Privacy Policy

CustomEApps (Pty) Ltd ("CustomEApps", "we", "us") is a software company registered in South Africa (registration number 2025/952060/07), at 2A Gouritz Street, Aerorand, Middelburg, 1050. We build and operate CPL, a production logging application for mining sites on Windows, macOS, Android and iOS.

This policy covers the CPL application on every platform and the service behind it. Questions about it go to hello@customeapps.com.

CPL is supplied to organisations, not to the public. You can only use it if your employer or the organisation you work for (the client organisation) has invited you.

For the information held in CPL, the client organisation decides what is recorded and why, and is the responsible party under the Protection of Personal Information Act 4 of 2013 (POPIA). CustomEApps processes that information on its behalf as an operator.

• Account details: your email address, name, and where your organisation records them your phone number, employee number and date of birth; the organisation, sites and roles you are assigned; your account status and when you were last active. Your password is stored only as a one-way hash by our authentication provider and is never visible to us.
• Device details: a random identifier generated for the installation, the device name, model, manufacturer, platform, operating system version and the CPL version. This lets an administrator see and revoke the devices signed in to an account.
• Work records you or your colleagues enter: shifts, loads, machine hours and meter readings, downtime, diesel, plans, comments and approvals, and the names of machine operators entered by a clerk.
• An audit history: who created or changed a record, on which device and when. It exists so that production figures can be trusted and corrected.

What we do not collect. CPL does not read your location, contacts, photos, camera, microphone or messages. It contains no advertising and no third-party analytics or tracking, and we do not sell personal information to anyone.

• To sign you in and show you only the sites and functions your role allows.
• To record, synchronise, report on and approve production data for the client organisation.
• To keep an accurate, auditable history of that data.
• To secure the service, investigate faults and deliver updates.
• To provide support.
• To meet legal obligations.

CPL keeps a working copy of your organisation’s data on your device so that it works without signal, and synchronises it over an encrypted connection to a database hosted for us by Supabase on cloud infrastructure. Supabase acts on our instructions under its own data-processing terms.

Its servers may be located outside South Africa. Where personal information is transferred across borders we rely on a provider that is bound by data-protection obligations substantially similar to POPIA’s, as section 72 of POPIA requires.

We do not share personal information with anyone else, except where the law requires it or your organisation instructs us to.

Data is encrypted in transit. Access inside CPL is restricted by organisation, site and role, enforced in the database itself and not only in the app. Administrators can revoke a device or an account. No system is perfectly secure; if a breach affects your personal information we will notify the client organisation, the Information Regulator and affected people as POPIA requires.

Information in CPL is kept for as long as the client organisation holds an active agreement with us, and afterwards for as long as that organisation or the law requires production and audit records to be kept. When an agreement ends we return or delete the data on the organisation’s instruction.

Under POPIA you may:

• ask whether we hold personal information about you and request a copy of it;
• ask for it to be corrected or deleted;
• object to its processing, or withdraw consent where processing rests on consent;
• complain to the Information Regulator (South Africa) at inforegulator.org.za.

Your organisation’s administrator can correct most of your information directly, and is the right first contact. You may also write to our Information Officer, Thandulwazi Ngwenya, at hello@customeapps.com, and we will pass the request to them and assist.

To have your CPL account and the personal details on it deleted, ask your organisation’s CPL administrator, or email hello@customeapps.com from the address you sign in with, with the subject "CPL account deletion". We confirm the request with your organisation and act on it within 30 days.

Your account details (name, email, phone, employee number, date of birth and registered devices) are deleted. Production records you captured or approved belong to your organisation and are kept as part of its audit history; where the law allows, your name on them is replaced with a reference that no longer identifies you.

CPL is a workplace tool and is not intended for anyone under 18. We do not knowingly collect personal information from children.

We may update this policy. The effective date at the top shows the current version, and material changes are announced in CPL’s release notes or to your organisation’s administrator.

Information Officer: Thandulwazi Ngwenya, CustomEApps (Pty) Ltd (Reg. No. 2025/952060/07), 2A Gouritz Street, Aerorand, Middelburg, 1050, South Africa.
hello@customeapps.com · 087 250 0310 · Contact form