TWFMO

Legal

Privacy Policy

Effective and last updated September 14, 2026

1. Scope

This Privacy Policy explains how TWFMO (The Washington Family Management Office, “TWFMO,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you use twfmo.com and related TWFMO applications and services (collectively, the “Services”). It also covers information processed through TWFMO’s employee time-clock and administrative features.

This policy does not govern independently operated websites or services that you may reach through links on the Services. Those services have their own privacy practices.

2. Information we collect

Information you or an administrator provides

  • Identity and account information: name, display name, email address, account role, and other information needed to authenticate or administer access.
  • Time-clock information: work punch times, business or work assignment, approval status, corrections, rejection reasons, and associated audit history.
  • Clock credentials: the time clock uses a six-digit PIN. Persistent PINs and enrollment codes are stored as one-way hashes rather than in readable form.
  • Communications: information you provide when you contact TWFMO or request support.

Information collected automatically

  • Security and technical information: IP address and limited request information may be processed for authentication, rate limiting, abuse prevention, troubleshooting, and security logging.
  • Session information: the clock system uses a short-lived, HttpOnly cookie after successful PIN identification so an authorized punch can be completed. The assertion is single-use and is cleared after use or when the session is ended.

3. How we use information

We may use personal information to:

  • provide, operate, maintain, and improve the Services;
  • authenticate users and control access to restricted functions;
  • record, review, approve, correct, and audit time-clock activity;
  • protect the Services against fraud, abuse, credential attacks, and other security threats;
  • diagnose errors, maintain reliability, and support users;
  • comply with applicable legal, tax, employment, accounting, and recordkeeping obligations; and
  • establish, exercise, or defend legal rights.

4. Cookies and similar technologies

TWFMO currently uses cookies that are necessary to provide authentication and session functionality. The TWFMO application does not currently use advertising cookies or cross-context behavioral advertising technology. If our practices materially change, we will update this policy and provide any notices or choices required by law.

5. How we disclose information

We may disclose personal information in the following circumstances:

  • Service providers: vendors that provide hosting, databases, authentication, security, rate limiting, logging, and other infrastructure or support functions on our behalf.
  • Authorized administrators and affiliated operations: when access is reasonably necessary to administer personnel, time records, security, or an affiliated TWFMO operation.
  • Legal and safety purposes: when we reasonably believe disclosure is required by law, legal process, or to protect rights, property, safety, or the integrity of the Services.
  • Business transactions: in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to applicable law.

We do not currently sell personal information, share personal information for cross-context behavioral advertising, or process personal information for targeted advertising.

6. Data retention

We retain personal information for as long as reasonably necessary for the purposes described in this policy, including operational, security, employment, accounting, tax, audit, dispute-resolution, and legal-compliance needs. Retention periods vary by record type and applicable obligations. We may retain deidentified information where permitted by law.

7. Security

We use administrative, technical, and organizational safeguards designed to protect personal information. Examples in the time-clock service include hashed PIN credentials, restricted administrative access, short-lived session assertions, rate limiting, and audit records. No system can guarantee absolute security, and you are responsible for protecting credentials entrusted to you.

8. Your privacy rights

Depending on where you live and the context in which we process your information, applicable law may give you rights to confirm processing, access or obtain a copy of personal information, correct inaccuracies, request deletion, obtain data portability, or opt out of certain sales, targeted advertising, or qualifying profiling. Where an appeal right applies, you may also appeal a decision on a privacy request.

TWFMO does not currently sell personal information or use it for targeted advertising. Some laws, including the Texas Data Privacy and Security Act, exclude certain employment-related information from consumer-rights coverage. We will evaluate each request under the law that applies to the relevant data and relationship.

To exercise an applicable right, email charper@scrumetrix.com. You may also use the contact channel through which you normally interact with TWFMO or, for workforce records, contact your TWFMO administrator. We may need to verify your identity before fulfilling a request. We will not unlawfully discriminate against you for exercising a privacy right.

9. Children

The public-facing Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 through public-facing features. Workforce information for a legally employed minor, if any, is handled for employment and administrative purposes and is not collected for advertising.

10. United States processing

TWFMO is based in the United States. Personal information may be processed and stored in the United States and other locations where our service providers operate, subject to applicable law and contractual protections.

11. Changes to this policy

We may update this Privacy Policy to reflect changes in the Services, our practices, or applicable law. We will post the revised policy here and update the effective date. If required by law, we will provide additional notice.

12. Contact

Questions about this Privacy Policy, TWFMO’s privacy practices, or a privacy-rights request may be sent to charper@scrumetrix.com. Workforce users may also contact their TWFMO administrator.