This policy explains what personal data the Freediver app ("Freediver", "we", "us") collects, why we collect it, how we use and share it, how long we keep it, and the rights you have over it. It applies to the Freediver mobile app and its backend service.
The data controller responsible for your personal data is [COMPANY_LEGAL_NAME]. For any privacy question or to exercise a right below, contact us at [CONTACT_EMAIL].
Freediver is not directed to children. You must be at least 16 years old to create an account. We ask you to confirm your age at sign-up. If we learn we have collected data from someone under the minimum age, we will delete it.
We practise data minimization: we collect only what the app needs to work. The categories are:
| Category | Examples | Why | Lawful basis (GDPR) |
|---|---|---|---|
| Account & identity | Email address, and a username you choose | To create and secure your account, and let friends find you by username | Contract |
| Dive & training logs | Depths, times, disciplines, breath-hold data, ratings, notes, and any dive-computer files you import | The core logbook: to store, display, and chart your own activity | Contract |
| Location | An optional home location, and coordinates of dive sites you add | To center your map and record where you dived — only when you provide it | Consent |
| Social | Friends, friend requests, blocks, and messages you send | To provide friend and chat features you choose to use | Contract |
| Consent records | Which policy version you accepted and when | To prove lawful consent | Legal obligation / legitimate interest |
| Technical & diagnostic | App version, device/OS type, and error logs | To keep the app working and fix bugs | Legitimate interest |
Freediving logs describe physical performance (depth, breath-hold duration, heart rate from an imported device). Depending on where you live, some of this may be treated as health-related or otherwise sensitive data. We use it only to provide the logbook and the statistics you ask for. We do not use it for advertising, and we do not sell it. Where the law requires explicit consent for such data, your use of the logging features and your acceptance of this policy constitute that consent, which you may withdraw at any time by deleting the data or your account.
We use your data to: operate the logbook and statistics; provide the map, events, and social features you choose to use; secure your account and prevent abuse; respond to your requests; and meet legal obligations. We do not sell your personal data, and we do not use it for third-party advertising or cross-context behavioural advertising. We do not use your data for automated decision-making that produces legal or similarly significant effects.
We share personal data only in these limited cases:
Your data may be processed in countries other than where you live, including where our service providers operate. Where required, we rely on recognized transfer mechanisms (such as the European Commission's Standard Contractual Clauses) to protect it.
We keep your account and log data for as long as your account is active. When you delete your account, we erase your private logbook and social graph promptly. Some data is kept longer where we have a legal basis: content reported for abuse may be retained for moderation and legal-claims purposes, and shared community content you contributed may remain visible but is disassociated from your identity. Backups are cycled out on a rolling schedule.
Depending on where you live (for example under the GDPR, UK GDPR, or the California CCPA/CPRA), you have some or all of these rights:
To exercise a right you can use the in-app tools or contact [CONTACT_EMAIL]. We will respond within the time the law requires.
We protect your data with encryption in transit and at rest, access controls, and least-privilege practices. Authentication is handled by our identity provider; we never store your password. No system is perfectly secure, but we work to protect your data and will notify you and the relevant authorities of a breach where the law requires.
We may update this policy. When we make a material change we will update the version and effective date above and, where appropriate, ask you to review or re-accept it. Continued use after an update means you accept the revised policy.
Questions or requests: [CONTACT_EMAIL]. Data controller: [COMPANY_LEGAL_NAME]. Governing jurisdiction: [GOVERNING_JURISDICTION].