Neraya
Privacy Policy
Effective date: 2 October 2026
This Policy explains what data the Neraya service (the web application at app.nerayamarine.com and the mobile apps) collects, why, and how you stay in control. The short version: your boat’s memory belongs to you — we store it to make the Service work for you, and you can delete it at any time.
Controller and contact: Neraya Marine team, nerayamarine.com — [email protected].
1. What we collect
| Data | Examples | Why |
|---|---|---|
| Account data | name, e-mail — as provided by your sign-in provider (Google, Apple) or e-mail sign-in | to create and secure your account, bind the boat’s memory to you |
| Boat data | what you and your crew add: facts, documents, logbook entries, photos, measurements, handover acts | to keep your boat’s memory and produce answers, dossiers and documents for you |
| Chat content | your messages and the Service’s replies, including voice transcribed to text | to answer you and to update the boat’s memory when you ask |
| Service data | usage quotas, billing status (plan, renewal date), security logs | to run quotas and subscriptions, protect accounts |
We do not sell your data, and we do not use it for third-party advertising. There are no third-party ad trackers in the Service.
2. AI processing and analytics
Part of the Service is powered by large language models. To generate answers, your messages and relevant fragments of the boat’s memory are sent to our AI processing providers (currently DeepInfra, running the DeepSeek model, and — for search — DeepSeek). Photos you add are processed by the same provider to read their content, and voice notes are transcribed by OpenAI (the Whisper model) before processing. These providers process the content only to produce the answer for you. Before any of this happens, the app asks for your explicit consent (one dialog before your first AI action); you can withdraw it at any time in Settings → Privacy, and AI features stop sending data to these providers the moment you do. Do not paste secrets you do not need the assistant to know — the assistant only needs what concerns the boat.
Product analytics works in two tiers. Tier 1 — anonymous and on by default: screens viewed and product events are processed for us by PostHog (PostHog PBC, EU cloud, Frankfurt, Germany) to understand how the Service is used and to improve it; it never identifies you (no account linkage, no person profiles, no advertising) — and you can switch it off any time in Settings → Privacy, which silences it completely (on the device and on our servers). Tier 2 — optional, off by default: if you opt in, usage events are linked to your account (identified analytics) to improve the product; withdrawing it severs the linkage immediately. Analytics in both tiers contains no message content. We do not record your screen and never have screen recordings.
3. Payments
Subscriptions are billed through Stripe (web) or Apple / Google in-app purchase where offered. Card details go directly to the payment provider; we receive only the billing status of your subscription (plan, period, renewal date). We never see or store your full card number.
4. Where data lives
The boat memory and account data are stored on managed servers in the European Union. Our providers (hosting, AI processing, payments, e-mail delivery) process data on our instructions under data-processing agreements; where data may leave the EEA, the transfers rely on the provider’s safeguards (such as Standard Contractual Clauses).
5. Retention and deletion
- A guest (anonymous) boat’s onboarding memory is kept for a limited grace period (about 3 days of inactivity) unless you create an account. You can also erase it yourself at any time: in the app’s settings, Erase guest data deletes that guest boat and everything it learned immediately and irreversibly.
- With an account, the boat memory is kept while your account exists, so the assistant remembers your boat.
- Deleting your account (settings of the mobile apps and the web app) starts a two-step deletion. First, your account enters a 14-day basket: your sign-in and all sessions stop working immediately, and signing in again with the same account before the deadline restores everything. After the basket runs out, the account and the personal data attached to it are erased for good from our records, and we send a confirmation e-mail when the erasure has completed.
- What the boat learned stays with the boat when it has a crew: memory contributed to a boat that other people still use remains with that boat in anonymized form (the author is shown as “a former member”), the way messages you sent to other people remain part of a shared space — your name, e-mail and identity are removed from it. A boat you alone used is erased together with all its memory when the deletion completes.
- Billing records are kept as long as required by tax and accounting law.
- Analytics data (anonymous usage events, plus identified events if you opted in) is kept by PostHog under its EU retention settings. Withdrawing Tier 2 stops identified collection immediately; the anonymous tier keeps running.
6. Your rights (GDPR and similar)
You can request access, correction, export, deletion of your data, and object to or restrict processing. In the Service you can do most of this yourself (edit the boat memory, delete the account); for anything else, write to [email protected] — we answer within 30 days. You also have the right to complain to your local data-protection authority.
7. Children
The Service is not intended for children under 16; we do not knowingly collect their data.
8. Security
Access to the Service is encrypted in transit (TLS); access to stored data is restricted to the components that need it and protected by row-level access rules. Sign-in goes through the identity providers or hashed passwords; we never store passwords in plain form.
9. Changes
If we change this Policy, we publish the new version on this page with a new effective date and announce material changes in advance in the Service.