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Privacy Policy

Last updated and effective: October 4, 2026

This Privacy Policy explains what personal data the Primo Nautic app for iPhone, iPad and Android and the website primonautic.com process, why, who else receives it, how long it is kept and what rights you have. We wrote it to describe what the app and the website actually do. If something here is unclear, write to us and we will explain.

1. Who We Are

The controller of your personal data is Primo Technology Ltd. (“we”, “us”). You can reach us about anything in this policy at the address under Contact. We have not appointed a data protection officer, because the law does not require one for our processing; privacy questions come straight to us at the same address.

2. What This Policy Covers

This policy covers the Primo Nautic app and primonautic.com, including its blog, courses, calculators and cruise ship tracker. It does not cover the App Store or Google Play, which process your purchase and your store account under their own policies, or websites we link to.

In short: you can use the app without giving us your name. The ships, ports and positions the app shows come from public AIS broadcasts by vessels, not from users. Your location is used only to show the ships near you and is not stored. We do not sell your data or show ads.

3. What We Collect, Why, and Our Legal Basis

3.1 Your Account

  • What: the app creates an anonymous account the first time you use it. You can instead sign in, or later link the anonymous account, with Apple, Google or an email and password. We store an account identifier, your email address if you sign in with one, how you signed in, your device platform, your language and time zone, whether you have premium, your usage counters and when the account was created and last used. We do not ask for or store your name.
  • Why: to keep the vessels you follow and your settings tied to you, to apply free and premium limits, and to let you sign in on another device.
  • Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).

3.2 The Vessels You Follow

  • What: the vessels you add, the name and icon you give each one, why you follow it (for example work or a cruise), your alert settings, and the latest position, weather, arrival estimate and AI summary we keep for it so the app opens quickly.
  • Why: to show your fleet, send the alerts you turned on and estimate arrivals.
  • Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).

3.3 Your Location

  • What: when you open the ships near you and allow location access, the app reads your approximate location, rounded to about 100 metres, only while the app is open. It is sent to our server, which turns it into a map area and asks our AIS data provider, MyShipTracking, for the vessels in that area. Your location is not stored and is not written to our logs. The app never reads your location in the background.
  • Why: to show the vessels around you.
  • Legal basis: performance of our contract with you, for a feature you choose to use (Art. 6(1)(b) GDPR). You can turn location access off in your device settings at any time; the ships near you then stop working and everything else keeps working.

3.4 Notifications

  • What: if you allow notifications, we store a push token for each of your devices and send it, through Firebase Cloud Messaging, the alerts you turned on, such as a vessel arriving at or leaving a port. Reminders, such as the notice before a free trial ends, are scheduled on your device.
  • Why: to deliver the alerts you asked for. We do not send marketing notifications.
  • Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR). You can turn notifications off in your device settings or per vessel in the app.

3.5 Subscriptions

  • What: Apple or Google processes your payment; we never see your card details. RevenueCat, our subscription provider, receives your account identifier, your email address if your account has one, your platform and sign-in method, an identifier of your app installation, the store’s record of your purchases and, on iPhone and iPad, Apple’s campaign attribution token, which says whether an Apple Search Ads campaign led to your purchase.
  • Why: to unlock premium, restore purchases on a new device and keep the records accounting law requires.
  • Legal basis: performance of our contract with you, and compliance with our legal obligations for financial records (Art. 6(1)(b) and (c) GDPR).

3.6 Analytics

  • What: Google Analytics for Firebase records how the app is used (screens, features used, app version, device type, language, approximate region) together with your account identifier and an app installation identifier. On iPhone and iPad the app asks whether you allow tracking; only if you allow it may Google Analytics for Firebase use the advertising identifier to measure our campaigns.
  • Why: to see which features work and which campaigns bring people to the app. We do not use this data to show you ads.
  • Legal basis: our legitimate interest in understanding and improving the app and our marketing (Art. 6(1)(f) GDPR), and your consent for Apple’s tracking prompt (Art. 6(1)(a) GDPR). You can object to analytics at any time by writing to us.

3.7 Maps and Places

Map tiles come from CARTO, using OpenStreetMap data, and port addresses and time zones are looked up with Google Maps Platform. These requests go directly from your device, so these providers receive your IP address and the map area or port being looked up, but not your account or your location.

3.8 The Website

  • Visits: Google Analytics 4 records the pages you view, how you arrived, your device and browser, an approximate location derived from your IP address (Google Analytics does not store the IP address itself) and actions such as tapping a download button. Fonts are loaded from Google Fonts, which receives your IP address. Legal basis: our legitimate interest in running and understanding the website (Art. 6(1)(f) GDPR).
  • Tools: the cruise ship tracker and the port and ship pages send the ship or port you look up to MyShipTracking. The sea distance calculator runs on our server and the MMSI lookup runs in your browser. We do not store what you look up. Legal basis: performance of the service you request (Art. 6(1)(b) GDPR).
  • Browser storage: the website does not set its own cookies. It remembers in your browser’s storage whether you closed the app download prompt and which version of that prompt you were shown.

4. AI Processing

Voyage summaries and arrival analyses in the app are generated by AI. To produce them we send OpenAI, our processor, the vessel’s public AIS data and voyage, the weather along it, why you follow the vessel, the name you gave it and your language. Under the API terms we use, OpenAI does not use this content to train its models; it may keep it for a limited period to detect abuse and then deletes it. AI makes no decision about you that has legal or similarly significant effects.

5. Who Receives Your Data

We do not sell your personal data and we do not share it for advertising. These service providers process data on our behalf, each only for the purpose described:

  • Google Firebase (Google Ireland Ltd. and Google LLC): sign-in, database, cloud functions, Cloud Messaging, Analytics and Remote Config.
  • Google Analytics 4, Google Maps Platform and Google Fonts: website analytics, place lookups and fonts.
  • MyShipTracking: AIS vessel data for the area, vessel or port requested.
  • OpenAI: AI voyage summaries and arrival analyses.
  • RevenueCat: subscription status and purchase records.
  • CARTO: map tiles.
  • Apple and Google, as the stores, process your purchase under their own privacy policies.

We may also disclose data where the law requires it, for example to a court or authority with a valid request.

6. International Transfers

MyShipTracking is based in the EU. Several of the other providers are based in the United States or process data there. Where a recipient is certified under the EU-US Data Privacy Framework, we rely on the European Commission’s adequacy decision for it; otherwise we rely on the European Commission’s Standard Contractual Clauses in our agreement with the provider. You can ask us for more detail on the safeguard that applies to a provider.

7. How Long We Keep Data

  • Your account, vessels and settings: until you remove a vessel or delete your account. Deleting the account erases them at once.
  • Your location: not stored.
  • Push tokens: until you delete your account or the token is replaced.
  • Port call history for alerts: public AIS events are kept for 14 days.
  • Server logs: up to 30 days.
  • Analytics: Google Analytics keeps event data for no longer than 14 months.
  • Subscription records: as long as you have a subscription and afterwards for as long as accounting and tax law requires.
  • AI provider: only for the limited abuse-monitoring period of its API terms.

8. Delete Your Account and Data

In the app: open Settings, choose Delete Account, type “delete” and confirm. This permanently deletes your account, the vessels you follow, your settings, alerts, usage records and push tokens, and clears the app’s data on your device.

Without the app: email us at the address under Contact with the subject “Delete my account” from the address you signed in with, or tell us how you signed in. We will confirm and complete the deletion within 30 days.

What is kept: purchase records we must keep under accounting and tax law, and data the providers above hold under their own retention periods, as described in section 7. On request we also ask RevenueCat to delete what it holds about you.

Subscriptions: deleting your account does not cancel a subscription. Cancel it in your App Store or Google Play account settings.

9. Children

Primo Nautic is intended for people aged 16 and over. It is not directed at children and we do not knowingly collect data from anyone under 16. If you believe a child has used Primo Nautic, write to us and we will delete the data.

10. Security

Data travels encrypted between your device, our servers and our providers. Our database rules let each account reach only its own data, and access to production systems is limited to the people who run the service. No system is perfectly secure, so if we learn of a breach that affects you, we will notify you and the supervisory authority as the law requires.

11. Your Rights

Under the GDPR you have the right to:

  • access the personal data we hold about you and get a copy;
  • have inaccurate data corrected;
  • have your data deleted, as described in section 8;
  • restrict our processing;
  • receive the data you gave us in a portable format;
  • object to processing based on our legitimate interests, including analytics;
  • withdraw a consent you gave at any time, without affecting processing that happened before.

To use a right, write to us at the address under Contact. We answer within one month and may ask you to confirm that the account is yours. Giving us your data is not a legal requirement, but without an account the app cannot keep your fleet. If you live outside the EU, for example in the United States, you can make the same requests and we will honour them.

12. Changes to This Policy

When we change how we process data, we update this policy and the date at the top. If a change materially affects you, we also tell you in the app or by email before it applies.

13. Contact

Primo Technology Ltd. Email: info@techprimo.ai.