1. Parties
The customer is the controller for personal data that it enters into Boordapp or has users enter. Valinta Shipping vof, trading under the trade name Boordapp, is the processor for that customer data.
This data processing agreement is necessary because customers can use Boordapp to process personal data of users, crew, contact persons and other relations. In that case, the GDPR requires written arrangements between the customer and the processor.
2. Subject matter, duration and instructions
Boordapp processes personal data on behalf of the customer in order to provide the SaaS service for maintenance and onboard management. These arrangements apply for as long as Boordapp processes personal data on behalf of the customer. Boordapp processes customer data only for the service, on the basis of the agreement, this data processing agreement, reasonable written instructions or a legal obligation.
3. Processing operations
- Users, roles, invitations and access rights.
- Vessel, maintenance, certificate, document and stock data.
- Crew, emergency contacts, qualifications, rosters and hours.
- Costs, port visits, AIS positions and reports.
- Support, feedback, usage data, error logs and audit logs.
The processing consists of collecting, recording, organising, storing, consulting, modifying, securing, exporting, deleting, logging, supporting, synchronising with suppliers and displaying to authorised users.
4. Security
Boordapp takes appropriate technical and organisational measures to protect customer data. These measures are aimed at confidentiality, integrity, availability, access restriction, recoverability and verifiable processing. Boordapp adjusts the measures when the service, technology or risks require it.
- Access to Boordapp runs via WorkOS with roles and session security.
- Customer data is separated per organisation.
- Important changes are logged for review and support.
- Production access is limited to management, security, incident handling and support.
- Persons with access to production or support data are bound by confidentiality.
5. Storage
The Boordapp service and standard document storage run on the Boordapp VPS at TransIP in the Netherlands. Uploaded documents are stored by default on Boordapp's server storage. Object storage will only be added as a sub-processor once that storage is actually used.
6. Sub-processors and connected service providers
The customer gives general authorisation for sub-processors and connected service providers that are necessary for Boordapp. Not every processing operation at a supplier is automatically a sub-processing activity: Stripe, WorkOS or push services may also be independently responsible for their own legal, security or payment obligations. For processing operations they carry out on behalf of Boordapp, we remain responsible to the extent that the GDPR provides. We will inform the customer of any material change. The customer may make a reasoned objection if a new sub-processor poses a demonstrable privacy risk.
| Sub-processor | Region | Purpose | Data |
|---|---|---|---|
| TransIP | The Netherlands | VPS, database, server storage, DNS and server infrastructure. | App data, documents, logs and technical metadata. |
| WorkOS | EU/US or other regions in accordance with the WorkOS terms. | Login, sessions, organisations, roles, invitations and authentication email. | Account data, organisation data, roles and sessions. |
| Stripe | EU/US or other regions in accordance with the Stripe terms. | Payment, subscriptions, invoices, VAT/tax and payment statuses. | Billing data, payment status, plan, customer ID and subscription ID. |
| Cloud86/Plesk | EU, exact hosting location depending on the mail setup. | Incoming support mailboxes, IMAP and webmail. | Support email, contact details and attachments. |
| Mistral AI | EU (France), in accordance with the Mistral terms. | Document recognition of certificates and onboard documents that the customer submits itself via upload or the vessel email address. | The content of the submitted document, including any personal data it contains. |
| OpenAI | US or other regions in accordance with the OpenAI terms, with appropriate safeguards. | Document recognition of invoices, and as a backup route for certificate recognition. | The content of the submitted document, including any personal data it contains. |
| TypeSafe AI | US, with EU standard contractual clauses in accordance with the TypeSafe data processing terms. | Suggestions for column mappings, parts and document types during import, and after separate consent selecting certificate fields from recognised candidates and smart search within a vessel. | Column headings and names of parts, jobs, folders and files; for certificates, recognised candidate values with the surrounding text; for smart search, the search query and names of engines, jobs, stock, certificates, documents, lists and bunkering entries, with their type, category or part. This input may contain personal data. |
| Push services and AIS service providers | Depending on the browser, device or AIS supplier. | Push notifications and AIS features when they are used. | Push endpoints, technical metadata, AIS identification and position data. |
7. Data breaches and data subject rights
Boordapp notifies the customer of a personal data breach without undue delay as soon as Boordapp becomes aware of it. Boordapp reasonably assists the customer with requests for access, rectification, erasure, restriction, objection or portability.
The customer remains responsible for assessing whether a notification to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to data subjects is necessary where customer data is concerned. Boordapp provides the available technical information reasonably needed for that purpose.
8. Return, deletion and audits
After termination, the customer may request an export of customer data within 30 days. After that, Boordapp deletes customer data to the extent reasonably possible, unless statutory retention obligations, security logs or backup rotation temporarily require otherwise. Boordapp provides, on reasonable request, information that allows the customer to assess compliance. An audit must be reasonable, confidential, proportionate and agreed in advance.
9. Transfers outside the EEA
WorkOS, Stripe, OpenAI, TypeSafe AI and push services may process personal data outside the EEA. Boordapp uses appropriate safeguards for this, such as standard contractual clauses, the EU-US Data Privacy Framework where applicable, or a valid adequacy decision.
10. Legal basis
These arrangements are based on Article 28 GDPR. That article requires, among other things, arrangements on the subject matter, duration, nature and purpose of the processing, categories of personal data, data subjects, the customer's instructions, confidentiality, security, sub-processors, assistance with data subject rights, data breaches, deletion or return and audit information.
11. Annex: processing details
| Nature and purpose | Providing Boordapp for maintenance, certificates, documents, stock, costs, crew, notifications, reports and AIS features. |
|---|---|
| Type of processing | Collecting, recording, organising, storing, consulting, modifying, securing, exporting, deleting, logging, supporting, synchronising with suppliers and displaying to authorised users. |
| Duration | For as long as the customer uses Boordapp and thereafter to a limited extent for export, deletion, backup rotation, security logs and statutory retention obligations. |
| Data subjects | The customer's users, crew members, emergency contacts, relations, suppliers and contact persons. |
| Personal data | Contact details, account data, roles, vessel data, maintenance data, document data, certificates, roster and working hours, emergency contact details, costs, billing data, AIS positions, usage data and technical logs. |
| Special categories of personal data | Not intended. The customer may only enter such data with a valid legal basis and under its own responsibility. |
| Recipients | Authorised users of the customer, authorised Boordapp administrators for support and security, and the sub-processors listed in this agreement. |