1. Who we are and how to read this Policy

This Privacy Policy explains how Port Guide & Distances mobile application (the “App”) and its backend services process personal data.

• Controller: Marine Solutions SD Group (“we”, “us”, “our”)
• App: Port Guide & Distances (Android / iOS)
• Contact email: support@msdmarine.com
• Website: www.msdmarine.com

We process personal data in accordance with applicable data protection laws, including:

• GDPR – Regulation (EU) 2016/679
• UK GDPR and the UK Data Protection Act 2018 (for UK users)
• Other local laws that may apply (e.g. CCPA/CPRA for California residents, where relevant).

By using the App or creating a Global Profile account, you acknowledge that you have read this Privacy Policy and understood how we process your personal data.

We do not sell personal data to third parties.

2. Scope & Applicability

This Policy applies to:

1. Your use of the Port Guide & Distances App on Android and iOS devices.
2. Your Global Profile account, which can be used across current and future projects of the Marine Solutions ecosystem.
3. Any direct communication you have with us (e.g. email support).

This Policy does not cover:

• Processing performed independently by Apple (App Store) or Google (Google Play) as store operators and OS providers. They act under their own privacy policies and as separate controllers.
• Processing carried out on third-party websites or services that we may link to from within the App (e.g. external websites). Always check those providers’ own privacy policies.

3. Summary (Short Version)

• You can use the App with or without a Global Profile account.
• If you create an account, we store your email, optional profile data, and information about your purchases, subscriptions, and Marcoin balance on our servers.
• We use this data to:
  • Provide access to the App and paid features;
  • Maintain your Global Profile across our ecosystem;
  • Prevent fraud and abuse;
  • Comply with legal obligations (e.g. accounting).
• We do not use your data for behavioural advertising and do not sell your personal data.
• We may use standard server logs (e.g. IP address) to secure our services.
• All payments are processed by Google Play or Apple App Store. We do not see or store full payment card details.
• You have rights under GDPR/other laws (access, deletion, etc.) and can contact us at support@msdmarine.com.

4. Personal data we process

We only process personal data that is necessary for the purposes described below. We do not intentionally process special categories of data (e.g. health data, political opinions).

4.1. Account & Identification Data (Global Profile)

When you create or use a Global Profile account (hosted with DigitalOcean, acting as our data processor), we may process:

• Email address (required – used as main identifier and for communication);
• Authentication data (for example, password or other authentication tokens, depending on implementation);
• Internal user ID generated by our systems;
• Account status (active, suspended, deleted);
• Timestamps related to account creation, last login, and key actions..

4.2. Optional Profile Data

You may choose (optionally) to add more information to your Global Profile:

• Job title / position;
• Company / organisation name;
• Date of birth;
• Website or social media link;
• Profile photo / avatar;
• Free-text description / bio or other text you decide to provide.

You can use the App without providing optional profile data. You can remove or update this information at any time in your profile settings (where available) or by contacting us. You are not required to fill in any optional profile fields, and you may choose to provide non-identifying information. However, any information you enter in your profile will be treated as personal data if it can directly or indirectly identify you.

Purposes: we process this data to (i) create and maintain your user account and Global Profile across the Marine Solutions ecosystem, (ii) provide access to your purchases and in-app entitlements, and (iii) contact you about account-related issues where necessary.

Legal basis (GDPR): performance of a contract (Art. 6(1)(b)) and our legitimate interests in operating and securing our services (Art. 6(1)(f)).

4.3. Purchase, Subscription & Marcoin Data

We offer:

• Subscriptions: Monthly, Quarterly, Half-Year, Annual (unlimited port views and distance calculations during the subscription period);
• In-app Marcoin packages:
  1. Trial – 8 Marcoin (24 port views, 8 distances)
  2. Standard – 30 Marcoins (90 port views, 30 distances)
  3. Professional – 60 Marcoins (180 port views, 60 distances)
  4. Captain’s – 150 Marcoins (450 port views, 150 distances)
  5. Fleet – 400 Marcoins (1200 port views, 400 distances)

For these purchases we process:

• Type of product purchased (subscription plan or Marcoin package);
• Number of Marcoins credited and consumed, usage counters (e.g. how many port views/distances remain or are used);
• Subscription status (active, expired, cancelled);
• Purchase date and time, renewal date, expiry date;
• Store-side purchase identifiers (e.g. order ID, transaction ID) received from Google Play or Apple App Store;
• Country / region information related to the store account (where provided by Apple/Google, mainly for tax compliance and pricing).

We do not receive or store full payment card numbers or bank account details. This data is processed only by Google and Apple as payment service providers.

4.4. App Usage Data (limited)

To ensure correct functioning of the App and your entitlements, we may process limited usage information, such as:

• When a port view or distance calculation is performed (for entitlement counting & fraud prevention—not detailed tracking of behaviour);
• Selected ports and routes in aggregated or anonymised form (for service improvement, where applicable);
• Error/diagnostic information if you choose to send it to us (e.g. when contacting support).

We do not use this information for behavioural advertising or cross-app tracking.

4.5. Device & Technical Data (server logs)

When your device communicates with our servers (e.g. to sync account, validate purchases, or update Global Profile), our server infrastructure may automatically log:

• IP address;
• Date and time of the request;
• Technical request data (e.g. HTTP method, URL, response code);
• Basic device / app information (such as OS type and version, app version, language, time zone).

These logs are used for security, troubleshooting, and to protect our services against abuse.

4.6. Communications & Support Data

If you contact us (for example via email):

• Email address;
• Name (if you provide it);
• Message content and attachments;
• Related metadata (timestamps, our replies).

We use this only to handle your request, resolve issues, and improve our support processes.

5. App data stored locally on your device

The App may store certain data only locally on your device, such as:

• Preferences and settings (e.g. default units, last used ports);
• Locally cached routing data and results;
• Offline content necessary for operation.

This data is not transmitted to us unless required for a specific online function (e.g. syncing your Global Profile) or unless you decide to share it when contacting support (e.g. sending a screenshot).

You can usually delete local data by uninstalling the App or using your device’s “clear data” functionality.

6. Marcoin and subscriptions – additional information

Marcoin is a virtual in-app currency used only inside Port Guide & Distances. It is not cryptocurrency, not a means of payment outside the App, and cannot be exchanged for real money or transferred to other users, except as technically allowed inside our ecosystem.

We process Marcoin and subscription data to:

• Provide you with the purchased functionality;
• Correctly count views and distance calculations;
• Restore purchases when you reinstall the App or change device (subject to the policies of Apple and Google);
• Prevent fraudulent use (for example, attempts to bypass limits).

Refunds for purchases are usually handled according to the rules of Google Play and Apple App Store and their own terms and policies.

7. Legal bases for processing (GDPR / UK GDPR)

We rely on the following legal bases:

1. Performance of a contract (Art. 6(1)(b) GDPR)
   • To create and manage your Global Profile account;
   • To provide access to the App and its functionalities;
   • To manage subscriptions and Marcoin packages;
   • To restore your purchases and maintain usage limits.
2. Legitimate interests (Art. 6(1)(f) GDPR)
   • To secure our services and infrastructure (e.g. server logs, fraud prevention);
   • To improve and develop the App (e.g. aggregated or anonymised statistics);
   • To respond to your requests and maintain our relationship with users;
   • To protect our rights, property, and users (e.g. dispute handling).
3. Legal obligation (Art. 6(1)(c) GDPR)
   • To comply with tax, accounting, and other mandatory legal requirements;
   • To respond to lawful requests from public authorities, where required.
4. Consent (Art. 6(1)(a) GDPR), where applicable
   • For example, if we ever introduce optional email marketing or certain types of optional analytics that require consent.
   • Where we rely on consent, you can withdraw it at any time, without affecting the lawfulness of processing before withdrawal.

8. How we share personal data

We may share personal data only with the following categories of recipients, strictly on a need-to-know basis:

1. Service providers (processors)

   • Cloud hosting providers;
   • Email and IT infrastructure providers;
   • Customer support tools (if used).

   These providers process data only on our instructions and under a data processing agreement (DPA), with appropriate confidentiality and security obligations.

2. App stores and payment platforms
   • Google Play and Apple App Store process purchases as independent controllers. We receive limited information from them (e.g. purchase identifiers, product type).
3. Other projects within Marine Solutions ecosystem
   • Your Global Profile may be used to sign in to and be recognised across other applications and services within our ecosystem, only where you choose to use the same account. In these cases, those projects will rely on this common profile and apply their own terms and policies, which will explain in more detail how your data is used there.
4. Professional advisers & legal authorities
   • Lawyers, accountants, auditors (only where necessary and subject to confidentiality);
   • Law enforcement or regulatory authorities, where required by applicable law.

We do not sell personal data and do not provide personal data to third-party advertisers or data brokers.

9. International transfers

Our servers or some of our service providers may be located outside your country, including outside the EEA/UK (for example, in the United States or other jurisdictions).

Where such transfers involve personal data from the EEA/UK/Switzerland, we ensure appropriate safeguards, for example:

• Use of Standard Contractual Clauses (SCCs) adopted by the European Commission; and/or
• Other mechanisms recognised by data protection law.

Hosting (DigitalOcean)

Our backend and databases are hosted with DigitalOcean, LLC (or the relevant DigitalOcean group entity), which acts as our data processor. DigitalOcean processes personal data only on our instructions and under a data processing agreement that includes appropriate security and data protection commitments.

You may request more information about the safeguards used for international transfers by contacting us.

10. Data retention

We retain personal data only for as long as it is necessary for the purposes described above or as required by law.

Indicative retention periods:

• Global Profile account data: as long as your account is active. If you request deletion, we will delete or irreversibly anonymise the data, except where a longer retention is required by law (e.g. for accounting or dispute resolution).
• Account / Global Profile data (email, optional profile information): stored for as long as your account and Global Profile remain active and for up to 24 months after deletion or last activity (in backups and logs), unless a longer retention period is required by law or is necessary for the establishment, exercise or defence of legal claims.
• Purchase and subscription records: retained for the duration necessary for accounting, tax and anti-fraud purposes (often up to 5–10 years, depending on applicable law).
• Marcoin usage data: retained as long as necessary to manage your entitlements and to prevent fraud, and then aggregated or anonymised.
• Server logs: typically retained for a short period (e.g. up to 12 months) for security and troubleshooting, unless a longer retention is justified for investigation of specific incidents.
• Support communications: usually retained up to 24 months after the last interaction, unless a longer period is required by law or needed for handling ongoing disputes.

When data is no longer needed, we will delete it or anonymise it in a secure manner.

11. Children’s privacy

The App is not specifically directed at children and does not require entering age-sensitive information. However, professional maritime tools are generally intended for adult users.

We do not knowingly collect personal data from children under the age where parental consent is required in their jurisdiction.

If you are a parent or guardian and believe that your child has provided personal data to us without your consent, please contact us; we will take steps to remove such data where required.

12. Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures may include:

• Encryption in transit where appropriate;
• Access controls and authentication for staff and systems;
• Data minimisation and pseudonymisation where feasible;
• Regular updates and monitoring of infrastructure;
• Limiting access to personal data strictly to those who need it.

However, no system is completely secure. If we become aware of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant data protection authorities as required by law.

13. Your rights

Depending on your place of residence and applicable law (e.g. GDPR, UK GDPR, CCPA/CPRA), you may have some or all of the following rights:

• Right of access: to obtain confirmation whether we process your personal data and to receive a copy.
• Right to rectification: to correct inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”): to request deletion of your personal data in certain circumstances (e.g. where data is no longer needed or you withdraw consent).
• Right to restriction of processing: to have the use of your data restricted in certain cases.
• Right to data portability: to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where technically feasible and where processing is based on consent or contract and carried out by automated means.
• Right to object: to object to processing based on legitimate interests, including profiling, on grounds relating to your particular situation.
• Right to withdraw consent: where processing is based on consent, you can withdraw it at any time.
• Right to lodge a complaint: with your local data protection authority if you consider that your rights have been violated.

Because a significant part of processing is linked to your Global Profile and support communications, exercising some rights may require that we verify your identity (for example, via your registered email).

To exercise your rights, contact us at support@msdmarine.com. We will respond within the time limits set by applicable law.

14. Cookies and tracking

The App itself does not use browser cookies.

Our website (e.g. msdmarine.com or associated domains) may use cookies or similar technologies. These are governed by a separate Cookie Policy, where applicable.

We do not use your personal data for cross-app or cross-site tracking for advertising purposes.

15. Automated decision-making & profiling

We do not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of GDPR Article 22.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the “Effective date” at the top; and
• Where appropriate, notify you via the App or our website.

We encourage you to review this Policy periodically to stay informed about how we process your personal data.

17. Contact us

If you have any questions about this Privacy Policy or how we process your personal data, please contact us:

Marine Solutions SD Group
Email: support@msdmarine.com
Website: www.msdmarine.com