Mobile Application Policy

Mobile Application Policy


INFORMATION NOTICE FOR USERS OF RAYMARINE FLIR CLOUD, RAYMARINE WEB SERVICES AND MOBILE APPLICATIONS

This information notice describes how Raymarine UK Limited, a company of the Teledyne FLIR group of companies, uses your personal data when you use a Raymarine app (Including, for example, Raymarine App and Fishidy) to provide app functionality and enable integration with Raymarine Multifunctional Display (MFD) devices which serve as navigation systems for vessel owners (collectively “ Apps”).

We would like to emphasize that we process your personal data in accordance with applicable data protection laws only. We would like to explain to you below in more detail which personal data we collect in connection with the use of Raymarine Apps and how we use this data in accordance with GDPR (and other similar privacy laws).

1 - Personal Data we collect

Signing up to Raymarine App  (log in information)

When you sign up for Raymarine Service Offerings and create a Raymarine SSO (Single Sign On) account  (including access to Raymarine FLIR Cloud and Chart Manager Cloud) we collect the following personal data from you:

  • E-mail address
  • Name
  • Password
  • Country

Signing up to Fishidy (log in information)

When you sign up for Fishidy Service Offerings and create a Fishidy account we collect the following personal data from you:

  • E-mail address
  • Name
  • Password
  • ZIP Code
  • Platform specific device identifiers (for push notifications and analytics) 

Downloading the Apps

When you download the Apps from a third party app store, all personal data that is necessary to facilitate the download will be transferred to the App store you are downloading the App from. This especially applies to your username, email address, account number, time of download, payment information and unique device number.

Raymarine  does not have any influence on this collection of data by the third party app store and we are not responsible for it. We solely process this data to the extent necessary to download the App onto your device. We do not otherwise store or use this data.

Using the Apps

When you are using the Apps we process the following information (which includes some personal data) which has been provided or uploaded by you (including Your Content), in order to make the App’s functionalities available to you:

RAYMARINE APP

  • Name
  • E-mail address
  • Password
  • Boat name
  • Payment data (processed by third party providers such as Google or Apple when purchasing subscriptions)
  • Photo gallery (if enabled) 
  • Phone camera (if enabled) 
  • Device Serial number for screen mirroring and file transfer
  • GPS-coordinates (for location-based services such as geofencing, if enabled)
  • Telephone number (for SMS notifications, if enabled)
  • Platform specific device identifiers (for push notification delivery, if enabled):
    • Android: Hardware ID (HWID) & Firebase registration token
    • Apple: Identifier for Vendors (IDVE) and Apple Push notification Service (APNs) token

FISHIDY APP

  • Name
  • E-mail address
  • Password
  • Device Serial number (e.g. MFDs)
  • GPS-coordinates (for location-based services including fishing spots)
  • Photo gallery (if enabled) 
  • Phone camera (if enabled) 
  • Content you provide or share (User generated content), including images, location markers, catches,  comments and other content you choose to share with other users  ;
  • Platform specific device identifiers for push notification delivery (if enabled):
    • Android: Hardware ID (HWID) & Firebase registration token
    • Apple: Identifier for Vendors (IDVE) and Apple Push notification Service (APNs) token

WI-FISH APP

  • (no data collection from user’s device, cloud integration or login).
  • Device serial numbers 
  • GPS co-ordinates 

2 - Purposes we process personal data for

We process this personal data for the following purposes:

  • To fulfill the delivery of the Raymarine Service Offerings / App functionalities to you;
  • To provide services you have requested, and respond to any comments or complaints you may send us;
  • We monitor use of our products and services, and may use your information to help us monitor, improve and protect our products, content, services and websites;
  • To send you marketing communications regarding similar Service Offerings ;
  • To comply with applicable laws and protection of our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially general trade compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).

3 - Legal basis for the processing of personal data

Your personal data is processed based on the following legal basis:

  • Art. 6 para 1 (b) GDPR to provide the Service Offerings you have requested, to establish and fulfill the contract for the provision of the Ignite Services, to communicate about the Services, or to respond to queries.
  • Art. 6 para 1 (f) GDPR to enable our business and pursue our legitimate interests, we particularly process it for research and analytics to improve and further develop service offerings, including but not limited to the Service Offerings, for marketing communication regarding similar Service Offerings.
  • Art. 6 para 1 (c) GDPR Art. 6 para 1 (c) GDPR to comply with applicable laws (such as record keeping obligations), export control and customs, compliance screening obligations (e.g. to prevent white-collar or money laundering crimes), and to protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially regulatory or investigative purposes (including disclosure of such information in connection with a legal process or litigation).

4 - Sharing personal data

Raymarine does not rent or share your Personal Information unnecessarily, or without a clearly defined purpose, and not without ensuring all the necessary protections are in place, to ensure Raymarine meets all its legal obligations around the storage, transmission and processing of Personal Information, as set out by all relevant legislations within the markets that Raymarine operates. When we share your Personal Information, we do not allow any third-party partners to use it for their own marketing purposes. When we do share your Personal Information, you can be assured that it will only be shared with third-party recipients who will protect your Personal Information as closely as Raymarine does.

We may share your personal data for the abovementioned purposes with the following third parties:

Affiliates: We may share your Personal Information with relevant Affiliates of Raymarine so that they may assist you locally with the sale of one of our products, service, support, training, or other tasks that need local representation, or if sharing the data is necessary to making available the Raymarine Site or Raymarine FLIR Cloud Services to you.  We are also a global enterprise comprised of a group of companies operating internationally. This entails that business functions handling Personal Information to achieve the purposes defined in this Privacy Policy are managed centrally or only by some Affiliates.

Raymarine’s internal access permissions are strictly controlled, and so Raymarine also does not allow access to your Personal Information by Raymarine employees, unless the employee requires access to fulfil their role and responsibilities. All companies in the Teledyne FLIR group are bound, as required by law, to ensure that Personal Information is protected consistent with EU standards as explained in section 7 “Transfer of personal data” below.

Service Providers: Personal data may be shared with third party service providers, who will process it for the purposes above. Such third parties include, but are not limited to, IT service providers, Cloud Storage service providers, Cloud service providers, providers of data analytics, training providers, survey service providers, investigators, auditors and data hosting providers.

Government Authorities / Law Enforcement Officials: Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

5 - Transferring personal data

We are committed to maintaining the security of data, including personal data, and we have comprehensive corporate policies regarding information security. We will protect personal data, regardless of whether it is inside or outside the EU and regardless of whether it is processed by us or by third party service providers on our behalf. 

Where information is transferred out of the European Economic Area (E.E.A.) or the U.K., and where this is to an affiliate of ours or to a third party in a country that is not subject to an adequacy decision by the E.U. Commission or the competent U.K. authority (as applicable), data is in all cases adequately protected under appropriate safeguards such as E.U. Commission or the competent U.K. authority (as applicable) approved standard contractual clauses, a valid and up to date  Privacy Shield certification or a vendor's Processor Binding Corporate Rules. If You or a concerned individual has any questions about the appropriate safeguards we have in place, please reach out to us at any time. The contact information is available in Section 7.

6 - Your rights

You may be entitled to ask us for a copy of your personal data, to correct it, erase or restrict its processing, or to ask us to transfer some of this personal data to other organizations. You may also have rights to object to some processing activities, such as the profiling we may perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Participating in the pre-release testing and providing feedback and receiving recommendations is entirely voluntary. However, if you whish to participate in the testing , it is mandatory for you to provide certain information to allow us to conduct a useful test in regard to its purpose (collecting user experience based on user profiles) or so that we can  comply with legal or contractual obligations: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us.  In all other cases, provision of requested personal data is optional.

7 - Contact options

For any questions or concerns relating to this information notice, or our data protection practices, please contact us at: Raymarine UK Limited, Marine House, Cartwright Dr, Fareham PO15 5RJ, UK;

E-Mail: [email protected]

8 - Data retention and deletion

We will keep your personal data for as long as necessary to provide the Service Offerings you have requested (ie as long as you are an active user or for 5 years if you are a nonactive user). All images and data you have uploaded will be deleted upon account suppression request. Afterwards, we may retain data for an appropriate period to protect ourselves from legal claims, to administer our business, , or to the extent permitted by applicable law, which may require us to hold your personal data for specific periods. We will delete your personal data, when you object to the processing in accordance with “What rights to you have in relation to your data” (see Section 6) or when we are obliged to delete it in accordance with an obligation under applicable law. If you or a concerned individual wish to have receive detailed information on our Retention and Deletion Policy and the applicable retention periods, please reach out to us at any time. The contact information is available in Section 7.

9 - Changes to this information notice

This information notice may, from time to time, change. Such amendments might become necessary due to the need to keep the information notice up to date, given changes in our business practice or in response to legislative changes, and whether they are international or national changes, and may be made without prior notice.

If there are any significant changes made to the use of your personal data, which differs from that which was stated at the time your personal data was collected, then we will notify you by e-mail to the e-mail address you have registered.

10 - Cookies

We use cookies within our Apps. Cookies are small text files sent by a web server to the App and saved locally on your device. The cookie allows the server to uniquely identify the App. Cookies do not cause any harm to your device and do not contain viruses.

We use the following categories of cookies on our App:

Category 1: Strictly Necessary Cookies - These cookies are essential in order to enable you to browse our website, move around the App and use its key features. Without these cookies, services you have asked for such as remembering your login details or data provided, cannot be provided.

Category 2: Analytics (or Performance) Cookies - These cookies collect information on how people use our Apps and websites. For example, we use Google Analytics cookies to help us understand how users arrive at our site, browse or use our site (i.e. pages visited, links clicked on) and highlight areas where we can improve areas such as navigation, App experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established (because the data is usually aggregated and anonymized).

Category 3: Preference (or Functionality) Cookies - These cookies allow you to remember choices you make such as the country you visit our App from, language and search parameters, to provide a more personalized service.

11 - Data Analytics

Our Apps use analytics data logs provided by third party analytics providers such as Google and Mixpanel which are used for the purpose of evaluating your use of our web App and mobile App, compiling reports on App activity and related application activities. The information generated by the cookies and other types of small text files about your use of the App is usually transmitted to and stored by the third-party data analytics providers on servers in the United States. Such transfers are covered by data processing agreements (including Standard Contractual Clauses) that we have concluded with these providers.

In particular, our Apps uses Google Analytics, Google Analytics for Firebase and Mixpanel Analytics to collect and process information about how the app is used by our users. This information may include, but is not limited to, data about user demographics, device information, browser and operating system used, app usage, and interactions with the App's features. To protect user privacy, we pseudonymize any personal information collected in compliance with applicable data protection laws. We use secure and strong pseudonymization techniques to ensure that the pseudonymous data cannot be linked back to the original user. By using our Apps, you consent to the collection, pseudonymization, and processing of this data by Google Analytics for Firebase and Mixpanel Analytics in accordance with their respective privacy policies. Google Analytics for Firebase and Mixpanel Analytics may use mobile identifiers or other similar technologies to collect this data. You may adjust your device settings to limit data collection by Google Analytics for Firebase and Mixpanel Analytics.