Privacy Policy

Updated September 25, 2026

Smile Attendance System (“we,” “our,” or “us”), operated by Smile Solutions, Inc., is committed to protecting your privacy. This Privacy Policy explains how personal information is collected, used, and disclosed when you use the attendance service at https://attendance.ezportal.online and its associated mobile application (together, the “Service”).

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, do not use the Service.

Definitions and key terms

• Company: Smile Solutions, Inc. (Paynesville, Liberia), the organization responsible for your information under this Privacy Policy.
• Service: the Smile Attendance System web application at attendance.ezportal.online and the related mobile app used to record and review attendance.
• Customer: the institution, organization, or person that signs up to use the Service to manage staff or member attendance.
• Member: a person whose attendance is recorded in the Service, including employees and other people enrolled by a Customer.
• Personnel: individuals employed by or contracted to Smile Solutions, Inc. to operate the Service.
• Personal Data: any information that identifies, or can reasonably be used to identify, a natural person.
• Device: a phone, tablet, computer, or attendance terminal used to access the Service.
• Cookie: a small amount of data saved by your browser so the Service can keep you signed in and remember session settings.

What information do we collect?

We collect information that Customers and users submit, and information generated when attendance is recorded.

Account and profile information may include:

• Name, middle name, and last name
• Username and password
• Email address
• Primary and secondary phone numbers
• Date of birth, place of birth, and gender
• Position, grade, department, and institution
• Card or badge number and member code
• Photograph, and, where enabled by the institution, a fingerprint template and punch photos used for face comparison

Attendance information may include clock-in and clock-out times, the method used to punch (such as card, PIN, or face), face-match results, and messages sent about a punch.

Technical information may include a device push token (so the mobile app can deliver notifications), IP address, and standard server logs.

Institutions may also store employment details they choose to enter, such as qualification or salary. That information is entered by the Customer for its own workforce records.

How do we use the information we collect?

• To operate attendance recording, reports, and member records for the institution that enrolled you
• To authenticate users and reset passwords
• To send attendance notices by email, SMS, or push notification when the institution has enabled those options
• To verify identity at punch time when face comparison or fingerprint is enabled
• To maintain the security and reliability of the Service
• To respond to support requests

We do not sell Personal Data. We do not use attendance records for advertising.

How do we use your email address and phone number?

Email addresses are used for account access, password reset, and attendance or account messages the institution has chosen to send. Phone numbers are used for SMS attendance notices when that option is turned on for the member. We do not send unsolicited marketing email.

Do we share information with third parties?

We share Personal Data only as needed to run the Service:

• With the Customer (institution) that enrolled the member, and with administrators that Customer authorizes
• With service providers that host the application, store data, deliver email, deliver SMS, or deliver push notifications (including Expo for mobile push)
• With a successor if the Service is sold, merged, or otherwise transferred, provided the recipient agrees to protect the information consistently with this policy
• With government or law enforcement when we believe disclosure is required to comply with law, legal process, or to protect the rights, property, or safety of users, the public, or the Company

Affiliates of Smile Solutions, Inc. that help operate the Service may receive information and must handle it under this Privacy Policy.

Where and when is information collected?

Information is collected when an administrator creates or updates a user or member, when someone signs in, when a punch is recorded, when a device registers for notifications, and when you contact us for support.

How long do we keep your information?

We keep Personal Data for as long as the Customer’s account is active and as long as needed to provide the Service, meet legal or audit obligations, and resolve disputes. Attendance history is retained so institutions can produce workforce reports. When information is no longer required, we delete it or de-identify it. Backups may retain a copy for a limited period before they expire.

How do we protect your information?

The Service is served over HTTPS. Passwords are stored as hashes, not as plain text. Access to member records is limited to authorized institution users. Photographs and biometric templates are used for attendance verification and are not used for advertising.

No method of transmission or storage is completely secure. We cannot guarantee absolute security of information you transmit to the Service.

Could my information be transferred to other countries?

Smile Solutions, Inc. is based in Liberia. Hosting, email, SMS, and push-notification providers may process data in other countries. By using the Service, you understand that information may be stored or processed outside your country, including in countries that may not have the same data-protection laws.

Can I update or correct my information?

Members should ask their institution’s administrator to update, correct, or remove profile and attendance information. Institution administrators can update records in the Service. You may also contact us using the details below. We may need to verify your identity, or confirm the request with the institution, before making a change.

Deleting an account or a member record does not always erase every backup copy immediately. We update or delete Personal Data in active systems as soon as it is reasonably practicable.

Personnel

If you apply to work for Smile Solutions, Inc. or you are our worker, we use the information you provide for human-resources purposes, including screening applicants and administering employment. You may contact us to update that information or to request a copy of what we hold about you.

Sale of business

If Smile Solutions, Inc. or the Service is sold, merged, or transferred, or if we discontinue the business or enter insolvency proceedings, Personal Data may be transferred to the successor, provided that party agrees to handle it under this Privacy Policy.

Governing law

This Privacy Policy is governed by the laws of Liberia, without regard to conflict-of-law rules. You consent to the exclusive jurisdiction of the courts of Liberia for disputes arising out of this Privacy Policy, except where applicable law gives you a non-waivable right to bring a claim elsewhere.

Your consent

By using Smile Attendance System, registering an account, or recording attendance, you consent to this Privacy Policy. If we make material changes, we will post the updated policy on this page. Continued use of the Service after the update takes effect means you accept the updated policy.

Links to other websites

The Service may link to websites we do not operate. Those sites have their own privacy policies. We are not responsible for their content or practices.

Cookies

We use a session cookie to keep you signed in and to protect forms against cross-site request forgery. These cookies are required for the Service to work. We do not use advertising cookies, and we do not place Personal Data such as your name or email inside cookies. If you block cookies, you will not be able to stay signed in.

Children’s privacy

The Service is a workforce attendance tool for institutions. It is not directed at children under 13. If you believe we have collected Personal Data from a child under 13 without appropriate authorization, contact us and we will delete it.

Changes to this Privacy Policy

We may update this policy when the Service or our practices change. The “Updated” date at the top of this page will change when we do. If a change materially affects how we use Personal Data, we will provide notice through the Service before the change takes effect where the law requires it.

Information about the GDPR

If you are in the European Economic Area or the United Kingdom, we process Personal Data to perform the attendance service requested by your institution, to comply with legal obligations, and, where applicable, on the basis of legitimate interests in securing and operating the Service. You may request access, correction, deletion, restriction, or a copy of your Personal Data, and you may object to certain processing, subject to the institution’s employment or membership records and applicable law. You may also lodge a complaint with a supervisory authority.

California residents

If the California Consumer Privacy Act applies to you, you may request to know the categories and specific pieces of Personal Information we have collected, to delete that information, and to not be discriminated against for exercising those rights. We do not sell or share Personal Information for cross-context behavioral advertising. To make a request, contact us. We will respond within the time required by law after we verify the request.

Contact us

Questions about this Privacy Policy or your Personal Data:

• Service: https://attendance.ezportal.online
• Company: Smile Solutions, Inc., Paynesville, Liberia
• Phone: +231 776 812 343

Members should also contact the administrator of their own institution, which controls the attendance records held for that organization.