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Privacy Policy

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This page explains what personal data we process when you use Wingo Marine, why, and how you can exercise your rights under Regulation (EU) 2016/679 (GDPR). We do not sell data, show ads or use advertising trackers.

1.The data controller

The controller is FREEVOX S.R.L., registered office Str. Crăițelor 2B, room 2, Otopeni, Ilfov County, 075100, Romania, tax ID (CUI) 43636649, Trade Register no. J23/494/2021 (“Freevox”, “we”).

For any question or request about personal data: office@freevox.ro · +40 770 348 017 · Șos. București–Ploiești 19, Băneasa Business Center, Sector 1, Bucharest, Romania.

2.In short

  • We process only what we need to provide your account, payments, the API and alerts, plus technical logs for security.
  • You enter your card details directly with Stripe; we never see or store them.
  • Passwords are stored only as hashes, API keys only as SHA-256 hashes, webhook secrets encrypted.
  • We use strictly necessary cookies and preferences saved on your device; our traffic statistics use no cookies, and we set the wm.vid statistics cookie only with your consent. You can object to the statistics at any time. Server logs, including IP addresses, are kept for 30 days.
  • Account data is hosted in the European Union (Hetzner, Germany).

3.What data we process

Your account

Your name, email address, password (stored only as a cryptographic hash), whether your email address is confirmed, your role (user or administrator), and the creation and last-update dates. Email-confirmation and password-reset links use temporary tokens that expire.

If you sign in with Google, Google sends us your name, email address, profile picture (URL) and Google account identifier, and the OAuth tokens Google issues are kept with your account.

Sessions and security

For each sign-in we keep a session: a random token, its expiry, the IP address and the browser user agent. The IP address is also used, briefly, to rate-limit sign-in attempts and requests to the public directory.

Subscription and payments

Your Stripe customer and subscription identifiers, plan, subscription status and billing period, and any discount or plan granted by an administrator. Card and payment details are collected and processed by Stripe; from Stripe we only receive the payment confirmation and the subscription details.

Credits and API use

The credit ledger (grants, consumption aggregated per endpoint, balances) and API usage statistics. For API keys we keep the name you gave the key, its first characters (prefix), its SHA-256 hash and the dates it was created, last used and revoked — the full key is never stored.

Fleets, webhooks and checks

Fleet names, the vessels you watch (MMSI) and their labels, auto-check settings; webhook URLs, event types, the signing secret (encrypted) and the delivery log (payload sent, response code, error). The log of on-demand position checks is linked to the account that requested them.

Communication with us

Emails you send us and our replies, and the transactional emails we send you (email confirmation, password reset). Account emails contain no tracking pixels and no tracked links.

Server logs

Like any website, our servers log every incoming request, robots included: IP address, date and time, method and requested URL (parameters that may contain tokens, email addresses or other personal data are removed before storage), response code, response size and duration, referrer, user agent, the languages your browser accepts and whether the request comes from a signed-in session (only the presence of the cookie, never its value). We use them for security, debugging, abuse prevention (for example throttling robots that overload the server) and for the traffic statistics below.

From the IP address we derive, on our own servers, an approximate location (country, region, city) and the network (ASN, e.g. the carrier or hosting provider), using the free DB-IP Lite database (IP Geolocation by DB-IP) stored locally — the IP address is not sent to DB-IP. From the user agent we derive the browser, operating system and device type, and whether the request comes from a robot (search engine, AI crawler, etc.). For visits that run our script we use our own geolocation service Wingo IP (see below).

Our own traffic statistics

Without cookies (default). On every page our servers and a script of our own (/wm.js) record which pages are visited (including which vessel or port), how long and how far they are read, clicks and other interactions on the page (which button or link, where on the page, vessel searches with the number of results, map interactions — zoom level, approximate area, the vessel opened, filters —, form steps without what you type, errors and loading speed), the referring website and campaign, the browser and device type, the size of the browser window and the light or dark theme. Your language comes from the setting your browser sends, the time zone and approximate location (country, region, city, network) from the IP address, through our own geolocation service Wingo IP or the local DB-IP Lite database. We do not set cookies or store anything on your device for this; visits on the same day are grouped with a key computed from IP address, browser and language with a secret that changes every day and is deleted after one day. If you are signed in, your browser sends our sign-in cookie with every request anyway, and we use it to link the visit to your account; this does not happen after you object (see below). Purpose: understanding and improving the website, measuring which channels bring customers, detecting bots and abuse. Legal basis: legitimate interest (Art. 6(1)(f) GDPR). Data is never sold or used for advertising. You can object at any time: "Reject all" (or turning off "Statistics") in Cookie settings, or a Global Privacy Control or Do Not Track signal from your browser, limits our statistics to anonymous counts (pages, time, errors), without the IP address, without an identifier and without linking them to your account. The server logs described above continue for security, but are no longer used for statistics and are not linked to your visits.

With your consent ("Statistics" in Cookie settings) we additionally set the first-party cookie wm.vid (13 months, not renewed on later visits) to recognize your browser across days, read further device details (screen size and pixel density, time zone and languages set in the browser, touch support, reduced-motion and color-scheme settings, processor cores, memory and connection type), record sampled mouse positions (for page heatmaps) and may record a replay of some visits: page structure, mouse movements, clicks and scrolling; everything you type is masked, inside the app (after sign-in) all page text is masked, and on the website names, email addresses and API keys shown on the page are masked; the sign-in, account, billing, API key and webhook pages are never recorded. Legal basis: consent (Art. 6(1)(a) GDPR, Art. 4(5) of Romanian Law 506/2004); withdrawing it removes the cookie, the replays and the browser identifier and stops recording. A Global Privacy Control or Do Not Track signal is treated as no consent and as an objection.

We also use Umami, hosted on a server run by Freevox (analytics.wingo.ro), which uses no cookies or local storage, does not keep the IP address and records only aggregated data (page, referrer, browser, operating system, device, language, country). We do not load it after you object.

When you create an account, we attach to it the source of the visit that led to the sign-up (search engine, referring website, campaign, AI assistant), the landing page, the approximate location and the device type, so we know which channels bring users; when you pay, the same source is linked to the payment.

Payment notifications

When a checkout starts, a payment succeeds, fails, needs confirmation (3-D Secure) or is refunded or disputed, or a subscription is canceled, we send ourselves a push notification with the plan, amount, a shortened email address (for example ma•••@gmail.com, or the full one if we turn that option on), approximate location and traffic source (legitimate interest in running sales).

Vessel data (AIS)

The Service processes the AIS messages ships broadcast publicly: MMSI, name, call sign, IMO, type, dimensions, destination, position, speed and course. For commercial ships this is usually not personal data. For small craft and leisure boats, however, the name, MMSI and position may relate to an identifiable individual (the owner or skipper). We treat it as possible personal data: we do not try to identify the people behind vessels, do not build profiles of individuals, and you can exercise your rights — including objecting to a vessel being shown in the public directory — by writing to office@freevox.ro.

4.Contact form and support tickets

When you write to us through the contact form (on the contact page, on the home page or in the app), we create a support ticket. We process your name, email address, company (optional), the category and subject, your messages and our replies, the page you wrote from and, to prevent abuse, your IP address and browser (user agent), which we keep for 30 days. If statistics are on for your visit (you have not refused them and your browser does not send Global Privacy Control or Do Not Track), we also keep with the ticket a copy of where the visit came from (for example the search engine, the referring website or the campaign), the country and the city; that copy stays with the ticket even after the statistics of the visit are deleted.

Purpose: to reply to you and keep a record of your request. Legal basis: performance of a contract or steps taken at your request before entering into one (Art. 6(1)(b) GDPR), for customers and for requests about plans and services; our legitimate interest in replying to people who write to us (Art. 6(1)(f) GDPR), for other requests.

How long we keep it: 24 months after the ticket is closed; messages marked as spam, 30 days; database backups, up to 14 days. When an account is closed or deleted, its tickets (and those sent with the account’s address) are anonymised: the name, email address, company, IP address, browser and visit source are deleted, and names, addresses, phone numbers and links in the messages are replaced with ‘[…]’; the conversation can no longer be opened or continued. Recipients: our email platform PowerMail, through Amazon SES (EU), through which you receive the confirmation and our replies; Wingo Notifications receives, for our internal notification, your name, a shortened email address (the full one only if we turn that option on), the subject, a masked excerpt of the message (no links, long numbers or addresses) and, when we have them, the country, city and source of the visit. Our log copy of that notification is emptied with the ticket and deleted after 400 days in any case.

The confirmation and our replies contain a personal link to the conversation: anyone who has it can read the conversation and reply in it, so do not forward it. If you want us to delete a ticket, write to us at office@freevox.ro. The form sets no new cookies.

5.Purposes and legal bases

  • Creating and running your account, signing in
    Data
    Account, sessions, Google data (optional)
    Legal basis (Art. 6 GDPR)
    Performance of a contract — Art. 6(1)(b)
  • Providing the features: map, fleets, alerts, API, checks
    Data
    Fleets, webhooks, API keys, credits, delivery and check logs
    Legal basis (Art. 6 GDPR)
    Performance of a contract — (b)
  • Payments, invoicing and accounting records
    Data
    Subscription, Stripe identifiers, credit ledger
    Legal basis (Art. 6 GDPR)
    Contract — (b); legal obligation (tax and accounting law) — (c)
  • Transactional emails (confirmation, password reset)
    Data
    Email, name
    Legal basis (Art. 6 GDPR)
    Performance of a contract — (b)
  • Offers and news about Wingo Marine
    Data
    Email, name, language, email preferences
    Legal basis (Art. 6 GDPR)
    Accounts created through the sign-up form that shows this notice (since 24 October 2026) and customers informed at checkout: Article 12(2) of Romanian Law no. 506/2004 (customers, similar services, with an opt-out at sign-up and in every email); other accounts: consent — point (a)
  • Choosing the right emails and offers
    Data
    Plan, credits, fleets and tracked vessels, API use, last sign-in, language, country and sign-up source, support ticket categories; vessels opened, map areas and site use only if you have not objected to statistics
    Legal basis (Art. 6 GDPR)
    Legitimate interest — point (f): sending you only what concerns you; you can object at any time (Article 21 GDPR), and once you unsubscribe from all marketing emails we stop
  • Other Wingo products by Freevox
    Data
    Email, name, language
    Legal basis (Art. 6 GDPR)
    Consent — point (a)
  • Security, fraud and abuse prevention, rate limiting
    Data
    IP, user agent, server logs, sessions
    Legal basis (Art. 6 GDPR)
    Legitimate interest — (f): protecting the Service and its users
  • Traffic statistics and site improvement (without cookies)
    Data
    Server logs, pages visited, on-page interactions, approximate location, account link when signed in, Umami data
    Legal basis (Art. 6 GDPR)
    Legitimate interest — (f): understanding how the site is used, where visitors come from and bot traffic; you can object at any time
  • Statistics with consent: recognizing your browser (wm.vid cookie) and visit replays
    Data
    The cookie identifier, further device details, the masked page recording
    Legal basis (Art. 6 GDPR)
    Consent — (a); Art. 4(5) of Law 506/2004
  • Internal payment notifications
    Data
    Plan, amount, shortened email, approximate location, visit source
    Legal basis (Art. 6 GDPR)
    Legitimate interest — (f): running sales
  • Answering your requests
    Data
    Correspondence
    Legal basis (Art. 6 GDPR)
    Contract or legitimate interest — (b) / (f)
  • The public ship directory and AIS data
    Data
    Publicly broadcast AIS data
    Legal basis (Art. 6 GDPR)
    Legitimate interest — (f): public information about maritime traffic
  • Defending legal claims, answering authorities
    Data
    The relevant data
    Legal basis (Art. 6 GDPR)
    Legal obligation — (c); legitimate interest — (f)

We send you offers and news only as described under ‘The emails we send you’, and you can object at any time, free of charge; once you unsubscribe from all marketing emails, we no longer use your data to choose offers or to contact you commercially. We take no decisions based solely on automated processing that produce legal effects for you.

6.The emails we send you

Account and service. Address confirmation, password resets, payments, credits, your alerts and important changes to the service or the terms are part of the service (contract — point (b); legal obligation — point (c)) and cannot be turned off while the account exists. They contain no offers.

Wingo Marine offers and news. You receive them if you created your account through the form that shows this notice and did not tick ‘I don't want…’, if you were informed at checkout and did not object, or if you asked for them in the app. Every email has an unsubscribe link.

Other Wingo products by Freevox (Wingo UI, Wingo Websites): only if you chose to.

How we choose what to send you. We look at your plan and credits, your fleets, your API use, your last sign-in, your language, country and sign-up source and the categories of your support tickets; vessels opened, map areas and pages visited are used only if you have not objected to statistics. We never use visit recordings, mouse movements or precise location. For informed accounts, our team sees a stage (for example ‘showing intent’) and a score computed from this data; they only help us choose emails and produce no decision with legal effects for you.

Your right to object. Unsubscribe with one click from any email, from the preferences page or from your Profile. Once you unsubscribe from all marketing emails, we no longer use your data to choose offers or to contact you commercially.

No personal tracking. Our emails have no open-tracking pixels and no personal tracking links: links carry the same campaign tags for every recipient. If you sign in after clicking, the visit is linked to your account like any other visit (see the statistics above).

How often. At most 3 marketing emails a week and 8 a month, between 07:00 and 21:00, in your time zone.

How long we keep it. Your preferences, as long as the account exists; the history of your choices, 3 years; the log of the emails we sent (date, subject, status), 400 days, linked to the account (the subject is cleared after 30 days); after you unsubscribe or delete the account, only a cryptographic fingerprint of the address, in a suppression list, so we don't write to you again.

7.How long we keep data

  • Account, fleets, webhooks, API keys, credit ledger
    Period
    As long as the account exists; after a deletion request, within 30 days (except data the law requires us to keep)
  • Sessions
    Period
    Until you sign out or they expire (30 days by default with “Remember me”)
  • Email-confirmation and password-reset tokens
    Period
    Until used or expired (a matter of hours)
  • Webhook delivery log
    Period
    30 days
  • Position-check log (including the HTTP log)
    Period
    30 days
  • Payment and invoicing documents
    Period
    The periods set by accounting law (usually 5–10 years)
  • Server logs (every request, with the IP address)
    Period
    30 days; afterwards only hourly / daily aggregates without IP addresses remain (at most 400 days)
  • Our statistics (sessions, pages, interactions)
    Period
    13 months (400 days)
  • Full IP addresses in statistics and logs
    Period
    30 days; afterwards only the network prefix and a monthly key that can no longer be reversed remain
  • Mouse positions and visit replays
    Period
    30 days
  • Link between payments and the visit they came from
    Period
    3 years
  • Daily visit grouping key
    Period
    one day
  • Anonymous counts (after an objection)
    Period
    13 months (400 days)
  • Payment notification log
    Period
    400 days
  • Support ticket notification log
    Period
    Emptied with the ticket; at most 400 days
  • The log of the emails we send (kind, delivery status, dates; no content)
    Period
    400 days, linked to the account and to a code derived from the address; the address itself and the subject, 30 days
  • Email content at our sending platform (PowerMail)
    Period
    One day for account and service emails, 7 days for offers and news; the delivery log, without content, 400 days
  • The list of addresses we no longer write to (permanent bounces, spam reports, unsubscribes)
    Period
    Without a time limit, only as a code derived from the address, so that your choice is respected even after the account is deleted; temporary bounces, 30 days
  • Email preferences
    Period
    As long as the account exists
  • The history of your email choices (proof of consent)
    Period
    3 years; after the account is deleted, without the link to the account
  • The log of the offer, news and service emails we send (date, subject, status)
    Period
    400 days, linked to the account; the subject is cleared after 30 days
  • The suppression list (a cryptographic fingerprint of the address)
    Period
    As long as needed to respect your objection
  • The stage, score and team notes about the account
    Period
    As long as the account exists; the stage history, 400 days
  • Database backups
    Period
    up to 14 days — may temporarily also hold the IP addresses above
  • Sign-up source (account attribution)
    Period
    As long as the account exists
  • Correspondence
    Period
    As long as needed to resolve it, then at most the general 3-year limitation period
  • Vessel position history (sampled)
    Period
    7 days; each vessel’s latest position is kept until a newer one arrives
  • Umami statistics
    Period
    Aggregated data, no personal identifiers

8.Who receives the data

We do not sell or rent personal data. We share it only with the providers we need to run the Service, under contract and only as far as necessary:

  • Hetzner Online GmbH (Germany)
    Role
    Processor — server hosting and storage (Storage Box)
    What it receives
    All Service data, hosted in the EU
  • FREEVOX S.R.L. — Wingo IP
    Role
    Our own IP geolocation service, on servers we run
    What it receives
    The IP address of visits that run JavaScript (not after an objection); for addresses not seen in the last 30 days Wingo IP asks apiip.net, ipgeolocation.io or ip-api.com, sending only the IP address. Wingo IP keeps the looked-up IP address and its location, separately from our statistics and with no link to the visit or the account, so that it does not ask the providers again; the result is refreshed after 30 days
  • FREEVOX S.R.L. — Wingo Notifications
    Role
    Push notifications to our own devices, delivered through Google Firebase Cloud Messaging
    What it receives
    Plan, amount, shortened email, approximate location and source of a payment; for a support ticket: the name, shortened email, subject, a masked excerpt of the message, the country, city and source of the visit; for informed accounts that can receive offers: the shortened email, the stage, the score and its reasons
  • AI analysis services chosen by us
    Role
    Analysing statistics to improve the site
    What it receives
    Pseudonymous statistics, without IP addresses, emails or account identifiers
  • Stripe Payments Europe, Ltd. (Ireland) and Stripe, Inc. (USA)
    Role
    Independent controller for payment processing
    What it receives
    Your email, account identifier, the payment details you enter with Stripe
  • Google Ireland Limited (Ireland) / Google LLC (USA)
    Role
    Independent controller — only if you choose Google sign-in
    What it receives
    The sign-in request
  • Amazon Web Services EMEA SARL (Luxembourg) — Amazon SES, EU region Frankfurt
    Role
    Processor — delivering the emails we send you through PowerMail: about your account, support and the service and, only if you receive them, offers and news
    What it receives
    Email address, name, subject and message content, delivery events (delivered, bounced, reported as spam). Amazon Web Services, Inc. (USA) is a sub-processor.
  • FREEVOX S.R.L. — PowerMail
    Role
    Our own email sending platform, on servers we run
    What it receives
    The same data; it keeps the content of account and service emails for one day and of the others for 7 days, and the delivery log, without content, for 400 days
  • FREEVOX S.R.L. (Romania) — our own email server
    Role
    Receiving the emails you write to our addresses (for example a reply to an email from us); account confirmation and password reset during a transition period while the domain changes, then only as a fallback if PowerMail is unavailable
    What it receives
    Email address, name, message content
  • Anthropic PBC (USA)
    Role
    Writing assistant for email copy, used only by our team
    What it receives
    We do not knowingly send it data about users: only template text, product information and aggregate counts of at least 5 accounts (for example “120 accounts”); email addresses, phone numbers and long digit strings in our text are removed automatically before sending. Anthropic keeps requests for at most 30 days and does not use them to train models.
  • OpenStreetMap Foundation (United Kingdom) — tile.openstreetmap.org
    Role
    Map provider for the app
    What it receives
    Your browser downloads the map tiles directly: your IP address and user agent reach this provider
  • OpenFreeMap — tiles.openfreemap.org
    Role
    Map provider for the public directory
    What it receives
    Likewise: your IP address and user agent, when the map loads
  • unpkg.com (public CDN)
    Role
    Serves the MapLibre map library on directory pages
    What it receives
    Your IP address and user agent, when the script loads
  • Advisers (accounting, legal) and public authorities
    Role
    When necessary or required by law
    What it receives
    Only the data strictly needed

For on-demand position checks we use Bright Data (fetching the vessel’s public page) and Mistral AI (France — automated position extraction). They receive only vessel identifiers (MMSI, IMO) and the public page content, no data about you. AIS data comes from aisstream.io and public receiver stations; we send these sources no data about our users.

Our own statistics and Umami run on servers operated by Freevox; IP geolocation uses Wingo IP (ours) and the local DB-IP Lite database. IP addresses do not reach third parties, except the Wingo IP providers above, for new addresses. With every checkout Stripe also receives, in the payment metadata, a pseudonymous visit identifier and no other data about the visit, so the payment can be linked to its source.

9.Transfers outside the EEA

Account data stays in the European Economic Area. Some transfers may take place through the providers above:

  • Stripe and Google (USA): under the EU-US Data Privacy Framework (the Commission’s adequacy decision of 10 July 2023), for certified companies, and the standard contractual clauses approved by the European Commission.
  • OpenStreetMap Foundation (United Kingdom): under the Commission’s adequacy decision for the United Kingdom.
  • CDNs (unpkg.com, OpenFreeMap) may serve content from locations outside the EEA; only your IP address and user agent reach them, when resources load.
  • Google Firebase Cloud Messaging (USA), through which Wingo Notifications delivers the notifications to our devices: on the basis of the EU-U.S. Data Privacy Framework and the standard contractual clauses.
  • Amazon Web Services, Inc. (USA), the sub-processor of Amazon Web Services EMEA SARL for email delivery (Amazon SES): emails are processed in the EU (the Frankfurt region), and access from the USA is possible only under the EU-US Data Privacy Framework and the standard contractual clauses.
  • Anthropic PBC (USA), the writing assistant: only text without data about users, on the basis of the standard contractual clauses.
  • The Wingo IP providers (apiip.net, ipgeolocation.io, ip-api.com) may process the IP address outside the EEA, on the basis of the standard contractual clauses or the applicable adequacy decisions.
  • The AI analysis services we choose (for example providers in the USA) receive only pseudonymous statistics, without IP addresses, emails or account identifiers, under a data processing agreement that excludes using them to train models, and the standard contractual clauses.

10.Your rights

Under the GDPR (Articles 15–22) you have the right:

  • of access — to know what data we hold about you and get a copy;
  • to rectification — to correct inaccurate data (you can also change your name on the Profile page);
  • to erasure — to have your account and data deleted, except data the law requires us to keep;
  • to restriction of processing;
  • to data portability — to receive the data you provided in a structured, commonly used format;
  • to object — to processing based on legitimate interest, including a vessel being shown in the public directory;
  • not to be subject to a decision based solely on automated processing.

You can object to our statistics at any time as described under "What data we process". Statistics linked to your account are part of the data export (you can download it yourself from the Profile page) and are deleted when your account is deleted; payments remain only as amounts, without the link to the account. For statistics without an account we can answer requests that give the IP address and the time range (within 30 days), or from the browser you used (in the Cookie Policy: "Download / delete this browser's data").

To exercise your rights, write to office@freevox.ro, preferably from your account’s email address. We reply free of charge within one month (extendable by two more months for complex requests, in which case we will tell you). We may ask for more information to confirm your identity.

You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28–30, Sector 1, 010336 Bucharest, Romania · anspdcp@dataprotection.ro · www.dataprotection.ro, or with the authority of your country of residence.

11.Data security

  • All communication with the website and the API is encrypted (HTTPS).
  • Passwords are stored only as hashes, API keys only as SHA-256 hashes; webhook secrets and sensitive settings are encrypted (AES-256-GCM).
  • The session cookie is HttpOnly and Secure; sign-in and the public directory are rate-limited.
  • Access to production data is limited to the Service’s administrators.

If a security breach puts your rights at risk, we notify ANSPDCP within 72 hours and inform you without undue delay, as the GDPR requires.

12.Children

The Service is meant for people aged 18 or over and for businesses. We do not knowingly collect data about minors. If you learn that a minor has given us data, write to office@freevox.ro and we will delete it.

13.Cookies

Details about cookies, local storage and consent settings are in the Cookie Policy; you can change them at any time from "Cookie settings" in the footer of every page.

14.Changes

We may update this policy when the Service or the law changes. The date of the last update is shown at the top of the page; for material changes we will notify you by email or in the app.

This policy is available in Romanian and English; if they differ, the Romanian version prevails.