Privacy Policy

1. Introduction

Brighton AI Holdings Pty Ltd ("Brighton AI", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, including Nero People, and our website (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information You Provide

• Account information (name, email address)
• Profile information (job title, department, branch/office location, profile photo)
• Authentication credentials (via email/password or Google OAuth)
• Organization and tenant membership information
• Communications you send to us

2.2 Information Collected Automatically

• Device information (device type, operating system, browser type)
• Log data (access times, pages viewed, app features used, login history)
• Session information (authentication tokens, active sessions)
• Push notification tokens (with your consent)

2.3 Nero People (neropeople)

When using Nero People, we collect:

• Attendance records (check-in/check-out times)
• Location data at check-in/check-out (GPS coordinates for workplace verification)
• Working hours and overtime records
• Leave requests and approval history
• Department and reporting structure information

3. How We Use Your Information

We use the collected information for:

• Providing, maintaining, and improving our Services
• Processing transactions and sending related information
• Sending technical notices, updates, push notifications, and support messages
• Responding to your comments, questions, and customer service requests
• Verifying workplace attendance through location data
• Generating reports for your employer or organization (attendance)
• Providing real-time alerts (attendance notifications)
• Protecting against fraudulent, unauthorized, or illegal activity

4. Location Data

Our Services collect location data in the following ways:

4.1 Nero People - Attendance Verification

When you check in or check out, your GPS location is collected to verify you are at an authorized workplace location. This location data is collected only at the moment of check-in/check-out and is not continuously tracked.

5. Information Sharing

We do not sell your personal information. We may share your information in the following circumstances:

• With your employer or organization (for enterprise accounts)
• Service providers who assist in our operations (cloud hosting, analytics)
• Legal requirements when required by law or to protect our rights
• Business transfers in connection with a merger, acquisition, or sale of assets

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including encryption in transit and at rest, secure authentication, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you Services. We may retain certain information as required by law or for legitimate business purposes.

8. Your Rights

Depending on your location, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your personal information
• Object to or restrict certain processing
• Data portability
• Withdraw consent where processing is based on consent

To exercise these rights, please contact us using the information below.

9. Children's Privacy

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including Australia. We ensure appropriate safeguards are in place when transferring data internationally.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at: