Legal

Privacy Policy

Last updated: 2026

Cambusa is committed to protecting your personal data. This policy explains what we collect, why, and how — in clear, plain language.

1

Introduction and Scope

This Privacy Policy applies to the mobile application Cambusa (the "App"), developed and operated by Mare Blu Sailing SNC di Khylko Andriy e Dariia ("Mare Blu", "we", "us", or "our"), with registered office at Sanremo (IM), Via Feraldi 3, CAP 18038, Italy.

P. IVA / VAT No.: 01797970082

Cambusa is designed to assist yacht crews, boat owners, and other users with meal planning, grocery management, and shopping list organization.

This Privacy Policy is compliant with:

  • the EU General Data Protection Regulation (EU) 2016/679 ("GDPR");
  • applicable Italian privacy laws, including Legislative Decree No. 196/2003 as amended.

By using the App, you acknowledge that you have read and understood this Privacy Policy.

2

Data Controller

The data controller responsible for processing personal data under this Privacy Policy is:

Mare Blu Sailing SNC di Khylko Andriy e Dariia

Sanremo (IM), Via Feraldi 3, CAP 18038, Italy

Email: privacy@mareblusailing.it

3

Categories of Data We Collect

We collect and process only the personal data necessary to operate and improve the App.

a) Contact Information

We may process:

  • email address,
  • support communications,
  • feedback messages.

This information is processed only when voluntarily provided by the user, for example when contacting support.

b) Subscription and Transaction Information

If you purchase premium features through an app store, we may receive:

  • subscription status,
  • transaction confirmation,
  • product type,
  • purchase date.

All payments are processed by third-party app store providers (Apple App Store, Google Play, Amazon Appstore, Samsung Galaxy Store). We do not collect or store payment card or banking information.

c) Technical and Diagnostic Information

The App may process limited technical information such as:

  • device model,
  • operating system version,
  • app version,
  • crash reports,
  • diagnostic information.

Used for app stability, debugging, performance improvement, and security monitoring.

d) Usage Analytics

If analytics tools are enabled, the App may process anonymous or aggregated usage information (sessions, features accessed, general statistics) to improve the App. Where required by law, this is based on user consent.

e) User-Generated Content

Meal plans, grocery lists, notes, and provisioning information are stored locally on the user's device only. We do not access, transmit, or store this content on our servers unless a future feature clearly states otherwise.

f) No Special Categories of Data

The App is not intended to collect health data, biometric data, precise geolocation data, or other special categories under GDPR.

4

Purposes of Processing

We process personal data only for legitimate and specific purposes:

a) Providing and Operating the App

To operate and maintain App functionality.

Legal basis: Performance of a contract; legitimate interest in providing the service.

b) Subscription and Purchase Management

To validate subscriptions and premium access purchased through app stores.

Legal basis: Performance of a contract; legitimate interest in service administration.

c) Customer Support

To respond to user inquiries, support requests, and technical issues.

Legal basis: Performance of a contract; legitimate interest in providing support.

d) Analytics and Service Improvement

To improve App functionality, stability, usability, and security.

Legal basis: Legitimate interest; consent where required by law.

e) Legal Compliance

To comply with legal obligations including tax, accounting, consumer protection, and data protection.

Legal basis: Compliance with legal obligations.

f) Security and Fraud Prevention

To protect the App, infrastructure, and users against misuse or unauthorized access.

Legal basis: Legitimate interest in ensuring security and service integrity.

5

Sources of Data

  • Directly from users — information voluntarily provided, including support requests or feedback.
  • Automatically through the App — limited technical and analytics information via device systems or analytics tools.
  • Third-party platforms — limited subscription or transactional confirmations from app store providers for purchase validation.
6

Third-Party Services

The App may use trusted third-party providers for technical operation, analytics, subscription validation, or app distribution:

Apple App StoreGoogle PlayAmazon AppstoreSamsung Galaxy StoreFirebaseAdapty

We do not sell personal data to third parties. Only limited information necessary for operation of the App may be shared with service providers.

7

International Data Transfers

Some third-party providers may process limited technical or analytics data outside the EEA, including in the United States. Where international transfers occur, we rely on Standard Contractual Clauses approved by the European Commission and contractual protections implemented by service providers.

We aim to minimize international transfers and limit processed data to what is necessary. Users may contact us for further information.

8

Data Retention and Storage

a) Local Storage

User-generated content is stored locally on the user's device. Deleting the App generally removes locally stored data. Users are responsible for their own backups unless explicitly provided within the App.

b) Subscription Information

Subscription and purchase records are retained by app store providers according to their own policies and legal obligations.

c) Technical and Analytics Data

Retained only for as long as reasonably necessary for operational, security, debugging, or legal purposes.

9

Automated Decision-Making

The App does not use automated decision-making or profiling that produces legal or similarly significant effects on users.

10

Security Measures

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or disclosure, including:

  • encrypted communications where applicable;
  • limited access to systems and data;
  • use of trusted service providers;
  • monitoring of service integrity and security.

No system can guarantee absolute security; users acknowledge that use of digital services involves inherent risks.

11

Children's Privacy

The App is not intended for children under the age of 14. We do not knowingly collect personal data from children under 14. If we become aware that such data has been collected unlawfully, we will take reasonable steps to delete it.

12

User Rights

Under GDPR and applicable law, users may have the right to:

  • access their personal data;
  • request correction of inaccurate data;
  • request deletion of personal data;
  • restrict processing;
  • object to processing;
  • withdraw consent where processing is based on consent;
  • lodge a complaint with a competent supervisory authority.

Where technically feasible, users may also request portability of personal data. Submit requests to: privacy@mareblusailing.it

13

Supervisory Authority

Users in the EU may lodge complaints with their local supervisory authority. In Italy, the competent authority is the Garante per la protezione dei dati personali.

14

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updated versions will be published within the App or through related distribution channels. If material changes affect how personal data is processed, we may provide additional notice or request consent where required.

15

Contact Information

For questions regarding this Privacy Policy or personal data processing, contact:

Mare Blu Sailing SNC di Khylko Andriy e Dariia

Email: privacy@mareblusailing.it

Contact Person: Andriy Khylko

Questions about your privacy?

We're happy to help. Reach out to our team directly.

privacy@mareblusailing.it