Nautly Legal Information
Legal Notice (Impressum)
Information according to § 5 DDG
Max Skupch
Friedrich-Stampfer-Str. 7
60437 Frankfurt am Main
Germany
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
Friedrich-Stampfer-Str. 7
60437 Frankfurt am Main
Germany
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. We do not use any analytics, advertising, or third-party tracking, and we do not sell your data. The app makes a single, optional network request — a short anonymous message you may choose to send after you take the real exam.
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. Information about whether you have unlocked the full app, and how many free mock exams you have used, is stored in Apple's iCloud key-value storage so it works across your own Apple devices; this is Apple infrastructure and is not shared with us.
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: 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. No data about you is sent or kept anywhere in this process — no identifier, no device information, nothing that could be linked to you. Our server stores nothing; it only forwards the plain message "a purchase happened" to our internal notification channel, and that message is all that channel ever holds (Art. 6 para. 1 lit. f GDPR — our legitimate interest in knowing about our own sales).
The app: our server (hub.nautly.io)
The server that receives the optional feedback and the anonymous purchase notification is operated for us by Railway (Railway Corp., USA) as a processor. 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 do not use cookies, local storage, device fingerprinting, or analytics of any kind on the website.
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).
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).
Note on data transfer to the USA
Some of our providers (Apple, Railway, Spaceship) 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. 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:
- The right to access, update or delete the information we have on you.
- The right of rectification if information is inaccurate or incomplete.
- The right to object to our processing of your personal data.
- The right of restriction of processing.
- The right to data portability.
- The right to withdraw consent at any time where we relied on your consent.
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). 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).
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.