PRIVACY POLICY

PyNav

Last updated: May 26, 2026

1. INTRODUCTION

CL Consulting SASU (hereinafter "we", "our" or "the publisher") places great importance on protecting your personal data.

This Privacy Policy describes how we collect, use, store, and protect your personal information when you use the PyNav mobile application (hereinafter "the Application").

Fundamental principle: The Application is designed to function locally on your network. No navigation data is transmitted to our servers.

2. DATA CONTROLLER IDENTITY

Data Controller:

Company name: CL Consulting SASU
SIRET: 94261399300016
Registered office: 24 rue Jean Paul Pandolfi, 20110 Propriano, France
Email: colin.larrue.pro@gmail.com

3. DATA COLLECTED

3.1 Data We DO NOT Collect

The Application does not collect or transmit to our servers:

❌ Your GPS positions or geographic coordinates
❌ Your navigation routes, tracks, or waypoints
❌ Your NMEA data (speed, heading, depth, wind, etc.)
❌ Your pypilot configuration parameters
❌ Your display preferences or dashboards
❌ Your navigation history
❌ Commands sent to the autopilot
❌ Any personally identifiable information (name, address, phone)

3.2 Technical Data Collected

Local network connection (does NOT leave your boat):

Local IP address of your pypilot server (e.g., 192.168.1.100)
TCP/IP connection port
This data stays strictly on your local WiFi/Bluetooth network and is never transmitted externally

In-app purchase token (Google Play / App Store):

If you purchase the PRO version, Google Play (Android) or the App Store (iOS) generates a unique token to verify your purchase
This token is managed by Google or Apple, not by us
We only have access to confirmation that you purchased the PRO version
No payment information is accessible to the publisher

Crash and error data (optional):

If you agree, the Application can send anonymous error reports via Firebase Crashlytics
These reports contain: error type, device model, Android version, Application version
These reports are completely anonymous and contain no navigation data
You can disable this feature in Application settings

3.3 Required System Permissions

Android permissions: INTERNET (mandatory):

Necessary to connect to your pypilot server via WiFi
No external Internet connection is established except for purchase verification

ACCESS_NETWORK_STATE (mandatory):

Allows detection if network connection is available
Necessary to display error message if WiFi is disconnected

WAKE_LOCK (optional):

Prevents screen from sleeping during use
Useful for keeping Application visible during navigation

BILLING (optional):

Necessary only if you wish to purchase PRO version
Managed entirely by Google Play

iOS permissions: Local Network Access (mandatory):

Necessary to connect to your pypilot server or NMEA gateway on the local WiFi network
No external Internet connection is established except for App Store purchase verification
iOS will prompt you the first time the Application attempts a local network connection

4. PROCESSING PURPOSE

Collected data is used exclusively for:

Application Operation:

Establish TCP/IP connection with your local pypilot server
Display NMEA data received from your navigation equipment
Transmit your commands to pypilot autopilot

Purchase Verification:

Verify that you purchased PRO version via Google Play
Unlock PRO features accordingly

Quality Improvement:

Analyze anonymous crash reports to fix bugs
Improve Application stability and performance

We NEVER use your data for:

❌ Targeted advertising
❌ Resale to third parties
❌ Marketing profiling
❌ Analysis of your movements or navigation habits

5. LEGAL BASIS FOR PROCESSING (GDPR)

Processing of your data is based on:

Contract execution (Art. 6.1.b GDPR):

Provide Application features you requested
Process your PRO version purchase

Legitimate interest (Art. 6.1.f GDPR):

Improve Application security and stability via anonymous crash reports

Consent (Art. 6.1.a GDPR):

Optional activation of Crashlytics
You can withdraw your consent at any time in settings

6. DATA RECIPIENTS

6.1 Data Remaining on Your Device

All your navigation data stays strictly on your device and local network.

6.2 Subprocessors

Google LLC (United States) — Android only:

Google Play: In-app purchase management and license verification
Google is Privacy Shield certified and GDPR compliant

Apple Inc. (United States) — iOS only:

App Store / StoreKit: In-app purchase management and license verification
Apple complies with GDPR requirements for non-EU transfers

6.3 No Other Third Parties

We do not share your data with any other third parties:

No advertising companies
No data brokers
No business partners
No government authorities (except legal obligation)

7. RETENTION PERIOD

Local connection data:

Retained only during Application use
Deleted when Application is closed

Google Play purchase identifier:

Retained while Application is installed
Deleted upon uninstallation

Crashlytics crash reports:

Retained by Google Firebase for maximum 90 days
Then automatically deleted

User preferences:

Stored locally on your device
Deleted upon Application uninstallation

8. TRANSFER OUTSIDE EUROPEAN UNION

Google LLC (Firebase Crashlytics):

Based in United States
Certified under EU Standard Contractual Clauses (SCC)
Complies with GDPR requirements for non-EU transfers

Your navigation data:

NEVER leaves your device or local network
No international transfer

9. DATA SECURITY

We implement appropriate security measures:

Technical security:

Encrypted local WiFi connection (WPA2/WPA3)
No transmission of sensitive data to Internet
Secure local preference storage (Android Keystore)

Organizational security:

Limited access to strictly necessary data
Regular code security review
Regular security updates

Limitations:

Security of your local WiFi network depends on your configuration
Ensure you use strong WiFi password (WPA2 minimum)

10. YOUR RIGHTS (GDPR)

Under GDPR, you have the following rights:

10.1 Right of Access (Art. 15 GDPR)

You can request what personal data we hold about you.

10.2 Right to Rectification (Art. 16 GDPR)

You can request correction of inaccurate data.

10.3 Right to Erasure (Art. 17 GDPR)

You can request deletion of your data:

By uninstalling the Application (deletes all local data)
By contacting us to delete Crashlytics crash reports

10.4 Right to Restriction of Processing (Art. 18 GDPR)

You can request processing limitation in certain cases.

10.5 Right to Data Portability (Art. 20 GDPR)

You can request your data in structured, readable format.

10.6 Right to Object (Art. 21 GDPR)

You can object to processing of your data:

Disable Crashlytics in Application settings

10.7 Right to Withdraw Consent

You can withdraw your consent at any time (e.g., disable Crashlytics).

10.8 Exercising Your Rights

To exercise your rights, contact us:

Email: colin.larrue.pro@gmail.com
Mail: CL Consulting SASU, 24 rue Jean Paul Pandolfi, 20110 Propriano, France

We will respond within maximum 30 days.

11. RIGHT TO COMPLAINT

If you believe your rights are not respected, you can file a complaint with the competent supervisory authority:

CNIL (France):

Website: https://www.cnil.fr
Address: 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
Phone: +33 1 53 73 22 22

12. COOKIES AND TRACKERS

The Application uses NO cookies or advertising trackers. Google Play:

May use cookies to manage in-app purchases
Managed directly by Google, not by publisher

13. USE BY MINORS

The Application is intended for adult users with navigation skills.

If you are under 18:

You must obtain consent from your parents or legal guardians
You must be accompanied by a competent adult in navigation

14. POLICY MODIFICATIONS

We may modify this Privacy Policy to reflect:

Changes in our practices
Legal or regulatory developments
New Application features

Modification notification:

By notification in Application
On Google Play Store / App Store page
"Last updated" date will be modified

Your consent:

Continued use of Application after modification constitutes acceptance
If modifications are substantial, we will request explicit consent

15. CONTACT AND QUESTIONS

For any questions regarding this Privacy Policy or your personal data:

CL Consulting SASU

Data Protection Officer

24 rue Jean Paul Pandolfi

20110 Propriano

France

Email: colin.larrue.pro@gmail.com

16. POLICY SUMMARY (TL;DR)

✅ What we do:

Local connection to your pypilot (WiFi only)
Display YOUR NMEA data on YOUR device
PRO purchase verification via Google Play
Anonymous crash reports (optional, disableable)

❌ What we do NOT:

Collect your GPS positions
Transmit your navigation data to our servers
Sell your data to third parties
Do targeted advertising
Track your movements

🔒 Your navigation data stays ON YOUR BOAT.

Last updated: May 16, 2026 CL Consulting SASU - PyNav Your privacy, our priority