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Privacy Policy

 


DirectPort Mobile Application
Effective Date: April 18, 2025
FraktionX BV, a Belgian-based technology company ("FraktionX", "we", "us", or "our"), is the controller and operator of the DirectPort Mobile Application ("App"). We are committed to safeguarding the personal data of our users and ensuring the privacy, security, and transparency of our data practices. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use the DirectPort Mobile App.
We understand that your personal and operational data is sensitive and essential to the safe and efficient conduct of maritime operations. As such, we uphold the highest data protection standards in accordance with EU General Data Protection Regulation (GDPR), Apple App Store Review Guidelines, and applicable global privacy regulations.


1. Purpose of This Policy
This Privacy Policy is intended to:

  • Provide transparency about the types of information we collect through the DirectPort Mobile App;

  • Explain how and why this information is processed;

  • Clarify your rights with respect to your personal data;

  • Assure you that your information will be treated securely and lawfully.

By installing and using the DirectPort Mobile App, you acknowledge that you have read, understood, and agreed to the practices described herein.


2. Who We Are
FraktionX BV is a private limited liability company registered in Belgium, with headquarters at:
FraktionX BV
Energielaan 16, 2950 Kapellen, Belgium
Enterprise Number: BE 0799.700.959
Email: privacy@fraktionx.com
We develop and manage DirectPort, a SaaS platform and mobile application supporting maritime logistics, voyage management, and real-time coordination for vessel operators, captains, and port stakeholders.


3. Information We Collect
We collect personal and operational data to provide a secure, efficient, and personalized user experience. The types of data we collect are as follows:


3.1. Personal Information
This includes information that can directly or indirectly identify you:

  • Name – used to personalize your profile and link activities to your user ID

  • Email Address – used for login, notifications, and support

  • Phone Number – used for coordination and verification

  • Company Name and Role – used to contextualize your access and permissions

  • Captain ID or User Reference ID – used to facilitate voyage assignments and identity validation

  • Other Contact Information – such as vessel number, assignment region, or dispatch authority

All personal data is collected and processed in accordance with GDPR Article 6(1)(b) (performance of contract) or Article 6(1)(a) (consent), depending on context.


3.2. Device & Diagnostic Information
To ensure stability, functionality, and support, we may automatically collect:

  • Device type, model, and operating system

  • App version and usage behavior

  • Crash logs and diagnostics

  • Screen navigation patterns

  • IP address and location metadata (if enabled)

  • Authentication tokens or session identifiers

This information is used for app performance monitoring, bug resolution, and service optimization, and may be processed under our legitimate interest in ensuring technical reliability and continuous improvement.
4. How We Use Your Information
Your data will never be used for unsolicited advertising or unauthorized profiling. The main purposes of processing your data are:

  • User authentication and account security

  • Voyage tracking and calendar-based route visualization

  • Logging and timestamping maritime events (arrivals, departures, loading, discharges)

  • Cargo validation, bill of lading management, and document access

  • Offline access to operational and compliance-related documentation

  • Real-time status updates between captains, port staff, and HQ operations

  • Fuel consumption and environmental performance reporting

  • Provision of technical support and customer service

  • System maintenance and diagnostic analytics

Data is processed using secure channels and stored on GDPR-compliant cloud infrastructure.
5. Legal Basis for Processing
We rely on one or more of the following legal bases to process your personal data:

  • Performance of a contract – Providing access to the DirectPort App and related services

  • Legitimate interests – Improving our products, securing our systems, and optimizing operations

  • Compliance with legal obligations – Such as maritime documentation and emissions reporting

  • Consent – Where required, such as enabling optional location services or push notifications

6. Data Sharing and Third-Party Services
FraktionX does not sell, lease, or rent user data. However, we may share limited data under strict conditions with:

  • Cloud infrastructure providers (e.g., Amazon Web Services or equivalent) for hosting and storage

  • Analytics tools (e.g., Firebase, Sentry) to monitor usage and identify issues

  • Operational partners (e.g., port authorities or logistics operators), but only to the extent necessary for supporting voyage activities and only when consent or operational necessity exists

  • Government authorities where required by law, subpoena, or legal proceeding

All third-party vendors are subject to data processing agreements and due diligence reviews.
7. Data Storage and Retention
Personal data is stored only as long as necessary for the purposes outlined in this policy or as required by applicable law, including maritime operational regulations.

  • Voyage logs, cargo records, and environmental data are retained in compliance with EU maritime safety protocols.

  • User profile and session information may be retained for up to 2 years after last activity unless a deletion request is received.

  • Diagnostic data is typically anonymized after 90 days and stored securely.

8. Data Security Measures
We are committed to ensuring that your data is protected against loss, misuse, unauthorized access, alteration, or disclosure. Our security measures include:

  • Encrypted communications (TLS/SSL)

  • Encrypted storage for all sensitive user data

  • Role-based access control and audit logging

  • Biometric access (if enabled by the device)

  • Routine security audits and penetration testing

  • Compliance with ISO/IEC 27001 principles

Despite our efforts, no system can be 100% secure. If a breach affecting your personal data occurs, we will notify you and the competent authorities as required.
9. Your Rights Under GDPR
As a data subject under the GDPR, you have the right to:

  • Access the data we hold about you

  • Rectify incorrect or outdated data

  • Erase your personal data (“right to be forgotten”)

  • Restrict or object to processing under certain conditions

  • Port your data to another provider (data portability)

  • Withdraw consent for processing (where consent was given)

  • Lodge a complaint with a supervisory authority (e.g., Gegevensbeschermingsautoriteit, Belgium)

To exercise your rights, email us at privacy@fraktionx.com with proof of identity and a clear request.
10. Children’s Privacy
The DirectPort Mobile App is not intended for children under the age of 18 and should only be used by professionals involved in maritime or logistics operations. We do not knowingly collect personal data from minors. If we become aware that a child has submitted personal information, we will delete such information without delay.
11. International Data Transfers
Your data may be processed and stored on servers located outside your home country, including in countries outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place, including:

  • The use of Standard Contractual Clauses (SCCs)

  • Hosting with GDPR-compliant cloud providers

  • Regular compliance checks of all cross-border processors

12. Updates to This Policy
We may update this Privacy Policy from time to time. When material changes are made, we will notify users via the app or email. The “Effective Date” at the top of this document will indicate when the latest revision was made.
We encourage users to periodically review this policy to stay informed about how we are protecting their data.
13. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or your data, you may contact:
FraktionX BV – Data Protection Office
Energielaan 16, 2950 Kapellen, Belgium
📧 privacy@fraktionx.com
🌐 www.fraktionx.com

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