Privacy Policy

Last Updated: March 2025

1. Information We Collect

1.1 Data You Enter

The following types of information may be stored locally on your device when you use SDM:

• Personal Details: Full name, date of birth, nationality, passport number, seaman's book number
• Contact Information: Email address, phone number, home address
• Professional Documents: Certificates of Competency (COC), Certificates of Proficiency (COP), STCW certificates, medical certificates, training records, employment history
• Photos: Profile pictures, document scans, passport photos
• Employment Data: Vessel assignments, rank/position, contract details, sea service records

1.2 Location Data (Midnight Position Check Feature)

SDM accesses and uses location data in the following two ways, both requiring your explicit consent:

• Foreground Location (Manual GPS): When you tap the GPS button inside the Midnight Position Check screen, SDM reads your current device coordinates once to pre-fill the latitude and longitude fields and determine whether your vessel is inside or outside UK territorial waters (12 nautical miles). This is a single one-time read — SDM does not track or monitor your position continuously.
• Background Location (Automatic Midnight Recording): If you enable the "Auto-Record" toggle in the Midnight Position Check screen, SDM uses background location access to automatically record your vessel's position once per day at 00:00 London time. This feature runs silently in the background and requires the "Always Allow" location permission on your device. You can disable this feature at any time by toggling off "Auto-Record" in the MPC screen.

How your location data is used:

• Location data is used exclusively to populate the Midnight Position Check log entries on your device
• Location data is never transmitted to the developer, any servers, or any third parties
• Location data is stored only locally on your device as part of your MPC log
• You can delete any or all MPC records at any time from within the app
• Location permissions are requested only when you first use the GPS or Auto-Record feature, preceded by an in-app explanation of why the permission is needed

1.3 No Automatic Data Collection

Aside from the optional location access described above, SDM does not automatically collect device information, usage analytics, crash reports, or any other data. No tracking or telemetry of any kind is performed by the application.

1.4 Cloud Storage (Optional, User-Controlled)

• Cloud Backup: If you choose to enable cloud backup, your data is stored in your personal cloud account (e.g., Google Drive or iCloud). The developer has no access to this data whatsoever.
• CV Export: You may export your CV as a PDF file. This file is generated locally on your device and shared only at your explicit request.

2. How We Use Your Information

SDM does not use your information for any purpose other than providing you with the app's core features. All processing happens locally on your device:

• Document Management: Store, organize, and manage your maritime documents on your device
• Document Expiry Tracking: Display local push notifications when your certifications are about to expire (no data leaves your device)
• CV Generation: Create professional maritime CVs in PDF format directly on your device
• Midnight Position Check: Record your vessel's daily GPS position locally for territorial waters compliance logging — only when this feature is explicitly enabled by you

3. How We Share Your Information

Your data never leaves your device unless you explicitly choose to:

• Create a Cloud Backup: Stored in your own cloud account, fully under your control
• Export Your CV as PDF: Generated locally and shared only by you, to whom you choose

4. Data Storage and Security

4.1 Where Your Data Is Stored

• Local Storage: All your documents, location logs, and data are stored locally on your device. The developer has no access to this data.
• Cloud Backup (Optional): If you enable cloud backup, copies are stored in your personal cloud storage account (e.g., Google Drive or iCloud). This is fully under your control.

4.2 Security

Since no data is transmitted to external servers, your information is protected by your device's own security measures:

• Device Encryption: Data is protected by your device's built-in encryption
• App Lock: Access to SDM can be secured with a PIN code or biometric authentication (fingerprint, face recognition)

5. Location Data — Detailed Disclosure

5.1 What Location Data Is Accessed

• GPS Coordinates: Latitude and longitude from your device's GPS sensor
• Accuracy: High-accuracy GPS fix (device GPS + Wi-Fi + cellular)

5.2 When Location Is Accessed

• Manual (foreground): Only when you tap the GPS icon in the Add/Edit position form. Single one-time read per tap.
• Automatic (background): Once per day at midnight London time, only if you have enabled the Auto-Record toggle. This requires "Allow Always" permission.

5.3 Why Location Is Accessed

The Midnight Position Check (MPC) feature is a professional maritime tool that helps seafarers maintain a daily log of their vessel's position relative to UK territorial waters (12 nautical mile limit). This is relevant for UK tax compliance purposes for seafarers working under the Seafarers' Earnings Deduction (SED) scheme.

5.4 Where Location Data Goes

• Location data is saved only to local device storage (AsyncStorage) as part of your MPC log entries
• Location data is never sent to any server, cloud service, or third party by SDM
• If you export a PDF report of your MPC log, the coordinates in that PDF are shared only by your explicit action

5.5 Revoking Location Permission

You can revoke location permissions at any time through your device's Settings → Apps → Seafarer Documents Manager → Permissions → Location. Revoking the permission will disable the GPS button and Auto-Record feature, but will not affect any already-saved MPC records.

6. Your Privacy Rights

Since SDM does not collect or store any of your data on external servers, there is no personal data held by the developer to access, correct, delete, or export. You have full and exclusive control over all your data at all times.

• Access: Your data is stored on your device — you can access it at any time directly within the app
• Deletion: Delete your data at any time by clearing the app data or uninstalling SDM
• Location Records: Delete individual MPC records or all MPC history from within the Midnight Position Check screen
• Cloud Data: If you use cloud backup, manage or delete your data directly through your cloud storage provider

For any questions, contact us at kukalab@mail.com

7. Data Retention

• Local Data: Stored on your device for as long as you choose to keep it. Deleted automatically when you uninstall the app or clear its data.
• Location Logs: MPC position records are stored locally until you manually delete them or uninstall the app.
• Cloud Backups: Retained in your personal cloud storage until you delete them or revoke SDM's access. The developer has no control over this data.

8. Children's Privacy

SDM is not intended for use by children under the age of 13 (or 16 in the European Economic Area). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

9. International Data Transfers

SDM does not transfer any data to external servers or across borders. All your information is stored locally on your device. If you use an optional cloud backup, data is stored in the cloud service you select, subject to that provider's own terms and data practices.

10. Third-Party Services

SDM does not integrate with any analytics, advertising, or tracking services. The only optional third-party interaction is cloud storage for backups, chosen and controlled entirely by the user:

• Google Drive / iCloud: For optional cloud backup (subject to their own privacy policies). The developer has no access to your cloud storage.
• RevenueCat: Used for in-app purchase management. Only transaction confirmation is processed — no personal documents, maritime data, or location information are shared.

We are not responsible for the privacy practices of these third parties. Please review their privacy policies.

11. Cookies and Tracking Technologies

SDM does not use cookies, analytics SDKs, crash reporting tools, or any other tracking technologies. No usage data is collected or transmitted.

12. California Privacy Rights (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA). Since SDM does not collect, store, sell, or share any personal information with the developer or third parties, there is no personal data held by Kuka Lab subject to CCPA requests. You retain full control over all data on your own device.

13. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR). Since SDM does not collect or process any personal data on behalf of the developer, Kuka Lab does not act as a data controller or processor in relation to your maritime documents or location data. All data is stored and processed locally on your own device, and any cloud storage is managed directly by you through your own cloud provider account.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted in the app and on our website. Material changes will be communicated via:

• In-app notification
• Email notification (if we have your email)
• Push notification

Your continued use of SDM after changes are posted constitutes acceptance of the updated Privacy Policy.

15. Contact Us