1. Who is responsible for the processing of your data?

The data controller is:

2. What personal data do we collect?

When you use YachtSpend, we collect and store only the data you choose to enter or capture, such as:

User data:

• Email
• Name(s) and Surname(s)
• Document ID (optional).
• Phone number (optional).

Expense control record data:

• Purchase ticket image (if using the image-based information capture tool).
• Purchase address (if applicable).
• Amount of expense (ticket).
• List of purchased items (if applicable).
• Name of the establishment or supplier (if applicable).
• Details of the company that owns the yacht (if applicable).
• Details of the company that hires the charter service (if applicable).

NOTE: We do not collect sensitive data or biometric data.

3. What do we use your data for?

YachtSpend does not use, process, or share your personal data with third parties. Our sole objective is:

• Store your data securely.
• Structure them in a visual and practical format (PDF).
• Make them available to you so that you can manage them as you wish.

4. What is the legal basis for the processing?

The legal basis for processing your personal data is your explicit consent, given when you registered and used our App.

5. Who can access, modify, or delete the data?

You, as a registered user, can:

• Access all your information.
• Edit or delete at any time.
• Download reports in PDF format with associated data via tickets.
• Request the complete deletion of your account and data.

As a platform administrator, YachtSpend can:

• View your account details.
• Suspend access to your account in case of misuse or any other justified reason.
• Perform password resets (which arrives to your email as a notification).
• View records associated with your account (tickets, uploaded images, reports).
• Reporting errors generated in the App during use. The data we collect is:
• Operating System: Build Code, Kernel Version, OS Name, Version.
• Device data: build code, model, processor architecture and model, RAM size, number of processor cores, date and time of the event.
• Data of the error generated in the App.
• Location data: country and time zone.

You don't need to contact us to exercise these rights; you can do so directly from your profile in the App.

6. How long do we keep your data?

We retain your data only as long as you maintain an active account. If you decide to delete your account, all your personal data will be automatically and irreversibly deleted from our servers within 30 calendar days from the date you request account deletion.

7. Where is your data stored?

Your data is stored on servers located in the European Union, operated by DigitalOcean, which complies with security guarantees and current data protection regulations.

8. Do we share your data with third parties?

No. YachtSpend does not sell, trade, or transfer your personal data to third parties, either within or outside the European Economic Area.

9. What rights do you have as a user?

In accordance with Regulation (EU) 2016/679 (GDPR), you have the following rights:

• Access to your personal data.
• Correction of inaccurate data.
• Data portability.
• Limitation of treatment.
• Opposition to processing.
• Withdrawal of consent at any time.

You can exercise these rights directly from the App or by writing to us at [email protected].

10. International data transfers

Although we are a US-based company, we do not engage in international data transfers, as all data is stored in the European Union. Should a transfer occur in the future, we ensure GDPR compliance through contractual clauses, standards, or equivalent mechanisms.

11. Information security

We implement appropriate technical and organizational measures to protect personal data against loss, unauthorized access, alteration, or destruction. We use encryption, restricted access, and other standard security practices for data protection.

12. Changes to this privacy policy

YachtSpend may update this Privacy Policy to reflect changes in the law or our services. We will send an email to your account address and post a notification in the App in the event of significant changes. We will also update the effective date of any changes directly on this page.

13. How to contact us?

If you have any questions about this policy or would like to exercise any of your rights, please write to us at: [email protected]