This privacy notice explains how we collect and use your personal data when you download, register for, or use Medvind mobile application, a sea navigation aid designed for recreational boaters and other private users.
1. Who is responsible for your data
Trelleborg Marine Systems Denmark A/S (CVR nr. 34452458) with the registered address at Sommervej 31 B, 8210 Aarhus V, Denmark, is the data controller for the processing of your personal data described in this Privacy Notice and is responsible for ensuring that all processing is carried out in accordance with applicable data protection legislation.
If you have any questions regarding the processing of your personal data or wish to exercise any of your rights, please contact us using the contact information in Clause 9.
2. What personal data we collect
We may collect the following categories of personal data:
- Account information, such as your email address, login details, as membership in a partner organisation (where relevant).
- Subscription information, your subscription plan, billing status, and transaction history (payment card details are handled directly by our payment provider);
- Vessel information, including vessel name, dynamic and static data related to your vessel;
- Location information, including real-time positioning of your device necessary for navigation. We also process location data in aggregated and de-identified form to analyse general navigation patterns.
- Device information - device model, operating system, app version and identifiers, language settings;
- App usage information, including how you interact with the app and related logs;
- Navigation preferences, including routes and annotations saved.
- Onboard sensor information, including real-time information from onboard sensors like wind-instruments, echosounders, engine data, level gauges, accelerometers, GNSS devices, heading devices, alarm systems, electric installations, switching equipment.
This information may be collected directly from you, automatically from your device when you use the app, as well as from third parties, where relevant, for example if you are a member of a partner organisation that gives you preferential access to this app.
3. Why we use your personal data and our legal basis
We only use your personal data where we have a lawful basis to do so. The table below sets out, for each purpose, what we do and on what legal basis.
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating and managing your account | Email address, membership number in a partner organisation (where relevant), device information. | Performance of a contract with you, as set out in Article 6(1)(b) of the GDPR. |
| Providing access to the App and its navigation features | Location data, vessel information, device information | Performance of a contract with you, as set out in Article 6(1)(b) of the GDPR. |
| Managing your subscription, billing and renewals | Email address, subscription information | Performance of a contract with you, as set out in Article 6(1)(b) of the GDPR. |
| Ensuring the App functions correctly and is secure | Device information | Legitimate interest as set out in Article 6(1)(f) of the GDPR, where our legitimate interest is to maintain a safe, reliable and secure mobile application. |
| Responding to your questions, complaints and other requests | Email address | Legitimate interest as set out in Article 6(1)(f) of the GDPR, where our legitimate interest is to handle questions and requests regarding our App. |
| Sending you marketing communications | Email address, membership number in a partner organisation, app usage information. | Your consent as set out in Article 6(1)(a) which you can withdraw at any time. |
| To improve our services | Device information, app usage information, information related to your vessel as well as de-identified general navigation patterns. | Legitimate interest as set out in Article 6(1)(f) of the GDPR, where our legitimate interest is to continuously develop our services. |
4. Who we share your data with
We may share your personal data with the following categories of recipients:
- Trelleborg Group companies that participate in the processing of personal data;
- Service providers supporting the operation of the app (e.g. hosting and technical services);
- Payment providers (including the relevant app store).
- Providers of analytical services that provide us with statistics on how users use our app, in order to improve our services to you;
- CRM system provider that enables us to communicate with you, such as sending out campaigns, emails, and notifications in our apps;
- Where required by law, public authorities.
Transfers of personal data outside the EU/EEA
Since some of our service providers are located outside the European Economic Area (EEA), we may transfer your data to a third country. We always ensure that such transfer takes place only if it is permitted and carried out in accordance with applicable laws. We also ensure that the service provider in question guarantees by agreement or otherwise that privacy is maintained at the same level of protection as the EU. That includes safeguarding such data transfer with necessary organisational and technical security measures. For international transfers, we rely on Standard Contractual Clauses (SCC) introduced by the European Commission. In addition to that, we rely on adequacy decisions passed by the EU Commission provided that the conditions for adequacy (if any) are fulfilled.
Where we disclose personal data to other companies within the Trelleborg group, we enter into an Intra-Group Data Transfer Agreement, implementing the European Commission Standard Contractual Clauses to any such transfer.
5. For how long do we keep your personal data
We only keep your personal data for as long as necessary for the purposes described in this notice. In general:
- Account information: we retain the information connected to your account, such as your email and vessel information for as long as the account is active.
- Subscription information: we retain information about your subscription for the duration of your active subscription. After the subscription has ended, we retain limited information in statistical form, indicating only whether you have previously held a subscription.
- Location information: We do not retain precise location data beyond what is necessary to provide navigation functionality. If you choose to save routes, your navigation history will be stored and remain available to you until you delete it.
- Device information: until a device is linked to an account, or for as long as the account is active.
- App usage information: is processed in aggregated and de-identified form for analytical purposes.
We may retain data for longer where required to comply with legal obligations. After these periods, we either delete your data or anonymise it.
6. Your rights
Under data protection law, you have the right to:
Access: You may request confirmation whether personal data is processed and, if that is the case, access to your personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
Request rectification of inaccurate data: If you identify that any personal data related to you is inadequate, incomplete or incorrect, you are entitled to have the personal data corrected.
Object to certain processing: You may object to the processing of your personal data, which is processed based on legitimate interest, on grounds relating to your particular situation and to processing for direct marketing purposes.
Erasure: You may request that your personal data be erased if it has been processed unlawfully, must be erased due to a legal obligation, is no longer necessary in relation to the purpose for which it was processed, you object to the processing and there are no legitimate reasons for the processing that outweigh your interests or the processing of your personal data is based on your consent and you withdraw your consent.
Restriction of processing: You may request us to restrict the processing of your personal data to only comprise storage of your personal data under certain circumstances such as for example when the processing is unlawful, but you do not want your personal data erased.
Withdrawal of consent: You have the right to at any time withdraw your consent to the processing of personal data to the extent the processing is based on your consent.
Data Portability: You have the right to receive your data in a portable format, which means that you have the right to receive personal data about you in a structured, commonly used and machine-readable format and to transmit it to another company without hindrance from us, if (i) the processing is based on your consent or a contract, and (ii) the processing is carried out by automated means, and (iii) this does not adversely affect the rights and freedoms of others. If technically possible, you also have the right to have your personal data transferred directly from us to another data controller.
7. Existence of automated decision-making
We may perform profiling to provide recommendations and personalised marketing. For example, if you have opted to receive marketing communications, we may use profiling to ensure that such marketing is tailored to your preferences and what we believe you will find interesting. To do so, we will process certain types such as the patterns of your usage of the app and categorise you into a group of individuals with similar preferences and behaviors. Anyone who is categorised in the same type of profile will receive the same type of marketing. This profiling does not produce legal or similarly significant effects.
8. Complaints
If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with a data protection supervisory authority in the EU Member State where you live, work, or where the alleged issue took place.
9. Contact us
If you have any questions about this notice or how we handle your personal data, please contact us using this contact form.