Privacy Policy

Privacy Policy – NCHD Clocks

Last updated: 26 August 2026

MiPaye Labs (“MiPaye Labs”, “NCHD Clocks”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how NCHD Clocks collects, uses, stores, protects and otherwise processes personal data when you use the NCHD Clocks mobile application (the “App”) and related services.

NCHD Clocks is intended exclusively for doctors aged 18 years and over working in Ireland. The App is a personal timekeeping and overtime-estimation tool. It is not an official hospital attendance system, employment record, payroll system or remuneration record.

This Privacy Policy should be read together with any applicable Terms of Use for NCHD Clocks.

1. Who We Are and Data Controller

NCHD Clocks is operated by:

MiPaye Labs
Company Registration Number: 716051
2A Shrewsbury Park
Ballsbridge
Dublin 4
Ireland
D04 N6W9

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (“GDPR”), MiPaye Labs is the data controller in respect of the personal data processed through NCHD Clocks, except where another party determines the purposes and means of processing independently.

For privacy, data protection or account-related enquiries, please contact:

Email: info@nchdclocks.ie
Website: https://nchdclocks.ie

If a Data Protection Officer (“DPO”) is required to be appointed under applicable law, the relevant DPO contact details will be made available through our website.

2. What Data We Collect

We aim to collect and process only the personal data that is reasonably necessary to provide and operate NCHD Clocks.

2.1 Account Information

When you create an NCHD Clocks account, we collect:

Your name
Your mobile phone number
Your email address

Your mobile phone number is used for account authentication and one-time verification codes.

You must provide certain information in order to create and maintain an account. If required information is not provided, we may not be able to provide the relevant functionality of the App.

2.2 Timekeeping and Clocking Data

When you use NCHD Clocks, we store information associated with your clocking activity, including:

Clock-in date
Clock-in time
Clock-out date
Clock-out time
Shift duration
Hospital associated with the clocking event

This information is used to maintain your personal timekeeping records and calculate estimated overtime.

Your employer, hospital or payroll department does not receive access to your NCHD Clocks clocking records through the App.

2.3 Pay Rate Information

You may enter an hourly or overtime pay rate into the App.

This information is used solely to calculate an estimate of your gross overtime pay based on your recorded working hours.

NCHD Clocks does not store your actual salary, payslips or bank account information.

Your entered pay rate is not used to process payments or transfer money.

2.4 Location and Geofencing Data

NCHD Clocks collects and uses precise device location in the background solely to enable its automatic clock-in and clock-out functionality.

The App monitors your device’s location to determine whether you have entered or left a predefined hospital geofence. This enables NCHD Clocks to automatically generate a corresponding clock-in or clock-out event.

The App contains predefined geofences for hospitals in Ireland. You may also create a custom geofence through the App settings.

NCHD Clocks does not store your precise latitude or longitude on its servers.

Location information is used on the device to trigger the relevant clocking event. The precise location itself is not retained by NCHD Clocks after the location-based event has been generated.

The App can perform this location monitoring while the App is running in the background, including when the App is not actively being used.

You may manually clock in or clock out without using automatic geofencing.

Disabling location permission may prevent automatic geofence-based clocking from functioning, but manual clock-in and clock-out functionality remains available.

2.5 Subscription Information

NCHD Clocks is available through a monthly subscription.

Subscription payments are processed through Google Play Billing. NCHD Clocks does not receive or store your credit card, debit card or bank account details through Google Play Billing.

NCHD Clocks uses RevenueCat for subscription management and to determine subscription status.

Information relating to your subscription may therefore be processed by RevenueCat and Google in connection with providing the subscription service.

3. How We Use Your Personal Data

We may use your personal data for the following purposes:

To create and maintain your NCHD Clocks account
To authenticate your account using your mobile number and one-time verification codes
To provide clock-in and clock-out functionality
To detect hospital arrival and departure using geofencing
To maintain your personal timekeeping records
To calculate shift durations
To calculate estimated gross overtime pay
To administer your NCHD Clocks subscription
To determine whether your subscription is active
To provide customer support
To maintain the security of the App and our systems
To diagnose and resolve technical issues
To prevent misuse, fraud or unauthorised access
To comply with legal and regulatory obligations
To establish, exercise or defend legal claims where necessary

We do not use your clocking data to provide your employer, hospital or payroll department with attendance or payroll information.

We do not sell your personal data.

4. Estimated Overtime Pay and Automated Calculations

NCHD Clocks uses information you provide, including your applicable pay rate and recorded working times, to calculate an estimate of your gross overtime pay.

The App is designed to use calculations corresponding to those used by hospital finance departments. However, the resulting amount is an estimate only.

NCHD Clocks does not guarantee that the estimated amount will correspond exactly to the amount ultimately paid by your employer.

Differences may arise because of payroll adjustments, deductions, pension contributions, taxation, rounding, approved overtime, contractual arrangements, payroll policies or changes in applicable hospital or employment arrangements.

The calculations performed by NCHD Clocks are not intended to constitute automated decision-making producing legal effects or similarly significant effects concerning you.

NCHD Clocks does not use your personal data for automated decisions concerning your employment, promotion, disciplinary status, access to healthcare, creditworthiness or other matters producing legal or similarly significant effects.

NCHD Clocks should not be relied upon as an official payroll, employment or attendance record.

5. Legal Bases for Processing

Where applicable under the GDPR and Irish data protection law, we process your personal data on one or more of the following legal bases:

Performance of a contract

We process information where this is necessary to provide the NCHD Clocks service you have requested, including creating and maintaining your account, providing clocking functionality and administering your subscription.

Legitimate interests

We may process personal data where necessary for our legitimate interests in operating, securing, maintaining and improving NCHD Clocks, preventing fraud or misuse, responding to enquiries, protecting our legal rights and ensuring the security of our systems, provided that those interests are not overridden by your rights and freedoms.

Legal obligation

We may process personal data where processing is necessary for us to comply with a legal obligation to which we are subject.

Consent

Where applicable law requires consent, we will request your consent before processing your information for the relevant purpose.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before consent was withdrawn.

For device permissions, including location permissions, you can manage permissions through your Android device settings.

6. Who Has Access to Your Data?

Your personal data is not sold.

We do not provide your clocking records to your employer, hospital, HSE organisation, payroll department or other doctors or users.

We may use trusted third-party service providers and technology providers where necessary to provide, maintain, secure and operate NCHD Clocks.

These may include:

Cloud hosting, infrastructure and data-storage providers used to operate NCHD Clocks
Subscription-management and payment-processing providers used to administer subscriptions and payments
Mapping, location and geofencing service providers used to support relevant App functionality
Authentication, communications, analytics, security, technical-support and other service providers used to maintain, secure and improve NCHD Clocks

The specific providers used may change from time to time as we develop and maintain the App. Third-party providers may process information in accordance with their own privacy policies, contractual obligations and applicable law.

Where applicable, payment providers process subscription payments on our behalf. NCHD Clocks does not intentionally receive or store your full payment card or bank account details through the App.

We require service providers processing personal data on our behalf to provide appropriate safeguards for that data and to process it only as permitted by applicable law and their contractual arrangements with us.

Third-party providers may process information in accordance with their own privacy policies, contractual obligations and applicable law.

We may also disclose personal data where reasonably necessary:

To comply with applicable law, regulation, court order or lawful request from a competent authority
To protect the rights, property or safety of MiPaye Labs, NCHD Clocks, our users or others
To detect or prevent fraud, security incidents or unlawful activity
To establish, exercise or defend legal claims
To professional advisers where reasonably necessary, including legal, accounting or auditing advisers

7. International Data Transfers

NCHD Clocks user data is hosted using AWS infrastructure in the eu-west-1 (Ireland) AWS Region.

Some third-party service providers or platform operators used by NCHD Clocks may process personal data outside Ireland or outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection law and that appropriate safeguards are in place where required.

Such safeguards may include an adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism recognised under applicable data protection law.

8. Data Retention

We retain personal data only for as long as it is necessary for the purposes for which it was collected, subject to any legal, regulatory or legitimate business requirements that require longer retention.

Active accounts

Your account information and clocking records are retained while your account remains active.

Account deletion

When you delete your account, your account information and associated clocking history will be deleted within 30 days.

Inactive accounts

Accounts that have been inactive for 12 months may be deleted.

Deletion may occur sooner where required by applicable law or where you request deletion.

Some information may need to be retained for a limited period following account deletion where reasonably necessary to comply with legal obligations, resolve disputes, prevent fraud, protect security or establish, exercise or defend legal claims.

Where information is retained for one of these purposes, it will not be retained for longer than reasonably necessary for that purpose.

9. Your Data Protection Rights

Subject to applicable law and certain legal exemptions or restrictions, you may have the right to:

Be informed about how your personal data is processed
Request access to personal data we hold about you
Request correction of inaccurate or incomplete personal data
Request deletion of your personal data
Request restriction of processing in certain circumstances
Object to certain processing of your personal data
Request data portability where applicable
Withdraw consent where processing is based on consent
Lodge a complaint with the relevant supervisory authority

You may exercise these rights by contacting:

info@nchdclocks.ie

We may need to verify your identity before fulfilling certain requests, particularly where necessary to protect personal data from unauthorised disclosure.

We will normally respond to valid requests within the period required by applicable data protection law.

10. Account Deletion

You may delete your NCHD Clocks account:

Through the account deletion functionality within the App; or
By contacting info@nchdclocks.ie.

Deletion of your account will result in the deletion of your associated account information and clocking history within the timeframe described in the Data Retention section of this Privacy Policy, subject to any information we are legally required or otherwise permitted to retain.

Users should note that deleting an NCHD Clocks account does not necessarily cancel a Google Play subscription. Subscription cancellation should be completed through the applicable Google Play subscription-management functionality.

11. Data Security

We take reasonable and appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.

Our security measures may include:

Encryption of data transmitted over the internet using HTTPS
Secure authentication mechanisms
Password or credential protection and hashing where applicable
Role-based access controls
Restrictions on access to databases and backend systems
Regular backups
Access controls limiting information to authorised personnel and systems where reasonably necessary

Despite these safeguards, no internet transmission or electronic storage system can be guaranteed to be completely secure.

We will take appropriate steps in response to any personal data breach in accordance with applicable data protection law.

12. Location Permissions and Background Location

The automatic clocking functionality requires access to your device location.

NCHD Clocks may access device location while the App is operating in the background, including when the App is not actively being used.

This background location functionality is used to:

Detect entry into a hospital geofence
Detect departure from a hospital geofence
Automatically generate the relevant clock-in or clock-out event

NCHD Clocks does not retain your precise GPS coordinates on its servers.

Your location is used to trigger the relevant clocking functionality. The precise location itself is not stored as part of your NCHD Clocks clocking record.

You may disable location permissions through your Android device settings.

If you disable location access, automatic geofence-based clocking may not operate, but you can continue to use manual clock-in and clock-out functionality.

13. Children’s Privacy

NCHD Clocks is intended exclusively for doctors aged 18 years and over.

The App is not directed at children and we do not knowingly collect personal data from children.

If you believe that a child has provided personal data to us, please contact us at info@nchdclocks.ie.

14. Third-Party Services and External Links

NCHD Clocks relies on third-party services to provide certain functionality, including cloud infrastructure, subscription management, payment processing and mapping services.

These services may have their own privacy policies and terms.

NCHD Clocks may also contain links or references to external websites or services.

Once you leave NCHD Clocks and access an external website or service, that external provider’s privacy policy and terms may apply. We are not responsible for the privacy practices or content of websites or services that we do not control.

We encourage you to review the privacy policy of any external service before providing personal information to that service.

15. Disclosure in Certain Circumstances

We will not ordinarily disclose your personal data except as described in this Privacy Policy.

However, we may disclose personal data where we reasonably believe that disclosure is necessary:

To comply with applicable law
To comply with a valid court order, legal process or lawful request from a public authority
To protect or defend our legal rights or property
To protect the safety of our users or others
To investigate fraud, security incidents or other unlawful activity
To establish, exercise or defend legal claims

Where legally permitted, we will take reasonable steps to ensure that such disclosure is limited to the information necessary for the relevant purpose.

16. Transfer of Business

If MiPaye Labs undergoes a merger, acquisition, restructuring, financing, sale of assets or other transaction involving all or part of the business, personal data may be transferred as part of that transaction where legally permitted.

Any such transfer will be subject to appropriate confidentiality and data protection requirements.

Where required by applicable law, we will provide appropriate notice concerning material changes in how your personal data is processed.

17. Your Responsibility for Account Security

You are responsible for taking reasonable steps to protect access to your NCHD Clocks account and device.

You should not knowingly allow another person to access your account or use your account credentials or verification codes.

If you believe that your account or personal data has been accessed without authorisation, please contact us promptly at:

info@nchdclocks.ie

18. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in:

The NCHD Clocks App
Our data-processing practices
Third-party service providers
Applicable law or regulatory requirements
Our services and business operations

The current version will be published at:

https://nchdclocks.ie/privacy-policy

The “Last updated” date at the beginning of this Privacy Policy indicates when it was most recently revised.

Where we make material changes, we will take reasonable steps to bring those changes to your attention, including through the App or by email where appropriate.

19. Supervisory Authority – Data Protection Commission

If you are concerned about how your personal data is being processed, you have the right to lodge a complaint with the relevant data protection supervisory authority.

For users in Ireland, the relevant supervisory authority is the:

Data Protection Commission (DPC)

Information about the DPC and how to make a complaint is available at:

https://www.dataprotection.ie/

Making a complaint to the DPC does not affect any other legal rights or remedies available to you.

20. Governing Law

This Privacy Policy is intended to operate in accordance with the laws applicable in Ireland and the European Union, including the GDPR and applicable Irish data protection legislation.

Nothing in this Privacy Policy is intended to limit any mandatory rights or protections available to you under applicable data protection law.

21. Contact Us

For questions about this Privacy Policy, your personal data, your account, or to exercise your data protection rights, please contact:

MiPaye Labs
2A Shrewsbury Park
Ballsbridge
Dublin 4
Ireland
D04 N6W9

Email: info@nchdclocks.ie
Website: https://nchdclocks.ie