Privacy policy
The short version
SeaSafe is designed to work with no network. Your questions, the answers and your conversation history are stored only on your phone and are never sent to us. The app has no accounts, no analytics and no advertising. The only network connections it makes are the one-time download of the language model and handbook from our file server, and, if you buy full access, the purchase handled by Apple or Google with RevenueCat keeping the receipt. Uninstalling the app deletes everything it stored.
Contents
1. Who is responsible
The data controller is ULADZISLAU DZIARKACH SYSTEMS, a sole proprietorship registered in Poland, tax number (NIP) 5842868641, ul. Obrońców Wybrzeża 17/902, 80-398 Gdańsk, Poland. Email: info@dervlad.com. We have not appointed a data protection officer because the scale of processing does not require one.
2. Data in the app
What stays on your phone
- Your questions and the answers, including conversation history (up to twenty recent conversations), are stored in the app's private storage on your device.
- Settings such as language, display mode and which model is installed.
- The language model and the handbook are files on your device.
- The free-question counter (three questions a day) is kept on the device.
None of this is transmitted to us or to anyone else. The language model runs entirely on the device; your questions are not sent to any AI service. There is no account, no sign-in, and we cannot see what you ask.
What the app does not do
- It does not use analytics, crash-reporting or advertising software development kits.
- It does not access your location, contacts, photos, microphone or camera. If a future version adds voice input, speech recognition will run on the device and this policy will be updated before release.
- It does not read your clipboard, your other apps or your files.
Your phone's operating system may collect its own diagnostic data about any app; that is governed by Apple's or Google's privacy policy, not ours.
3. Model and handbook download
On first run the app downloads the language model (about 0.6 GB or 2.6 GB depending on your phone) and the handbook package from a file server we rent from Cloudflare, Inc. (R2 object storage with its content delivery network). Like any web server, it records technical data about each request: your IP address, the time, the file requested, and the app or system version in the request header. Cloudflare keeps these logs for a short period for security and traffic management; we do not receive them as personal data and we do not link them to you. The purpose is delivering the files you asked for and protecting the server from abuse. Legal basis: performance of the contract with you (Art. 6(1)(b) GDPR) and our legitimate interest in running a secure service (Art. 6(1)(f)).
The app also checks this server occasionally for handbook updates when it has a network. That check sends the same technical data and the version numbers you have installed, nothing more.
4. Purchases
Full access is a one-time in-app purchase made through the Apple App Store or Google Play. Apple or Google processes your payment and holds your payment details; we never see your card number, name or billing address. Their privacy policies apply to the payment: Apple, Google.
To know that you have paid and to restore the purchase on a new phone, the app uses RevenueCat, Inc., a purchase-management service. RevenueCat receives a random identifier generated by the app on your device (not your name or email), the store's purchase receipt, the product bought, the price and currency, the app version, device type and operating system version, and the IP address of the request. It uses this to validate the receipt with the store and to tell the app whether full access is unlocked. We can see aggregated sales figures and individual anonymous purchase records in the RevenueCat dashboard. RevenueCat acts as our processor under a data processing agreement. Its privacy policy: revenuecat.com/privacy. Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and compliance with tax and accounting law for sales records (Art. 6(1)(c)).
5. This website
This website is static and hosted by Vercel Inc. It sets no cookies and runs no analytics or tracking scripts. Vercel records standard server logs (IP address, time, page requested, browser header) to serve the pages and protect against abuse, and keeps them for a limited time under its own policy: vercel.com/legal/privacy-policy. Legal basis: our legitimate interest in operating a website (Art. 6(1)(f) GDPR).
6. When you write to us
If you email us, for support, to ask to be told about the launch, or for any other reason, we process your email address, your name if you give it, and the content of the message, to answer you. Launch-notification requests are used for exactly one email and then deleted. Support messages are kept for as long as needed to resolve the issue and then up to twelve months in case the issue recurs. Legal basis: our legitimate interest in answering you (Art. 6(1)(f) GDPR), or your consent where you asked for a notification (Art. 6(1)(a)), which you can withdraw at any time by replying.
7. Legal bases
| Processing | Legal basis (GDPR) |
|---|---|
| Serving the model and handbook files | Art. 6(1)(b), contract; Art. 6(1)(f), security |
| Validating and restoring purchases | Art. 6(1)(b), contract |
| Keeping sales records | Art. 6(1)(c), legal obligation |
| Website server logs | Art. 6(1)(f), legitimate interest |
| Answering your email | Art. 6(1)(f), legitimate interest; Art. 6(1)(a), consent for notifications |
We do not make decisions about you by automated means that have legal or similarly significant effects. We do not sell personal data and never have.
8. Who else sees data
- Cloudflare, Inc. (file hosting and delivery for the model and handbook).
- Apple Inc. and Google LLC (app distribution and payment).
- RevenueCat, Inc. (purchase validation).
- Vercel Inc. (website hosting).
- Our email provider, for messages you send us.
- Public authorities, only where the law requires it.
There are no other recipients. We do not share data with advertisers or data brokers.
9. Transfers outside the EEA
Cloudflare, RevenueCat, Vercel, Apple and Google are United States companies and may process data outside the European Economic Area. Each relies on the EU-US Data Privacy Framework or the European Commission's standard contractual clauses for such transfers. Copies of the relevant safeguards are available on request.
10. How long we keep data
- Data on your phone: until you delete a conversation, remove the model in settings, or uninstall the app. We cannot delete it for you because we do not have it.
- Server logs at Cloudflare and Vercel: according to their retention policies, typically days to a few weeks.
- Purchase records: as long as required by Polish tax and accounting law, currently five years from the end of the tax year.
- Email correspondence: as described in section 6.
11. Security
Data on your device is protected by your phone's own storage encryption and screen lock. Downloads are served over HTTPS and every file is verified with a checksum before it is used, so a tampered model cannot be installed. Our accounts with service providers use two-factor authentication. No system is perfectly secure; if we learn of a breach affecting you we will inform you and the supervisory authority as the law requires.
12. Children
SeaSafe is intended for adults who hold or are training for a boating licence. It is not directed at children under 16 and we do not knowingly collect data from them. Because the app stores nothing about you, there is nothing for us to delete if a child has used it; the parent can uninstall the app.
13. Your rights
Under the GDPR you may ask us for access to, correction or deletion of personal data we hold about you, for restriction of processing, for a copy of your data in a portable form, and you may object to processing based on legitimate interest. Where processing is based on consent you may withdraw it at any time without affecting what was done before. Write to info@dervlad.com; we answer within one month. You also have the right to complain to a supervisory authority, in Poland the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl), or the authority of the country where you live.
In practice, for most of what the app does the answer will be that we hold nothing about you, because it lives on your phone. To delete it: in the app, delete individual conversations or clear history in settings; to remove everything including the model, uninstall the app.
14. Changes to this policy
We update this policy when the app changes in a way that affects data, for example if voice input or an optional online feature is added. The date at the top shows the current version; material changes will also be announced inside the app before they take effect.
15. Contact
ULADZISLAU DZIARKACH SYSTEMS
ul. Obrońców Wybrzeża 17/902
80-398 Gdańsk, Poland
info@dervlad.com