Privacy Policy

ShipMatrix operates the website and the platform. You can reach us at contact@shipmatrix.uk.

Our role depends on the data:

• Controller. For people who visit our website, people who email us, and the account, sign-in and security records of people who use the platform, we decide why and how the data is used.
• Processor. For the project data a customer puts into the platform or connects to it (for example inspection records, punch items, photos, documents and team rosters), the customer is the controller. The customer is usually the shipyard, shipowner or contractor that holds the subscription. We process that data on its instructions, only to provide the service.

If your personal data appears in a customer's project, please contact that customer first. If you contact us instead, we will pass your request to the customer and help it respond.

The website is an information site. It has no accounts and no forms, and we do not run analytics, advertising or tracking scripts on it.

• Language cookie. When the language shown differs from your browser's language preference, or you switch language, the site sets a cookie called NEXT_LOCALE that remembers "en" or "zh". It holds nothing else and expires when you close your browser.
• Request data. The website runs on Cloudflare's network. Like any web server, Cloudflare receives technical data with each request, such as your IP address, the page requested, the time and your browser's user-agent. We have Cloudflare's logging and monitoring turned on for the site, so we can see request logs to diagnose errors and keep the site running.
• Emails. If you email us, we receive your email address, your name and anything you include, and we use them to reply.

Account and security data (we are the controller)

• Account details: your name, email address, role and module permissions, and your password in hashed form. We never store the password itself. Accounts are created by an administrator; there is no public sign-up.
• Sign-in records: every sign-in attempt, successful or not, with the email address entered, the outcome, the time, your IP address and your browser's user-agent. When a browser that is still signed in is reopened, that is recorded once per browser session.
• Activity log: when you create, change or delete records, we log who made the change, when, what changed and the IP address it came from. Passwords are never written to this log.
• Inspection board visits: when you open the daily inspection board we record, for each browser session, a random device identifier kept in your browser, the date and time, how many times the board was opened, the browser, operating system and device type, the user-agent, the IP address and your account.
• When an administrator views sign-in or board records, an approximate location (country, region or city) is worked out from the IP address using geolocation databases on our own server. The location is not stored and is not sent to anyone.

Customer project data (we are the processor)

• Names of people in project records, such as inspectors, assignees, the authors of punch items, comments and reports, and the users who bind NFC equipment cards or submit equipment status reports.
• Site team rosters: names (including Chinese names where given), department, discipline, role, and periods away such as trips, leave, sick leave or rotation, with notes. Reasons for absence are shown only to users with full access; users whose account is confined to the inspection board see a person who is away as unavailable, without the reason.
• Photos and files that users upload, such as inspection photos, check-sheet photos and documents. They are stored as uploaded, including any metadata the file carries (for example a photo's location, if the camera recorded one).
• Data imported from other systems at the customer's request (see section 4).
• NFC equipment cards hold only a web address that identifies a piece of equipment, such as csl.shipmatrix.uk/t/K0001. They contain no personal data. Scanning a card opens that equipment in the platform.

Team rosters can record sick leave, which is health information and special category data under UK GDPR. A customer that records it is responsible for having a condition under Article 9 of UK GDPR for doing so.

• From you, or from your organisation's administrator: account details, records you enter and files you upload.
• From your browser or device, automatically: sign-in records, IP address, user-agent and the device and session identifiers described in section 7.
• From Aquila: where a customer asks us to enable it, the platform signs in to the Aquila inspection system with an Aquila account the customer supplies for that purpose, and downloads the customer's project export (inspection, punch, FAT, PAT, ITP and NCR records) once a day or when a user asks. These records can name inspectors and other people.
• From automated file uploads: daily inspection plan spreadsheets can be uploaded automatically, either by a script on a computer that reads them from a synced folder, or through an email route operated on Google's services (Gmail and Apps Script). These uploads use a limited-scope import key, which the platform stores only in hashed form.

For the data we control, we rely on these lawful bases under UK GDPR:

• Running your account and the platform (signing you in, keeping you signed in, applying permissions): performance of our contract with the customer, and our legitimate interest in providing the service to the people the customer authorises.
• Sign-in records, the activity log and board visit records: our legitimate interests in keeping the platform secure, showing who changed project records and when, and understanding how much the inspection board is used.
• Website request logs: our legitimate interest in operating and protecting the website.
• Replying to emails: our legitimate interest in answering enquiries, or taking steps you ask for before entering into a contract.
• Complying with the law, where a legal obligation applies.

For customer project data, the customer decides the purposes and the lawful basis. We use that data only to provide the service to that customer, as it instructs. We do not sell personal data, use it for advertising, or use customer data to train AI models.

The platform can draft the weekly progress report, and polish its wording, using an AI model from Anthropic, PBC (United States) through Anthropic's API. This happens only when a user asks for a draft or a polish.

The request contains that week's project figures and can also contain the names of inspectors, site notes, issue register entries and text extracted from documents uploaded for that week. The result is a draft, which users review and edit before it is published.

Website: the only cookie is NEXT_LOCALE, the language preference described in section 2.

Platform: the platform does not use cookies to sign you in. It uses your browser's local storage, session storage and IndexedDB, and a service worker:

• Sign-in: your access and refresh tokens and basic profile (name, email address and role) are kept in local storage. If you untick "Remember me", they are kept in session storage instead and are cleared when you close the browser.
• Preferences: for example the selected ship, light or dark theme, and recent offline searches.
• Device and session identifiers: a random device ID and a browser-session ID with a last-active time. They are used to count inspection board visits and sign-ins per browser session.
• Offline use: if you use offline mode, the platform downloads text data such as cable, equipment and punch lists into IndexedDB on your device so it can be read without a connection, and the service worker stores the app's pages and files. Findings you record offline are held on the device until they have been uploaded.

Signing out removes the sign-in data and the downloaded offline data from the device. Findings that have not yet been uploaded are kept, so that they are not lost. You can also clear this storage in your browser settings; you will then be signed out.

We use these service providers, who process personal data on our behalf:

• Cloudflare, Inc.: hosts the website, and carries all traffic to the platform as a network and security proxy. Cloudflare operates a global network, so requests may be handled in data centres outside the UK.
• Oracle (Oracle Cloud Infrastructure): provides the virtual server on which the platform, its database and uploaded files are hosted.
• Anthropic, PBC: provides the AI model for weekly report drafting (section 6), in the United States.
• Google (Gmail and Google Apps Script): only where the email upload route in section 4 is used, the spreadsheets pass through Google's services.
• NetEase: hosts the mailbox for our email address, so emails you send us are received and stored by NetEase's mail service in China.

Aquila is a source, not a recipient: the platform only reads from it. Apart from the sign-in credentials of the account the customer supplies, the platform sends nothing to Aquila.

Within a customer's organisation, data is visible to the users its administrators grant access to; the daily inspection board shows inspection assignments, including inspector names, to every signed-in user of that customer. We also disclose data where the law requires it.

The platform does not send email.

Some of these providers process data outside the UK, including in the United States and China. For our hosting, network and AI providers we rely on their data processing terms, which include the UK International Data Transfer Addendum. Emails you send to our mailbox are transferred to China because that is where our mail provider operates; we hold them only to deal with your enquiry. You can ask us for details.

The platform has no automatic deletion schedule. In practice:

• Account details are kept while the account exists.
• Sign-in records, the activity log and board visit records form the audit trail and are kept for the life of the customer's account or project.
• Customer project data is kept for the life of the customer's project or subscription, and is deleted or returned when the customer asks.
• Emails are kept for as long as the conversation and related business records need them.
• Website request logs are kept by Cloudflare under its retention settings for our account.

You or the customer can ask us to delete data at any time, subject to section 11. Deleted data can remain in backups made before the deletion until those backups are themselves deleted.

Measures in place include:

• HTTPS for all platform traffic (TLS 1.2 or 1.3), with plain HTTP redirected and HTTP Strict Transport Security enabled.
• Passwords stored only as bcrypt hashes.
• Access and refresh tokens that expire within at most 7 days. Every token for an account can be revoked at once, for example when the password changes or the account is deactivated.
• A limit on sign-in requests, and a 15-minute lockout after 10 consecutive failed sign-ins to an account.
• Role-based and module-based access control on the platform's interfaces.
• Import keys stored only in hashed form, and passwords removed from the activity log.

No system is completely secure. If we become aware of a personal data breach that affects you, we will act as UK data protection law requires.

Under UK data protection law you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have data erased;
• restrict how we use it;
• object to processing based on our legitimate interests;
• receive data you gave us in a portable format, where that right applies;
• withdraw consent at any time, where we rely on consent.

To use these rights, email contact@shipmatrix.uk. We will reply within one month. For data in a customer's project, we will pass your request to that customer, as the controller, and help it respond.

You can complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first.

The website and platform are business services and are not intended for children. We do not knowingly collect children's personal data.

We may update this policy. The date at the top shows when it last changed. If a change materially affects how we handle customers' data, we will tell customers before it takes effect.

Questions about this policy or your personal data: contact@shipmatrix.uk.