Comcore Reader Privacy Policy

Last updated: October 20, 2026

Operator: Qingdao Comcore Technologies Co., Ltd.

This Privacy Policy explains how Comcore Reader (the “App”) collects, uses, stores, and protects your information. The App is intended for authorized personnel in the public water utility sector worldwide to perform water meter reading and related field operations. Access requires a dedicated account assigned by a specific water utility organization. The App does not offer self-registration to the general public.

We process your information in accordance with the data protection laws applicable to the relevant personal information processing activities. Your specific rights and our corresponding obligations may vary depending on your country or region and the applicable laws.

1. Information We Process

We process only the information necessary to provide the relevant functions:

Account and organization information: Your account is created and managed by your organization. We collect account information, roles, department details, and organization information provided by your organization solely for authentication and access management.

Precise location information: Only when you actively use the map-based meter reading function, with the App in the foreground and the screen on, will we request location permission to obtain your current location. This is used solely to display your position relative to water meters and help you locate unread meters. When using this basic map function, location trails are not stored or shared with any third party.

Field operation photographs and associated location information: If a water meter cannot be read automatically and you use the manual meter reading entry function, we access your camera, with your permission, to photograph the meter. When a photograph is taken, the App obtains your current location coordinates and uploads the photograph, manually entered data, your location coordinates captured at that moment, and the capture time together to our server as supporting evidence for reviewing meter reading exceptions. The location information is used to display the water meter’s position on the GIS map, helping the water utility manage its meters and conduct business analyses. We obtain this location only when you take a photograph in the foreground and do not continuously track you in the background.

Water meter and business information: Meter numbers, customer names, customer addresses, and, where supported by the meter, cumulative water volume, voltage, temperature, valve status, and alarm information, such as empty pipe and reverse flow alarms, are used solely to carry out meter reading and field operations. Customer profile information is provided by your organization, while meter readings, operating status, and alarm information are collected from devices.

External device and connection information: Information about receiving devices connected via USB, connection status, and communication parameters is used solely to establish connections and read water meter data.

2. Device Permissions and Access

Depending on the functions used, the App may require you to grant the following permissions or access:

Location permission: Used solely to display your current location on the map in real time. You may disable this permission in your device’s system settings. If disabled, your current location cannot be displayed, but functions that do not depend on location and other functions remain available.

USB device access authorization: Used solely to connect external receiving devices via USB to collect water meter data.

Network access: Used solely to retrieve task lists, load online maps, and synchronize collected results with the designated server.

We will request the relevant authorization before accessing device functions that require permission.

Camera/photo library permission: Used to take photographs of water meters in the field as supporting business records when meter reading exceptions occur. Photographs taken will not be automatically saved to the local photo library.

3. Use and Sharing of Information

The information described above is used solely for authentication, access management, task retrieval, map display, meter reading and data collection, result synchronization, and necessary operational security management.

Your data controller: Your organization determines the purposes and means of processing meter reading business data. As a technical service provider, we process the relevant data in accordance with our agreement and your organization’s lawful instructions. For processing activities that require your consent, we will provide a separate explanation and obtain the necessary consent. Reading this Policy does not constitute blanket consent to all information processing activities.

No sale or advertising use: We do not sell personal information or provide it to advertisers for advertising purposes.

Scope of sharing: Only where necessary, we provide information relevant to the services or responsibilities of the following recipients:

4. Data Storage and Cross-Border Transfers

The location where data is stored depends on the deployment method selected by your organization:

Use of our cloud services: Your account, task, and meter reading business data will be stored on our servers. Depending on your location and applicable law, the relevant processing may involve cross-border transfers of personal information. We will implement encryption and security safeguards that meet legal requirements to protect the data.

Use of services deployed by your organization: The relevant business data is stored on servers designated by your organization. Whether cross-border transfers are involved depends on the location of the servers and whether there are overseas backups, onward transfers, or remote access from abroad.

Photograph storage: Water meter photographs taken and uploaded through the App will be stored in encrypted form on the server for business review by the water utility organization.

Where cross-border transfers are involved, we will implement encryption and security safeguards that meet legal requirements. Network requests generated by online map services are handled as described in the “Map Services” section of this Policy.

For information about the actual storage location, cross-border transfer arrangements, or relevant safeguards, please contact your organization’s system administrator or email our designated Data Protection Officer at chenxiuhua@techen.cn.

5. Map Services

The App uses map display functions based on OpenStreetMap and does not integrate a native map SDK.

After you grant location permission, the App reads your device’s current location solely for real-time map display. It does not store GPS coordinates or location trails, or upload them to our business servers or those of your organization.

When online maps are loaded, the map service provider may receive information necessary for network requests, such as your IP address and the requested map area. These requests may reveal the map area you are viewing. The relevant processing is subject to the actual service provider’s privacy policy.

For information about the actual map service provider and its privacy policy, please contact your organization’s system administrator or our designated Data Protection Officer at chenxiuhua@techen.cn.

6. Data Retention and Security

Retention period: We retain your personal information only for the minimum period necessary to fulfill the purposes described in this Policy. Retention periods for business data, field photographs, and location records used as supporting evidence are determined by your organization in accordance with the regulations governing its operations. When your organization stops using the service or instructs us to delete the data, we will permanently delete or anonymize the relevant copies of data on the server within 24 hours.

Deletion and anonymization: When the conditions for lawful retention are no longer met, the data must be deleted or anonymized in accordance with the law. We assist with relevant requests in accordance with our responsibilities and your organization’s lawful instructions.

Deployment methods and data management: When our cloud services are used, we manage server-side data in accordance with our agreement. When servers deployed by your organization are used, your organization manages server-side data retention, backups, and deletion, and we provide technical assistance as agreed.

Special provisions for photographs and location data: GPS coordinates and location trails used in the standard map function are not stored. However, location coordinates captured when a photograph is taken and manually uploaded are uploaded and stored together with the photograph as supporting business records until your water utility organization instructs us to delete them. We apply encryption during both transmission and storage. The map service provider’s retention of network request information is subject to its own privacy policy.

Security measures: We implement appropriate measures, including access controls and secure transmission, to prevent unauthorized access to, disclosure of, or alteration of information. Use of the App requires authorization and a valid enterprise account. Please safeguard your account and field devices, and promptly contact your system administrator if you notice any irregularities.

Signing out: Signing out of or uninstalling the App does not automatically delete data already uploaded to the server.

7. Your Rights

Depending on applicable law, you may have rights to be informed about the processing of your personal information, to access, correct, or delete it, to restrict or object to processing, to obtain or transfer your data, and to withdraw consent. The scope, conditions, and exceptions applicable to these rights are governed by applicable law.

How to exercise your rights: You may submit a request by contacting your organization’s system administrator or using the email address below. In accordance with our responsibilities, we will handle the request within the time limits prescribed by applicable law or assist in forwarding it to the organization responsible for the data. We may verify the requester’s identity where necessary.

Deletion: Deleting an account and deleting historical data are separate operations. To request deletion of relevant personal information, please use the channels described above. For data that may or must continue to be retained by law, we will explain the reason for retention and the applicable retention period or the criteria used to determine it.

You may also lodge a complaint with the relevant data protection supervisory authority.

8. Policy Updates and Contact Information

Updates to this Policy will be published in the App. We will notify you of material changes through appropriate means. Where renewed consent is required, we will obtain it before the relevant processing begins.

If you have questions about this Policy or the processing of personal information, or wish to exercise your rights, please contact your organization’s system administrator.

If you are unable to contact your organization, or have questions about the App’s technical security or privacy safeguards, please contact our designated Data Protection Officer using the details below:

Company name: Qingdao Comcore Technologies Co., Ltd.

Address: 8th Floor, Block A, International Innovation Park, No. 1, Keyuanweiyi Road, Laoshan District, Qingdao City, Shandong Province, China

Privacy contact email: chenxiuhua@techen.cn