Your Mobile Privacy, Protected
Policy summary
Personal Data collected for the following purposes and using the following services:
Location-based interactions
Non-continuous geolocation
Personal Data: geographic position
Attachments
Selected photos
Personal Data: photos
Registration and authentication
Clew OAuth using QR Code or forms Personal Data: various types of Data as specified in the privacy policy of the service
Full policy
Thank you for using CGRF Mobile! Here we describe how we collect, use and handle your information when you use our mobile app. We take your privacy very seriously. Because of this we want to provide you with explicit information on how we collect, gather, and identify information during your use of the CGRF Mobile app. This information may be expanded or be updated as we change or develop our app.
This Privacy Policy governs your use of the software application CGRF Mobile (“Application”) for iOS and Android mobile devices that was created by Corporate Governance Risk Pty Ltd. The Application is designed for risk, incident, and other business management users to use to assist them to respond to risks and opportunities as effectively as possible.
Data Controller and Owner
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: non-continuous geographic position, selected photos. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
Place
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.
The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes:
Location-based interactions and Registration and authentication.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Location-based interactions
Non-continuous geolocation (this Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by this Application.
The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data collected: geographic position.
Attachments
Selected photos
The Application allows the selection and upload of photos from the iOS or Android mobile device. All of this user-provided information is optional, but not providing the information may materially affect your experience with the Clew platform.
Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.
Clew OAuth using QR code or forms
Clew OAuth is a registration and authentication service provided by CGR Foundation Pty Ltd and is connected to the main Clew platform.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Australia
Additional information about Data collection and processing
With your company
Your information may be shared with others in your organisation that administer your overall Clew subscription (for example your IT department). This information is only shared to help organisations ensure they have the appropriate licensing level and help them manage their devices.
Legal action
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.
Information about this privacy policy
The Data Controller is responsible for this privacy policy, prepared by Clew.
Definitions and legal references
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
Usage Data
Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User
The individual using this Application, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.
Data Subject
The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this privacy policy.
Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The hardware or software tool by which the Personal Data of the User is collected.
Children
Our Services are not intended for children under the age of 13. Therefore we do not knowingly collect personal information via our websites, applications, services, or tools from anyone under 13.
Legal information
Notice to European Users: this privacy statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.
This privacy policy relates solely to this Application.
Information security
In the UK, we operate and are registered in accordance with the Data Protection Act. This information will not be shared with other organisations for marketing purposes.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorised employees and contractors who need to know that information in order to operate, develop or improve our Application.
Your consent: By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. Contact us If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us.