Nautly Legal Information

Legal Notice (Impressum)

Information according to § 5 DDG
Max Skupch
c/o POSTFLEX PFX-620-839
Emsdettener Straße 10
48268 Greven
Germany
Please do not send parcels or packages to this address.

Contact
Phone: +49 151 51957591
E-Mail: contact@nautly.io

VAT ID
Sales tax identification number according to § 27 a of the Sales Tax Law (Umsatzsteuergesetz): DE352406028

EU Dispute Resolution
The European Commission provides a platform for online dispute resolution (ODR): https://ec.europa.eu/consumers/odr/. You can find our e-mail address above in the Legal Notice.

Consumer Dispute Resolution / Universal Arbitration Board
We are not willing or obliged to participate in dispute resolution proceedings before a consumer arbitration board.

Responsible for content according to § 18 Abs. 2 MStV (German State Media Treaty)
Max Skupch
c/o POSTFLEX PFX-620-839
Emsdettener Straße 10
48268 Greven
Germany
Please do not send parcels or packages to this address.

Privacy Policy

This Privacy Policy covers both the Nautly iOS app and the nautly.io website. The controller responsible for data processing is Max Skupch (contact details in the Legal Notice above).

The short version: the Nautly app has no accounts and no login. Your study data stays on your device. There is no advertising, no advertising identifier, and no tracking across other apps or websites; we never sell your data or share it with advertisers or data brokers. The app does measure how it is used, but only with your consent — you are asked once, nothing is pre-selected, and you can change your answer at any time in the app's settings. Apart from that, the app contacts our server to keep its lesson content up to date, to report a failed content update, to tell us anonymously that a sale happened, and to send the exam feedback you choose to submit. Each of these is described below.

The app: data stored only on your device

When you use the app, the information needed to make it work — your progress through the lessons, your practice scores, your mock-exam history and your settings — is stored locally on your device and is not sent to us. It is removed when you delete the app. Two small technical values are kept in Apple's iCloud key-value storage so that they work across your own Apple devices: how many free mock exams you have used, and which of your purchases we have already counted (so that one sale is not counted twice). This is Apple infrastructure and is not shared with us. Whether you have unlocked the full app is not stored there — it is read from the App Store itself. Your answer to the analytics question described below is stored only on the device where you gave it, and is deliberately not synchronised to your other devices, because consent is given for a particular device.

The app: optional post-exam feedback

After you sit the official exam, the app offers a voluntary "I took my exam" form. Only if you choose to submit it, the app sends the following to our server (hub.nautly.io): whether you passed or failed; an optional rating (0–10); optional free text describing what the examiner asked you; an optional note; the app version; your in-app learning progress at the time of submission (three percentage values for the Learn, Train and Test areas); and a pseudonymous per-install identifier (a random ID generated on your device — not your name, e-mail, phone number, Apple ID, or advertising identifier).

We use this solely to understand how well the app prepares people and to improve the content (Art. 6 para. 1 lit. a GDPR — your consent, given by choosing to submit; you can withhold it simply by not submitting). It is not linked to any account or real-world identity. Please do not include personal information in the free-text fields.

The app: feedback and problem reports

The app has a voluntary feedback form: from Account you can report a problem, suggest a feature or send general feedback, and every lesson and question carries a link to report a problem with that specific piece of content. The form is a web page served by our server (hub.nautly.io) and opens inside the app.

Only if you choose to send it, the following reaches our server: the message you write; the type of report; where relevant, the identifier of the lesson or question you were on; and, optionally, your e-mail address — asked for only if you tick "reply to me", and used only to answer you. The app also prefills a few pieces of context — the app version, the content version, your device model and iOS version, your language, and your in-app learning progress (three percentage values) — each shown as a removable chip, so you can take any of them off before sending. The report carries no per-install identifier; it is stored under a random ID generated for that one report.

We use this to fix mistakes in the content, to fix faults in the app and to decide what to build next (Art. 6 para. 1 lit. a GDPR — your consent, given by choosing to send; withhold it simply by not sending). Please do not include personal information in the message unless you want us to have it.

The app: purchases

The one-time purchase to unlock the full app is processed by Apple through the App Store using StoreKit. We receive confirmation from Apple that a purchase or refund occurred (so the app can unlock), but we do not receive your name, card number, or billing details — those are handled under Apple's Privacy Policy (https://www.apple.com/legal/privacy/).

When a purchase completes, the app additionally sends a single anonymous notification to our server (hub.nautly.io) so we know a sale has happened. It contains the price and currency Apple charged and nothing else. Nothing identifying you is sent — no name, no e-mail address, no device or installation identifier, and nothing that could be linked to you or to anything else you do in the app. Our server keeps a record of the sale so that we can count our own sales, and sends a short notification to our internal business channel. That record says that a purchase happened, when, and for how much — it contains nothing about the buyer, so it cannot be traced back to you (Art. 6 para. 1 lit. f GDPR — our legitimate interest in knowing about our own sales).

The app: keeping the lesson content up to date

So that corrections to lessons and questions can reach you without waiting for an App Store update, the app periodically asks our server (hub.nautly.io) whether newer content is available and downloads it if so. Every version of the app also ships with a complete copy of the content, so it works fully offline and before any request is made.

These requests carry no information about you — no identifier, no account, nothing about your progress or your answers. They ask for a file and receive it. As with any request to any server, your IP address necessarily reaches the server so that the reply can find its way back, and may appear briefly in the server logs described below (Art. 6 para. 1 lit. f GDPR — our legitimate interest in providing and securing the service).

If a content update fails — the download breaks, the server answers with an error, or the downloaded content does not pass the app's own checks — the app sends us a short error report, so that we find out something is broken rather than leaving you with content that never improves. It contains: the type of error and how serious it is, the app version and build, the content version involved, an optional short technical detail, and a pseudonymous per-install identifier (the same random ID described above — not your name, e-mail, phone number, Apple ID, or advertising identifier). The identifier is there so that one device failing repeatedly is recorded as a single problem rather than hundreds of separate ones; without it we could not tell one broken installation from a widespread outage. Nothing about your study data, your answers or your progress is included. Legal basis: Art. 6 para. 1 lit. f GDPR (our legitimate interest in noticing and fixing faults in the app). We keep these reports only for as long as they are useful for diagnosing the fault.

The app: analytics — only if you turn them on

The app can measure how it is used, so that we can see which parts help people pass and which do not. You are asked once, during the app's introduction, with nothing pre-selected, and you can change your answer at any time under Settings → Advanced. Our analytics provider is Mixpanel (Mixpanel, Inc., USA), acting as our processor on its European infrastructure (api-eu.mixpanel.com), where the data is held.

If you say yes. Events describing how you use the app are sent to Mixpanel: which screens and features you open, how far you get through lessons, how practice sessions and mock exams go, which lesson or question was involved, and whether you started, completed or cancelled a purchase or a restore. With each event we send a pseudonymous per-install identifier — the same random ID described above — together with your app version and ordinary technical details about the device (model, operating-system version, language, screen size), and the fact that you consented. Your IP address reaches Mixpanel with the request, as it does with any network request, and is used to derive an approximate location no more precise than a region; we do not store your IP address. Mixpanel's software keeps that random ID on your device, so that repeated visits are counted as one user rather than many. Legal basis: Art. 6 para. 1 lit. a GDPR and Sec. 25 para. 1 TDDDG — your consent, given by choosing yes.

We never send text you have typed — not your name, not an e-mail address, and nothing you write in the exam-feedback form. Figures that might be revealing on their own are grouped into ranges before they are sent (a length of time becomes "under a minute" rather than an exact value, for example).

If you say no, or do not answer. The app still counts how it is used, but in a way that cannot be connected to you or to any earlier session: nothing is written to your device at all, the identifier sent with each event is a random number created afresh every time you start the app and discarded when you close it, and we instruct Mixpanel to discard your IP address, so no location is derived from it. Because nothing is stored on or read from your device, this needs no consent under Sec. 25 para. 2 TDDDG, and the resulting counts are not personal data. Legal basis for the processing itself: Art. 6 para. 1 lit. f GDPR (our legitimate interest in knowing how many people use which parts of the app).

Withdrawing your consent. Turning the setting off stops the analytics software, deletes the identifier it had stored on your device, and falls back to the anonymous counting described above. It takes effect immediately, and nothing in the app stops working.

Never for advertising. This data is used to improve the app and for nothing else. It is not used for advertising, not combined with data from other apps or websites, not sold, and not passed to data brokers. There is no advertising identifier (IDFA) and no App Tracking Transparency prompt, because we do not track you in the sense that Apple's rules use the word.

The app: our server (hub.nautly.io)

The server that delivers the lesson content and receives the optional feedback, the anonymous purchase notification and the content error reports is operated for us by Railway (Railway Corp., USA) as a processor, and runs on Railway's European infrastructure in Amsterdam, where the data is stored. As with any server, standard technical access data (such as an IP address) may appear briefly in server logs for security and reliability (Art. 6 para. 1 lit. f GDPR — our legitimate interest in a secure service). We do not merge this with other data.

The website (nautly.io)

The nautly.io website is a static informational site. We use no cookies and no third-party tracking, and we do not sell or share data with advertisers. We do run our own visitor statistics using Umami, an open-source analytics tool running on our own instance, hosted for us by Railway in the EU (Amsterdam) — the data stays on infrastructure we control, inside the EU, and is never sent to a third-party analytics company. It sets no cookies and writes nothing to your device, which is why this site needs no cookie banner. For each page view it records: the page address and title, the site you came from, your browser's language setting, your screen size, and the browser, operating system and device type. Your IP address reaches our server with the request, as it does on any website, and is used to work out which country you are in; the statistics themselves record the country, not your address. We do not build a profile of you and do not follow you across other websites, and you can switch the measurement off for yourself at any time by setting the value umami.disabled to 1 in your browser's local storage for this site (Art. 6 para. 1 lit. f GDPR — our legitimate interest in understanding which of our pages are useful). The site does store two small technical values in your browser: your language choice, so you are not asked again on every page, and, only if you use the Android interest form described below or open the launch-offer box, a random session identifier and a note of that choice. All of these are strictly necessary for a function you asked for, neither is used to recognise or track you, and the session identifier is deleted as soon as you close the browser tab (Sec. 25 para. 2 no. 2 TDDDG).

Hosting. The website is hosted by an external service provider (hoster). Personal data that may arise when you visit the site can be processed on the hoster's servers — in particular IP addresses and technical access data in server log files. The hoster is used in the interest of a secure, fast, and efficient provision of our online offer (Art. 6 para. 1 lit. f GDPR).

Spaceship
Provider is Spaceship, Inc., 4600 East Washington Street, Suite 300, Phoenix, AZ 85034, USA (hereinafter Spaceship). Details can be found in the privacy policy of Spaceship: https://www.spaceship.com/legal/privacy-policy/.

Server log files

The hoster of the website automatically collects and stores information in so-called server log files, which your browser automatically transmits when you access the site. These may include: browser type and version, operating system used, referrer URL, host name of the accessing computer, time of the server request, and IP address. We do not merge this data with other data sources. The collection is based on Art. 6 para. 1 lit. f GDPR (legitimate interest in the technically error-free presentation and optimization of the website).

Launch notification sign-up (nautly.io)

The website offers an optional form to be notified when the app launches. Submitting it is voluntary and it works only if you enter an e-mail address. If you choose to submit it, we process the e-mail address you enter — together with the date you submitted it — for the sole purpose of sending you a notification when Nautly becomes available, and closely related launch updates. (The form also contains a hidden anti-spam field, which is not personal data.)

Your address is transmitted to and stored on our server (hub.nautly.io, operated for us by Railway — see above). We do not share it with advertisers or other third parties and do not use it for any purpose other than the launch notification. Legal basis: Art. 6 para. 1 lit. a GDPR (your consent, given by submitting the form). You can withdraw your consent and ask us to delete your address at any time by e-mailing contact@nautly.io; we also delete it once the launch notification has been sent and it is no longer needed.

Android interest form (nautly.io)

The website offers an optional form to tell us you would like an Android version. Pressing the button and choosing a price answer is anonymous: we record only the answer itself and which language version of the page you were on. No name, no e-mail, no IP address and no device identifier is stored with it, so this part is not personal data. To link the steps of the form while you fill it in, your browser holds a random session identifier that is discarded when you close the tab (see above).

The form's last step optionally asks for an e-mail address. That step is voluntary and can be skipped. If you do enter one, we store it — together with the date — for the sole purpose of sending you at most two messages: one if we decide to build an Android version, and one when it is ready. We do not share it with advertisers or other third parties and use it for nothing else. Legal basis: Art. 6 para. 1 lit. a GDPR (your consent, given by entering the address and submitting it). You can withdraw your consent and ask us to delete the address at any time by e-mailing contact@nautly.io. (The form also contains a hidden anti-spam field, which is not personal data.)

Your answers are transmitted to and stored on our server (hub.nautly.io, operated for us by Railway — see above).

Contact by e-mail

If you contact us by e-mail, your inquiry including all personal data resulting from it (e.g. e-mail address, content of your message) will be processed by us for the purpose of answering your request. We will not pass on this data without your consent. The processing is based on Art. 6 para. 1 lit. f GDPR (our legitimate interest in the effective processing of inquiries) or, where applicable, Art. 6 para. 1 lit. b GDPR. Please note that e-mails to us are business correspondence and are subject to statutory retention obligations under German commercial and tax law (Sec. 257 German Commercial Code (HGB), Sec. 147 German Fiscal Code (AO)). We retain e-mail correspondence uniformly for ten years — the longest of these statutory periods — and delete it after that. Legal basis: Art. 6 para. 1 lit. c GDPR and, insofar as retention goes beyond an individual statutory obligation, Art. 6 para. 1 lit. f GDPR (our legitimate interest in a uniform retention practice and in establishing and defending legal claims).

How long we keep things

We do not keep personal data for longer than the purpose it was collected for requires. In practice:

Note on data transfer to the USA

Some of our providers (Apple, Railway, Spaceship, Mixpanel) are based in the USA, so personal data (e.g. an IP address in server log files) may be transferred to and processed in the USA. Mixpanel processes our analytics data on European infrastructure, but as a US company it may nonetheless be subject to US law. No level of data protection comparable to that of the EU can be guaranteed there; US companies may be obliged to surrender personal data to authorities. Where required, such transfers are based on appropriate safeguards such as the EU Standard Contractual Clauses.

Your data protection rights (GDPR)

Under the General Data Protection Regulation (GDPR), if you are a resident of the European Economic Area (EEA), you have the following rights:

Because the app uses no account and only a pseudonymous per-install identifier, we usually cannot identify you from a submission; for most requests the fastest remedy is to delete the app (which removes on-device data). If you consented to analytics, you can withdraw that consent at any time under Settings → Advanced in the app, which also deletes the identifier stored on your device. You also have the right to lodge a complaint with a Data Protection Authority in the EEA (in Germany, the competent authority for the controller).

We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. The app does adapt what it shows you to how you are doing — which questions come back, and how often — but that happens on your device, from data that never leaves it.

Terms

By downloading or using the Nautly app you agree to these Terms. If you do not agree, please do not use the app.

What Nautly is — and is not

Nautly is an independent study aid to help you prepare for the Croatian Voditelj brodice kategorije B ("Skipper B") recreational boat-licence exam. Nautly is not affiliated with, endorsed by, or connected to any government body, ministry, Lučka kapetanija (harbour master's office), or official examining authority. It does not issue, register, or grant any licence, and it is not a substitute for the official exam, fees, documents, or in-person application. Using Nautly does not guarantee that you will pass. The official syllabus and the examining authority are the definitive source; where anything in the app differs from official rules, the official rules govern.

Content accuracy

We work hard to keep the study content correct and current, but it is provided for general study purposes only and may contain errors, omissions, or out-of-date information as rules change. Do not rely on it as legal, safety, or navigational advice. Always confirm safety-critical and regulatory information against current official sources before acting on the water. You use the content at your own risk.

Your licence to use the app

We grant you a personal, limited, non-exclusive, non-transferable, revocable licence to use the app for your own personal, non-commercial exam preparation, in line with these Terms and the applicable App Store rules. You may not copy, reproduce, scrape, resell, sublicense, or redistribute the app's content (lessons, questions, images); use it to build or train a competing product or dataset; or reverse-engineer the app except as permitted by law.

Purchases, free tier, and refunds

Part of the app is free to try; the full content is unlocked with a one-time purchase (no subscription). All purchases are made through Apple's App Store and are subject to Apple's terms; prices are shown before you buy. Refunds are handled by Apple — we do not process payments and cannot issue App Store refunds directly. Your statutory consumer rights remain unaffected.

Intellectual property

The app and its content are owned by Nautly (Max Skupch) or our licensors and are protected by law. These Terms do not transfer any ownership to you.

Disclaimer and liability

To the fullest extent permitted by law, the app is provided "as is" and "as available", without warranties of any kind (including fitness for a particular purpose, accuracy, or that you will pass any exam), and we are not liable for indirect, incidental, or consequential damages, or for loss arising from reliance on the content. Nothing in these Terms limits liability that cannot be limited by law (such as for death or personal injury caused by negligence, or for intent and gross negligence), and your mandatory statutory consumer rights remain.

Apple App Store terms

The app is licensed, not sold, and its use is also subject to Apple's Licensed Application End User License Agreement (LEULA); if these Terms conflict with the LEULA, the LEULA governs for App Store matters. These Terms are between you and Nautly (Max Skupch), not Apple; Apple has no obligation to provide support or maintenance for the app; and Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce them.

Governing law

These Terms are governed by the law of the Federal Republic of Germany, excluding its conflict-of-law rules and the UN Convention on Contracts for the International Sale of Goods, and without prejudice to the mandatory consumer-protection rights you have in your country of residence.

Changes and contact

We may update these Terms and this Privacy Policy; the current version is the one published here. Questions: contact@nautly.io.