Privacy Policy

1. Introduction

Maritime Safety & Security ("we," "us," "our," or "Company") operates the Na Oku mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our App.

2. Information We Collect

2.1 Location Data

• GPS Coordinates: Latitude and longitude of event locations
• Speed: Speed over ground (in knots) when available
• Course: Course over ground (in degrees) when available
• Compass Heading: Device compass direction (in degrees) when available

2.2 Images and Photos

• Photos or images you capture or upload through the App
• These are processed and compressed for efficient storage

2.3 Device Information

• Device ID: A unique identifier for your device
• Device model and operating system information
• Device information collected through our device analytics service

2.4 Event Data

• Event titles, types, and descriptions
• Comments and notes you create
• Event timestamps and metadata
• All information you voluntarily enter

2.5 Analytics Data

• App usage patterns and feature interactions
• Crash reports and error logs
• Performance metrics

3. How We Use Your Information

We use the collected information for the following purposes:

1. Operational Use: To create, store, and manage event records in your local database
2. Synchronization: To sync events with our Firebase Firestore database for access across devices
3. Analytics: To understand App usage patterns and improve functionality (via Google Analytics)
4. Support: To troubleshoot issues and provide technical support
5. Compliance: To comply with legal obligations and regulatory requirements

4. Data Storage and Security

4.1 Local Storage

• Your data is stored locally on your device using SQLite database
• Local data remains under your control

4.2 Cloud Storage

• Event data is uploaded to Google Firebase Firestore for synchronization
• Images are stored as base64-encoded data (up to 640 KB per image)
• Firebase encrypts data in transit (TLS) and at rest

4.3 Security Measures

• All data transmitted to Firebase is encrypted in transit using TLS 1.2+
• Firebase implements industry-standard security controls
• Access to your data is restricted to authorized devices using your Firebase authentication
• We implement appropriate administrative, technical, and physical safeguards

5. Data Retention and Deletion

5.1 Automatic Deletion

• Events not accessed or updated for 90 days are automatically deleted from Firebase
• You can manually delete events at any time through the App
• Local copies on your device remain unless you delete them

5.2 User-Initiated Deletion

• You can delete individual events immediately through the App
• The event is removed from both local storage and Firebase Firestore
• Deletion is permanent and cannot be undone

5.3 Account Deletion

If you request to delete your account, we will:

• Remove all associated events from Firebase Firestore
• Remove associated device records
• Process your request within 30 days

Contact Piotr Gawronski (cbm@pngsystem.com) to request account deletion

6. Third-Party Services

6.1 Google Firebase

• Purpose: Cloud database, real-time synchronization, and authentication
• Data Shared: Event data, location information, images
• Privacy Policy: https://firebase.google.com/support/privacy
• Data Processing Agreement: Firebase processes data as a data processor on our behalf

6.2 Google Analytics

• Purpose: Understand App usage and improve features
• Data Collected: App usage events, crashes, performance metrics
• Privacy Policy: https://support.google.com/analytics/answer/6004245
• Opt-Out: You can disable analytics in App settings (if provided)

7. Data Sharing

7.1 Data We Share

• We do not sell your personal data to third parties
• We do not disclose event data to external parties

7.2 Service Providers

• We share data with Google Firebase and Google Analytics solely to provide App functionality and analytics
• These companies are contractually obligated to maintain confidentiality and use data only for specified purposes

7.3 Legal Compliance

• We may disclose information if required by law (court order, subpoena, government request)
• We will notify you of such requests unless legally prohibited

7.4 Data Aggregation

• We may use anonymized, aggregated data for research and improvement purposes
• Aggregated data cannot identify you individually

8. GDPR Compliance (EU Users)

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

8.1 Your Rights

• Right of Access: You can request a copy of your personal data
• Right to Rectification: You can correct inaccurate data
• Right to Erasure: You can request deletion of your data (subject to legal obligations)
• Right to Data Portability: You can request your data in a portable format
• Right to Withdraw Consent: You can withdraw consent at any time (does not affect past processing)
• Right to Object: You can object to certain data processing

8.2 How to Exercise Your Rights

Contact Piotr Gawronski at cbm@pngsystem.com with:

• Your full name
• Email address
• Specific right you wish to exercise
• Details of your request

We will respond within 30 days (extendable to 90 days if complex).

8.3 Legal Basis for Processing

• Performance of Contract: Data necessary to provide App functionality
• Legitimate Interests: Analytics and App improvement
• Consent: For Firebase synchronization (opt-in)

9. Children's Privacy

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete such information promptly.

For users between 13-18 (minors), we recommend parental/guardian review of this policy.

10. International Data Transfers

Your data may be transferred to and stored in countries other than your country of residence. These countries may not have data protection laws equivalent to your home country.

By using the App, you consent to:

• Transfer of your data internationally
• Storage of your data on servers located in various jurisdictions
• Processing of your data according to this Privacy Policy

If you do not agree to international transfer, do not use the App.

11. Data Breach Notification

In the event of a data breach affecting your personal information:

1. We will notify you without undue delay (within 72 hours where feasible)
2. Notification will include:
   • Nature of the breach
   • Data affected
   • Likely consequences
   • Measures taken to address the breach
   • Our contact point for further information
3. We will also notify relevant authorities as required by law

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in our practices
• Changes in technology
• New legal requirements
• Other factors we deem necessary

Changes will be effective immediately upon posting to the App or website.

We will notify you of significant changes via:

• Email notification (if contact provided)
• In-App notification
• Updated "Last Updated" date on this policy

Your continued use of the App constitutes acceptance of the updated Privacy Policy.

13. Contact Information

For questions, concerns, or requests related to this Privacy Policy:

14. Compliance and Jurisdiction

This Privacy Policy is governed by and construed in accordance with applicable laws, including GDPR for EU users.

Any disputes arising from this Privacy Policy shall be subject to the jurisdiction of the courts in the relevant jurisdiction.

Appendix A: Data Collected Summary

Appendix B: Frequently Asked Questions

Q: Is my data encrypted?

A: Yes. Data in transit to Firebase is encrypted with TLS 1.2+. Firebase also encrypts data at rest on their servers.

Q: Can I use the App without creating an account?

A: The App uses local storage by default. Firebase synchronization is optional but recommended for multi-device access.

Q: How do I delete all my data?

A: You can delete individual events in the App. For complete account deletion, email cbm@pngsystem.com.

Q: How long does deletion take?

A: Local deletion is immediate. Firebase deletion (after 90 days of inactivity) is automatic. Manual deletion requests are processed within 30 days.

Q: Can I export my data?

A: Currently, data export is not supported in the App. Contact cbm@pngsystem.com to request your data.

Q: Is this App GDPR compliant?

A: Yes. We implement GDPR-required safeguards including data minimization, encryption, and user rights (access, deletion, portability).