Tobe Twin Privacy Policy

Introduction

IDD Tech Pty Ltd ("IDD Tech", "we", "our", or "us") operates Tobe Twin, Tobe Twin Mobile, and related services.

Tobe Twin is a digital twin. Tobe Twin Mobile is an application that, with your permission, uses location services to track you as you drive, walk, and move in real time, and shows that as a device in Tobe Twin.

This Privacy Policy explains how we collect, use, disclose, and protect information when you use Tobe Twin, Tobe Twin Mobile, and related services.

By using Tobe Twin or Tobe Twin Mobile, you agree to the collection and use of information described in this Privacy Policy.

Employment, corporate website, and CIMIC Group matters are covered by the IDD Tech corporate privacy policy at https://www.iddtech.com.au/about/corporate-governance/privacy-policy. This page is for Tobe Twin and Tobe Twin Mobile only.

Information We Collect

Depending on how you use Tobe Twin or Tobe Twin Mobile, we may collect:

Tobe Twin Mobile location

• Real-time location while you have granted permission and tracking is on
• A historical trail of that movement, which is stored in the Twin

Location collection is off until you grant permission. See Tobe Twin Mobile location below.

Asset and operational information

Tobe Twin also holds asset and operational information that your organisation already puts in the Twin. This policy does not list industrial sensors. The new collection described here is Tobe Twin Mobile location.

How We Use Information

We use the information we collect to:

• Provide and maintain Tobe Twin and Tobe Twin Mobile
• Show a permitted person or device in the Twin, including the stored movement trail
• Operate and support the Twin for your organisation
• Respond to customer support requests
• Comply with legal obligations
• Protect the security of our services

We do not use Tobe Twin Mobile location for advertising.

Tobe Twin Mobile location

Tobe Twin Mobile can show you as a device in Tobe Twin while you drive, walk, and move. This section explains that location collection.

Consent

• Location collection is off until you grant permission through the device operating system and, where offered, in the app.
• We do not collect Tobe Twin Mobile location without that permission.

Purpose

• We use this location only to show that person or device in Tobe Twin.
• We do not use it for advertising.
• We do not sell Tobe Twin Mobile location or other personal information.

Real-time location and historical trail

While tracking is on and permission is granted, Tobe Twin Mobile uses location services to collect your position in real time so the Twin can show the device. We also store a historical trail of that movement in the Twin. Stopping tracking stops new points. It does not delete the trail already stored.

Who can see it

• Authorised users of that Twin may see the live device location while tracking is on, and the stored historical trail.
• IDD Tech staff may see it only as needed to operate or support the service.

How to stop

You can stop Twin Mobile location by:

• Turning off location permission in device settings
• Stopping tracking in the app, if that control is available
• Uninstalling Tobe Twin Mobile
• Requesting deletion using the contact details below

Stopping tracking stops new location collection. It does not delete the historical trail already stored in the Twin. To delete personal information we already hold, including that trail, use a deletion request.

Work use

If you use Tobe Twin Mobile for work, authorised users of that Twin, which may include your employer, may see your live location while tracking is on and the stored historical trail. Workplace surveillance rules may apply. Employment matters stay on the IDD Tech corporate privacy policy.

Information Sharing

We do not sell personal information.

Information may be shared:

• With authorised users of the relevant Twin
• With service providers assisting us in operating the applications
• With hosting, security, and support providers
• Where required by law
• To protect rights, safety, or property
• During business transactions such as mergers or acquisitions

IDD Tech staff may access personal information only as needed to operate or support the service.

All third-party providers are required to appropriately safeguard personal information.

Data Retention

We retain personal information only for as long as reasonably necessary to:

• Provide services
• Show a permitted device in the Twin
• Meet contractual obligations
• Resolve disputes
• Comply with legal requirements

Tobe Twin Mobile location includes a stored historical trail. We keep that trail until you request deletion, or until that Twin is closed. We then securely delete or de-identify it. There is no fixed number of days. Stopping tracking does not delete the trail.

Where information is no longer needed, it will be securely deleted or de-identified.

International Data Transfers

Information may be processed or stored in Australia or other countries where our service providers operate. Where international transfers occur, we take reasonable steps to ensure personal information receives protections consistent with applicable privacy laws.

Security

We implement administrative, technical, and physical safeguards designed to protect information from:

• Unauthorized access
• Disclosure
• Alteration
• Loss
• Misuse

No method of transmission or storage is completely secure; however, we take reasonable measures to protect personal information.

Children's Privacy

Tobe Twin and Tobe Twin Mobile are not directed to children under the age of 13, or a higher minimum age where required by local law. These products are not for children. We do not knowingly collect personal information from children without appropriate parental or guardian consent. If we become aware that children's personal information has been collected inappropriately, we will take steps to remove it.

Your Rights

Where applicable, users may request:

• Access to their personal information
• Correction of inaccurate information
• Deletion of personal information
• Restriction of processing
• Withdrawal of consent

Requests can be submitted using the contact details below.

Deletion Requests

Users may request deletion of their personal information, including Tobe Twin Mobile location and the stored historical trail, by contacting privacyofficer@cimic.com.au. We will respond within a reasonable timeframe and subject to any legal retention obligations.

Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be published on our website and within the application where appropriate.

Contact Us

Privacy Officer
IDD Tech Pty Ltd
Level 25, 177 Pacific Highway
North Sydney NSW 2060 Australia

Email: privacyofficer@cimic.com.au