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Smart Herding Privacy Policy

Last updated: 18.03.2026

SMART HERDING is an application (hereafter “app”) designed by CLS to display your CLS’ beacon on a map and to allow you to create a route from your current location using your navigation app (Google maps, Plans etc.). The SMART HERDING app is a simple mobile version of the LAND platform. It is used solely to display data from the LAND platform and does not allow for any data transfer or communication.

You will be logged in to the app automatically using your account on the CLS LAND platform. You do not need to create a new account to use the app. The app itself does not process your personal login details. The user account for the SMART HERDING app is already created via the secured LAND platform owned and hosted by CLS.

However, due to the fact that the app needs to be connected to internet, the use of the app implies the processing of some of your personal data. Thus, this Privacy Policy explains how your personal data is protected and what your rights are.

The support (phone, tablet…) on which you have installed the SMART HERDING app is call hereafter “your device”.

1. Data Processor Identity

COLLECTE LOCALISATION SATELLITES
Simply joint stock company
Parc Technologique du Canal, 11 rue Hermès, 31250 Ramonville-Saint-Agne
Represented by Stéphanie LIMOUZIN its President

2. Collected Data and Purpose of Processing

Your personal data in relation to your authentication on SMART HERDING app is not processed by the app. Your authentication is made on a specific platform in order to allow the application to open.

The geolocation of your device is not necessary for the functioning of the SMART HERDING app. However, you have the option to activate the geolocation in order to create a route from your position to your beacon. If you accept the use of the geolocation, please note that your location will not be transferred or disclosed in any way.

COLLECTED DATA PURPOSE OF PROCESSING
Cookies Analytics cookies for Google Analytics and Crashlytics in order to allow Google Analytics and Crashlytics to analyse bugs and crash.
Metadata

Regarding the operation of the app:

  • Phone language used
  • Phone contrast

No transfer of metadata.

Regarding Google Analytics and Crashlytics:

  • Device: brand, model, orientation, available RAM, available storage space
  • Operating system: version, orientation, root mode enabled
  • Usage: Date and time, App version, Country of use

This data is necessary for Google Analytics and Crashlytics. No other use is made by CLS.

3. Access to Device Functions

SMART HERDING requires the following permissions:

  • Internet: user authentication
  • Route creation: the SMART HERDING app may open – on demand – the device’s default navigation app (Google Maps, Plans for example) in order to integrate the GPS coordinates of the relevant CLS ’beacon and to create a route from the use position to the CLS’ beacon.

⚠ There is no geolocation transfer. CLS will never have access to the geolocation of your device.

4. Legal Basis for Data Processing

In compliance with the General Data Protection Regulation (GDPR), we process your data based on the following legal grounds:

  • Contract performance: SMART HERDING functionalities.

5. User Rights

Under the GDPR, you have the following rights regarding your personal data:

  • Right of access: Obtain a copy of the list of data stored about you.
  • Right to rectification: Correct any inaccuracies.
  • Right to erasure: Request deletion of your data when legally applicable.
  • Right to restriction of processing: Temporarily limit data processing under certain conditions and if it’s possible with the use of CLS INSTALL.
  • Right to object: Refuse the processing of your data in specific cases when legally applicable and if it’s possible with the use of CLS INSTALL.
  • Right to data portability: Receive your data in a structured, commonly used format.

To exercise these rights, you may contact us at dpo@groupcls.com.

6. Data Recipients and International Transfers

CLS does not collect or process any of your personal data.

Your metadata and cookies are collected by Google Inc. in order to improve the operation of the app.

Transfers outside EU

Metadata and cookies may be transferred outside the European Union (EU) due to the use of Google tools (Google Analytics and Crashlytics).

7. Data Security

We implement strict measures to protect your data:

  • Secure access: Authentication via login and password through a specific authentication platform owned and hosted by CLS.
  • Accounts access managed by CLS.
  • Security: CLS is ISO 27001 certified
  • Encrypted communication: Use of a CLS-generated token for internet communications.
  • Secure storage: Google privacy policy and Google data centres.

Google Firebase user accounts are strictly controlled by CLS.

Access accounts managed by CLS, with passwords stored in encrypted password managers.

8. Data Retention Period

Data processed through Google Firebase tool is stored for 14 months.

9. Contact & Complaints

For any questions or to exercise your rights, please contact us at: dpo@groupcls.com.

If you believe your rights are not being upheld, you may file a complaint with the CNIL (French Data Protection Authority).

CNIL (COMMISSION NATIONALE DE L’INFORMATIQUE ET DES LIBERTÉS)
3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Tel.: 01 53 73 22 22
Fax: 01 53 73 22 00

If you wish to file a complaint with the CNIL, you can fill out the online complaint form available at the following address: https://www.cnil.fr/fr/plaintes.

If you have a question about your rights regarding data processing and liberties, you can consult the CNIL website: www.cnil.fr.

10. Changes to the Privacy Policy

We may update this policy due to legal or technical developments. Any significant changes will be communicated through the application.