Privacy Policy

This Privacy Policy describes how KJR TELECOM collects, uses, shares, and protects personal information when you use our mobile application FieldFlows. It also explains the choices and rights you have regarding your information.

KJR TELECOM is a company registered in Morocco under registration number RC 480099, ICE 002654143000090, IF 47288473, Patente 36340938, CNSS 2292022, with its registered office at Résidence Rami, 7 rue Sebta, 2ème étage, Bureau N°8, Casablanca, Morocco.

By using FieldFlows, you confirm that you have read and understood this Privacy Policy.

FieldFlows is a mobile application (Android APK and Progressive Web App) used by field technicians who work for telecom subcontractors carrying out fiber-to-the-home (FTTH) installations on behalf of telecom operators.

The application allows authorized technicians to:

• Receive their daily intervention assignments.
• View the customer information needed to perform an FTTH installation visit.
• Capture photographs of the optical equipment installed and of the customer premises.
• Record the GPS coordinates and timestamps of the intervention.
• Collect the customer's signature on a completion form.
• Report the outcome of the visit (success, partial installation, blocking issue, etc.).

FieldFlows is provided exclusively for professional use by technicians whose subcontractor employer has been authorized by a contracting telecom operator. The application is not available to the general public and cannot be self-installed without prior account provisioning.

Because FieldFlows is installed on the personal or professional mobile devices of field technicians, we use the WhatsApp Cloud API (provided by Meta Platforms Inc.) to deliver short operational messages to the technician's registered phone number. These messages include:

• The secure download link for the FieldFlows Android APK when the technician is onboarded or when an update is published.
• The initial password for the technician's account.
• The password of the mutual-TLS (mTLS) certificate required to authenticate the application against our back-end services.
• Operational notifications strictly necessary to perform the contracted services (intervention reminders, work-order updates, security alerts).

All WhatsApp messages we send use templates that have been submitted to and approved by Meta. We do not send marketing or commercial promotional content over WhatsApp. We do not initiate conversations outside the approved templates.

When we send a WhatsApp message, the recipient's phone number and the message template payload are transmitted to Meta for delivery. Meta processes this information under its own privacy policy and the WhatsApp Business Solution Terms.

4.1 Information you provide through your account

When your employer registers you as a FieldFlows user, the following information is provided to us on your behalf:

• Identity: first name, last name, internal technician identifier assigned by your employer or by us.
• Contact: mobile phone number, used to deliver WhatsApp messages and to identify your account.
• Authentication data: account password (stored as a hash), two-factor authentication secret, mutual-TLS client certificate.

4.2 Information generated when you use FieldFlows

While performing an intervention, FieldFlows collects:

• GPS coordinates of the worksite at key moments (arrival, signature, departure).
• Timestamps of significant actions in the workflow.
• Photographs of the fiber equipment and of the customer premises that you take in the application.
• Customer signature on the digital completion form.
• Free-text comments that you enter and the outcome of the visit (selected from a predefined list).

4.3 Information automatically collected

Like most mobile applications, FieldFlows automatically logs technical information necessary for security and troubleshooting:

• IP address, application version, device model, operating system version.
• Session and activity logs (login attempts, requests made, errors encountered).

4.4 Information about end customers

When a telecom operator transmits a work order to us, we receive the end customer's name, contact phone number, and service address. This information is processed strictly to enable the technician to reach the customer and perform the installation. We do not collect billing, banking, or marketing data from end customers.

• To deliver the FieldFlows application to authorized technicians, including sending the secure APK download link, account credentials, and certificate passwords via WhatsApp.
• To coordinate FTTH interventions, including assigning work orders, scheduling appointments, collecting completion evidence, and reporting outcomes back to the relevant telecom operator.
• To authenticate technicians and secure the application, including enforcing two-factor authentication, issuing and rotating certificates, and detecting suspicious activity.
• To send operational notifications required to perform the contracted services.
• To comply with legal and regulatory obligations applicable to telecom operations, including record retention.
• To investigate incidents, prevent fraud and abuse, and to enforce our Terms of Service.
• To diagnose technical issues and improve the application, based on aggregated and non-identifying usage data.

We do not use your personal information for advertising. We do not sell personal information.

Where data protection law requires us to identify a legal basis (for example, under the EU/UK GDPR or comparable regimes), we rely on:

• Performance of a contract between us and the contracting telecom operator or the subcontractor that employs the technician.
• Legitimate interests in operating, securing, and improving the application, where these interests do not override the rights and freedoms of users.
• Legal obligations related to telecom regulation, accounting, and tax law in Morocco.
• Consent, where it is specifically requested.

We share personal information only when necessary to operate FieldFlows or to comply with the law:

• With the contracting telecom operators (such as INWI, Maroc Telecom, Orange Maroc, or other operators that have contracted with us), who receive intervention reports, completion evidence, and order status updates.
• With the subcontractor employer of the technician, whose managers can view their own employees' assignments and activity within the application.
• With Meta Platforms Inc. through the WhatsApp Cloud API, as described in Section 3.
• With cloud infrastructure providers and technical subprocessors that host the back-end services of FieldFlows, deliver email, store backups, and provide monitoring, under appropriate data processing agreements.
• With public authorities, when required by law, court order, or a legally binding request.
• In the context of a corporate transaction (merger, acquisition, sale of business), in which case we will require the acquirer to honor the commitments made in this Privacy Policy.

We do not sell personal information, and we do not share it with third parties for their own marketing purposes.

Some of our subprocessors operate outside Morocco. In particular, Meta processes data transmitted through the WhatsApp Cloud API in jurisdictions outside the European Economic Area. When personal information is transferred internationally, we rely on appropriate legal safeguards, including Standard Contractual Clauses or any equivalent mechanism recognized under applicable law.

We retain personal information only for as long as is necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations:

• Active technician accounts and operational records are retained for the duration of the underlying contractual relationship.
• Records related to fiber installations are retained for the period required by telecom regulations in Morocco, typically several years after the intervention.
• Deleted records are retained in a soft-deleted state and purged according to our retention schedule.
• Audit logs are retained for the period required to investigate security or compliance incidents.

Specific retention durations can be obtained on request from our Data Protection Officer.

Subject to applicable law, you have the right to:

• Access the personal information we hold about you.
• Correct inaccurate or incomplete information.
• Delete your information, in defined cases ("right to be forgotten").
• Object to or restrict certain processing activities.
• Data portability — receive a copy of your information in a portable format.
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
• Lodge a complaint with the competent data protection authority in Morocco (CNDP) or in the country where you live.

You can also stop receiving WhatsApp messages at any time, as described in Section 3. To exercise any of these rights, contact privacy@kjr-telecom.com. We will respond within the legal time frame applicable in your jurisdiction.

We implement appropriate technical and organizational measures to protect personal information, including:

• TLS encryption in transit and encryption at rest for sensitive fields.
• Mandatory two-factor authentication for FieldFlows users.
• Mutual TLS (mTLS) for back-end-to-back-end communication.
• Role-based access control with the principle of least privilege.
• Continuous audit logging of significant actions.
• Regular security reviews, dependency scanning, and incident response procedures.

No security measure is perfectly effective. If a personal data breach affects your information, we will notify you and the competent authority as required by applicable law.

FieldFlows is intended exclusively for professional use by authorized adults. We do not knowingly collect personal information from children. If you believe a child has provided us with information, please contact us at privacy@kjr-telecom.com and we will take appropriate steps to delete it.

We may update this Privacy Policy from time to time to reflect changes in our practices, the application, or applicable law. When we publish a material change, we will update the "Last updated" date above and, where appropriate, notify users through the application or by other reasonable means. Continued use of FieldFlows after a change takes effect constitutes acknowledgment of the updated policy.

If you have any question about this Privacy Policy or about our data processing practices, please contact us: