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DRAFT - not yet reviewed. This was written from how the app actually works, but it has not been checked by a solicitor. Highlighted items [[like this]] still need your details. Do not publish until both are done.

Privacy policy

Last updated: [[DATE]]

FleetRight helps boat owners and operators keep maintenance, checks, defects and documents in one place. This policy explains what personal data we hold, why, who helps us handle it, how long we keep it, and what you can do about it. We have tried to keep it plain.

1. Who we are

The service is run by [[COMPANY NAME]], [[company number]], [[registered address]] ("we", "us"). We are registered with the UK Information Commissioner's Office (ICO), registration number [[ICO NUMBER]].

Questions about your data: privacy@fleet-right.co.uk [[create and monitor this inbox]]. Security issues: security@fleet-right.co.uk.

For your own account and sign-in details we are the controller of your data. For the vessel records, files and crew details that you or your company put into FleetRight, you (or your company) decide what goes in, and we handle it on your behalf as a processor. Section 9 explains this for company accounts.

2. What we collect and why

WhatExamplesWhyOur legal basis
Account detailsEmail address; your password (stored only as a one-way hash, never readable); two-factor secret if you turn it on (stored encrypted); when you accepted the termsTo create your account, let you sign in, and keep it secureContract
Vessel and maintenance records you enterBoat name, type, make, model, year, home marina, registration number, engine details and hours; routine tasks, operational checks and their results, defects, maintenance history, spares, refit plans and costs, contractor and supplier names, "assigned to" namesTo provide the service you signed up forContract
Files you uploadInsurance, registration, surveys, manuals, quotes, photosTo store them and show them to you and anyone you give access toContract
Crew accessThe name or label and (optionally) email address you enter when you create a crew access code; the dates it works; checks and defect reports made with the codeTo give crew temporary access and email them their codeContract; legitimate interests of the vessel owner or operator
Company detailsCompany name, members' email addresses and rolesTo run company and fleet featuresContract
BillingYour plan, status, renewal date and a Stripe customer reference. Card details go straight to Stripe and never reach usTo charge for paid plans and keep tax recordsContract; legal obligation
Security and technical dataYour IP address and a log of security events (sign-ins including failed attempts, two-factor use, password and email changes, crew codes created, plan changes, account deletion). Standard server logsTo protect accounts, spot abuse and investigate incidentsLegitimate interests (keeping the service and your data secure)
Emails we send youConfirmation, password reset, security notices, crew access codes, receiptsTo run your accountContract

What we do not do: we do not sell your data, show adverts, use advertising or analytics trackers (the only outside service on any page is the sign-up bot check above), track your location, or send marketing email. If that ever changes we will ask you first.

Some of what you enter may be about other people (for example a contractor's or crew member's name). Please only enter what you have a good reason to hold.

3. Who else handles your data

We use a small number of providers (our "sub-processors"). Each is bound by a data processing agreement and only handles data to provide its service to us.

ProviderWhat forWhere
Fly.ioHosting the app, database and uploaded files, with automatic disk snapshotsLondon, UK
Cloudflare (R2 storage)Encrypted off-site backup copies. We hold the key; they cannot read them[[EU - confirm bucket region]]
Cloudflare (Turnstile)A "are you a real person?" check on the sign-up page, to keep automated sign-ups out. Cloudflare sees your IP address and some browser details when the check runs. It only loads when you open the sign-up form, never for people who just sign inGlobal [[confirm]]
ResendDelivering the emails listed aboveUnited States [[confirm]]
StripeTaking payments and managing subscriptionsUK / EU / United States [[confirm]]
Have I Been Pwned (Troy Hunt)Checking a new password against known breaches. Only the first five characters of a one-way fingerprint of the password are sent, so neither the password nor your email is ever sharedGlobal
Healthchecks.io and an uptime monitorAlerting us if the site goes down or our nightly backup stops. They only receive "still alive" signals and the public health address, never personal dataEU [[confirm]]

We may also disclose data if the law requires it, or to protect people's safety or our legal rights.

4. Transfers outside the UK

Where a provider is outside the UK, we rely on the UK's approved safeguards (an adequacy decision or the ICO's International Data Transfer Addendum) so your data keeps UK-standard protection. [[Confirm against each provider's current agreement]]

5. How long we keep it

DataHow long
Account, vessel records and filesUntil you delete them or your account
Sign-in sessions30 days, then deleted
Crew access codes (including the name and email you entered)Until you revoke them, and automatically deleted 180 days after they expire
Security log12 months
BackupsUp to 30 days. Data you delete can remain in backups for up to that long, then is gone for good
Payment and invoice records6 years, as tax law requires (held by us and Stripe)

6. Your rights

7. How we protect it

Passwords are hashed; two-factor secrets and backups are encrypted; sessions and email links can't be replayed from a copy of the database; connections use HTTPS; accounts are walled off from one another; and we log security events. More detail, including what we are still working on, is on our security page. If we have a breach that puts people at risk, we will tell you and the ICO as the law requires.

8. Cookies

We use two cookies, both strictly necessary to keep you signed in, and nothing else. See the cookie notice.

9. Company accounts and crew

If your boat belongs to a company on FleetRight, the company's owners and operations managers can see and manage the vessels, records and crew codes in their fleet. In that case the company decides what is recorded and who has access, and is responsible for having the right to enter its crew's and contractors' details. We act on the company's instructions for that data. A written data processing agreement for business customers is available on request at privacy@fleet-right.co.uk.

Crew who use an access code do not have an account. They can see and do only what the code allows, for the dates it is valid.

10. Children

FleetRight is for adults who own or operate boats. It is not aimed at anyone under 16 and we do not knowingly collect their data.

11. Changes

If we make a material change we will tell you in the app or by email before it takes effect. The date at the top shows the latest version.