PunchGuard™ Privacy Policy
Effective Date: August 1, 2026
Version: 1.0
This Privacy Policy describes how ELE Consulting Inc., doing business as Wage Counsel Group ("Company," "we," "us," or "our"), collects, uses, discloses, and retains information in connection with PunchGuard™ (the "Service"), available at wagecounselgroup.com and any successor domain.
This Privacy Policy applies only to the Service. It does not apply to wagecounselgroup.com, our marketing website, which is governed by a separate privacy policy available at wagecounselgroup.com/privacy.
This Privacy Policy should be read together with the PunchGuard Terms of Service ("Terms"), which govern use of the Service and define terms used here, including **Subscriber**, **Employer Data Owner**, **Authorized User**, and the account types described in Terms Section 3.2 (Direct Employer Account, Attorney-Directed Account, and Employer Account with Authorized Advisor Access).
1. Who This Policy Covers — and an Important Gap
This Policy describes our practices toward the Subscriber — the party that registers for, logs into, and controls a PunchGuard account.
It does not describe a direct relationship with the individual employees whose timeclock, wage, or personnel data may be uploaded to the Service.** Depending on the account type, those employees may have no direct relationship with Company, no notice that their data has been uploaded, and no ability to access this Policy through their own use of the Service, because they are not users of the Service. Responsibility for notifying employees about, and obtaining any consent required for, the use of their data through the Service rests with the Subscriber and/or the Employer Data Owner, consistent with Terms Section 4.3. If you are an employee whose data you believe may have been uploaded to the Service and have questions about how that data is handled, we encourage you to direct those questions to your employer or its counsel in the first instance; you may also contact us using the information in Section 9.
2. Information We Collect
2.1 Account Information
When a Subscriber registers, we collect account information such as name, email address, organization name, and account type (employer or attorney/firm), processed through our authentication provider, Clerk.
2.2 Billing Information
Subscription and payment information is collected and processed by our payment processor, Stripe. Company does not directly store full payment card numbers.
2.3 Uploaded Timeclock and Payroll Data ("Customer Data")
Customer Data — timeclock exports, pay rate information, and related data uploaded to generate an analysis — is processed to produce the Service's output. **Consistent with Terms Section 4.7, violation-level Customer Data (dates, hours, dollar amounts, and employee-level results) is processed to produce analysis output and export files, and is not stored by Company beyond the active session in which the upload and analysis occur.
To allow settings to carry over between sessions, we retain, on an ongoing basis, tied to the Subscriber's account:
- Analysis configuration settings (e.g., pay period start date, pay frequency, minimum meal break threshold)
- Pay rate sheets uploaded to the account
- A record of the dates on which the Service was used ("Run History"), reflecting only the date of use, with no violation-level detail, dollar figures, or employee-identifying information
2.5 Information Collected Automatically
We and our service providers may automatically collect technical information necessary to operate the Service, such as IP address, browser and device information, authentication session data, and application log data reflecting general usage and errors. This is used to operate, secure, and troubleshoot the Service, not to build a profile of individual behavior for marketing purposes.
How We Use Information
We use the information described above to:
- Provide, operate, and maintain the Service
- Authenticate accounts and process billing
- Preserve configuration settings and rate sheets between sessions
- Maintain Run History as described in Section 2.4
- Diagnose and resolve technical issues
- Comply with legal obligations
- Communicate with Subscribers about their account or the Service
We do not use Customer Data to train external or general-purpose models, and we do not sell personal information.
4. How We Share Information
We do not sell personal information. We share information only as follows:
- Service providers: Clerk (authentication), Stripe (billing), and our hosting provider (Vercel), each of which processes information on our behalf and under obligations to protect it.
- Legal process: As required by law, subpoena, or court order. Consistent with Terms Section 4.6, where Company receives legal process seeking Customer Data, we will provide prompt notice to the affected Subscriber, to the extent permitted by law, before producing any data.
- Business transfers: In connection with a merger, acquisition, or sale of business assets, subject to confidentiality protections consistent with this Policy.
Data Segregation. Consistent with Terms Section 4.5, one Subscriber's account-level data is never shared or made visible to another Subscriber, including across different employer accounts and different attorney/firm accounts.
5. Data Retention
See Terms Section 4.7 and Section 2 of this Policy. In summary: violation-level Customer Data is not retained beyond the active session; account configuration, rate sheets, and Run History dates are retained for the life of the account and are available for export for 30 days following account termination, after which they may be deleted, except as required to be retained by law.
This retention practice is applied uniformly to all accounts and sessions and is not adjusted based on the existence, status, or subject matter of any actual or anticipated litigation.
6. Cookies and Similar Technologies
The Service uses cookies or similar technologies necessary for authentication and session management (via Clerk) and billing (via Stripe). The Service does not currently use third-party advertising or cross-site tracking cookies. Disabling essential cookies will prevent the Service from functioning.
7. Security
We use reasonable administrative and technical safeguards designed to protect information processed through the Service, including relying on established third-party providers (Clerk, Stripe, Vercel) for authentication, billing, and hosting infrastructure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
8. Your Privacy Rights (California)
8.1 Subscribers. If you are a Subscriber and a California resident, you may have rights under the CCPA/CPRA with respect to your account information, including the right to know, delete, and correct certain personal information, and the right to opt out of sale or sharing — which we do not engage in. To exercise these rights, contact us using the information in Section 9.
8.2 Employees Whose Data Is Uploaded. As described in Section 1, Company does not have a direct relationship with, and generally cannot independently verify the identity of, employees whose data may be uploaded to the Service by a Subscriber. Consistent with the retention practices in Section 5, violation-level data concerning individual employees is not retained beyond the active session in which it is processed. Requests concerning that data should generally be directed to the employer, who is best positioned to locate, verify, and respond to them; Company will reasonably cooperate with a Subscriber responding to such a request to the extent Company retains relevant information.
9. Contact Us
ELE Consulting Inc. d/b/a Wage Counsel Group
Woodland Hills, California
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be reflected by an updated effective date and, consistent with Terms Section 14, may require re-acceptance before continued use of the Service.