Privacy Policy
This Privacy Policy explains how personal data is processed when you use the App, in accordance with the EU General Data Protection Regulation (GDPR) and the Austrian Data Protection Act (DSG). The App is designed to be offline-first and data-minimal: most of your data never leaves your device.
1. Controller
The controller responsible for data processing under Art. 4(7) GDPR is:
Johannes Püller
Eisenhüttelgasse 79B
2380 Perchtoldsdorf, Austria
Email: info@sailorscompanion.com
A Data Protection Officer is not appointed, as it is not required under Art. 37 GDPR for this processing.
2. Principles — what stays on your device
By design, the following are stored only locally on your device (and, if you enable it, in your own iCloud — see §4.4) and are not transmitted to the controller: your logbooks, log entries, recorded GPS track, observations, statistics, and settings. The controller operates no account system and no central database of your voyages.
3. Location data
With your permission, the App accesses your device location (including in the background, “Always”) to record your track and compute distance, speed and course, and to trigger movement-based reminders. This processing happens on your device. Your position is transmitted to third parties only in the limited cases described in §4 (e.g. as coordinates sent to the weather service to fetch a local forecast, or to the map/geocoding services to display the chart and place names). The App never shows or invents data it cannot actually know.
Legal basis: performance of the service you requested and our legitimate interest in providing core logbook functionality (Art. 6(1)(b) and (f) GDPR). You can withdraw location access at any time in iOS Settings; background recording then stops.
4. Third-party services (recipients / processors)
The App uses the following external services. Each receives only the data necessary for its function.
| Service | Provider | Data received | Purpose |
|---|---|---|---|
| Weather forecast | Open-Meteo (open-meteo.com) | Approximate coordinates (rounded to a grid) | Retrieve the local weather/marine forecast for a log entry |
| Map tiles & geocoding | OpenStreetMap / OpenSeaMap; OSM-based reverse geocoding | Coordinates / map view bounds | Display the chart, seamarks and human-readable place names |
| Map rendering (PDF export) | Apple MapKit (Apple Inc.) | Coordinates / map extent | Render the static chart image in the PDF export |
| iCloud backup (optional) | Apple Inc. | Your local App data (if you enable backup) | Back up the App database to your own iCloud account |
| App distribution, purchases & subscriptions | Apple Inc. (App Store) | Purchase/subscription data handled by Apple | Deliver the App and process in-app purchases; the controller does not receive your payment details |
| Feedback & support (optional, see §5) | Hosted by the controller on domainFactory servers in Germany | Your message text, technical metadata, and an optional reply email | Receive and process feedback/support requests |
Where a recipient acts as a processor, an appropriate data processing agreement (Art. 28 GDPR) is in place. For transfers to providers outside the EU/EEA (e.g. Apple), processing is safeguarded by the EU Standard Contractual Clauses and/or the EU–US Data Privacy Framework as applicable. The App contains no advertising, no analytics/tracking SDKs, and no advertising identifier.
4.4 iCloud backup
If you enable backup, a copy of the App’s local database is stored in your own iCloud account, under your Apple ID and Apple’s terms and privacy policy. The controller has no access to your iCloud backups.
5. Feedback & support
If you choose to send feedback from within the App, the following is transmitted to the controller’s own server: your free-text message, technical metadata (e.g. app version and build, iOS version, device model, language, current screen and status, coarse counts) and, only if you fill it in, a reply email address. No position data, contacts, or persistent device identifiers are attached. If you leave the email field empty, the submission is anonymous and we cannot reply.
The exact metadata is shown to you in the App before sending. Note that free text you type may itself contain personal data; please do not include more than necessary.
Legal basis: your consent and the controller’s legitimate interest in improving the App and providing support (Art. 6(1)(a) and (f) GDPR).
6. Permissions used
| Permission | Why |
|---|---|
| Location (While Using / Always) | Track recording, distance/speed/course, movement reminders. “Always” enables background recording; the App still works (foreground only) if you choose “While Using”. |
| Notifications | Reminders (e.g. log a position, check the forecast). The App remains usable if declined. |
| iCloud | Optional backup of your data to your own iCloud. |
7. Retention
Data on your device is kept until you delete it (entries, logbooks, track) or uninstall the App. Feedback submissions are retained only as long as needed to handle and analyse them, and are deleted after 24 months at the latest (or earlier on request).
8. Your rights
Under the GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), and to object (Art. 21) to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time with effect for the future. To exercise these rights, contact us at info@sailorscompanion.com. Because most data is stored only on your device, you can also exercise many of these rights directly in the App (edit/delete entries, disable backup, revoke permissions).
9. Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority. The competent authority in Austria is the Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, Austria — www.dsb.gv.at.
10. Children
The App is not directed at children and does not knowingly collect personal data from children.
11. Changes to this policy
We may update this Privacy Policy to reflect changes to the App or legal requirements. The current version is always available at https://www.sailorscompanion.com/privacy; the “Last updated” date above indicates the latest revision.