← ÉascaDesk

Privacy Policy

Last updated: 21 May 2026  ·  Fleet Rewind Ltd

Contents

  1. Who We Are
  2. Scope of This Policy
  3. Data We Collect
  4. How We Use Your Data
  5. Legal Bases for Processing (GDPR)
  6. Data Sharing & Third Parties
  7. International Transfers
  8. Retention
  9. Your Rights
  10. Employee Data & Spanish Compliance
  11. WhatsApp & Meta
  12. Security
  13. Cookies
  14. Children
  15. Changes to This Policy
  16. Contact Us

1. Who We Are

Fleet Rewind Ltd ("we", "us", "our") is a company registered in Ireland. We operate the ÉascaDesk platform, including ÉascaDesk Desk Booking and ÉascaDesk Scheduler, accessible at www.eascadesk.ie and scheduler-lite.eascadesk.ie.

Registered address: 17 Keatingstown, Wicklow, A67 DH73, Ireland.

Fleet Rewind Ltd is the data controller for account and platform data. Where our business customers (managers) store their employees' personal data in ÉascaDesk Scheduler, Fleet Rewind Ltd acts as a data processor on behalf of those customers, who are themselves the data controllers for their employees' data.

2. Scope of This Policy

This policy applies to:

If you are an employee whose data has been entered by your employer, your employer (the manager account holder) is responsible for informing you that your data is held in ÉascaDesk and for obtaining any consent required under their own legal obligations. This policy explains how we, as processor, handle that data.

3. Data We Collect

3.1 Manager / Account Holder Data

DataSourcePurpose
Name, email addressRegistration formAccount creation & authentication
Password (bcrypt hash)Registration formAuthentication
Country, timezone (IANA)Settings pageLocalising schedule output & compliance exports
Stripe customer ID, subscription statusStripe payment flowPlan management & billing
Last login timestampAutomatically on loginSecurity & account integrity
Uploaded Excel files (schedule data)File uploadSchedule generation; deleted after solve
Generated schedule JSONSolver outputDisplayed & exported to manager

3.2 Employee Data (Pro plan — entered by manager)

DataNotes
Full nameRequired for scheduling
WhatsApp phone number (E.164)Used by clock-in/out bot; globally unique per platform
Skills / rolesUsed for shift matching
Availability preferencesFed into scheduling solver
NIF (Spanish tax ID)Optional; used for Spanish compliance CSV export
Clock-in / clock-out timestampsRecorded via WhatsApp bot, manual entry, or auto-close
Break start / end timestampsRecorded via WhatsApp bot
Shift assignmentsGenerated by solver or assigned manually
WhatsApp session state30-minute TTL; holds conversation context only

3.3 Automatically Collected Data

4. How We Use Your Data

We do not use personal data for advertising, profiling, or sale to third parties.

5. Legal Bases for Processing (GDPR Art. 6)

Processing activityLegal basis
Account registration & authenticationContract (Art. 6(1)(b))
Providing scheduling featuresContract (Art. 6(1)(b))
Stripe billingContract (Art. 6(1)(b))
Employee clock-in/out records (Pro)Legitimate interests of the manager (employer legal obligation under Real Decreto-ley 8/2019) (Art. 6(1)(f) / Art. 6(1)(c) as processor)
WhatsApp session dataLegitimate interests — necessary to operate the bot (Art. 6(1)(f))
Compliance CSV export & audit logLegal obligation of the controller (employer) — we process as data processor (Art. 6(1)(c))
Server access logsLegitimate interests — security (Art. 6(1)(f))
Marketing communications (if any)Consent (Art. 6(1)(a)) — we will ask separately

6. Data Sharing & Third Parties

We share personal data only with the following processors, under appropriate data processing agreements:

ProcessorPurposeLocation
Stripe Inc.Payment processing & subscription managementUSA (SCCs)
Meta Platforms Ireland LtdWhatsApp Business Cloud API — delivering bot messagesEU / USA (SCCs)
Hosting / cloud infrastructure providerServer & database hosting (PostgreSQL)EU

We do not sell, rent, or trade personal data. We do not share data with any third party for advertising purposes.

We may disclose data if required by law, court order, or regulatory authority, or to protect the rights and safety of Fleet Rewind Ltd or others.

7. International Transfers

Where data is transferred outside the European Economic Area (EEA) — for example, to Stripe or Meta servers in the United States — we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission under Art. 46 GDPR.

8. Retention

Data typeRetention period
Manager account dataFor the duration of the account, plus 12 months after deletion request
Schedule runs (JSON)Retained while the account is active; deletable by the manager
Uploaded Excel filesDeleted immediately after the solve completes
Employee records (Pro)Retained while the manager account is active; deletable by manager at any time
Clock events (including soft-deleted)Minimum 4 years — required by Spanish Real Decreto-ley 8/2019 for accounts subject to Spanish law
Clock event audit logMinimum 4 years (immutable by design)
WhatsApp session state30-minute TTL; automatically expired
Server access logsUp to 90 days
Stripe billing recordsGoverned by Stripe's retention policy (typically 7 years for financial records)

9. Your Rights Under GDPR

Depending on your relationship with us and applicable law, you have the following rights:

If you are an employee whose data is held in ÉascaDesk by your employer, please contact your employer in the first instance. We will cooperate with your employer to fulfil any rights requests. You may also contact us directly at the address below.

To exercise your rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Data Protection Commission (Ireland) at www.dataprotection.ie or with the Agencia Española de Protección de Datos (AEPD) at www.aepd.es if your complaint relates to Spanish-law processing.

10. Employee Data & Spanish Compliance

ÉascaDesk Scheduler's Pro plan includes features specifically designed to help employers comply with Real Decreto-ley 8/2019 (Spain's mandatory digital working-time recording regulation).

Under this regulation, employers are required to:

To fulfil these requirements, ÉascaDesk Scheduler implements soft-delete (records are never permanently removed), an immutable audit log for every create, edit, and delete action, and a correction workflow where employees are notified via WhatsApp and must approve any time changes proposed by their manager.

The employer (manager account holder) is the data controller for their employees' working-time data. Fleet Rewind Ltd processes this data solely on the employer's documented instructions as data processor, pursuant to a data processing agreement incorporated into these terms.

11. WhatsApp & Meta

ÉascaDesk Scheduler's clock-in/out bot uses the Meta WhatsApp Business Cloud API. When an employee sends a WhatsApp message to the ÉascaDesk bot number:

Meta's own privacy practices are governed by WhatsApp's Privacy Policy. We are not responsible for Meta's data handling.

Employee phone numbers are stored in E.164 format and are used exclusively for operating the ÉascaDesk bot. They are not used for marketing.

12. Security

We take reasonable technical and organisational measures to protect personal data, including:

No system is completely secure. If you believe your account has been compromised, contact us immediately at [email protected].

13. Cookies

ÉascaDesk Scheduler is a single-page application (React/Vite). Authentication uses JWT tokens stored in browser memory and/or localStorage — not cookies. We do not use advertising cookies or third-party tracking cookies on the application.

Our marketing website (www.eascadesk.ie) may use essential cookies for page functionality. We will update this section if analytics or other cookies are introduced.

14. Children

ÉascaDesk is a business tool intended for use by adults in an employment context. We do not knowingly collect personal data from children under the age of 16. If you believe a child's data has been submitted to our platform, please contact us and we will arrange deletion.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify registered account holders by email. Continued use of the platform after the effective date constitutes acceptance of the updated policy.

16. Contact Us

For any privacy-related queries, data subject rights requests, or concerns:

We aim to respond to all enquiries within 30 days.