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CleverResponder Privacy Policy

Last updated: June 1, 2026

PRIVACY POLICY FOR CLEVERRESPONDER

Last updated June 1, 2026

This Privacy Notice for CleverCam (Pty) Ltd ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use the CleverResponder mobile application (the "App").

CleverResponder is the field companion app for armed-response and security units operating on the CleverCam platform. It is an operational tool for security personnel — not a consumer product. Responders sign in to the App using their mobile number and a one-time PIN (OTP), and use it to receive dispatch alerts, navigate to incidents, capture on-scene evidence, and complete on-scene checklists.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use the App. If you still have any questions or concerns, please contact us at hello@clevercam.co.za.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

  • What personal information do we process?
    When you use the App, we process personal information needed to dispatch you to incidents and record your on-scene activity. This includes your location (including in the background while you are on shift), your phone number, evidence photos and QR scans you capture, your device push token, and the checklist responses you submit. Learn more in "WHAT INFORMATION DO WE COLLECT?".

  • Do we collect location in the background?
    Yes — but only while you are on shift. The App collects precise and approximate location, including in the background, so the control room can dispatch the closest unit and track your approach to an incident. Location is not collected when you are off shift. Learn more in "WHAT INFORMATION DO WE COLLECT?".

  • Do we process any sensitive personal information?
    We do not process information such as racial or ethnic origin, sexual orientation, or religious beliefs.

  • Do we collect any information from third parties?
    Your responder account is created and managed by your security company, so some details (such as your name and assigned unit) originate from that company rather than from you directly.

  • How do we process your information?
    We process your information to dispatch you to incidents, route you to the scene, record the evidence and checklist responses you submit, send you dispatch notifications, and keep the App secure. We process your information only when we have a valid legal reason to do so. Learn more in "HOW DO WE PROCESS YOUR INFORMATION?".

  • In what situations and with which parties do we share personal information?
    We share information with the data processors that run the platform on our behalf, and with the security company that operates your account. We do not sell your personal information. Learn more in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".

  • How do we keep your information safe?
    We have organizational and technical measures in place to protect your personal information, and data is encrypted in transit. However, no system can be guaranteed to be 100% secure. Learn more in "HOW DO WE KEEP YOUR INFORMATION SAFE?".

  • How do you exercise your rights?
    Because responder accounts are managed by your security company, requests to access or delete your personal information are handled through that company via CleverOps, or by contacting us. Learn more in "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?".

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  4. HOW DO WE HANDLE LOCATION DATA?
  5. HOW LONG DO WE KEEP YOUR INFORMATION?
  6. HOW DO WE KEEP YOUR INFORMATION SAFE?
  7. HOW ARE RESPONDER ACCOUNTS CREATED AND MANAGED?
  8. DO WE COLLECT INFORMATION FROM MINORS?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  11. DO WE MAKE UPDATES TO THIS NOTICE?
  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect the information needed to dispatch you to incidents, record your on-scene activity, and sign you in.

The personal information we collect depends on how you use the App. We collect the following:

Location Information (including background location).
The App collects precise and approximate location from your mobile device, including in the background. We collect this location only while you are on shift, so that the control room can:

  • dispatch the closest available unit to an incident, and
  • track your unit's approach to the incident as you respond.

Location is not collected when you are off shift. When you go off shift, background location collection stops. You can also revoke the App's location permission at any time in your device settings; doing so will limit the App's ability to dispatch you and route you to incidents.

Camera and Photos.
The App requests access to your device camera so you can:

  • capture on-scene evidence photos that are attached to the incident, and
  • scan QR codes at a site (for example, to confirm your presence at a checkpoint or asset).

Phone Number.
We collect your mobile number to sign you in. You authenticate using your phone number and a one-time PIN (OTP) sent to you; the number also identifies you as the responder on an incident.

Device Identifiers.
We collect a push notification (FCM) token from your device so we can deliver dispatch alerts and other operational notifications to you.

App Activity.
We collect the checklist responses you submit on scene (for example, confirming the steps you completed at an incident), together with the associated incident and timestamp.

Account Information from Your Security Company.
Your responder profile (such as your name and the unit you are assigned to) is provided and maintained by the security company you work for. See "HOW ARE RESPONDER ACCOUNTS CREATED AND MANAGED?" below.

Sensitive Information. We do not process sensitive information such as racial or ethnic origin, sexual orientation, or religious beliefs.

All personal information that you provide to us must be true, complete, and accurate, and you must notify your security company of any changes to such personal information.

Google API.
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to dispatch you to incidents, route you to the scene, record your on-scene activity, notify you, and keep the App secure.

We process your personal information for the following reasons:

  • To dispatch the closest unit. We process your on-shift location so the control room can select and send the nearest available responder to an incident.
  • To track your approach to an incident. We process your on-shift location so the control room can see your unit moving toward the scene while an incident is active.
  • To record on-scene evidence. We process the photos you capture and the QR codes you scan so they can be attached to the relevant incident.
  • To record on-scene checklists. We process the checklist responses you submit so the control room has an accurate record of the actions taken at an incident.
  • To sign you in and identify you. We process your phone number and one-time PIN to authenticate you and associate you with incidents.
  • To send you dispatch alerts. We process your device push token to deliver dispatch and operational notifications.
  • To maintain security and operation of the App. We process information for troubleshooting, abuse prevention, and to keep the service running.
  • To comply with our legal obligations. We may process your information to respond to legal requests and to establish, exercise, or defend legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information with the processors that run the platform on our behalf and with the security company that operates your account. We do not sell your personal information.

We share your personal information in the following situations:

  • With our data processors (sub-processors). We use the following third parties to process data on our behalf, under agreements that require them to safeguard your information:

    • Supabase — hosts our database and handles authentication (including your phone-number/OTP sign-in).
    • Firebase (Google) — delivers push notifications (dispatch alerts) to your device.
      Data exchanged with these processors is encrypted in transit.

  • With your security company. The security company you work for operates the control room that dispatches you. Your location while on shift, the incidents you respond to, and the evidence and checklists you submit are visible to that company through the CleverCam platform so they can manage their response operation.

  • With Google Maps Platform. The App uses mapping and navigation services to route you to incidents, which involves processing your device location to provide directions.

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We do not sell your personal information.

4. HOW DO WE HANDLE LOCATION DATA?

In Short: The App collects precise and approximate location, including in the background, but only while you are on shift.

Location is the core of how CleverResponder works: the control room cannot dispatch the closest unit or track a unit's approach without it. To support this, the App collects precise and approximate location, including when the App is in the background or closed — but only while you are on shift.

  • When you go on shift, the App begins collecting your location (including in the background) so the control room can dispatch you and track your approach to incidents.
  • When you go off shift, background location collection stops.
  • You can revoke the App's location permission at any time in your device settings. Without location access, the App cannot reliably dispatch you to incidents.

We do not use your location for advertising, and we do not sell it.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to operate the response service and to maintain an accurate record of incidents, unless a longer period is required by law.

We retain your personal information for as long as it is necessary to provide the response service, to maintain an accurate operational and incident record for your security company, and to comply with our legal obligations (such as tax, accounting, or other legal requirements). Operational location data used for live dispatch is retained only as long as needed for that purpose and for incident records.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because it is stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures, and data is encrypted in transit.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, and information exchanged between the App and our platform is encrypted in transit. However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the App within a secure environment.

7. HOW ARE RESPONDER ACCOUNTS CREATED AND MANAGED?

In Short: There is no in-app sign-up. Your responder account is created, managed, and removed by your security company through CleverOps.

CleverResponder does not offer self-service registration. You cannot create an account inside the App. Instead:

  • Your security company creates and configures your responder account using CleverOps, the CleverCam operations platform.
  • Your company assigns you to a unit, manages your access, and removes your account when you no longer require access.
  • You simply sign in to the App with your mobile number and the one-time PIN (OTP) sent to you.

Because of this, requests to access, correct, or delete your personal information are handled by your security company through CleverOps. You may also contact us directly at hello@clevercam.co.za and we will work with your security company to action your request. See "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" below.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: The App is intended for use by professional security personnel and is not directed to children under 18.

CleverResponder is an operational tool for employed or contracted security responders. We do not knowingly collect, solicit data from, or market to children under 18 years of age. If we learn that personal information from a person under 18 has been collected, we will take reasonable measures to delete such data. If you believe we may have collected information from a person under 18, please contact us at hello@clevercam.co.za.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on where you live, you may have rights to access, correct, or delete your personal information.

Depending on your country, province, or state of residence, applicable privacy law may give you rights regarding your personal information, including the right to request access to it, request correction or deletion, and, where we rely on consent, to withdraw that consent.

Because your responder account is managed by your security company, the easiest way to exercise these rights is through that company via CleverOps, or by contacting us using the details in "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing consent for location. Where we rely on consent to process your location, you may withdraw it at any time by revoking the App's location permission in your device settings or by going off shift. This will not affect the lawfulness of processing before its withdrawal.

10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@clevercam.co.za or contact us by post at:

CleverCam (Pty) Ltd
Den Haag street
Die Heuwel
Witbank, Mpumalanga 1035
South Africa

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Because responder accounts on CleverResponder are created and managed by your security company, requests to review, update, or delete your personal information are handled by that company through CleverOps. To make a request, contact your security company, or email us at hello@clevercam.co.za and we will coordinate with your security company to action your request.