the first instance. Where Radius WFM is the appropriate point of contact (for example, for technical deletion), contact us at the details in Section 16.

Your rights under the CDPA (Zimbabwe) CDPA

If your employer is a Zimbabwean company or you are a Zimbabwean data subject, you have the following rights under the Cyber and Data Protection Act:

To exercise these rights, contact your employer or Radius WFM using the details in Section 16. We will respond within 30 days. Where a request is refused or cannot be fulfilled, we will provide reasons in writing.

Automated processing and profiling

Radius WFM uses automated processing in the following ways:

• Identity verification — clock-in selfies are automatically compared against stored face embeddings using cosine similarity. A threshold score below the configured minimum results in a failed clock-in. All failures are logged for human review by employer administrators.
• Geofence checking — GPS coordinates are automatically checked against the employer's configured site boundaries. If outside the boundary, clock-in is refused.
• Late/early flagging — the system automatically flags clock-ins that fall outside scheduled shift windows. Flagging is informational; disciplinary decisions remain with human managers.
• Payroll calculation — gross pay, deductions, and net pay are calculated from verified hours. Payroll runs are reviewed and approved by authorised administrators before payslips are issued.

No decision that significantly and adversely affects an individual (such as termination of employment) is made by automated means without human review. The automated outputs described above are presented to responsible humans who make the final determination.

Children

Radius WFM is a business-to-business platform intended for use by employers and adult employees in the workplace. We do not knowingly process personal information relating to children (persons under the age of 18) as part of normal platform operation. Employers are responsible for ensuring that only adults are enrolled on the platform. If we become aware that personal information of a child has been collected without appropriate legal basis, we will delete it promptly.

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory guidance. When we make material changes, we will:

• Update the "Last updated" date at the top of this policy;
• Notify Tenant administrators by email at least 14 days before the change takes effect (for material changes);
• Where required, obtain fresh consent from data subjects (for example, if we introduce a new category of biometric processing).

The current version of this policy is always available at radiuswm.app/privacy.html. Continued use of the platform after notification of changes constitutes acceptance of the revised policy.

Information Officer and contact details

Radius WFM has designated an Information Officer as required by POPIA (Section 55) and the CDPA. The Information Officer is responsible for ensuring compliance with data protection law, handling data subject requests, and serving as the point of contact with supervisory authorities.

We aim to acknowledge all data subject requests within 5 business days and to respond substantively within 30 days, consistent with the requirements of POPIA and the CDPA.

Regulatory complaints

If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the relevant supervisory authority.