CapMate — Privacy Policy

The same text is available in the app: Settings → Documents and data. The privacy notice for this website is a separate page: Website privacy

Version 1.0 · dated 21 October 2026 · effective from 21 October 2026
Applies to: CapMate for iPhone, Apple Watch, Android phones, Wear OS watches and Garmin watches, and to the related online data services (together, the "App").

This Privacy Policy explains:

• which personal data the App processes, and why;
• on what legal basis;
• with whom the data is shared;
• for how long it is kept;
• what rights you have.

It is provided in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") and Portuguese Law No. 58/2019 of 8 August. It is available in English, Portuguese, Spanish, Russian, German, French, Italian, Dutch, Polish and Ukrainian. If the language versions differ, the rule in clause 24.3 of the CapMate Terms of Use also applies to this Privacy Policy.

This Privacy Policy is information about how personal data is processed. It is not part of the contract formed by the Terms of Use.

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In short

• No account. You do not need to register or sign in to use the App.
• No advertising, tracking or third-party analytics. The App contains no advertising, no tracking and no third-party analytics or crash-reporting tools.
• Your data stays on your device. Your settings, boat profile, points, routes, tracks and alarm history are stored only on your phone or watch. We do not receive them.
• Some functions send a position or an area. For example, the App sends coordinates to obtain a weather forecast. Clause 4 lists all such transfers.
• Off until you switch them on. Two online functions send data to recipients outside the European Economic Area: vessels nearby over the internet, and place photos and descriptions from Wikipedia. Both stay off until you switch them on. On Apple Watch and Garmin watches, no position is sent until you have agreed to it.
• We never sell your data. We do not sell your personal data and do not use it for profiling or marketing.

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1. Who is responsible (controller)

The controller of your personal data is:

Iurii Afanasev, individual developer, tax number (NIF) 310772079, R. Cooperativa das 7 Bicas, 256, 1C, 4460-212 Senhora da Hora, Porto, Portugal · e-mail: privacy@capmate.app ("we", "us").

We have not appointed a data protection officer, because we are not required to. For any question about this Privacy Policy, or to exercise your rights, write to privacy@capmate.app.

If we transfer the App to a company, as described in clause 24.4 of the Terms of Use, that company will become the controller. We will tell you in advance.

2. Scope

This Privacy Policy covers the App and our own online services that the App uses. It does not cover the following, which are governed by their own privacy policies:

• the app stores and platforms from which you obtain the App (the "Platforms": Apple, Google, Garmin);
• the operating systems of your devices;
• the websites you open from the App;
• the processing that the independent data providers listed in clause 4 carry out for their own purposes.

Clause 4 explains what the App sends to those providers.

3. Data processed on your device only

The App stores the following data only on your device:

• your settings, including your choices on the online functions described in clause 4;
• the profile of your boat (for example, name, length, draft, air draft);
• waypoints, marks and routes you create;
• recorded tracks;
• the state and history of the anchor watch and other alarms;
• the man-overboard position;
• downloaded chart packages, chart tiles cached from the online chart, and cached forecasts, warnings and place information;
• the date and version of your acceptance of the Terms of Use.

The App also reads the following data locally:

• data from your device's sensors (satellite positioning, compass, and barometer where available);
• data from your boat's instruments, received over your local Wi-Fi network: NMEA 0183 from a chartplotter or Wi-Fi gateway, NMEA 2000 data from a Wi-Fi gateway, or the data stream of a Signal K server. To receive it, the App asks for permission to access your local network. It connects only to devices on your local network and sends them nothing but connection requests; a Signal K server also receives read-only requests (whether it is there and whether it allows read-only access) and one message listing the data the App subscribes to.

That data is displayed and used on the device and is not sent to us.

The App stores information on your device, and reads your device's location and sensors, only where this is strictly necessary to provide a function you have requested. This is the exemption in Article 5(3) of Directive 2002/58/EC and Article 5 of Portuguese Law No. 41/2004. The App uses no cookies or similar technologies for any other purpose.

We have no access to this data. It remains under your control. You can delete it at any time by deleting the relevant items in the App or by uninstalling the App. If your device backs up app data to a cloud service (for example iCloud or a Google account backup), that backup is governed by your arrangement with that service provider.

Phone and watch. If you use a watch together with a phone, the App exchanges data between the two devices: position, instrument data, alarms, points, routes and settings. The exchange uses the connection provided by your devices' operating systems (Bluetooth or Wi-Fi). Apple or Google may relay it through their services when the devices are not near each other. For Garmin watches, the exchange goes through the Garmin Connect app on your phone, under Garmin's terms. We do not receive this data.

Apple Health (Apple Watch). If you start a sailing workout on Apple Watch, the App saves it in Apple Health: the start and end time, the route and the data your watch measures during the workout, such as heart rate and active energy. During the workout, the App reads your heart rate to show it on the screen. You decide in the Health settings what the App may save and read, and you can change this at any time. This data stays in Apple Health on your devices: the App does not send it anywhere, and we do not receive it.

4. Data sent from the App to provide functions you use

Some functions only work if the App sends a request over the internet. Each request reveals your device's IP address to the recipient. Each request also contains standard technical data, such as the App version, the operating system and, on some devices, the device model (user agent). Some requests also contain a position or an area. The table below lists every recipient in this version of the App.

Background. While the screen is off, the App sends data off your device only in these cases: for AIS approach monitoring, if you have switched it on; during an anchor watch, at most every 3 hours, a forecast request to OpenMeteo GmbH with your rounded position (as in the table above), so that the night plan stays current (iPhone, Android phones and Wear OS watches); and requests to our chart server to download the region where you are over Wi-Fi, if it has not been downloaded yet, or to obtain the chart around your boat for a connected Garmin watch (iPhone and Android phones). Apart from that, the anchor watch with its alarms and track recording work on your device without sending your position.

Who is responsible for what. We decide which data the App sends, and we are responsible for that transmission. Clause 6 gives the legal basis. Each recipient decides for itself how it then processes the data, including in its server logs. For that processing, each recipient is a separate controller under its own privacy policy. For example, OpenMeteo GmbH states that its web server logs are deleted after 90 days. We send each recipient only the data needed to answer the request. We do not send your name, contact details, device identifiers, boat profile, points, routes or tracks.

Your choices.

• Permissions. The App asks your device's permission before it accesses your location or your local network. On iPhone and Android, background location is used only for functions that must keep running when the screen is off: the anchor watch, track recording, AIS approach monitoring and the connection to your watch. On Apple Watch, it is used for the anchor watch, man overboard, guidance to a point or along a route, and during a sailing workout. You can withdraw any permission at any time in your device's settings. The functions that need it will then stop working.
• Online functions. The two functions marked "off until you switch it on" in the table are offered on the App's first screen and in its settings. You can switch them on or off at any time.
• Garmin watches. No function sends your position until you have agreed on the App's first screen. You can change this in the App's settings. Data entered into the Garmin app is submitted to us and to the recipients in this clause, not to Garmin.
• Apple Watch. The watch requests weather by itself only if you have agreed to it on the watch's first screen. You can change this in the watch's settings.

5. Data we receive directly

5.1 Chart server logs. For each request, our chart server records:

• the IP address;
• the date and time;
• the file, chart tile or area requested (including the coordinates contained in the request);
• the result;
• the user agent.

We use these logs only to operate the service and keep it secure, for example to detect abuse and errors. The logs are deleted automatically after no more than 14 days. We do not combine them with any other data. The chart server runs on our own equipment in Portugal, and no hosting provider has access to it.

5.2 Messages you send us. If you contact us by e-mail, we process the following data to answer you and handle your request:

• your e-mail address;
• your name, if you give it;
• the content of your message;
• any information you choose to include.

Messages to our @capmate.app addresses are forwarded by ImprovMX Incorporated (USA) to our mailbox at Google (Gmail); our replies may be sent through Resend, Inc. (USA). These providers process the messages on our behalf. Where they process data in the USA, the transfer relies on the safeguards they offer, such as the EU–US Data Privacy Framework or Standard Contractual Clauses (clause 7).

5.3 Purchases through Apple or Google. If you buy Paid Features through the App Store or Google Play, the payment is processed by Apple or Google, not by us. We do not receive your payment card details. Apple or Google may provide us with transaction information, such as the product, date, country, price and a transaction identifier. We use it to provide the purchased features, to handle refunds and complaints, and to keep the records required by tax law. The App verifies your entitlement on your device using the Platform's purchase system.

5.4 Purchases for the Garmin app. Paid Features for the Garmin app are not offered at present. If we start selling them other than through Apple or Google, we will update this Privacy Policy before that and name the payment provider.

5.5 Statistics from the Platforms. Apple, Google and Garmin may provide us with aggregated statistics, for example on downloads, sales, app stability and crashes. On iPhone, crash and usage data is shared with developers only if you have agreed to it in your device settings. The Platforms collect these statistics under their own privacy policies. We do not use them to identify you.

6. Purposes and legal bases

Where we rely on our legitimate interest, you have the right to object (clause 9). We do not use automated decision-making or profiling that produces legal or similarly significant effects for you.

Providing the data in clause 4 is not a legal requirement. It is necessary only for the function concerned. If you do not want a position or area to be sent, do not use that function, or switch it off or withdraw the corresponding permission. The other functions of the App remain available.

7. Transfers outside the European Economic Area

• Switzerland. OpenMeteo GmbH is located in Switzerland. The European Commission has recognised that Switzerland provides an adequate level of data protection.
• Vessels over the internet (aisstream.io). We have not been able to identify the operator of aisstream.io or where it processes data. No adequacy decision or other safeguard covers this transfer, so your data may be less protected than in the EU. The App sends the box around your boat, the access key and your IP address only if you switch on "Vessels over the internet" and confirm this notice (explicit consent, Art. 49(1)(a) GDPR). You can withdraw your consent at any time by switching the function off. We intend to route this function through our own server in Portugal, so that aisstream.io no longer receives your IP address. When we do, we will update this Privacy Policy.
• United States (Wikimedia Foundation). If you switch on "Photos and descriptions from Wikipedia", your device sends the coordinates of the selected place and your IP address to the Wikimedia Foundation in the USA. There is no adequacy decision covering the Wikimedia Foundation, and US authorities may be able to access the data. We rely on your explicit consent (Art. 49(1)(a) GDPR), which you can withdraw at any time in the App's settings.
• E-mail (ImprovMX, Google, Resend). Messages you send to our @capmate.app addresses, and our replies, may be processed in the USA by ImprovMX Incorporated, Google and Resend, Inc. The transfer relies on the safeguards these providers offer, such as the EU–US Data Privacy Framework or Standard Contractual Clauses.
• Platforms. The Platforms (Apple, Google, Garmin) may process data in other countries under their own terms and safeguards.

8. How long data is kept

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data rectified;
• have your data erased;
• restrict processing;
• data portability;
• object at any time to processing based on our legitimate interest;
• withdraw consent at any time where processing is based on consent, for example by switching off "Vessels over the internet" or "Photos and descriptions from Wikipedia". Withdrawal does not affect the lawfulness of processing carried out before it.

To exercise your rights, write to privacy@capmate.app. We will answer within one month. This period can be extended where the law allows, in which case we will tell you. We may ask for information to confirm your identity.

We generally cannot link IP addresses in server logs to you (Article 11 GDPR). If you give us your IP address and the time of your requests, we will search the logs. Data held only on your device is under your direct control: you can view it, export it where the App allows, and delete it yourself.

You also have the right to lodge a complaint with a supervisory authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, www.cnpd.pt. You may also complain to the authority of the EU country where you live or work, or where the alleged infringement took place.

10. Security

The App communicates with our chart server and with the recipients in clause 4 over encrypted connections (HTTPS or WSS). The connection to your boat's instruments over your local Wi-Fi network (NMEA 0183 or NMEA 2000 over TCP or UDP, Signal K over HTTP and WebSocket) is not encrypted. It stays within your local network, and you are responsible for securing that network. On our server, we use access restrictions, rate limiting and short log retention.

If a personal data breach occurs that is likely to result in a high risk to you, we will inform you without undue delay, as required by Article 34 GDPR. We will do so in the App, through the Platform, or by e-mail where we have your address.

11. Children

The App is not intended for children under 16. We do not knowingly process personal data of children under 16. If you believe that a child has provided us with personal data, for example by e-mail, contact us and we will delete it.

12. Changes to this Privacy Policy

We will update this Privacy Policy whenever the App's processing changes, for example when a function, a data provider or a payment method is added. If a change involves a new use of your data that is not described here, we will inform you in the App before that processing begins, and ask for your consent where it is required. The address of this Privacy Policy will stay the same, or will redirect to the new address. The version and date are shown at the top, and clause 13 contains a record of the versions.

13. Version history

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