Tobe Twin Mobile Privacy Policy

1. Introduction

IDD Tech Pty Ltd ABN 17 655 977 656("IDD Tech", "we", "our" or "us") operates the Tobe Twin Mobile application ("App") for iOS and Android, and related services.

The App is a field data capture application used with Tobe Twin. Authorised users of an organisation may use the App to view projects and maps, complete survey and inspection forms, capture photographs, and, with permission, record their location so that it is shown in Tobe Twin.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you use the App. It should be read together with the Tobe Twin Privacy Policy. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

By using the App, you acknowledge the collection and use of information described in this Privacy Policy. Employment and corporate website matters are covered by the IDD Tech corporate privacy policy.

2. Who May Use the App

The App is provided to organisations that hold a Tobe Twin subscription and to individuals whom those organisations authorise. You can sign up for an account through our Microsoft Azure AD B2C sign-in, or your organisation may invite you. The App is not intended for children.

3. Information We Collect

3.1 Account information. When you sign in through our identity provider, we receive your user identifier, email address, name, and information about the organisations, projects and permissions assigned to you.

3.2 Location information. With your permission, the App collects precise location from your device, including latitude, longitude, accuracy, altitude, speed, heading and time:

• (a) while the App is in use, to display maps, provide "use my location" and record coordinates against survey entries; and
• (b) during an active tracking session for a project that you have started or agreed to, until tracking is stopped.

Background tracking depends on the permission you choose. During an active tracking session, the App continues to record location while it is in the background or the screen is off, and resumes tracking after the device restarts, only if you have granted the matching location permission in your device settings:

• iOS: with "Always", tracking continues in the background. With "While Using the App", location is recorded only while the App is open and in use. With "Allow Once", location is recorded only for that session of use.
• Android: background tracking requires "Allow all the time". A persistent notification is displayed while tracking is active.

You can stop tracking in the App, or change or withdraw the location permission in your device settings, at any time.

During tracking, location is recorded at intervals and uploaded at intervals. The default settings are to record approximately every two minutes and on movement of approximately 10 metres or more, and to upload approximately every five minutes. These are defaults only; the project administrator can configure different intervals for a project. The App also records when your device enters or leaves control areas defined for the project.

3.3 Device information. With each location record, the App collects a device identifier generated for the App, device make and model, battery level and charging state, network connection type, and an accelerometer reading. The App uses motion activity on the device to reduce battery consumption; motion activity data stays on the device and is not uploaded.

3.4 Photographs and content. If you use camera or photo library features, the App collects the images and sketches you capture or select. The App collects the survey responses, notes and other content you enter.

3.5 Work-related data. The App is provided for work use. Location tracking and data collection are limited to project work and to the working periods agreed between your organisation, its workers and subcontractors, and the project. Field data, including numbers, text and photographs, is entered and submitted by individual users and subcontractors through the App.

3.6 Information stored on your device. The App stores sign-in credentials in the device's secure storage, and stores project data, survey entries and location records locally so that the App can operate offline. Location records remain on the device until uploaded.

3.7 Information we do not collect. The App does not contain advertising, analytics, crash reporting or third-party tracking software, and does not track you across apps or websites owned by other companies.

4. How We Use Information

We use personal information to:

• provide, maintain and secure the App and Tobe Twin;
• authenticate you and apply your organisation's access permissions;
• display your location and movement trail, and associated device information, in Tobe Twin for the relevant project;
• record survey, inspection and field data, including location and photographs, for your organisation;
• detect entry to and exit from project control areas;
• provide support and respond to enquiries; and
• comply with legal obligations.

We do not use personal information for advertising and we do not sell personal information.

5. Permissions and Consent

The App requests the following device permissions. Each is requested only when the relevant feature is used, and may be withdrawn at any time in your device settings:

• Location (while using and always / background): maps, coordinates and project tracking;
• Camera: capture photographs for survey questions;
• Photos: attach and save survey images;
• Motion and fitness (iOS): reduce battery use during tracking.

Withdrawing a permission will disable the related feature. Stopping tracking or withdrawing location permission stops the collection of new location information but does not delete information already uploaded.

6. Who Can See Your Information; Disclosure

Information may be disclosed to:

• authorised users of the relevant organisation and project in Tobe Twin, which may include your employer;
• IDD Tech personnel, only as necessary to operate and support the service;
• service providers who provide hosting, identity and security services to us, including Microsoft (Azure); and
• other parties where required or authorised by law, or to protect rights, safety or property, or in connection with a business transaction.

Our service providers are required to protect personal information and to use it only to provide services to us.

Workplace use. Where the App is used for work, your organisation may view your location while tracking is active and the stored trail. Workplace surveillance laws may apply, and your organisation is responsible for providing any notice required of it.

7. Storage, Security and Overseas Disclosure

Information uploaded from the App is stored in Microsoft Azure in the region that applies to the project: Australia East for projects in the Asia-Pacific, US Central for projects in the United States, and Germany for projects in Europe. Information is encrypted in transit. We implement administrative, technical and physical safeguards designed to protect information from unauthorised access, disclosure, alteration, loss and misuse. No method of transmission or storage is completely secure.

This means your information may be stored outside Australia, in the United States or Germany. Where information is stored outside Australia, we take reasonable steps to make sure it is protected in a way consistent with Australian privacy law.

8. Data Retention

Tobe Twin Mobile location, including the stored historical trail, is kept for the life of the project the Twin belongs to, plus 7 years. After that we securely delete or de-identify it. Stopping tracking stops new location collection but does not delete the trail already stored. Survey records and photographs submitted through the App are kept for the same period.

You can ask us to delete your personal information at any time. We will respond within 30 days. Where we must keep information for legal, contractual, or dispute reasons, we will tell you what we are keeping and why, and delete the rest.

Signing out of the App does not delete information that has already been collected or uploaded. Information stored on your device is removed when you uninstall the App.

9. Account and Data Deletion

You can ask us to delete your account and associated personal information, including location trails, at any time. The App does not have an in-app deletion option; deletion is by email request only. To request deletion, email help@iddtech.com.au with the subject "Tobe Twin Mobile deletion request".

• We respond within 30 days.
• Where we must keep information for legal reasons, we will tell you what we are keeping and why, and delete the rest.

10. Access, Correction and Complaints

To ask for access to or deletion of your personal information, email help@iddtech.com.au. We respond within 30 days.

For correction requests, privacy questions or complaints, contact the Privacy Officer using the details below. If you are not satisfied with our response to a complaint, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au).

11. Children's Privacy

The App is not directed to children under the age of 13, or a higher minimum age where required by local law. We do not knowingly collect personal information from children. If we become aware that such information has been collected, we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be published on our website and, where appropriate, notified in the App.

13. Contact Us

Deletion and access requests

Email: help@iddtech.com.au
We respond within 30 days.

Privacy questions and complaints

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

Email: privacyofficer@cimic.com.au