TeCluster

Privacy Policy

Effective from the app's first release · Draft

DRAFT — This is a draft prepared ahead of release. It will be reviewed by legal counsel before launch.

We do not create an account. Location is processed on your device and never sent to our server. Vehicle data is received only if you connect a Tesla account, and is deleted automatically after 24 hours. We use no advertising or analytics tools.

The Korean version of this policy is the authoritative text. In case of any discrepancy, the Korean version prevails.

1. General

  1. CGFlow ("the Company") complies with the Personal Information Protection Act of the Republic of Korea and related laws, and processes personal data as set out in this policy.
  2. This policy applies only to the mobile app TeCluster and is separate from the privacy policy of the cgflow.kr platform.
  3. The Company collects only what the service needs and deletes it automatically once the stated period passes.

2. What we collect

  1. Location: used to show speed and drive power and to provide guidance. It is processed on the device and never sent to the Company's server. When you start guidance it is passed to the map service you selected.
  2. Vehicle data (optional — when a Tesla account is connected): VIN, battery level, range, cabin and outside temperature, odometer, gear, charging state.
  3. Destination (optional — when guidance was started in the car): destination name and coordinates, estimated time of arrival.
  4. Trip history (optional — when a Kakao account is connected): time, distance, average and top speed, harsh acceleration and braking counts, battery used, destination name.
  5. Tesla access token: held on the Company's backend as the credential for reading vehicle data. It is not stored in the app.

3. What we do not collect

  1. We do not create an account. We never ask for your email address, name or password.
  2. We do not store a record of the coordinates you drove through. Where you have been is not logged.
  3. We do not access contacts, photos, the microphone or call history.
  4. We do not collect advertising identifiers, and the app contains no advertising, analytics or tracking tools.
  5. We do not sell personal data or provide it for advertising purposes.

4. Why we use it

  1. Cluster display — speed, drive power, battery, range, temperature, odometer, gear.
  2. Guidance — route calculation, turn instructions, estimated arrival time.
  3. Continuing guidance that was started in the car.
  4. Providing trip history and checking the subscription plan.

5. How long we keep it

  1. Vehicle data: deleted from the server automatically 24 hours after the vehicle's last signal.
  2. Destination: deleted from the server automatically one hour after guidance ends.
  3. Trip history and Tesla token: kept until you delete your data or disconnect the vehicle.
  4. Vehicle data and destination exist to show the current state, so there is no reason to keep them; the server deletes them on the schedule above.

6. Sharing and processors

  1. The Company does not sell personal data and does not disclose it externally except as follows, in order to provide the service.
  2. Kakao Mobility: location and destination — map display and route guidance when Kakao guidance is used.
  3. Kakao: your Kakao account identifier — when you sign in with Kakao to link your trip history (optional).
  4. Apple: location and destination — map display and route calculation when Apple Maps guidance is used.
  5. Tesla, Inc.: Tesla account authentication — to read data from the vehicle you connected.
  6. Oracle Cloud: server operation and data storage.
  7. Location is passed to a map service only when you start guidance, and each provider's own policy applies as well.

7. Transfer abroad

  1. The Company's server is located in Singapore (Oracle Cloud), where the vehicle data and destination described in section 2 are stored. The purpose is to provide the service and the retention periods are those in section 5.
  2. You may use the app without connecting a Tesla account; in that case no vehicle data or destination is transmitted.

8. Your rights

  1. Delete your data: in the app, Settings → This device → Delete my data. The car registration and the vehicle data held on the server are deleted together, and this cannot be undone.
  2. Disconnect the vehicle: Settings → Sign out of Tesla account. No further vehicle data is received.
  3. Withdraw location permission: at any time in iOS Settings. Speed display and guidance will then not work.
  4. Access and correction: write to contact@cgflow.kr and we will handle the request after verification.

9. Security

  1. All traffic between the app and the server is encrypted with HTTPS.
  2. Data sent from the vehicle to the server uses a connection protected by mutual certificates.
  3. Reading from the server requires an app-specific authentication key.

10. Children

  1. The app is intended for drivers, is not directed at children under 14, and does not knowingly collect their personal data.

11. Data protection officer

  1. Data protection officer: Junghoon Lee / Contact: contact@cgflow.kr
  2. In Korea, complaints may also be filed with the Personal Information Infringement Report Center (privacy.kisa.or.kr, 118).

Supplementary

  1. This policy takes effect on the app's first release date.
  2. Changes will be announced in the app and on this page at least seven days before they take effect.