Privacy policy

1. Who is responsible for what

Labourix has two distinct roles, and it matters which one applies:

• Your company is the controller of all worker and project data you put into Labourix — hours, GPS clock-in points, identity documents, A1 certificates, LIMOSA declarations, wages, housing. You decide what is collected and why. We act as processor and only follow your instructions. This relationship is governed by our Data Processing Agreement.
• Labourix is the controller of the data about your account itself — the name and e-mail of the person who signs up, billing details, support conversations, and how the application is used. This policy describes that role, and also explains — for transparency towards workers — what we process on your behalf.

2. What personal data is processed

Account & billing (we are controller)

• Name, business e-mail, phone, company name, VAT number, address.
• Billing and payment status. Card details are handled by our payment provider — Labourix never sees or stores full card numbers.
• Support messages you send us, and technical logs (IP address, browser, timestamps) needed to run and secure the service.

Worker & project data (your company is controller, we process)

• Identification: name, language, role, employer, national/INSZ number where required for LIMOSA or Checkinatwork.
• Documents: identity documents, A1 certificates, LIMOSA receipts, contracts, certificates and their expiry dates — including data extracted from them by our scanning feature.
• Time & place: clock-in and clock-out times, and a single GPS position at the moment of each clock-in and clock-out, used to confirm the worker was at the site. Labourix does not track workers' location during the day, after hours, or in the background.
• Work & pay: hours, tasks, leave, wage or rate information, expenses, housing and vehicle assignments where you use those modules.

3. Why, and on what legal basis

• To provide the service (contract, Art. 6(1)(b)) — your account, the app, the worker app.
• To comply with the law (legal obligation, Art. 6(1)(c)) — Belgian posted-worker rules: LIMOSA declarations, Checkinatwork registration, the 2027 obligation for real-time check-in and check-out, and the duty to keep documents available for inspection.
• Legitimate interest (Art. 6(1)(f)) — securing the platform, preventing abuse, and confirming that clock-ins really happen at the site. We have weighed this against workers' privacy, which is why GPS is captured only at the two moments of clock-in and clock-out, and why the worker sees exactly what was recorded.
• Billing and accounting (legal obligation).

We do not use worker data for advertising, profiling or automated decisions that produce legal effects. Document scanning assists a human — it never automatically fires a declaration without a person confirming it.

4. Special categories

Labourix is not designed to hold health data, union membership, or other special-category data, and you should not upload it. If a document you scan happens to contain such data, it is stored only as part of that document and is not indexed or used for anything else.

5. Who we share it with

We do not sell personal data and we do not share it with advertisers. We share it only with:

• Belgian authorities, when you file a LIMOSA declaration or a Checkinatwork registration — that is the entire point of the feature, and it happens on your instruction.
• Your client, but only what you explicitly send: an hour report for approval, or a document bundle. Nothing is shared automatically.
• Subprocessors who run our infrastructure. The current list is in the DPA. All are bound by contract, and all process data in the EU or under an adequate transfer mechanism.

6. Where the data lives, and for how long

• EU hosting. Application and database run in the European Union.
• Active accounts: we keep data as long as your account is active, because you need the history.
• Compliance records (hours, LIMOSA, Checkinatwork, contracts): kept for the retention period Belgian law requires, generally 5 years, because that is how far back an inspection can reach. This retention is in your interest, not ours.
• After you cancel: you can export your data. We delete or anonymise it within 90 days, except records we must legally keep (invoices, and compliance records still inside their statutory period).
• Backups roll off on their own cycle, within 35 days.

7. Rights of workers and users

Under the GDPR you can request access, correction, erasure, restriction, portability, and object to processing based on legitimate interest.

Every worker can, at any time, open the Labourix app and see their own hours, their own clock-in positions and their own documents — in their own language. Transparency is built in, not requested by form.

You also have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), Drukpersstraat 35, 1000 Brussels.

8. Security

Encryption in transit, EU hosting, strict tenant isolation, role-based access, and no use of your data for model training. The details are on our security page.

9. Changes

If we change this policy in a way that matters, we will tell you in the app or by e-mail before it takes effect. The date at the top always reflects the current version.