Privacy Policy
Effective Date: 01 April 2025
App: KTool – Sail Performance Analysis App
Website: www.ktool.hu
Company: H B D C SOFTWARE SOLUTIONS DWC-LLC
Address: 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
• 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)
• 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)

You can withdraw your consent at any time 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)
• 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

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. Children’s Privacy
Our app is not intended for children under the age of 16. We do not knowingly collect data from children.

11. 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.

12. 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.