Version 2026-09-25 · Last updated 25 September 2026
Lowen's Tides runs on WhatsApp. To join the waitlist we ask for one thing: your phone number — and we only have it because you messaged us first.
Brewyon & Co Ltd is the data controller for the personal data described in this notice. That means we decide why and how it is used, and we are responsible for it.
| Company | Brewyon & Co Ltd, registered in England and Wales |
| Company number | 17343425 |
| Registered office | 66 Paul Street, London, England, EC2A 4NA |
| Data protection contact | Joshua Marsh — josh@brewyon.com |
| ICO registration | ZC200666 |
We have not appointed a Data Protection Officer, and we are not required to: none of the conditions in Article 37(1) UK GDPR applies to us. Joshua Marsh is our point of contact for anything in this notice.
| What | Why | Lawful basis |
|---|---|---|
| Your phone number, from WhatsApp | To send you one message when Lowen's Tides opens | Consent — Article 6(1)(a) UK GDPR, and regulation 22 PECR for the message itself |
| The date and time you agreed, the version of this notice you were shown, the exact wording you agreed to, and the message you sent to agree | To prove your consent was properly obtained, as Article 7(1) requires us to be able to do | Legal obligation — Article 6(1)(c) |
| A campaign tag from the link you clicked, if there was one | To know which posts brought people in | Legitimate interests — Article 6(1)(f) |
| What | Why | Lawful basis |
|---|---|---|
| The messages you send us — place names, dates, questions | To answer them. "Padstow tomorrow" is the request | Contract — Article 6(1)(b) |
| A location pin, if you choose to share one | To work out which stretch of coast you mean. We round the coordinates we store to roughly 1 km | Contract |
| Places you save, and your usual spot | So you don't have to type them again | Contract |
| A spot watch: the place you asked about and its rounded coordinates | So Lowen can tell you if the sewage monitors near it start running. Kept 7 days from the last time you asked, then deleted. A watch you set yourself with "watch place" stays until you say "unwatch place" | Contract — Article 6(1)(b) |
| Which spill we have already told you about | So the same overflow isn't reported to you over and over | Contract |
| A record of messages received and sent | Security, preventing abuse, and not answering a retried message twice | Legitimate interests — Article 6(1)(f) |
| What | Why | Lawful basis |
|---|---|---|
| Your phone number, encrypted | So Lowen can send you the tides at the time you chose. Every other message is a reply, where WhatsApp tells us who you are; a scheduled one is the only thing we start, and we cannot start it without your number | Contract — Article 6(1)(b) |
| Your plan, its status and its dates | To know what you are entitled to | Contract |
| Stripe's customer and subscription identifiers | So a payment can be matched to an account, changed or cancelled | Contract |
| Your email address, held by Stripe, not by us | Receipts, and so we can reach you about your subscription if WhatsApp is ever unavailable | Contract |
| Who referred you, and any bonus days | To honour "give a month, get a month" | Contract |
| Your delivery choices, daily or weekly, the day, the time, and your usual spot | So the tides arrive when and where you asked | Contract |
| A holiday spot and dates, if you set them | So Lowen follows you for the week. They stay until you clear them or your subscription ends | Contract |
| Your personal share code and how often it has been used | To run "give a month, get a month" from your side too | Contract |
Lowen also sends the occasional message when something at your spot is worth knowing: the sea passing a temperature, or an unusually low tide two days ahead. "Updates off" stops these along with the Sunday digest.
We never see or store your card details. Payment is handled entirely by Stripe.
If you buy a gift year for someone else: Stripe processes your payment and holds your email, as above; we hold only the gift code you're given, the reference for the payment that bought it, and once it is redeemed, the recipient's subscription. We learn nothing about the recipient until they message Lowen themselves, and nothing about you beyond the purchase. We never ask you for your name, date of birth or home address. We do not need them.
When you reply STOP we delete your waitlist entry, but we keep one thing: a scrambled one-way marker derived from your number, with the date. That is how we know never to contact you again. We are required to honour an opt-out, and we cannot do that with no record of who opted out. It holds no number, no message content and nothing else, and we keep it indefinitely. This is permitted by Article 17(3)(b) UK GDPR.
Your number is the only identifying thing we hold, so we treat it accordingly:
We use a small number of service providers. They process data on our instructions under written contracts meeting Article 28 UK GDPR, except where noted.
| Provider | What they do | Where |
|---|---|---|
| Meta Platforms Ireland Ltd (WhatsApp) | Carries the messages. Meta also processes data about your use of WhatsApp under its own privacy policy, as a separate controller — we do not control that, and we'd encourage you to read it | Ireland |
| Stripe Payments Europe Ltd | Takes payment and holds your email address for receipts and subscription notices. We never see your card details | Ireland, with sub-processors in the United States |
| Vercel | Runs the service | London (UK) |
| Supabase | Database | European Union |
| UKHO Admiralty, Open-Meteo, Environment Agency, Ordnance Survey | Supply tide, weather, water-quality and place data, and the maps the app draws. They receive a place name or a coordinate — never your number, and nothing that identifies you. The maps are fetched by our server rather than by your phone, so Ordnance Survey never sees your device | UK / EU |
| OpenStreetMap Foundation (Nominatim) | Turns a place name into a point on the map, and a dropped pin back into a place name. It receives the place name you typed or the coordinates of your pin, never your number, and nothing that identifies you | UK / EU |
| The water companies: South West Water, Wessex Water, Southern Water, Thames Water, Anglian Water, Severn Trent Water, Yorkshire Water, Northumbrian Water, United Utilities and Scottish Water | Publish the live storm-overflow feeds behind Water UK's Stream. When you ask about a spot, we ask each of them what is spilling near it, so each of them receives those coordinates, never your number, and nothing that identifies you | UK / EU |
Transfers outside the UK. Everyone in the table above processes your data in the UK or the European Economic Area, with one exception: Stripe is established in Ireland but uses sub-processors in the United States. For that transfer we rely on UK adequacy regulations where they apply, including the UK Extension to the EU–US Data Privacy Framework, and otherwise on the International Data Transfer Addendum to the EU Standard Contractual Clauses, with a transfer risk assessment on file. You can ask us for a copy of the safeguards in place.
We will also disclose data where we are legally required to — a court order, or a lawful request from a regulator or the police.
| Data | Kept for |
|---|---|
| Waitlist entry, never confirmed | 90 days, then deleted automatically |
| Waitlist entry, confirmed, before we launch | Until we launch and message you — and in any case no more than 18 months, after which we delete it rather than message you on stale consent |
| Waitlist entry, after we have sent the launch message | 12 months, so we can answer any complaint about that message, then deleted |
| Spot watch from asking about a place | 7 days from the last time you asked about it |
| Spot watch you set yourself | Until you remove it, or your subscription ends |
| Record of which spills you were told about | 3 months |
| Waitlist entry, where you were let in by an invite or gift code | Kept while your subscription lasts, because it records how you joined, then 24 months after it ends |
| Waitlist entry, after you reply STOP | Deleted immediately |
| Opt-out marker (section 2.3) | Indefinitely — it is what stops us contacting you again |
| Message records | 12 months |
| Favourites and settings | Until you delete them, or 24 months after you last use the service |
| Subscription and payment records | While your subscription is active, then 24 months — the record that someone paid us carries tax and consumer-law duties of its own |
| A trial that never became a subscription | 24 months from its end — long enough that a used trial is remembered, and no longer |
| Delivery settings, milestone history, your share code | Deleted with your subscription |
| Cached tide, weather and place data | Contains nothing about you; kept while it is useful |
Under UK GDPR you have the right to:
Complain to us first, if you're willing — we would rather fix it. Email josh@brewyon.com with "Data protection complaint" in the subject line, or reply to Lowen on WhatsApp with the word COMPLAINT and we will pick it up. You don't need to use any particular form of words.
We will acknowledge your complaint within 30 days and respond as quickly as we can after that.
You can also complain to the regulator at any time, whether or not you come to us first. The Information Commissioner's Office: ico.org.uk/make-a-complaint, or 0303 123 1113, or Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Lowen's Tides is not intended for children under 16, and we do not knowingly collect their data. If you believe a child has joined the waitlist, email us and we will delete the entry.
We set no cookies, and we use no analytics or tracking of any kind. Fonts, images and everything else are served from our own domain, so loading a page contacts no third party at all.
Your private tide page is a web app, and it does keep a few things in your own browser's storage on your device. We are telling you because the rules on storing anything on your device are not limited to cookies. What it keeps:
| What | Why |
|---|---|
| Your access token, from the private link | So the page opens without the link every time |
| Tide and conditions data you have already loaded | So the page works when the signal goes |
| Which view you last had open | So it opens where you left it |
All three are needed to give you the page you asked for, which is what the law allows without asking your permission first. None of it is analytics, none of it is shared with anyone, none of it leaves your device, and clearing your browser data removes all of it. Installing the page to your home screen also stores it for offline use, for the same reason.
If we change anything material we will update the version number at the top and, where the change affects what you consented to, ask you again. Previous versions are available on request.
Lowen's Tides is for general information. Conditions at sea change fast, our data comes from third parties and can be wrong, delayed or missing, and it must not be used for navigation or relied on for safety. Always check official sources and use your own judgement. In an emergency at sea, call 999 and ask for the Coastguard.