This policy explains separately how District Web processes personal data through the reef-buddy.app website and the Reef Buddy mobile application.
Last revised: · Version 1.1
District Web is the data controller for the processing described here. No data protection officer has been appointed. You can contact the privacy team by email or write to the registered office:
District WebWebsite processing covers browsing, optional audience analytics, the Reef Score calculator, and the password-recovery page. App processing covers accounts, aquarium records, Shrimpy requests, subscriptions, product analytics, diagnostics, and feedback. Website analytics choices do not change the separate analytics configuration of the mobile app.
| Processing | Data | Purpose and legal basis | Recipient, location, and transfer | Retention |
|---|---|---|---|---|
| Site delivery and security | IP address, requested URL, date and time, user agent, and security events | Deliver and secure the site; legitimate interests in availability and abuse prevention | Netlify, Inc. — United States; protected by applicable transfer safeguards | Operational access and security logs: no more than 30 days |
| Website analytics (optional) | Page URL and title, referrer, timestamp, browser/device information, approximate network location, and a pseudonymous identifier | Measure audience and improve content; consent | PostHog, Inc. / PostHog EU Cloud — European Union (Frankfurt, Germany) | Analytics events: 12 months; browser cookie: up to 12 months or until withdrawal |
| Cookie preference | Accepted/rejected choice, policy version, and decision timestamp | Remember and demonstrate your choice; legal obligation and legitimate interests | Your browser only; no transfer | Until browser storage is cleared or the consent version changes |
| Reef Score calculation | Aquarium measurements submitted, IP address, and request metadata | Return the calculation you request; steps taken at your request and service security | District Web / Scaleway (Reef Buddy API and database) — European Union | Measurements are not intentionally persisted; technical access logs: no more than 30 days |
| Password recovery | Email address, one-time code hash, attempt count, timestamps, IP address, and the new password in encrypted transit | Restore and secure your account; contract and legitimate security interests | District Web Reef Buddy API, self-hosted Appwrite, and Mailgun Technologies, Inc. (EU endpoint) — European Union; contractual support may involve the United States | Recovery code expires after 30 minutes; recovery and delivery records: no more than 30 days |
| Processing | Data | Purpose and legal basis | Recipient, location, and transfer | Retention |
|---|---|---|---|---|
| Account and aquarium records | Email, account identifier, tanks, equipment, measurements, tags, notes, and related timestamps | Create the account, synchronize devices, and provide app features; contract | District Web (self-hosted Appwrite and PostgreSQL) / Scaleway — European Union | For the account lifetime; erasure requests are completed within 30 days, subject to legal obligations and rolling backups |
| Shrimpy AI | Questions, selected aquarium measurements and context, photos you choose to submit, model responses, and technical metadata | Generate the analysis you request and monitor its quality; contract and legitimate interests | OpenAI, L.L.C. and PostHog EU Cloud (AI telemetry) — United States and European Union (Frankfurt); protected by applicable transfer safeguards | Not intentionally stored in the Reef Buddy database; OpenAI API abuse-monitoring logs: up to 30 days; PostHog AI telemetry: 12 months |
| Subscriptions | App account identifier, Apple transaction and product identifiers, entitlement, and subscription status | Process purchases and manage premium access; contract and accounting obligations | RevenueCat, Inc. — United States; protected by applicable transfer safeguards | Entitlement record for the account lifetime; invoices/accounting records where held: 10 years |
| App analytics and feature flags | Pseudonymous account/device identifier, app version, screens, feature actions, success/failure state, and coarse technical properties. Shrimpy AI telemetry is disclosed separately above | Understand and improve app use; legitimate interests, and consent where required | PostHog, Inc. / PostHog EU Cloud — European Union (Frankfurt, Germany) | Analytics events: 12 months |
| Crash and error diagnostics | Error details, stack traces, app/device version, request context, and pseudonymous identifiers | Diagnose failures and secure the service; legitimate interests | Functional Software, Inc. (Sentry EU region) — European Union (Germany); contractual support may involve the United States | Diagnostic events: 90 days |
| App Store distribution and payments | Apple account and payment data handled by Apple; District Web receives transaction and entitlement status | Distribute the app and complete purchases; contract and legal obligations | Apple Distribution International Ltd. / Apple group companies — European Union and other locations described by Apple | According to Apple’s policy; District Web accounting records where held: 10 years |
| Feedback | Account identifier, feedback text, and timestamps | Respond to feedback and improve the service; legitimate interests | District Web / Scaleway (Reef Buddy API and database) — European Union | Up to 24 months, or earlier on a valid erasure request |
We only give providers the data needed for their role and bind them by applicable data-protection terms. PostHog website and app analytics use the EU service. Sentry uses its EU region and Mailgun uses its EU API endpoint. Where a provider or its support personnel may access data outside the European Economic Area, District Web relies on an adequacy decision where available or appropriate safeguards such as the European Commission’s Standard Contractual Clauses. Provider privacy notices are linked in the tables above.
The website stores one essential local preference containing your analytics choice, consent version, and decision date. PostHog is not downloaded or initialized until you accept. Use “Cookie settings” in the footer at any time to accept, reject, or withdraw consent. Withdrawal stops future website analytics and clears PostHog browser storage; it does not automatically erase events already received, so contact us if you also want to request their deletion.
Subject to the conditions in the GDPR, you may request access, rectification, erasure, restriction, or portability of your data; object to processing based on legitimate interests; and withdraw consent at any time without affecting earlier lawful processing. You may also give instructions concerning your data after death where French law permits.
Email your request to the address below or send it to our registered office. Please identify the account, email address, or browser activity concerned and the right you want to exercise. We may ask for only the additional information reasonably necessary to verify your identity, such as confirmation from the account email address; an identity document will be requested only where there is reasonable doubt. We respond without undue delay and within one month. For a complex or numerous request, this may be extended by two months, and we will explain the extension within the first month.
If you believe your data-protection rights have not been respected, you may lodge a complaint with the French supervisory authority:
Commission nationale de l’informatique et des libertés (CNIL)District Web uses access controls, encrypted transport, secrets management, and monitoring intended to protect personal data. No online service can guarantee absolute security. Please keep your account credentials confidential and contact us if you suspect unauthorized access.
Reef Buddy is not directed to children under 18, and District Web does not knowingly create accounts for them. Contact us if you believe a minor has supplied personal data so we can investigate and take appropriate action.
We may revise this policy when processing or legal requirements change. Material changes will be highlighted on the website or in the app where appropriate. The fixed revision date and version above identify the text that applies; a site deployment alone does not change them.