Privacy Policy

Last updated: 23 September 2026

This Privacy Policy explains how WhoWorked (“we”, “us”, the “Service”) collects, uses and shares information when you visit whoworked.com, use the WhoWorked web app, browser extension, or MCP server, or otherwise interact with us.

We aim to comply with the EU General Data Protection Regulation (GDPR) and the UK GDPR where they apply to our processing, and with the privacy law of the United States jurisdictions we are subject to.

1. Data controller

The data controller responsible for your personal data is:

  • Gratia, LLC (a Delaware limited liability company)
  • Registered office: 12520 Philmont Drive, Herndon, VA 20170, United States
  • Contact: hello@gogratia.com

WhoWorked is part of Gratia. The provider of the Service and the party you contract with is Gratia, LLC, as set out above.

2. What the Service is

WhoWorked is a time-tracking platform for human teams and AI agents. It records work sessions, project budgets, agent contributions, and produces billing-ready reports. The Service includes:

  • The marketing site at whoworked.com.
  • The web app at whoworked.com/app.
  • The WhoWorked browser extension for capturing time entries.
  • An MCP (Model Context Protocol) server that lets authorised AI assistants read and write your WhoWorked data on your behalf.

3. What we collect and why

3.1 Account data

When you create an account we collect your email address, display name, and, where you sign in via an identity provider, a provider-issued user ID and (optionally) your profile photo. We use this to authenticate you, operate your workspace, and communicate service notices.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

3.2 Workspace and time-tracking data

When you use the Service you create content that may include project and client names, task descriptions, time entries, budgets, invoices, uploaded logos, and notes. This content is stored on your behalf and under the direction of the workspace owner.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR); where you are a member of a workspace operated by a third party, that third party acts as the controller of your time-tracking data and we act as processor for them.

3.3 Browser extension data

The WhoWorked browser extension runs locally in your browser and, when authenticated, syncs time entries with your workspace. Specifically, the extension:

  • Stores your access and refresh tokens, workspace ID, and local preferences in browser extension storage.
  • Uses the browser’s idle-state API to detect periods of inactivity (approximately every 60 seconds) so it can pause running timers and prompt you to resume.
  • Lets you right-click selected text to start a timer using that text as the description (you explicitly trigger this).

The extension does not take screenshots, record keystrokes, read page content, or transmit the URLs of tabs you visit.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

3.4 Billing data

If you purchase a paid plan, payment is processed by Stripe. We receive a Stripe customer ID, the subscription status, invoice metadata, and billing address; we do not receive or store your full card number. Invoices we issue include your legally required billing identifiers.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR) for the purchase; legal obligation (Art. 6(1)(c) GDPR) for invoicing and accounting records under applicable tax and accounting law.

3.5 Product analytics and error tracking

We use PostHog(hosted in the EU) for product analytics and server-side error tracking. PostHog receives an anonymous distinct ID stored in a first-party cookie, a description of the event (page viewed, button clicked, error thrown), technical metadata (browser, device, approximate location derived from IP), and—once you sign in—a link between the distinct ID and your account.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in measuring, securing and improving the Service. You can opt out at any time using the controls described in section 7.

3.6 Transactional email

We use Resend to send transactional email (verification, invitations, receipts, password resets, service notices). If you sign up for the waitlist, your email may be added to a Resend audience so we can notify you about launch.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR) for service email; consent (Art. 6(1)(a) GDPR) for waitlist notifications, which you can withdraw using the unsubscribe link in any message.

3.7 AI-generated report summaries

When you generate a client report, we may send a small amount of aggregate metadata (project names, hours consumed, budgets, utilisation percentages) to Anthropic (US) to produce a plain-English summary. We do not send email addresses, time-entry descriptions, or identifying user data to Anthropic. This feature can be disabled by the workspace owner.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in providing helpful reporting.

3.8 Branding lookup

We use Logo.devto fetch a client’s logo from its domain when you request branding for a client record or report. We send the client name or domain you entered.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in providing a usable workspace UI.

3.9 Server logs and security

Our hosting providers (Vercel, Neon) generate short-lived operational logs that include IP addresses, user-agent strings, and request paths. We use these to detect abuse, diagnose outages, and defend the Service.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in keeping the Service secure and available.

4. Sub-processors

We rely on the following sub-processors. Each is bound by a data processing agreement with appropriate safeguards for any international transfer.

Sub-processorPurposeRegion
Vercel Inc.Web hosting, CDN, PDF blob storageEU & US (global edge)
Neon Inc. (AWS Frankfurt)Primary databaseEU (eu-central-1)
PostHog Inc.Product analytics, error trackingEU
Stripe, Inc.Payment processingUS / EU
Resend (Plusten, Inc.)Transactional emailEU (AWS Ireland)
Anthropic, PBCAI summaries (if enabled)US
Logo.devClient logo lookupUS

We are established in the United States. Where you are in the EEA or the UK, your personal data is therefore transferred outside your home jurisdiction when you use the Service, both to us and to the sub-processors above. We rely on the Standard Contractual Clauses (2021/914/EU) and the UK International Data Transfer Addendum for those transfers, and on the EU-US Data Privacy Framework where a recipient is certified under it.

5. Cookies and similar technologies

The Service uses a small number of first-party cookies:

  • Session cookies (prefixed whoworked-) set by our authentication layer to keep you signed in. Strictly necessary.
  • Preference cookies such as last_workspace and your theme choice. Strictly necessary for a functional UI.
  • Analytics cookies (prefixed ph_) set by PostHog to attach an anonymous distinct ID to your events. You can opt out in the cookie banner or by enabling your browser’s “Do Not Track”/Global Privacy Control signal.

We do not use advertising cookies or third-party tracking pixels (no Meta, Google Ads, LinkedIn, TikTok, or X pixel).

6. How long we keep your data

  • Account and workspace data: for as long as your account is active, then deleted within 30 days of account closure, unless a longer period is required below.
  • Invoices and accounting records: for as long as applicable tax and accounting law requires us to keep them.
  • Analytics events: up to 7 years in PostHog (default retention), linked to an anonymous distinct ID.
  • Server logs: up to 30 days.
  • Support email: up to 2 years from the last correspondence.

7. Your rights

Under the GDPR, and under comparable rights given by other applicable privacy law, you have the right to:

  • access your personal data;
  • request correction of inaccurate or incomplete data;
  • request erasure (“right to be forgotten”) where applicable;
  • restrict or object to processing;
  • request portability of the data you provided to us, in a machine-readable format;
  • withdraw consent at any time where processing relies on consent;
  • lodge a complaint with a supervisory authority, in particular the one where you live, where you work, or where the matter you are complaining about happened.

To exercise any of these rights, email hello@gogratia.com. We respond within one month and may ask for proof of identity where reasonably necessary.

To opt out of analytics, you can either (a) decline analytics in the cookie banner, (b) turn on Global Privacy Control or “Do Not Track” in your browser, or (c) email us to have your distinct ID suppressed.

8. Automated decision-making

We do not use your personal data to make decisions about you that produce legal effects or similarly significant effects through automated processing alone.

9. Security

We use industry-standard measures to protect your data, including TLS in transit, encryption at rest provided by our hosting sub-processors, scoped OAuth tokens, and workspace- level access controls. No system is perfectly secure; if we become aware of a personal data breach that poses a risk to your rights, we will notify you and the relevant supervisory authority in accordance with Articles 33–34 GDPR.

10. Children

The Service is not directed to children under 16, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

11. Changes to this policy

We may update this policy to reflect changes in the Service or the law. We will update the “Last updated” date at the top and, for material changes, notify account holders by email at least 14 days before the change takes effect.

12. Contact

Questions, concerns, or requests regarding this policy: hello@gogratia.com.