Privacy Policy

§ 1. Controller

1. The controller responsible for processing personal data in connection with BSS PORT WALK is:

2. This Privacy Policy describes the processing of data of users of portwalk.byshipseas.com, the user account and the PORT WALK application.

§ 2. Data we may process

Depending on how the service is used, we may process in particular the following data:

• account data, e.g. first name, email address and user ID,
• authentication data in the form of a secure password hash,
• information about ports purchased and assigned to the account,
• data relating to orders, payments and billing records,
• technical data, e.g. IP address, device type, browser, operating system and error logs,
• data relating to app settings and downloaded offline packages,
• GPS location data only to the extent required for navigation features,
• data voluntarily provided in support messages or complaints.

§ 3. Purposes and legal bases for processing

Account data is processed in order to enter into and perform the contract for the use of BSS PORT WALK, including sign-in, storage of purchased ports and provision of app features.

Order data is processed to handle purchases, record payments, process refunds and complaints, and fulfil tax and accounting obligations.

Technical data and logs may be processed to detect errors, prevent misuse, protect accounts and maintain operation of the service.

Data from messages may be used to answer enquiries, process complaints or resolve technical problems.

§ 4. GPS location

1. Walking and navigation features may access the device location after the relevant permission has been granted in the browser or operating system.

2. Location may be used, among other things, to determine the current position, provide route guidance, detect arrival at points and calculate the remaining distance.

3. Granting GPS access does not automatically mean that movement history is transmitted to the server or stored in the user account. The scope of stored location data will be limited to functions that are actually required for the operation of the application.

4. The user can revoke location permission in the browser or device settings; this may limit navigation features.

§ 5. Offline data and device storage

1. PORT WALK is designed so that selected features can work during sightseeing without a permanent internet connection.

2. For this purpose, the device may locally store, among other things, port data, walk settings, the status of selected points, audio files, map or navigation data and information about downloaded packages.

3. Locally stored data may be kept in browser storage, the app cache or other mechanisms available on the device.

4. Deleting browser data, app storage or the application may remove offline data and require packages to be downloaded again.

§ 6. Payments

1. Payments are processed by an external payment service provider.

2. BSS PORT WALK should not store full card details when payment processing is performed directly by a certified payment service provider.

§ 7. Recipients of data

Data may be shared with companies that support the operation of PORT WALK where this is necessary to provide the service, in particular with:

• hosting and server infrastructure providers,
• payment service providers,
• providers of email and transactional messaging services,
• technical, security and backup service providers,
• accounting or tax service providers where necessary,
• public authorities where there is a legal obligation to disclose data.

§ 8. Data transfers outside the EEA

If a service provider processes data outside the European Economic Area, the transfer will take place only on the basis of the conditions and safeguards required by applicable data protection law.

Details will be added once the final technical and payment service providers have been selected.

§ 9. Retention period

1. Account data is generally stored for as long as the account exists and thereafter for as long as necessary to handle claims and fulfil legal obligations.

2. Transaction and accounting data is stored for the period required by tax and accounting regulations.

3. Technical logs and security data are stored for a period appropriate to their purpose and are then deleted or anonymised.

4. Data stored exclusively locally on the device may remain until it is deleted by the user, app storage is cleared or the data is replaced by an update.

§ 10. User rights

Subject to applicable data protection law, users may in particular have the following rights:

• access to their data,
• rectification of data,
• erasure of data,
• restriction of processing,
• data portability,
• objection to certain processing,
• withdrawal of consent where processing is based on consent,
• lodging a complaint with the competent supervisory authority.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

§ 11. Cookies and similar technologies

1. The website may use cookies and similar mechanisms required for sign-in, sessions, storage of settings, account protection and offline features.

2. Technologies not required to provide the service, e.g. analytics or marketing features, will only be used in accordance with legal requirements and, where required, after consent has been obtained.

3. If analytics services are introduced, the relevant tools and providers will be described in this policy and, where required, in the consent management system.

§ 12. Data security

The controller uses appropriate technical and organisational measures to protect data against unauthorised access, loss, alteration or disclosure.

User passwords should not be stored in plain text. Communication with the website should take place over encrypted HTTPS connections.

§ 13. Children's data

PORT WALK is not designed as a service directed specifically at children. Where the consent of a legal guardian is required under applicable law for use by minors, that consent should be obtained before an account is created or a purchase is made.

§ 14. Changes to this Privacy Policy

This policy may be updated due to changes in features, service providers, data processing or legal requirements.

The date of the current version is stated at the beginning of the document. Material changes may also be communicated to account holders.

§ 15. Privacy contact

Questions and requests relating to personal data may be sent to:

The current version of the Privacy Policy is available at portwalk.byshipseas.com/it/privacy/.