Privacy policy

Your company is the data controller: it employs you, it decides what data it needs and it is the one required to keep it.

SmartHubCRM SL, tax ID B05593355, registered at Avenida de los Apóstoles 3, 1.º B, 28011 Madrid (Spain), email direccion@smarthubcrm.com, which runs SmartHub, acts as a processor: it handles that data on your company's behalf and on its instructions, not on its own.

SmartHubCRM SL always acts as the processor, never as the controller: the controller of your data is always your company.

Who you are. Name, work email and your role in the tool. It is the minimum needed for the app to know what to show you.

Your employment record. ID document, date of birth, home address, personal phone and email, social security number, bank account and emergency contact. They are there because your payslip and your social security registration cannot be done without them. They are stored encrypted, and anyone who sees them inside the tool sees them masked unless they have an explicit permission not to.

Your working day. Clock-in, break and clock-out times. This is a legal obligation in Spain (Royal Decree-Law 8/2019) and the record counts as evidence before a Labour Inspection.

Where you clock in, only when you clock in. If your company has it switched on, when you clock in the app checks whether you are where you are due to work that day. Your company has to inform you first (the app shows you that text); it is not a permission you give. We store whether you were inside or outside, how far away and how accurate the reading was, and if you were outside your manager sees it. Your exact position is not stored, and you are not tracked between clock-ins. If you turn location off in your phone settings, you can still clock in and the entry is marked as “no location”.

Your time off, payslips, expenses and documents. What you request and what is decided, your salary receipts and the acknowledgement you sign, the expenses you log and the invoice you attach — encrypted too.

What you write. Messages in the internal chat and on the noticeboard. A suggestion sent anonymously does not record who wrote it: neither your company nor we can find out afterwards.

Your birthday, only if you say so. Your date of birth is on your record, but it is not shown to your colleagues unless you switch it on yourself from the app. And even then it shows the day and the month, never the year.

Alerts on your phone. A device identifier so we can send you notifications. It can be turned off in Settings.

Time records, four years, which is what Royal Decree-Law 8/2019 requires. Employment paperwork and payslips, for the periods set by Spanish employment and tax law. Everything else, for as long as your relationship with the company lasts and, after that, only what has to be kept by law or to defend a claim.

That is why there is no button that deletes your account instantly: it would be a lie, and it would leave you without your own payslips. What you can actually do is right below.

To access your data, correct it, ask for the erasure of anything not subject to a legal retention period, object to a specific processing, ask for it to be restricted, or take it elsewhere.

From the app: under “Me → My account and my data”. The request goes out with your name and the date, and there is one month to answer you.

To delete your account and your data, the steps and what is deleted and kept are on Delete your account and your data.

You can also write to your company's HR. And if you get no answer, you can lodge a complaint with the Spanish Data Protection Agency (AEPD).

Your data is never sold or shared for advertising. It is shared with whoever is needed for the employment relationship to work: the payroll firm that prepares the payslips, the Spanish Social Security and Tax Agency where applicable, and the technology providers that host the service, who act as sub-processors and are bound by contract.

Inside your company, everyone sees their own: a colleague does not see your record, and someone with a team sees, of their own people, what they need in order to approve time off or review a working day — not their personal data, and not the reasons for a sick leave.

The sensitive data in your file is stored encrypted. Access goes through identity —your Google account, Apple, or the password you set when you accepted the invitation— and every permission is logged. Documents are served decrypted only to those allowed to see them, and never through a link that can be shared.

If the tool hits an error, a technical report is sent to our issue tracking system, and that report includes a recording of the seconds just before, so we can reproduce what happened. Only when there is an error: while everything works, nothing is recorded.

It is used to fix the fault and for nothing else. It is not linked to your record, it is not used to measure what you do, and it is not shared with your company.

Almost nothing here is processed because you consent to it, but because it is needed for the employment relationship to exist or because the law requires it. And that matters: where the basis is legal, withdrawing consent does not delete the data, because there never was any consent to withdraw.

Performance of the contract (art. 6.1.b GDPR): your record, your payslips, your expenses, your time off and your rota.

Legal obligation (art. 6.1.c): the time record (Royal Decree-Law 8/2019), social security contributions and tax withholdings, and health and safety paperwork. And checking where you clock in, when your company has it switched on: the time record must reflect reality (art. 34.9 of the Spanish Workers' Statute), together with the legitimate interest in checking it (art. 20.3 of the Statute and art. 90 of the LOPDGDD).

Legitimate interest (art. 6.1.f): the security of the platform and the technical access log, so we can tell who did what if something goes wrong.

Consent (art. 6.1.a): only where you are asked in those words, such as showing your birthday. There you can withdraw it whenever you want, and withdrawing it has no consequences for your job.

The data your record asks for is not optional: without it, a payslip cannot be prepared and you cannot be registered with the Social Security. Not providing it is not a fine — it is that the procedure cannot be carried out.

What is optional is marked as such and can be left blank with no consequences.

The service and the database are hosted in the European Union. Some technology providers may have support outside it; when that happens, the transfer relies on the standard contractual clauses approved by the European Commission or on an adequacy decision.

There is no automated decision-making or profiling that produces effects on you. Time off is approved by a person, payslips are reviewed by a person, and clock-in incidents are resolved by a person.

The alerts the tool generates —a document about to expire, a working day left open— are exactly that: alerts so that someone looks. They decide nothing.

SmartHubCRM SL is not required to appoint one and has not appointed one. For anything to do with privacy, the contact is direccion@smarthubcrm.com. If your company has its own, it will tell you.

When the text changes, the revision date at the top changes with it. If the change affects what your data is used for, we will tell you through the tool itself.