Privacy Policy
This Privacy Policy explains how Scubbl collects, uses, shares, retains, and protects personal data processed in connection with the mobile application, the website, and the related services.
It supplements the Terms of Use, the Terms and Conditions of Sale where a purchase or subscription is involved, the Cookies and Tracking Technologies Policy, the GDPR Rights page, and the Account Deletion and Deactivation page.
In this policy, “Scubbl”, “we”, “our”, or “us” means the Scubbl service. “You”, “your”, or “user” means any person who uses the application, the website, or the related services.
1. Data controller and contact
The Scubbl service is published under the trade name Scubbl. The data controller is the publisher of the Scubbl service, as identified in the legal notice applicable to the service.
For any question relating to the protection of personal data or to exercise your rights, you may contact Scubbl at privacy@scubbl.com. For general requests, you may use contact@scubbl.com.
Scubbl acts as data controller for personal data processed as part of the operation of its services, except where a service provider acts as an independent controller for its own purposes, for example certain payment services, app stores, or advertising partners.
2. Scope
This policy applies to personal data processed when you use Scubbl, including when creating an account, managing your profile, publishing content, and using community, mapping, weather, species, dive spot, region, statistics, subscription, support, reporting, moderation, and security features.
It applies to registered users, website visitors, clubs, free or paid users, and any person interacting with Scubbl.
3. Personal data collected
Scubbl collects only the data necessary for the purposes described in this policy. Some data is necessary to create an account or use the service, while other data depends on your choices, settings, system permissions, or consent.
3.1 Data provided when creating and managing the account
When you create or manage an account, Scubbl may process your surname, first name, email address, user identifier, username or pseudonym, password in protected form or technical authentication data, date of birth, sex, language, country or approximate geographic area, account creation date, account settings, and account status.
The date of birth may be used to verify the minimum required age, adapt certain features, limit certain uses, or comply with safety and user protection obligations.
3.2 Profile data and settings
When you complete your profile or configure the application, Scubbl may process your profile photo or avatar, biography, diving level or experience, certifications or information related to diving practice, clubs followed or associated with you, and your display, language, privacy, and notification preferences.
Some profile information may be visible to other users where the community nature of the service, your settings, or the features used imply this.
3.3 Published or transmitted content
Scubbl processes content that you create, publish, upload, share, or transmit, including posts, text, comments, images, species observations, references to dive spots, regions or clubs, shared activities, reactions, likes, favourites, community contributions, reports, and messages sent to support.
When you publish content in a community or public area, that content may be visible to other users, clubs, visitors and, only where the content is made publicly accessible through the service, search engines. You should avoid publishing confidential or sensitive information, or information that you do not want to make visible.
3.4 Activity, diving and observation data
When you use logbook, tracking or activity-sharing features, Scubbl may process the information that you enter or associate with an activity, such as the date, place, dive spot, observed species, declared conditions, associated weather or environmental data, depth, duration, visibility, temperature, difficulty level, photos, media, statistics, history, badges, challenges, and calculated indicators.
This data is used to provide the activity logbook, statistics, memories, community features, and recommendations related to your use of Scubbl.
3.5 Location and mapping data
Scubbl may process location data where necessary to display nearby dive spots, species, regions or content, associate an activity with a place, display a map, provide geographic recommendations, perform reverse geocoding, or improve the relevance of displayed content.
Precise location is used only if you allow it from your device or the application. You may withdraw this permission at any time from your device settings. Scubbl may also process an approximate location, inferred for example from your IP address, a manually selected region, or an interaction with the map.
3.6 Purchase, subscription and access-rights data
When you subscribe, make a purchase or use a paid feature, Scubbl may process the subscription status, the type of offer subscribed to, the start, renewal, expiry or cancellation dates, technical transaction identifiers, a limited history of purchase events, and the information necessary to verify premium or club access rights.
Payments are processed by the relevant stores or payment providers. Scubbl does not collect full bank card numbers when purchases are made through the Apple or Google in-app purchase systems or their associated providers.
3.7 Technical, security, device and notification data
When using Scubbl, certain technical data may be collected automatically, including IP address, device type, operating system, application version, device language, technical identifiers, connection logs, error events, diagnostic information, and data necessary to prevent abuse, fraud, spam, or unauthorised access.
If you enable push notifications, Scubbl may also process a technical notification token in order to send the notifications that you have authorised or that are necessary for the operation of the service. You can disable these notifications from your device settings or, where the option is available, from the application settings.
3.8 Advertising data, consent and advertising identifiers
When Scubbl displays advertising, certain data may be processed to display ads, measure their delivery, limit repetition, prevent advertising fraud and, if you consent, personalise advertisements. This data may include your advertising consent status, your device advertising identifier, for example IDFA on iOS or Advertising ID on Android where available and authorised, technical identifiers linked to the application or device, information relating to the display of or interaction with an advertisement, and diagnostic and security information.
In the European Union, the United Kingdom and Switzerland, advertising processing subject to consent is enabled only where you have given your consent through the consent screen shown in the application or an equivalent mechanism. You may also manage certain permissions from your device settings, including ad tracking on iOS, the advertising identifier on Android, and its reset or limitation.
Detailed information on cookies, SDKs, trackers, advertising identifiers, and choice-management methods is provided in the Cookies and Tracking Technologies Policy.
3.9 Data processed through automation or artificial intelligence
Scubbl may use automation or artificial intelligence tools to translate, improve, adapt, organise, moderate or enrich certain content, and to improve the quality of the data displayed in the application. Where user content is processed by these tools, Scubbl limits the data transmitted to what is necessary for the relevant purpose.
Scubbl does not make decisions producing legal effects concerning you, or significantly affecting you, solely on the basis of fully automated processing.
4. Source of the data
Data processed by Scubbl may come directly from you when you create an account, complete a profile, publish content, configure your settings, contact support, or use application features.
It may also be generated automatically when using the service, for example when the application produces technical logs, calculates statistics, associates an activity with a place, or stores information necessary for security.
Finally, some data may come from third parties where this is necessary for the operation of the service, including app stores, subscription services, hosting providers, mapping services, weather services, reverse-geocoding services, advertising services, translation tools, or technical processing services.
5. Purposes and legal bases
Scubbl processes personal data only where this is necessary for a specific purpose and, depending on the case, relies on performance of the contract, the user’s consent, compliance with a legal obligation, or Scubbl’s legitimate interest.
Account, profile, authentication, settings, published-content, activity, observation, community-interaction and, where applicable, subscription data is mainly processed to create and manage the account, provide application features, allow content to be published and viewed, manage free or paid services, provide user support, and perform the terms applicable to the service.
Some data may be processed on the basis of the user’s consent, including when the user authorises access to precise location, enables certain notifications, accepts trackers or advertising identifiers subject to consent, or chooses to use an optional feature requiring a specific permission. Consent may be withdrawn at any time, without affecting the lawfulness of processing already carried out.
Scubbl may also process certain data on the basis of its legitimate interest, including to ensure the security of the service, prevent abuse, fraud, spam or unauthorised access, moderate content, handle reports, maintain and improve the technical operation of the application, produce aggregated or anonymised statistics, retain items necessary to defend its rights, and protect users or the integrity of the platform.
Finally, certain data may be retained or processed in order to comply with legal, accounting, tax or regulatory obligations, or to respond to a request from a competent authority.
6. Mandatory and optional data
Some data is necessary to create an account, authenticate the user, provide essential features, secure the service, process a purchase, or comply with a legal obligation. If you refuse to provide this data, certain features may be unavailable or the service may not be able to be provided.
Data related to certain optional features, such as profile photo, biography, certain diving information, precise location, push notifications, personalised advertising, or certain published content, is processed only if you choose to use the relevant feature, grant the corresponding permission, or give your consent where required.
7. Visibility of content and public information
Scubbl is a community application. Depending on your settings and the features used, certain information may be visible to other users, including your username or pseudonym, profile photo, biography, posts, comments, images, species observations, shared activities, interactions, groups, clubs, dive spots, or regions associated with content.
You remain responsible for the information that you choose to publish. Scubbl does not control screenshots, copies, or re-sharing carried out by other users outside the features provided by the service.
8. Recipients and sharing of data
Scubbl does not sell your personal data. Data may be disclosed only where this is necessary, proportionate, and consistent with the purposes described in this policy.
Recipients may include other users where you publish or make content visible, authorised members of the Scubbl team where access is necessary for operation, support, security or moderation, technical providers involved in hosting, authentication, databases, media storage, mapping, weather, reverse geocoding, in-app purchases, subscriptions, advertising, notifications, translation, content enrichment, maintenance or security, and competent authorities where required by law or where necessary to protect the rights, security or integrity of the service.
Providers process data according to Scubbl’s instructions where they act as processors. Some providers may also act as independent controllers for their own purposes, including certain stores, payment services, or advertising partners, according to their own privacy policies.
9. Cookies, SDKs and trackers
Scubbl may use cookies, SDKs, advertising identifiers, or similar technologies on its website or in its application. Some are necessary for the operation of the service, while others may be used for measurement, advertising, personalisation, or security.
Where required by regulation, these trackers are used only after your consent has been obtained. Details relating to the trackers used, purposes, retention periods for your choice, and consent-management methods are provided in the Cookies and Tracking Technologies Policy.
10. Retention periods
Scubbl retains personal data only for the period necessary for the purposes for which it is processed, subject to applicable legal, accounting, tax, contractual, or litigation-related obligations. Actual retention periods may vary depending on the nature of the data, the feature used, the user’s choices, and applicable obligations.
By way of indication, account data is retained for the lifetime of the account, unless a longer retention obligation applies; profile data is retained until it is modified, deleted or the account is deleted; posts, comments, media, activities and observations are retained until they are deleted, moderated, anonymised or the account is deleted, depending on the case; precise location data is retained for the period necessary for the relevant feature, unless it is associated with published content or an activity retained in the account; purchase and subscription data is retained for the period necessary to manage rights, contractual follow-up and compliance with legal, accounting or tax obligations; support requests are retained for the period necessary to process them and then, if necessary, archived on a limited basis; reports and moderation data are retained for the period necessary for security, moderation, abuse prevention and dispute management; technical and security logs are retained for a limited period appropriate to operational, security, diagnostic and evidentiary needs; advertising and tracker consents are retained according to the periods specified in the cookies and trackers policy.
When data is no longer necessary, it is deleted, anonymised, or archived where required by law.
11. Account deletion, deactivation and anonymisation
You may deactivate your account or request its deletion according to the procedures available in the application. For security and authentication reasons, certain account-related requests must be made from within the application where this makes it possible to verify that you are the account holder.
Account deletion results in the deletion or anonymisation of personal data that no longer needs to be retained. Some data may be retained temporarily where this is necessary to comply with a legal obligation, prevent fraud or abuse, ensure the security of the service, handle a claim, report or dispute, retain contractual or accounting evidence, or preserve the integrity of community content where it is anonymised.
Detailed procedures are described on the Account Deletion and Deactivation page.
12. Security
Scubbl implements technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure, or misuse. These measures may include authentication, access control, permission restrictions, secure communications, technical logging, backups, role separation, application security rules, and mechanisms to prevent abuse or unauthorised access.
No security measure can guarantee absolute protection. You must also protect your login credentials, use a strong password, avoid sharing your account, and avoid publishing sensitive information in public areas.
13. Transfers outside the European Union
Some providers used by Scubbl may process data outside the European Union or the European Economic Area. Where such transfers occur, Scubbl ensures that they are governed by appropriate safeguards, including an adequacy decision, standard contractual clauses, supplementary measures where necessary, or any other mechanism recognised by applicable regulation.
14. Minors
Scubbl is not intended for children who do not meet the age required to use the service under applicable regulation, the terms of distribution platforms, and the Terms of Use.
The date of birth may be used to verify the minimum required age, adapt certain features, or limit certain uses. If Scubbl discovers that an account has been created by a person who does not meet the required age or necessary authorisation, the account may be limited, suspended, or deleted.
15. Sensitive data
Scubbl does not ask users to publish sensitive data in community areas. You should avoid publishing sensitive or confidential information, including health data, medical information, personal documents, financial information, data relating to minors, or information that could precisely identify a person in a high-risk context.
If you choose to publish content that directly or indirectly reveals sensitive information, you do so under your own responsibility, subject to the moderation rules, the Terms of Use, and the measures that Scubbl may take to protect users or comply with the law.
16. Your rights
In accordance with applicable regulations, you may have a right of access, rectification, erasure, objection, restriction of processing, portability, withdrawal of consent, a right not to be subject to a decision based solely on automated processing producing legal or significant effects, and the right to define instructions regarding the fate of your data after your death.
You may exercise your rights by contacting privacy@scubbl.com. Scubbl may request additional information where necessary to confirm your identity or process your request. Scubbl responds to rights requests within the time limits provided by applicable regulation, in principle within one month from receipt of a complete request.
You also have the right to lodge a complaint with the CNIL or any other competent supervisory authority.
Practical details are provided on the GDPR Rights page.
17. Changes to the policy
Scubbl may modify this policy to reflect changes to the service, the addition or removal of features, technical changes, changes in the providers used, or regulatory changes.
The applicable version is the one published on this page. In the event of a material change, Scubbl may inform users by a message in the application, on the website, or by any other appropriate means.
18. Contact
For any question relating to this policy or the protection of personal data, you may contact privacy@scubbl.com.
For any other general, legal or contractual request relating to the service, you may contact contact@scubbl.com.