Part 1 — Privacy notice (for users)
*Last updated: 16 October 2026. Controller: Razorbill Technology Limited, Kildee, Dunmanway, Co. Cork, P47 NH01, support@fulmaire.com.*
The short version
Fulmaire records where you have paddled. That means we hold precise location
data about you, which is sensitive, and we treat it that way.
We do not sell it, and we never give advertisers where you paddle. The free
version shows ads from Google; premium has none. We hide the water
around the slipways you use regularly so the map does not tell anyone where you
launch from. You can download everything we hold, or delete all of it, at any
time, from inside the app.
What we collect
From the files you upload. GPS positions and timestamps for the whole
paddle, and where the file carries them, your device model and serial number
and your speed. We keep the original file.
From recording on your phone. If you press "Record a paddle on this
phone", Fulmaire asks your phone for its location until you press Stop. In a
web browser that is only while Fulmaire is open on screen; in the Android app
it carries on with the screen off, and Android shows a notification for as long
as it does. The positions are saved on your phone as they arrive and reach us
only when you stop, as an ordinary uploaded file, treated exactly like one. A
recording that has not been sent yet stays on your phone until it is, or until
you discard it. The Android app keeps your most recent finished recording on
the phone so you can send it again.
From you. A handle, and an email address if you have given one.
Anything you send us through Feedback, with the page you were on and the app
version unless you untick that. It is deleted with your account.
Derived by us. Which stretches of water you covered, which counties and
named waters you were in, distance and duration, which awards you have earned,
and which cells you currently hold.
Automatically. Basic server logs. And which parts of the app you use, by
day: for example, that on 15 October you opened Awards and uploaded a paddle.
One mark per part per day, not every tap, not the time, not where you were.
Fulmaire counts this itself, in its own database, and sends it to nobody,
Google included. We look
at it only as totals (how many people used Awards this month), to learn what
is worth improving and what is not.
Why, and on what basis
| What | Why | Lawful basis |
| Processing your tracks into claims and awards | It is the service | Contract |
| Showing your claims to other paddlers | It is a shared map; a private one would be a different product | Legitimate interests |
| Keeping your original files | So your history can be recalculated when the maps or the algorithms improve | Legitimate interests |
| Account security, abuse prevention | Keeping the register trustworthy | Legitimate interests |
| Emails about your account | Running the service | Contract |
| Counting which parts of the app are used, by day | Knowing what to improve, and whether people come back | Legitimate interests |
| Showing ads on the free version | It pays for the free version | Your consent, for advertising cookies and ads chosen for you; legitimate interests, for ads that are not |
Where we rely on legitimate interests you can object at any time, and we will
stop unless we have compelling grounds not to. Our assessment is in Part 3
below; ask and we will send it.
Advertising
The free version shows one ad at the foot of Paddles and of Awards, served by
Google Ireland Limited. Before any ad loads, Google's consent message asks
whether you agree to cookies for advertising. If you agree, Google may use
cookies and your device's identifiers to choose ads for you and to measure
them. If you do not, Google shows ads not chosen from your activity, and may
still use cookies to prevent fraud and limit how often you see the same ad,
where the law allows. Like any website you open, Google also sees your IP
address (which can suggest your rough area), your browser and the address of
the page.
We never give Google your paddles, positions, sightings, handle or email. You
can change your answer at any time under Settings, "Cookie and ad choices".
Premium has no ads. How Google uses this information:
policies.google.com/technologies/partner-sites
Who can see what
Competing for water is off when you join. While it is off, none of your
water appears on the World map, you hold no cells, and you are on no
leaderboard or league; your own map and awards are unaffected. You can switch
"Compete for water" on or off at any time on My map.
If you compete, other paddlers see the name you appear under on the map,
the cells you hold, the awards you have earned, and your position on
leaderboards. That name
is a generated alias such as "Paddler 4821" unless you choose an alias of your
own or choose to show your handle. You can change it at any time on My map.
If you make your profile public, other signed-in paddlers can open it from
the map: the cells you hold, your awards and your totals, under the same name.
Your profile is private until you switch it on. Your paddles, their dates, your
routes and your heat map are never shown to anyone else, public profile or not.
If you turn on "Show who I paddled with", and another paddler who has also
turned it on recorded a paddle on the same water at the same time, each of you
sees the other's map name on that paddle, six hours after you both finished. It
is off until you switch it on, it only ever names someone who has switched it
on too, and it shows nothing about anyone's other paddles. You can switch it
off on My map; names stop showing from then on.
If you turn on river times, your best time down each river stretch is shown
to other paddlers who have paddled that stretch, by your map name. Only your
best time is shown, never when it was or your route. It's off unless you turn
it on.
Notes you write on your paddles (a title and a few lines) are yours alone.
They are never shown to anyone else, and they are included when you download
your data and deleted with the paddle or your account.
Sightings you record (wildlife, a coastal or river feature, an invasive
plant, litter or pollution, a hazard) each keep a point and a time: placed
along one of your paddles, put on the map by hand, or taken from your phone's
location at the moment you press "Mark a sighting here". The phone's location
is read only when you press it, never in the background; without signal the
mark waits on your phone until it can be sent. Other paddlers never see your
sightings. Unless you switch off "Share my sightings" on My map, we share
what each sighting was, where it was (wildlife and other passing things to
about 100 metres, a coastal or river feature exactly), when (to the hour, or
for a feature only the day), how many, a feature's size and tidal access, and
what you wrote about it, with any email address, link, handle or phone number
taken out, with wildlife,
environmental and heritage recording groups, and may publish them in our
own publications. A shared record never carries your name, your account
or anything about the paddle, and we do not share one recorded near the places
you habitually launch from, or until six hours after the paddle. Please do not
name people in what you write about a sighting. Your sightings are included
when you download your data and deleted with the paddle or your account, or
one at a time; what was already shared, carrying nothing that identifies you,
cannot be recalled.
If you join a club, its other members see the water you have paddled on
the club's map, along with your map name, your recent awards, and your share of
the club's paddle and distance totals. Each cell shows how many members have
paddled it, never who or when. Your privacy zones still apply, nothing appears
until six hours after a paddle, and paddles from a source whose terms keep them
private to you are left out. Only members can open a club's page. We keep which
clubs you are in and when you joined; you can leave on the club's page, and
leaving or deleting your account removes you from every club at once.
A club's name is not private to its members. The club leagues, which every
signed-in paddler can see, show each club's name, its distance or count for
the period and how many of its paddlers counted, but never who they are.
If you join a club trip (an outing a member organises), the trip's club sees
that you are going, as a number, and the others going see your map name and
the club you are paddling for. Paddlers from other clubs can join by the
trip's link if its organiser allows it, and an organiser who asks to approve
people sees the map name and club of anyone asking. What you write in the
trip's chat is seen only by those going. Any of them can report a message to
us; we read the report and either leave the message or take it down, and if
we take down something you wrote you see that it was removed and why. The
person you reported is not told it was you. The chat closes a day after the trip
ends and its messages, and any reports of them, are deleted 48 hours after that. Paddles you log during
the trip count towards what it covered: those going see a map of the water covered,
with no names on it, and how much each club paddled; the trip's club sees the
totals. The same privacy zones, six-hour delay and private sources apply.
Leaving a club takes you off the trips it organised, and deleting your account
takes you off every trip and deletes your messages.
Other paddlers do not see your email, your device details, your original
files, your exact routes, or the water inside your privacy zones.
Two protections are on by default and you do not have to switch them on.
*Privacy zones.* Once you have launched from the same place more than once, we
treat it as a habitual put-in and hide the water within 1 km of it from the
public map. Those cells are still yours and still count towards everything.
They are simply not shown next to your name, because a cluster of cells around
one slipway tells a stranger where you launch, and for most people that is
close to where they live. You can widen or narrow the radius.
We never show who is on the water right now. Nothing you upload appears on
the public map until at least six hours after the paddle ended.
We never suggest where to paddle. Fulmaire records where you have been. It
does not point you at water nobody has recorded, because water nobody has
recorded is sometimes unrecorded for a reason.
How long we keep it
Your tracks, claims and awards stay while your account exists, because a
logbook you cannot look back through is not a logbook.
If your account is inactive for three years we will email you, and if we hear
nothing within 30 days we delete it. Server logs are kept 90 days. The record
of which parts of the app you used is kept 400 days, so one season can be set
beside the last. Deleted
accounts are gone within 30 days, including backups.
Your rights
Under the GDPR you can get a copy of your data, correct it, delete it, object
to processing, restrict it, and take it elsewhere.
Two of these are buttons rather than requests:
- Download everything — in your account settings, or
GET /api/me/export. - Delete everything — in your account settings, or
DELETE /api/me.
Deletion removes your account, your tracks, your original files and every
record of where you paddled. Cells you held return to whoever held them before
you. Anything else, email support@fulmaire.com and we will respond within one month.
You can complain to the Data Protection Commission, 21 Fitzwilliam Square
South, Dublin 2, or to your own supervisory authority.
Where it is stored
On servers in the European Union — Amsterdam — and backed up continuously to
object storage also held in the EU.
Our hosting (Fly.io), backup (Cloudflare) and sign-in (Google) providers are
US companies. We use their EU locations for your data, but we cannot rule out
that they, or their support staff, can reach it from outside the European
Economic Area. Where that can happen, it is covered by the safeguards the GDPR
requires for it, such as the European Commission's standard contractual
clauses in each provider's data processing terms. Ask us and we will tell you
which applies to each one.
Signing in
You sign in with an account you already have, currently Google. We never see
your password. Google tells us a permanent identifier for your account and the
email address on it, and we keep both: the identifier so that signing in again
reaches the same paddling history, and the address so you can see which account
you linked. Signing in tells Google that you use Fulmaire.
You can see what we hold under *Your rights*, and deleting your account deletes
the link along with everything else.
Connected apps
You can connect an account you already have elsewhere, so that new paddles
arrive without you uploading them. Two are offered: Polar, for Polar watches,
and intervals.icu, a free training site that Garmin watches can send to.
Nothing is connected unless you press Connect and agree on that service's own
page.
Once connected, the service tells us when you have recorded a new activity,
and we fetch that one file from it. It is the same kind of file you could have
uploaded yourself, and we treat it exactly as an upload: a walk or a run is
skipped, a paddle goes on your map, and the privacy zones and six-hour delay
apply as usual. We keep the service's identifier for your account and the
access key it gives us, so that we can ask for new files and nothing else. The
key is never shown to anyone, including you, and is not in your data download.
You can disconnect on My map at any time. That stops new paddles arriving;
paddles already here stay until you delete them or your account. Each service
is a separate company with its own privacy notice, and connecting tells it
that you use Fulmaire.
The Fulmaire field on a Garmin watch
If you add the Fulmaire field to your watch, it keeps your position every ten
seconds while your activity's timer runs, and sends it to us through the
Garmin Connect app on your phone every few minutes. It records only while it
is on the activity you added it to, and only while the timer is running. What
it sends is kept as sent, in the same way we keep every uploaded file, and
becomes a paddle once the activity ends. From then on it is treated exactly
as an upload: the privacy zones and the six-hour delay apply as usual.
You link the watch by typing a code from My map into the field's settings.
The watch then holds a key of its own, and we keep only a scrambled form of
it. Disconnecting on My map stops the watch sending; removing the field from
your activity stops it recording. The points travel through Garmin's apps on
your watch and phone, so Garmin's own privacy notice also applies to them.
Processors
- Fly.io — hosting, Amsterdam. The application and the ledger.
- Cloudflare — R2 object storage, EU jurisdiction. Continuous backup of the
ledger.
- Google — sign-in only (OpenID Connect). No paddling data is sent to
Google; we receive an identifier and an email address.
- Google Workspace — email, including support@fulmaire.com.
- A payment provider, once billing exists.
Each under a data processing agreement. Current list on request.
Children
Fulmaire is not intended for under-16s and we do not knowingly hold their data.
Changes
We will email you before anything material changes.
Part 2 — Record of processing (Article 30)
*Internal. Required if asked; users never see it.*
| Field | Entry |
| Controller | Razorbill Technology Limited, Kildee, Dunmanway, Co. Cork, P47 NH01, support@fulmaire.com |
| DPO | Not required at this scale. Contact point: support@fulmaire.com |
| Purposes | Recording and recognising paddled water; shared map; leaderboards; account security; counting which parts of the app are used; advertising on the free version |
| Categories of data subject | Registered paddlers |
| Categories of data | Precise location traces with timestamps; device identifiers; handle; email; connected-app account identifiers and access keys (Polar, intervals.icu, the Garmin field); derived claims, awards, ownership; which parts of the app each paddler used, by day |
| Special categories | None intended. See the risk note below |
| Recipients | Hosting provider; email provider; Google, for ads on the free version, receiving no location data. No data brokers, no sale |
| Third country transfers | Possible, through US-owned processors (Fly.io, Cloudflare, Google) using EU locations; covered by each processor's GDPR transfer safeguards, such as standard contractual clauses |
| Retention | Account lifetime; 3 years inactivity then deletion; logs 90 days; app use by day 400 days; deletion completes within 30 days including backups |
| Security | TLS in transit; Fulmaire sign-in tokens stored as SHA-256 hashes only; connected-app access keys stored as issued (they must be presented to the provider), never exported or displayed, deleted on disconnect; per-account rate limiting; ledger on an encrypted volume; daily snapshots with 14-day retention |
Risk note, recorded deliberately. Location traces can reveal special
category data by inference — a route ending at a place of worship every Sunday,
or at a hospital. Fulmaire does not seek this and cannot prevent it existing in
an uploaded file. Mitigations: privacy zones on by default, no route geometry
exposed publicly, original files never shared. This is the residual risk that
most justifies keeping the public surface as small as it is.
DPIA. Likely required: systematic monitoring of location at scale is on the
supervisory authority's list. Commission one before public launch.
Part 3 — Legitimate interest assessment
For the processing activities that rely on it.
A. Showing your claims to other paddlers
Purpose. A shared map is the product. Territory nobody else can see is a
private logbook, which is a different and much less useful thing.
Necessity. No less intrusive option achieves it. Fully anonymous claims
would remove the recognition that is the entire point.
Balancing. In the paddler's favour: they chose to join a shared map, the
public surface is a name (an alias unless they choose to show their handle)
plus a hexagon, no route geometry or timing is
published, privacy zones are on by default, and publication is delayed six
hours. Against: cumulative claims still reveal a pattern of activity.
Conclusion. Proportionate, with those mitigations, and only with them. A
right to object is offered and honoured by deleting the account or making it
private.
B. Keeping original uploaded files
Purpose. The ledger is derived from the file by a cleaning and mapping
pipeline. Without the original, a bug fix or a resolution change cannot be
applied to past paddles, and a paddler's history would be silently frozen at
whatever the code did on the day they uploaded.
Necessity. No alternative. Derived data cannot be re-derived from itself.
Balancing. In the paddler's favour: files are never shared, are deleted
with the account, are stored on the same encrypted volume, and the benefit
accrues to them — their own history improves. Against: it is the most detailed
data we hold and it is retained longest.
Conclusion. Proportionate, provided files are never shared and deletion is
genuinely complete.
C. Counting which parts of the app are used
Purpose. Knowing whether people come back between paddles and which parts
of the app they use, so effort goes where it helps and unused parts can be
removed. Uploads alone cannot tell one person ten times from ten people once.
Necessity. Totals with nothing per person cannot answer "did they come
back". A day and the name of a part is the least that can.
Balancing. In the paddler's favour: one mark per part per day, no times,
no positions, no taps; counted by Fulmaire on its own server from requests the
app already makes, with no tracker, no extra cookie and no third party; read
only as totals; included in the export, deleted with the account, kept 400
days. Against: it is a record of the days someone opened the app.
Conclusion. Proportionate at that grain. Anything finer, or anything
shared, would need a fresh assessment and probably consent.