Privacy Notice

Last Updated: January 12, 2026

When I Work, LLC (“When I Work,” “WIW,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice explains how information about you or associated with you (“personal information” or “personal data”) is collected, used, and disclosed by When I Work and its affiliates for our own purposes. This Privacy Notice applies to: (a) our website www.wheniwork.com, or any other When I Work websites or virtual events where this Privacy Notice is posted (“Sites”), and (b) our Software as a Service (“SaaS”) workforce management solution (“SaaS Solution”), which is available as a desktop or a mobile application (collectively our Sites and SaaS Solution are referred to as our “Services”). By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Notice and Terms of Service.

“You” or “your” means a user of the Services, which could refer to a visitor to our Sites, or to a Workplace User using the SaaS Solution, including an account admin, supervisor, manager, or individual shift worker, associated with a Workplace account, or any other authorized user of the Services. Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms of Service.

We recommend that you read this Privacy Notice in its entirety to ensure you are fully informed. However, in order to simplify your reading, we have included quick links to each section below:

1. Personal Information We Collect

The personal information we collect depends on the context of your interactions with When I Work and the choices you make, the Services and features you use, your location, and applicable laws, but can include the following:

• Information You Provide to Us. We collect personal information you provide us when you interact with us, such as when you complete a form on our website to obtain additional information about our Services, or create a When I Work account. This information may vary depending on how you interact and what you choose to share with us, and includes:
  • Account information, such as your email address, password, and any authentication and security credential information used to create and administer your When I Work account.
  • Address book, calendar and contact information. With your permission, When I Work may access your contact list available on your mobile device, in your email accounts or other information system you connect with the Services in order to locate your friends, contacts, and workers on the Services and to invite them to register with our Services. With your permission, we may integrate our Services with your calendar system (such as Google Calendar, Microsoft Outlook, etc.) in order to provide updates of your schedule on the Services to your calendar, and to integrate your calendar entries with your When I Work schedule.
  • Contact and professional information, such as your name, address, phone number, email address, Workplace name, job title/level, department, and industry.
  • Contract and payment information, such as your signature, credit card and bank account information, VAT numbers and other tax identifiers that you use to pay for When I Work Services.
  • Communications information, such as your feedback on our Services and other communications with us (including when you interact with our customer service online and offline), any queries you raise (including when you fill out a form on our website), and chat, email, or call history. This includes information as to how you contact us, and the channel of communication that you use, as well as any information that you send to us. 
  • Audio and video recordings. If you attend a When I Work in-person or virtual event, answer a telephone call from When I Work, or otherwise join a telephone or video meeting with us, we may record some or all of that event or meeting (including audio and video content). For events, we may document the event in various ways, such as by taking photos, conducting interviews, or recording your participation in an interactive session. We will obtain your consent where required under applicable laws.
  • Advertising and marketing information, such as your interests based on your use of our Services and other websites and online services, your preferences in relation to receiving marketing materials from us, communication preferences, and your preferences for particular products or services.

Providing your personal information is optional. You are not under a legal duty to provide your personal information, but it may be necessary for certain Services, such as account registration. In such cases, if you do not provide your personal information, we may not be able to provide you with the requested Services.

• Information We Collect Automatically. We automatically collect certain types of information when you interact with our Services, such as when you visit our Sites or log into your SaaS account. We use common information gathering tools, such as tools for collecting usage data, cookies, web beacons, and similar tracking technologies to automatically collect information that may contain personal information from your computer or mobile device as you navigate our Services or interact with emails we have sent you. This information includes:
  • Usage and interaction information. The full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and other Services, content you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).
  • Log data and device information, such as IP address, information about your Internet service provider, computer and device information including device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting, authentication and security credential information, access dates and times, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs.
  • Inferred location information. We may look up your IP address to determine your general location.
  • Location information. Certain Services may request permission to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your mobile device settings.
• Information We Collect from Other Sources. Depending on how you use our Services, we may collect information about you from other sources and combine this information with personal information that you provide. These sources include: 
  • Your Workplace and their partners. We may receive information about you from your Workplace and their service providers (such as identity verification and payroll vendors).
  • Other When I Work users. We may receive information about you, such as contact and professional information, from other users, such as our customers or partners who may refer you to When I Work.
  • Third-party service providers and business partners. We may receive information about you from third parties we use to verify your identity, and prevent fraud, such as your name, address, phone number, and IP address. 
  • Public and third-party sources for marketing. We collect information about prospective users of our Services from publicly and commercially available services including aggregators and social media networks, as well as through third-party marketing initiatives, such as events where we are a sponsor. This information may include marketing and sales generation information such as your social profile (e.g. LinkedIn), name, email address, physical address, phone number, and professional information. 
  • Social networking sites. When you interact with our site through various social media, such as when you login through Facebook or Google, or share When I Work content on Facebook, Twitter, or other sites, we may receive information from the social network including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and we will not post information about you on third party social media sites without your consent. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Services.

2. How We Use Your Personal Information and our Legal Bases for Processing It

Our purposes and legal bases for using personal information depend on the context of your interactions with When I Work and the choices you make, the Services and features you use, and your location, but can include those set out below, as permitted by applicable laws:

• Register and administer your account: Create, maintain and administer your When I Work account.
• Process transactions: Process any transactions for When I Work Services (including registrations, purchases, and payments).
• Providing When I Work’s Services: Operate, provide, deliver, and assess eligibility for our Services.
• Communicate with you: Communicate with you regarding our Services via different channels (e.g., by phone, SMS, or email), send you service updates, confirmations, invoices, technical notices, updates, security alerts, support and administrator messages, and respond to your inquiries, requests, or complaints.
• Measure, troubleshoot, develop, and improve our Services and our business: Provide, maintain, improve, and develop our Services, including by measuring their use, analyzing their performance, and fixing errors.
• Recommendations and personalization: Recommend When I Work Services that might be of interest to you, identify your preferences, and personalize your experience with When I Work Services.
• Advertising and marketing: Send you promotional messages, messages, marketing, advertising, and other information based on your preferences, and personalize, measure, and improve our advertising. We may also use personal information to administer referral programs, rewards surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by When I Work or its third-party partners, and to invite you to events and relevant opportunities. For more information about your choices relating to our marketing activities, see “Your Rights and Choices” section below.
• Prevent and investigate security and fraud issues: Prevent, detect, mitigate, and investigate potential security issues, as well as fraudulent or illegal activity on our Services, or to comply with legal obligations.
• Comply with legal and regulatory obligations: Comply with, and enforce our rights under, any applicable laws. This includes complying with our obligations to respond to your requests under applicable data protection laws.

We collect and use this information on the following legal basis:

• Performance of a contract entered between you and When I Work with respect to the provision of our Services in accordance with our Terms of Service or as otherwise agreed between the parties.
• Our legitimate interests (to operate, provide, and improve our Services; to communicate with you, where our communications are not necessary to perform or enter into a contract with you).
• Compliance with legal obligations and the exercise of our legal rights.
• With your consent (where required under applicable laws).

3. How We Disclose Your Personal Information

We may disclose your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Rights and Choices” section below.

We may disclose your personal information with:

• Other members of the Services. Your information will be shared with other Users of the Services, as needed to provide the Services to you. For example, some of your information may be shared with your Workplace and with other workers of the same Workplace in order to facilitate scheduling, timekeeping, and communication. You may be able to control the visibility of some of your information and actions through your Settings (see “Your Rights and Choices” below). We also share information about your use of the Services with your Workplace for analytic purposes. For example, we provide reporting tools to allow a Workplace to evaluate the efficiency of its workforce, and its workers’ responsiveness and availability;
• With your consent. From time to time, we may provide an opportunity to share your information with one of our third party partners or other individuals. We will ask for your consent before engaging in this type of sharing;
• Other companies owned by or under common ownership as When I Work, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we under this Privacy Notice;
• Third party vendors, consultants, and other service providers that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving targeted advertisements, hosting services, or providing analytics services;
• Third-party advertising services. We provide information (such as your internet or other similar network activity, identifiers such as your name and email address, location information, and inferences about your interests) to third parties, including advertising networks that allow them to serve you with more useful and relevant When I Work ads and to measure their effectiveness. For more information about your choices relating to our advertising, see “Your Rights and Choices” section below.
• Other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings; and
• Protection of us and others. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Service, or other contract between us, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of When I Work, its Users, or the public as required or permitted by law, and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security, or technical issues.

We may also disclose information with others in an aggregated and/or anonymous form that does not reasonably identify you directly as an individual.

4. How Long We Keep Your Personal Information

When you register as a User of When I Work’s SaaS Solution, the personal profile you create within your User account allows you to, e.g., set a profile image, set your personal information, and configure your preferences. We keep your personal information in accordance with our applicable data retention periods or for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

For further information on When I Work’s applicable data retention periods, please visit our Help Center or contact us at the address stated under the “How to Contact Us” section below.

Generally, the following applies when a workplace account or user account is closed, deactivated, or cancelled:

• If your workplace closes, deactivates, or cancels its When I Work account, no Users can access that account but When I Work internally retains the personal information in your User account as set forth above.

• If you stop being a User at a Workplace that is an active customer of our SaaS Solution, you can ask your Workplace to “archive” your user account. Once your user account is archived by your Workplace, you are removed from the schedule, your User account for that Workplace is deactivated, and you are no longer able to access the Workplace through When I Work. However, your Workplace has the ability to reactivate your account and access the personal information and data in it – for example, for faster onboarding if you return to the Workplace as a User, or if the Workplace needs the information for its legal obligations, such as tax reporting. When I Work cannot archive a User account, only the User’s Workplace can do so.

Depending on your age and location, you may have certain rights regarding your personal information. See “Children’s Personal Information” and “Your Rights and Choices” sections below. For example, you may request When I Work to delete your personal information by contacting us at support@wheniwork.com. If you are a User in a Workplace that is an active customer of our SaaS Solution, we will need to contact your Workplace (or ask you to contact your Workplace) to advise of your request, so that your Workplace may: (a) choose to provide you (if you are an active User in the Workplace account) with an alternative means of scheduling shifts and providing you with notifications such as open shifts, recording your time and attendance, (b) save the information it needs for its legal obligations before it archives your User account; and/or (c) archive your account. Due to the nature of our Services, we may not be able to delete all of your personal information if, for example, that content has been stored, republished, shared with or reposted by a third party or another user, including the shift and time records maintained by your Workplace. We may also maintain your information in identifiable form for our internal use in accordance with this Privacy Notice, even if your personal data is no longer visible to others on our Services.

For further information on applicable data retention periods, please visit our Help Center or contact us at the address stated under the “How to Contact Us” section below.

5. International Transfers

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates or service providers maintain facilities. 

We maintain primary data centers in the United States. We take steps designed to ensure that the personal information we collect under this Privacy Notice is processed as described in this Privacy Notice and according to any applicable laws. As a result, your personal information may be subject to the laws of foreign jurisdictions, including laws that permit or require the disclosure of information to law enforcement or national security authorities upon request. When transferring personal information from a jurisdiction restricting such exports, we will adopt appropriate data transfer tools such as approved standard contractual clauses or your consent (based on applicable laws). 

For further information on the transfer tools we use, please contact us at the address stated under the “How to Contact Us” section below.

6. Cookies

We use cookies and similar technologies to enable our systems to recognize your browser or device, to provide our Services, and to improve your experience. For more information, please see our Cookie Notice.

7. Security

When I Work cares about the security of your information and employs physical, administrative, and technological safeguards designed to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems up to 100%. In the event that any information under our control is compromised as a result of a breach of our security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. If you are a worker whose information is associated with a Workplace account on our Services, we will notify the Workplace or Workplace User of a breach of security which requires legal notification, and your Workplace shall be responsible for informing you of the incident.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. To exercise your rights, please contact us as described under the “How to Contact Us” section below, or as otherwise described in this Privacy Notice. Subject to applicable law, you may have the right to:

• Ask whether we hold personal information about you, and request copies of such personal information and information about how it is processed;
• Request information about our processing of your personal information, including information about third parties to whom we disclose personal information and why we process your personal information through these third parties;
• Request that personal information about you is corrected;
• Request deletion of your personal information;
• Request us to restrict the processing of your personal information where the processing is inappropriate;
• Request that we inform any third parties to whom we’ve disclosed your personal information of your correction, deletion, or restriction requests;
• Object to certain processing of your personal information;
• Request portability of personal information that you have provided to us;
• If we have collected and processed your personal information with your consent, withdraw your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. However, please note that the withdrawal of your consent may affect our ability to continue to provide you with When I Work Services because the continued use and disclosure of your personal information is necessary to make When I Work Services available to you; 
• Unsubscribe from receiving promotional emails or direct mail from us through the applicable link in the communication received. You can opt out from receiving promotional calls or SMS by contacting us at privacy@wheniwork.com or, in the case of SMS, texting “STOP”. If you do not want to receive in-app notifications from us, you can adjust your notification settings in the app or device; and/or
• Submit a complaint to a data protection authority about our collection and use of your personal information. A full list of European Economic Area (“EEA”) data protection authorities by country is here. The UK Information Commissioner’s Office can be contacted here.

9. Children’s Personal Information

The Services and their content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information collected from a child under 13, please contact us at support@wheniwork.com.

If you are under 18 years of age, you may request to delete or anonymize user content that you posted to the Services such that your personal information will not be identifiable publicly on our Services by contacting us at support@wheniwork.com. While we will use all commercially reasonable efforts to delete or anonymize your user content upon request, please be aware that due to the nature of our Services, you may not be able to completely remove all of your personally identifiable user content if, for example, that content has been stored, republished, or reposted by another user or a third party. We may also maintain your information in identifiable form for our internal use, even if your personal data is no longer visible to the public on our Service.

10. Links to Third-Party Websites

The Services may contain links to and from third-party websites of our business partners, advertisers, social media sites, and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

11. Updates to this Privacy Notice

We reserve the right to modify this Privacy Notice, including any region-specific disclosures referenced herein, from time to time. If we make any changes to this Privacy Notice, we will change the “Last Updated” date indicated at the top and will post the updated Privacy Notice. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Notice means that you are consenting to the changes.

12. How To Contact Us

If you have questions about our Privacy Notice or privacy practices, please contact us at privacy@wheniwork.com or by writing to us at: When I Work, Inc. 420 North 5th St. Suite 500 Minneapolis, MN 55401 U.S.A.

Subject to applicable laws, you can also contact us if you wish to lodge a complaint about our privacy practices, or to appeal our actions with regards to your rights and choices.

13. Additional Information for California Residents

Below are the additional disclosures for California residents that are required by the California Consumer Privacy Act and the California Privacy Rights Act (together, the “CCPA”), effective as of January 9, 2026. These disclosures supplement the rest of this Privacy Notice.

• Categories of Personal Information we Collect. The personal information that we have collected from consumers in the preceding twelve months, fall into the following categories established by the CCPA: 

Category of Personal Information Collected	Collected	Categories of Sources
Identifiers, such as your name, email address, password and contact information	✅	• Directly from you • Our business partners and affiliates • Third parties you direct to share information with us • Social networks • Data sellers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as contact information and payment information.	✅	• Directly from you • Our business partners and affiliates • Third parties you direct to share information with us • Social networks • Data sellers
Protected Classification Characteristics, such as age and gender.	❌
Commercial Information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	✅	• Directly from you • Your browser or device • Data sellers
Biometric Information, such as face, eye or other biometric scans.	❌
Internet/Network Information, such as device information, logs and analytics data.	✅	• Your browser or device
Geolocation Data, such as precise location information from your device or generated based on IP address	✅	• Your browser or device
Sensory Information, such as visual information or, where permitted by law, recordings of phone calls with us.	✅	• Directly from you
Profession/Employment Information, such as your job title, pay-scale and shift information.	✅	• Directly from you • From our customers • For applicants, from third parties you direct to share information with us
Non-Public Education Information, such as personal information from an education record.	✅	• Directly from you • From our customers • Third parties you direct to share information from us
Other Personal Information, including information that you provide to us directly or through a third-party service, including messages you send us through our Services or on social media.	✅	• Directly from you • Third parties you direct to share information from us • Your browser or device
Inferences, such as predictions about your interests and preferences.	✅	• Your browser or device • Information generated or derived from your online browsing and usage activity

The chart above and the chart below refer to the categories of personal information we collect about you and to whom it is disclosed. We have provided descriptions of each category for example only. If a personal information category is included in the sections of these charts, that means we maintain (or disclose) one or more (but not necessarily all) of the specific pieces of personal information in that category about you.

To learn more about the types of personal information we collect and the purposes for which we collect this information, please refer to the section of our Privacy Notice titled “Personal Information We Collect” and “How We Use Your Personal Information and our Legal Basis for Processing It.”

• Categories of Personal Information Disclosed for a Business Purpose. The personal information that we disclosed about consumers for a business purpose in the preceding twelve months fall into the following categories established by the CCPA, depending on how you engage with us:

Categories of Personal Data Disclosed	Disclosed	To Whom Personal Information is Disclosed and the Business Purpose
Identifiers, such as your name, email address, password and contact information	✅	• Third Parties solely for the purpose of providing the Services: (i) if you have a User account, the Workplace(s) that you direct us to share information with; (ii) our corporate affiliates; (iii) our service providers and advisors; (iv) marketing and strategic partners; (v) promotional partners; (vi) ad networks and advertising partners; (vii) analytics providers; and (viii) social networks.
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as contact information and payment information.	✅	• Third Parties solely for the purpose of providing the Services: (i) if you have a User account, the Workplace(s) that you direct us to share information with; (ii) our corporate affiliates; (iii) our service providers and advisors; (iv) marketing and strategic partners; (v) promotional partners; (vi) ad networks and advertising partners; (vii) analytics providers; and (viii) social networks.
Protected Classification Characteristics, such as age and gender.	❌
Commercial Information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	✅	• The User’s Workplace (Account Holder) who has signed up with When I Work.
Biometric Information, such as face, eye or other biometric scans.	❌
Internet/Network Information, such as device information, logs and analytics data.	✅	• Third Parties solely for the purpose of providing the Services: (i) if you have a User account, the Workplace(s) that you direct us to share information with; (ii) our corporate affiliates; (iii) our service providers and advisors; (iv) marketing and strategic partners; (v) ad networks and advertising partners; (vi) analytics providers; and(vii) social networks.
Geolocation Data, such as precise location information from your device or generated based on IP address.	✅	• The User’s Workplace (Account Holder) who has signed up with When I Work in connection with our Time and Attendance Feature.
Sensory Information, such as visual information or where permitted by law, recordings of phone calls with us.	✅	• The Workplace and User The User can add a photo (avatar) to their account for the Workplace and other Workplace Users to view.
Profession/Employment Information, such as your job title, pay-scale and shift information.	✅	• The Workplace or User
Non-Public Education Information, such as personal information from an education record.	✅	• The Workplace or User can include information regarding Non-Public Educational information for the purpose of scheduling – e.g. CPR Certified, Lifeguard Certified, High School Graduate.
Other Personal Information, including information that you provide to us directly or through a third-party service, including messages you send us through our Services or on social media.	✅	• The Workplace and other Workplace Users for the purpose of scheduling and communicating.
Inferences, such as predictions about your interests and preferences.	✅	• The Workplace and other Workplace Users for the purpose of scheduling – e.g. preferences for positions and availability to work.

For more information about our disclosures of these categories of personal information, please see the “How We Disclose Your Personal Information” section above.

• Categories of Personal Information “Sold” and/or “Shared.” We do not currently “sell” personal information as most people would typically understand that term; however, we use cookies and similar technologies to understand how well our online advertising works, and deliver more targeted online advertising and marketing campaigns. Over the past twelve months, we may have disclosed your internet or other similar network activity, identifiers and location information, and inferences about your interests to third parties, including, advertising networks, data analytics providers, social networks and advertising partners for the purposes of serving ads for When I Work and its affiliated companies that may be relevant to the user, for ad campaign measurement and analytics, for the purposes of analyzing and optimizing our Services, and for fraud detection and reporting. The CCPA may consider our disclosures of this information to third parties as “sales” or “sharing” of personal information. When I Work does not have actual knowledge that it “sells” or “shares” the personal information of individuals under 16 years of age.
• Sensitive Personal Information. The categories of data that When I Work collects and discloses for a business purpose include “sensitive personal information” as defined under the CCPA. When I Work does not use or disclose sensitive personal information for any purpose not expressly permitted by the CCPA.
• Your California Rights and Choices. Under CCPA, you may have rights to ask us to:
  • Provide descriptions of the personal information we hold about you;
  • Provide access to certain personal information we hold about you, in some cases in a portable format, if technically feasible;
  • Update or correct your personal information;
  • Delete certain personal information we hold about you; and
  • Opt out of our “sale” and “sharing” of your personal information, as those terms are defined in the CCPA.
• Verification and Authorized Agents. When you submit a rights request to us, we will take steps to verify your identity, including by validating your name and the email you use when interacting with us. You may also have the right to designate an authorized agent to help you exercise these consumer rights. To ensure the security of your When I Work account, we will generally ask you to verify your, or your authorized agent’s, request using the contact information you have already provided.
• Exercising your rights. If you would like to exercise any of these rights, please contact us by:
  • Emailing privacy@wheniwork.com with the subject line “California Rights Request,” or
  • Calling 1-800-977-3675
• No Discrimination. We will not discriminate against any consumer for exercising their rights under the CCPA.
• Retention of Personal Information. For information on how long we retain your personal information, please see the “How Long We Keep Your Personal Information” section above.