What we collect, what we deliberately do not, and why a seafarer can use MWApp without telling us who they are.
International Maritime Welfare Innovation Research and Support Association (IMWIRSA) is a non-profit association established in Estonia. This policy explains how we handle personal data on this website, in MWApp, and across our research, correspondence and welfare initiatives more broadly — in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR).
MWApp needs no registration, no email address and no phone number. A seafarer can use it without telling us anything about themselves.
What MWApp remembers — a name if given, a chosen assistant, a marked ship position — stays in the phone's own storage. We do not receive it.
We measure how many times the app is opened — in aggregate and by port. We do not track what any individual does inside it.
Last updated: 1 November 2026. MWApp is in active development and currently has no server of its own for the app itself. When that changes, this policy will be updated before the change goes live, and the date above will tell you when.
MWApp is a progressive web app. It runs in the browser and, at present, has no back-end server. That is not a temporary shortcut — it is why so little data exists to protect.
All of the following is kept in the phone's local storage. It never leaves the device, and we have no way to read it:
All of it can be erased at any time from Settings → Clear my data. Because nothing is held on a server, deletion is immediate and final — there is no copy anywhere for us to remove.
MWApp can use the phone's location for two things, and only when the seafarer asks it to. The first is finding the nearest port: the coordinates are used for a single calculation on the device and are then discarded — only the result, which port, is kept. The second is marking where the ship is docked, so the seafarer can find their way back. That position is stored on the phone and is handed to the phone's own maps application when navigation is requested. Neither is transmitted to us.
The assistant works right on the phone, without internet. It understands the question with a small language model that is downloaded to the phone together with the app, and it answers from the checked data of the port cards and from prepared answers. Nothing you type in the chat is sent anywhere — not to us, not to anyone else.
The conversation history is kept only on the phone, so the conversation isn't lost when you close the app. You can erase it with “Start new conversation” in the chat or with Settings → Clear my data. If the assistant suggests writing to the IMWIRSA Central Office or a helpline, WhatsApp opens — the chat text is not copied there; you decide what to write.
An online assistant that works over the internet is being prepared. Before it launches, this section will be extended to say plainly, in advance, what will be sent and where.
We need to know roughly how many seafarers have the app on their phone. That number matters to the unions and welfare organisations we work with, because it shows whether seafarers actually want this. We measure it by recording that the app was opened from a home screen rather than from a browser. The record is a page count and nothing more: it contains no identifier, no MWA-ID, and nothing that could distinguish one seafarer from another.
We count openings by port in the same way. The code of the port selected in the app (for example, tallinn-muuga) is added to the page address, and the Cloudflare Web Analytics counter sees only that code. It is not the phone's location and is not linked to anyone personally.
If you choose to send a “Something wrong in port?” report from the app, or answer the “How are things going?” survey, the text reaches us by e-mail at info@imwirsa.org through the FormSubmit service. With it come the port, the section, the app language and a random message number (for example, MW-4K7Q), which lets you see later that it was fixed. No name is needed and no MWA-ID is sent. We receive a contact (e-mail or WhatsApp) only if you entered one yourself so that we can answer you personally, and we use it only for that answer. A copy of your messages stays on your phone and is deleted with Settings → Clear my data.
We use Cloudflare Web Analytics. It sets no cookies, stores nothing on your device, and does not identify visitors by IP address or browser fingerprint. It tells us how many pages were viewed and roughly where visitors came from. Nothing more, and nothing about you personally.
The contact form sends what you type to us by email through a mail relay we operate ourselves (a Cloudflare Worker) using Resend as the email delivery service, which acts as a processor. That means your name, email address and message pass through Resend's systems on the way to info@imwirsa.org. Messages are then held in our mailbox for as long as needed to deal with your enquiry and to keep a record of the partnership.
If you would rather not use the form, write to us directly at info@imwirsa.org. It reaches the same place, one step shorter.
Coordinators who send us port information give us their name, organisation and contact details so that we can work with them. Their name appears in the app only if they have agreed to it — we ask explicitly, and the default is no. This information is not shared with anyone outside IMWIRSA.
We do not sell data. We do not share it with advertisers. We run no advertising. We do not build profiles of seafarers, and we do not pass information about any seafarer to a shipowner, a manning agent or an employer. This last point is not merely a policy — it is the reason MWApp is designed without accounts in the first place.
This section exists because it needs to under the GDPR — it is more technical than the rest of this page on purpose.
Depending on the situation, we rely on one of the following: your consent (for example, agreeing to have your name shown in the app, which you can withdraw at any time); our legitimate interest in running IMWIRSA and communicating with partners, coordinators and researchers; steps necessary for an agreement or cooperation we've entered into with you or your organisation; or, occasionally, a legal obligation we're required to meet.
Where we collect personal data through surveys or research — including the port questionnaires our coordinators complete — participants are told what it's for and how it will be used. Where the purpose allows it, results are presented in aggregated or anonymised form. Participation in voluntary IMWIRSA surveys is voluntary unless stated otherwise.
IMWIRSA works with port coordinators, unions and welfare organisations across a genuinely international network — as of today, that includes people in Georgia and Türkiye alongside those inside the EU, and the network keeps growing. Where personal data crosses outside the European Economic Area as a result — for instance, a coordinator's own contact details, submitted from where they work — we take the safeguards required under GDPR for that transfer.
We do not sell personal data, and we share it only where genuinely necessary — with a service provider actually helping run something (like Resend, above), or where the law requires disclosure. Where someone processes data on our behalf, we put the appropriate data protection terms in place.
We keep personal data only for as long as it's actually needed for the reason we collected it, or as long as the law requires — this varies by what it is and why we have it, so we don't give a single fixed number here.
IMWIRSA is established in Estonia and is subject to the General Data Protection Regulation.
You may ask what we hold about you and have it corrected. For most seafarers the answer will be: nothing, because the app never sent us anything.
You may ask us to erase what we hold. In the app you do not need to ask — Settings → Clear my data does it immediately.
You may ask us to limit how we use your data, or object to a particular use of it — for example, being listed by name as a port coordinator.
Where it applies, you may ask for a copy of your data in a portable format to take elsewhere.
Where we rely on your consent — like showing your name in the app — you can withdraw it at any time, with effect going forward.
If you believe we have handled your data wrongly, you may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
To exercise any of these rights, write to info@imwirsa.org. We answer within 30 days, usually much sooner.
Data controller: IMWIRSA — International Maritime Welfare Innovation Research and Support Association, Estonia. Contact: info@imwirsa.org
This policy was last updated on 11 August 2026. Earlier versions are available on request.