Legal
Privacy Policy
Effective date: 21 August 2026
App: kTool — Sail Performance Analysis
Website: www.ktool.hu
Company
H B D C Software Solutions DWC-LLC
Business Center Logistics City, Dubai Aviation City, P.O. Box 390667, Dubai, U.A.E.
Contact: info@ktool.hu
1. Introduction
We respect your privacy and are committed to protecting your personal data. This Privacy Policy describes how we collect, use, and safeguard your information when you use the kTool app or visit our website www.ktool.hu. By using our app or submitting your information, you consent to the practices described in this policy.
2. What data we collect
We collect two categories of data.
a. Personal data
Full name
Email address
Boat class or type
This data is used to identify you, manage your account, personalize your experience, and provide customer support.
b. Sensor and device data
Collected through connected boat tracking devices or manual upload:
GPS data (coordinates, course, speed)
Gyroscope and magnetometer data
Wind sensor data (wind speed, direction)
Boat dynamics (speed, heading, pitch, roll, heel, acceleration)
Environmental data (e.g. temperature, water conditions)
Timestamps, device identifiers, and session metadata
3. How we use your data
We process this data to:
Deliver personalized sailing performance analytics
Improve accuracy and value of features within the app
Communicate with users for service updates and support
Measure the effectiveness of our advertising and understand which campaigns bring people to kTool
Maintain functionality, ensure security, and comply with legal obligations
We may also use sensor data, separated from personally identifying information, for training and improving algorithms and machine learning models. This data is fully anonymized and cannot be used to identify you.
4. Legal basis for processing
We rely on the following legal bases:
Your consent (via app registration or checkbox acceptance, and — for analytics and advertising cookies — via our cookie banner)
Performance of a contract (i.e. providing you the app's services)
Legitimate interest (e.g. improving app functionality, ensuring security)
Legal compliance (where required by law)
Advertising and campaign-measurement cookies are used only with your consent — never on the basis of legitimate interest. You can withdraw your consent at any time: for cookies, use the “Cookie settings” link in the website footer or, in the app, Profile → Data management; for anything else, by contacting us.
5. Data retention
We retain personal data only as long as necessary to fulfill the purposes described in this policy or as required by law. Anonymized sensor data used for research and improvement may be retained indefinitely in a non-identifiable form.
6. Data sharing and storage
We do not sell your data. We may share your information with:
Third-party service providers (e.g. cloud storage, analytics, email services)
Advertising partners — Google, Meta, TikTok and Reddit — where you have consented to advertising cookies (see “Cookies and analytics” below)
Legal or regulatory authorities if required by law
Sensor data used for algorithm development is aggregated and anonymized before any sharing or research use.
7. Data transfers
If data is transferred outside of your jurisdiction (e.g. outside the EU or UAE), we apply appropriate safeguards, such as:
Standard Contractual Clauses (for EU)
Adequate protection agreements under UAE PDPL
Our analytics and advertising partners are based in, or transfer data to, the United States. Those transfers rely on Standard Contractual Clauses and, where the recipient is certified under the EU–US Data Privacy Framework, on that framework. Not every partner is certified, and certification status can change over time.
8. Your rights
Depending on your location, you may have the right to:
Access your personal data
Request correction or deletion
Withdraw consent
Object to or restrict certain processing
Lodge a complaint with a data protection authority
To exercise your rights, contact us at info@ktool.hu.
9. Data security
We implement technical and organizational measures to protect your personal data, including:
Encrypted data transmission
Secure server environments
Access controls and audit logs
10. Cookies and analytics
We use cookies and similar technologies to operate the Service, keep it secure, and understand how it is used so we can improve it. We use the following categories:
Essential — required for the app to function, such as authentication and security. These are always active.
Product analytics — we use PostHog to understand how features are used and improve the app.
Error monitoring — we use Sentry to detect, diagnose and fix crashes and bugs.
Advertising and campaign measurement — we use Google Tag Manager to load advertising tags (it sets no cookies of its own), together with Meta (_fbp, _fbc), TikTok (_ttp), Reddit (_rdt_uuid) and Google Ads and Google Analytics (_gcl_au, _ga). These measure whether an advert led to a visit or a sign-up. They are set only if you consent, and never on the basis of legitimate interest.
PostHog and Sentry act as processors and may set cookies or use similar identifiers to process limited usage and technical data on our behalf, as described in “Data sharing and storage” above.
Our advertising partners — Google, Meta, TikTok and Reddit — are different. They act as independent controllers, not processors: they use the data they receive for their own purposes, under their own privacy policies, and we do not control that use. This is why advertising cookies are set only with your consent.
Your cookie choice applies to both ktool.hu and app.ktool.hu. You can change or withdraw it at any time using the “Cookie settings” link in the website footer, or in the app under Profile → Data management; withdrawing also clears the advertising cookies already stored on your device. You can additionally control cookies through your browser settings. Disabling some cookies may affect functionality.
11. Children's privacy
Our app is not intended for children under the age of 16. We do not knowingly collect data from children.
12. Updates to this policy
We may update this Privacy Policy from time to time. Any significant changes will be communicated through the app or email.
13. Contact
If you have questions or concerns about this Privacy Policy or your personal data, please contact:
Email: info@ktool.hu
Address: Business Center Logistics City, Dubai Aviation City, P.O. Box 390667, Dubai, U.A.E.