DRAFT · pending legal review
Privacy policy
Last updated: 14 October 2026. Courtesy translation; in case of discrepancy, the Spanish version prevails.
1. Data controller
Infinity Dreams Labs LLC (trade name Raftyx), a limited liability company incorporated in the State of Wyoming, USA, with registered address in Sheridan, Wyoming, USA. Privacy contact: hola@raftyx.app.
EU representative (Art. 27 GDPR) and possible establishment in Spain: [LAWYER TO REVIEW: determine whether a representative must be appointed].
2. What data we process, why and on what legal basis
- Waiting list: email, language, consent with date and time, and a pseudonymised identifier derived from your IP (anti-abuse). Purpose: to notify you of the launch. Basis: consent (Art. 6(1)(a) GDPR).
- Contact: name, email, subject and message. Purpose: to handle your enquiry. Basis: pre-contractual steps or legitimate interest (Art. 6(1)(b) and (f)).
- Purchase and billing: email, country and billing details you provide at payment, Stripe customer and subscription identifiers, subscription status and dates. Card data is processed by Stripe and does not pass through our servers. Purpose: to provide the service, collect payment and meet legal obligations. Basis: performance of the contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)).
- Acceptance log: for each acceptance of the Terms we store date and time, the Terms version accepted, plan, your IP address and browser user agent. Purpose: to prove your consent and defend against claims and chargebacks. Basis: legitimate interest (Art. 6(1)(f)).
- Account, vessel and liferaft (when the service is live): account, vessel and liferaft data and service history (date, station, comment). Purpose: to provide the service. Basis: performance of the contract. The liferaft history is kept as an equipment record, without the owner's personal data after cancellation. Legal basis for that retention: legitimate interest in a permanent history [LAWYER TO REVIEW].
- Reminders: email and, in the app, push notifications. Notification services: [PENDING: not yet defined].
- Security: technical server logs and a temporary per-IP submission limit. Basis: legitimate interest in security (Art. 6(1)(f)).
- Aggregated or anonymised data: we may generate statistics and aggregated or anonymised data (for example, to improve the service or offer it by API to authorised third parties) that no longer identify you. Basis: legitimate interest in anonymisation [LAWYER TO REVIEW].
We do not take automated decisions with legal effects on you nor build profiles for advertising. You must be at least 18 to use the service. We do not use tracking cookies (see the cookie policy).
3. Retention periods (proposal under review)
- Account and liferaft records: while the account is active. After cancellation, deletion or anonymisation of personal data within 30 days at most, except what must be kept by law or for defending claims (then blocked and unused).
- Billing and tax data: the applicable legal period [LAWYER / ACCOUNTANT TO REVIEW].
- Acceptance log: for as long as claims or chargebacks may be raised [LAWYER TO REVIEW: set period].
- Waiting list: until you unsubscribe or 24 months from sign-up if there is no activity.
- Server technical logs: 90 days. Sent email and bounces: 12 months.
- Backups: made daily. Backup retention period: [PENDING].
4. Recipients and processors
We do not sell your data. We process it using:
- Hosting and database: servers managed by Infinity Dreams Labs LLC.
- Email: our own mail server, with no external email provider.
- Payments: Stripe, Inc. and its affiliates (stripe.com/privacy), which processes payment data as controller or processor as applicable. International transfers may occur under the safeguards Stripe publishes (e.g. standard contractual clauses) [LAWYER TO REVIEW].
- Push notifications: [PENDING: services not yet defined].
As the responsible entity is established in the USA, processing involves international transfers from the EU; they will rely on appropriate safeguards under Chapter V GDPR [LAWYER TO REVIEW].
5. Your rights
You may exercise the rights of access, rectification, erasure, objection, restriction and portability, and withdraw consent at any time (without affecting prior processing), by writing to hola@raftyx.app. You have the right to lodge a complaint with your data protection authority (in Spain, the Agencia Española de Protección de Datos, www.aepd.es).
6. Security
We apply reasonable technical and organisational measures (encrypted connection, access control, data minimisation, backups). No system is infallible; in case of a breach affecting you, we will inform you as required by law.
7. Changes
We may update this policy; we will publish the new version with its date and, if the change is material, notify you.