Privacy Policy

1. On-device content

Videos and associated metadata, vessel and survey records, notes, analysis results and reports (“App Content”) are stored in the App’s private storage on your device. Analysis runs on your device using AI models included with the App. App Content is not sent to us or external services for analysis or used for model training.

No account is required. We have no remote access to App Content and provide no cloud synchronisation.

2. In-app purchases (Apple and RevenueCat)

Apple processes App Store payments. We use RevenueCat, Inc. as our purchase service provider to validate purchases, manage access to paid features and analyse purchase activity.

The App and Apple provide RevenueCat with a random app-specific identifier, purchase records and status, and technical information (device type, operating system, app version, connection times and country derived from transactions or IP addresses). This processing may occur without a completed purchase. App Content is not shared with RevenueCat. Payment card details are handled by Apple and its payment providers.

Further information is available in the RevenueCat Privacy Policy and Apple’s App Store Privacy Notice.

3. Email support

For email support, we process the email address, correspondence, attachments and any purchase support identifier you send us. The identifier may be used to locate your purchase record and link it to the support correspondence. Our email service provider handles the correspondence on our behalf. Retention and deletion are described in section 6. Support material is not used for model training.

4. Legal bases for processing

Performance of a contract. Purchase identifiers, transaction information and related support correspondence are processed as necessary to fulfil our contract with you: validating purchases, providing or restoring paid access, and resolving requests concerning that access.

Legitimate interests. Purchase and technical information are processed to protect the purchase service against misuse and assess purchases, renewals and cancellations. General support correspondence is processed to respond to enquiries. These activities are based on our legitimate interests in administering paid features and providing support. Processing must be necessary for those purposes and must not override your interests or fundamental rights and freedoms.

Legal obligations. Relevant purchase and support records are processed to comply with statutory recordkeeping duties, legally binding requests from competent authorities and obligations to respond to data protection requests.

Establishment, exercise or protection of legal rights. Purchase and support records are retained and used only to the extent necessary to establish, pursue or defend a legal claim. Where the GDPR or UK GDPR applies, this processing is based on our legitimate interest in protecting legal rights, subject to the necessity and balancing requirements above.

5. Service providers

We require the providers described in this Policy to use information for the stated purposes and protect it to the standard set out here. Apple handles account and payment information under its own privacy notice.

Purchase and support information may be disclosed where required by law or necessary for legal claims. We do not sell this information or use it for targeted advertising.

Our purchase provider processes information in the United States; our email provider may process support correspondence in other countries. RevenueCat’s Data Processing Addendum describes its processing terms and contractual transfer safeguards.

6. Retention and deletion

Saved App Content and associated archive files can be deleted within the App. Deletion does not affect original videos in Photos or Files, or copies previously exported or shared outside the App. Temporary copies created for import, processing or sharing may remain in the App’s local cache until cleared by the App or the operating system.

Email correspondence and attachments are retained for up to one year after the last message in the exchange. If you request deletion, we delete the correspondence under our control within one month of receiving your request, or sooner where required by law. If retention is required by law or necessary for an ongoing dispute, we retain only the relevant records and explain the reason within the same period.

Purchase records are retained while needed to maintain or restore paid access and, where applicable, for required legal recordkeeping or an ongoing dispute. We delete or anonymise records under our control when these grounds for retention end.

Deleting the App does not remove purchase records held by Apple or our purchase provider. Requests concerning records processed on our behalf can be made under section 7; Apple handles requests about its own records.

7. Privacy requests

We have no remote access to App Content stored on your device. Requests to us concern the purchase and technical information described in section 2 and any support correspondence you send us.

For that information, you may contact apps@kaleoka.com to exercise rights available under applicable data protection law, including access, correction, deletion, restriction, portability and objection. Where processing is based on consent, it may be withdrawn without affecting prior lawful processing. You may also lodge a complaint with the competent data protection authority.

We handle requests without undue delay and within the deadlines required by applicable data protection law.

8. Changes and contact

This Policy may be amended to reflect changes in processing or legal requirements. The revision date appears above. Material changes are notified before taking effect where required by law.

Developer: Furkan Engin.

Contact: apps@kaleoka.com