Privacy at LEM Crew.

Controller & Contact

Operator of LEM Crew and point of contact for technical operations:

As a rule, your respective employer is the controller responsible for processing your employee data. Your employer determines which working-time rules apply, who is authorised to view data and which features are used. Where another company uses LEM Crew, L.E.M. processes its employee data on behalf of that company and in accordance with its instructions as part of technical operations. For its own employees, L.E.M. is itself the employer and data controller.

Your employer’s privacy notices supplement this policy, in particular regarding company-specific legal bases, recipients and retention periods. Enquiries concerning technical operations or help routing your request can be sent to the contact address above.

What data is processed and why?

Data comes from your entries and clock events, from your employer, or is generated during technical use. Your account is created by an authorised person within your company; the mobile app does not offer public self-registration.

Absences and health-related information

A sickness record may already indicate health data through its absence type alone. Such information requires special protection. Do not enter diagnoses or other medical details in free-text fields that are not necessary for the process. You may leave optional notes blank.

Legal bases and required information

Employee data is processed insofar as required for carrying out the employment relationship (§ 26(1) BDSG). Statutory documentation and retention obligations may additionally base processing on Art. 6(1)(c) GDPR. Where health data is required, Art. 9(2)(b) GDPR and § 26(3) BDSG may apply. The decisive factor is the specific processing purpose defined by your employer.

Art. 6(1)(b) GDPR applies to contractual enquiries and contract performance. Operating the service securely and reliably and defending against unauthorised access serve our legitimate interests under Art. 6(1)(f) GDPR. Where processing is based on separate, voluntary consent, Art. 6(1)(a) GDPR applies; such consent may be withdrawn at any time with future effect.

Without the required account and booking data, we cannot provide the relevant access or time-tracking function. Your employer will inform you whether a particular entry is required under employment law. Granting a device permission does not replace a legal basis under data protection law.

Location only when clocking

Your company can disable location capture, offer it as optional, or require it for specific clock events. When enabled, the app requests your device’s location permission. When starting or stopping work or a break, a single location point with its timestamp and accuracy can be sent to the server and stored with that clock event. Depending on your device settings, this may be an approximate or precise location.

The app does not create a continuous movement profile and does not track location in the background. Authorised persons in your company can view the location stored with a clock event. The displayed location represents the point of booking, not live tracking.

You can change the device permission at any time in your system settings. When location capture is optional, you can clock without sharing your location. If your company requires a location, the clock event cannot be completed without sufficient permission or accuracy. Your employer is responsible for explaining the purpose, necessity and legal basis of such a requirement.

Storage on your device

Web portal and strictly necessary cookies

The web portal uses strictly necessary cookies and local storage for sign-in, security features, company selection and language preference. A service worker may cache interface assets. These functions are necessary to provide the service you requested (§ 25(2) no. 2 TDDDG). You can delete cookies in your browser; doing so may require you to sign in again.

Mobile app and offline bookings

The mobile app stores session credentials in the operating system’s secure storage. Previously loaded calendar and working-time data as well as unsent clock events are stored in local app storage so you can use supported features while offline. Once connectivity returns, pending clock events— including any attached notes and location data—are transmitted to crew.l-e-m.de.

Signing out does not delete working-time records already saved on the server. Uninstalling the app or clearing app data may remove unsynchronised offline events; please check that all pending events have been synced beforehand.

Widgets and debug mode

If you add a home-screen widget, your shift status and the values needed to display elapsed time are provided locally to the widget and may be visible on your home screen. The optional debug mode displays technical error details on your device; it does not enable any external analytics service.

LEM Crew does not integrate advertising networks or behavioural analytics services. The mobile app does not read your contacts, private messages or device calendar. The in-app calendar displays records from LEM Crew.

Who has access to your data?

Connections to the web portal and between the mobile app and the API are encrypted via HTTPS/TLS. Accounts, sessions and role permissions protect access to stored records.

You see the data enabled for your personal workspace. Managers, HR staff and administrators receive access according to the configured company, team and role permissions. Authorised persons can generate reports and exports. A live team view may, for example, show who is currently working or on a break. Data is not published publicly.

Hosting, backups and email delivery

• IONOS: Provides the server infrastructure for the web portal, API and database, processing the application and connection data required for operation.
• Backups: Database backups are stored on additional storage infrastructure managed by us, including a Synology system at our office, to support recovery in the event of outages or data loss.
• Microsoft 365 / Microsoft Graph: Sends account, security and operational emails, processing the recipient address and the content required for each message. LEM Crew logs delivery status and dispatch metadata.

When using Microsoft services, processing may take place outside the EU/EEA, in particular in the United States. Microsoft describes the applicable Standard Contractual Clauses in its Products and Services Data Protection Addendum (DPA). You may contact us to request information on the safeguards applicable to the relevant contractual relationship and a copy thereof.

Further disclosures may be necessary if your employer shares data with appointed payroll providers or where a statutory obligation to disclose exists. The respective controller will inform you accordingly. We do not sell your personal data.

Apple App Store and Google Play

When downloading or updating the app, Apple or Google processes data under its own responsibility in accordance with the privacy notices of the respective store. Installing the app through a store does not grant the store access to your LEM Crew working-time or absence accounts.

Optional calendar subscription

If you create a personal calendar link in the web portal and add it to an external calendar service, that service can fetch your completed working times, break totals and approved absences including their type. Notes are not exported. Treat the link as confidential: anyone who knows it can retrieve the included entries. You can revoke the subscription at any time in your personal settings; copies already stored by the external calendar service are not automatically removed.

Retention, archiving and deletion

Retention periods depend on the purpose of processing, the employment relationship, statutory documentation duties, open claims and the policies of the responsible company. Working- time and absence records may therefore still be required after account access ends. Not every category of data shares the same retention period.

• Accounts and operational records: Archiving ends regular sign-in access but is not a deletion. The responsible controller reviews deletion requests and any required continued retention.
• Delivery and audit logs: These ensure traceability of actions and are taken into account when reviewing an account erasure request. The system does not currently apply a blanket automatic deletion of all logs after a fixed number of days.
• Local app data: Cached data and pending offline bookings remain on the device until replaced or until app data is removed. Older caches are not used indefinitely as current data.
• Backups and exports: Deleting data in the live system does not immediately remove existing backups, already delivered emails or previously downloaded exports. Separate retention and deletion rules apply to those copies, and prior deletions must be respected if a backup is restored.

For the retention period applicable to your case or to request a deletion review, please contact your employer or use our contact details above. We will examine which data is still required and which can be deleted or restricted in processing.

Your rights

Subject to the statutory requirements, you have the following rights:

• Access to your personal data (Art. 15 GDPR).
• Rectification of inaccurate or incomplete data (Art. 16 GDPR).
• Erasure and restriction of processing (Art. 17 and 18 GDPR).
• Data portability where applicable (Art. 20 GDPR).
• Objection, on grounds relating to your particular situation, to processing based on legitimate interests (Art. 21 GDPR).
• Withdrawal of given consent with future effect, without affecting the lawfulness of processing prior to withdrawal.

To exercise your rights, write to info@l-e-m.de or contact the responsible department at your employer. Suitable verification of your identity may be required to route your request and protect your data.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the place of your habitual residence, your place of work or the place of the alleged infringement. For L.E.M. in Berlin, one point of contact is the Berlin Commissioner for Data Protection and Freedom of Information.

Automated calculations

Working hours, breaks and account balances are calculated according to configured rules. LEM Crew does not make solely automated personnel decisions producing legal or similarly significant effects within the meaning of Art. 22 GDPR. If you have questions about a calculation or correction, please contact the responsible person in your company.

Changes to this policy

We update this policy when features, services used or legal requirements change. The effective date of the current version is shown at the top of this page.