GDPR Rights
This page is intended to inform Scubbl users about the rights they have regarding their personal data, in accordance with the General Data Protection Regulation (GDPR) and the applicable French regulations.
It explains how these rights may be exercised, the applicable response times, and the cases in which certain requests may be limited or refused.
This page supplements the Privacy Policy, the Terms of Use and, where applicable, the other documents applicable to Scubbl services.
1. Purpose of this page
Scubbl may process certain personal data as part of the use of its mobile application, website and associated services.
This page presents in particular:
the rights users have over their personal data;
the practical arrangements for exercising these rights;
the timeframes for processing requests;
the limits provided for by the applicable regulations;
the ways to contact Scubbl for any question relating to personal data.
2. Personal data concerned
The rights described on this page may relate to personal data processed by Scubbl in connection with its services.
This data may include in particular:
account identification information;
the email address associated with the account;
profile information;
the user’s personal settings;
content published, saved or shared in the application;
interactions with other users or with Scubbl services;
usage data relating to the application and the website;
technical data necessary for the operation, security and improvement of the service;
information relating to purchases, subscriptions or transactions, where necessary for service follow-up.
Details of the categories of data processed, the purposes, legal bases, recipients and retention periods are specified in the Privacy Policy.
3. Right of access
The user may ask Scubbl to confirm whether personal data concerning them is being processed.
Where this is the case, the user may request access to the personal data concerned and to certain information relating to its processing, including:
the purposes of the processing;
the categories of data concerned;
the recipients or categories of recipients;
the planned retention period or the criteria used to determine it;
the existence of their other rights;
the source of the data where it was not collected directly from the user;
the possible existence of automated decision-making, including profiling, where applicable.
4. Right to rectification
The user may request correction of personal data concerning them where it is inaccurate, incomplete or outdated.
Where certain information can be modified directly from the application, the user is invited to make the change from their account.
For data that cannot be modified directly in the application, the user may exercise their right to rectification according to the procedures set out in Article 12.
5. Right to erasure
The user may request the deletion of personal data concerning them, under the conditions provided for by the applicable regulations.
This right may apply in particular where:
the data is no longer necessary for the purposes for which it was collected;
the user withdraws consent, where the processing is based solely on that consent;
the user objects to the processing and no overriding legitimate grounds justify its continuation;
the data has been unlawfully processed;
the data must be erased in order to comply with a legal obligation.
The right to erasure is not absolute. Certain data may be retained where retention is necessary, in particular:
to comply with a legal obligation;
for the establishment, exercise or defence of legal claims;
to prevent fraud, abuse or security breaches;
to manage reports, disputes or complaints;
for the temporary retention of technical logs;
to manage purchases, subscriptions or transactions made through Apple, Google or a payment service provider;
to preserve the integrity of certain community content, where that content is anonymised.
The specific procedures for account deactivation and deletion requests are described on the Account deletion and deactivation page.
6. Right to restriction of processing
The user may ask Scubbl to temporarily restrict the use of certain personal data concerning them.
This right may apply in particular where:
the accuracy of the data is contested by the user;
the processing is contested;
the data is no longer necessary for Scubbl, but remains necessary for the user for the establishment, exercise or defence of legal claims;
the user has objected to processing and verification is required.
During the restriction period, the data concerned may be retained but is no longer used, except in the cases authorised by the applicable regulations.
7. Right to object
The user may object to certain processing of their personal data where the processing is based on Scubbl’s legitimate interest.
The objection request must specify the processing concerned and the reasons relating to the user’s particular situation.
Scubbl may refuse an objection request where compelling legitimate grounds justify continuing the processing, or where the processing is necessary for the establishment, exercise or defence of legal claims.
Where the data is used for direct marketing purposes, the user may object to such processing at any time.
8. Right to data portability
Where the conditions provided for by the GDPR are met, the user may request to receive certain personal data that they have provided to Scubbl in a structured, commonly used and machine-readable format.
This right concerns only certain processing operations:
based on consent or on the performance of a contract;
carried out by automated means;
relating to data provided by the user.
The right to portability does not necessarily apply to all data processed by Scubbl, in particular derived, aggregated, anonymised or Scubbl-generated data produced as part of the operation of the service.
9. Withdrawal of consent
Where the processing of certain data is based on the user’s consent, the user may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.
Certain Scubbl features may require the processing of specific data. Withdrawal of consent may therefore limit access to certain features or prevent their normal operation.
10. Right not to be subject to a solely automated decision
The user has the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal effects concerning them or significantly affects them.
Unless otherwise stated in the Privacy Policy, Scubbl does not make decisions producing legal effects for the user or significantly affecting the user solely on the basis of automated processing.
Scubbl may, however, use certain data to personalise the user experience, recommend content, improve the service, ensure application security or analyse the use of its services, under the conditions described in the Privacy Policy.
11. Right to define post-mortem instructions
In accordance with the applicable French regulations, the user may define instructions relating to the retention, erasure and communication of their personal data after their death.
These instructions may be general or specific, under the conditions provided for by the applicable regulations.
For any request relating to these instructions, the user or their beneficiaries may contact Scubbl according to the procedures set out in Article 12.
12. How to exercise rights
To exercise rights relating to personal data, the user may contact Scubbl at the following address:
The request should ideally specify:
the email address associated with the Scubbl account;
the username, where applicable;
the right the user wishes to exercise;
the data or processing concerned by the request;
any information making it possible to identify the account concerned.
Where the request concerns account deactivation or deletion, the user is invited to use, as a priority, the dedicated procedure available directly in the application, where that procedure is accessible.
For security reasons, Scubbl may request strictly necessary additional information in order to verify the identity of the requester and prevent fraudulent or unauthorised requests.
Scubbl will not request additional documents or information where the information already available makes it possible to sufficiently identify the user.
13. Free exercise of rights
Exercising rights is free of charge.
However, where requests are manifestly unfounded, excessive or repetitive, Scubbl may, within the limits provided for by the applicable regulations:
refuse to act on the request;
or request payment of reasonable fees taking into account the administrative costs of processing the request.
14. Response time
Scubbl responds to requests relating to user rights as soon as possible and, in principle, within one month from receipt of the complete request.
This period may be extended by two additional months where the request is complex or where a large number of requests is being processed.
In the event of an extension, the user is informed within the initial one-month period of the reasons for the extension.
Where the request is incomplete or where additional information is necessary to verify the requester’s identity, the period may be suspended until the requested information is received.
15. Refusal or limitation of a request
Scubbl may refuse or limit a request where permitted by the applicable regulations, in particular if:
the request is manifestly unfounded or excessive;
the requester’s identity cannot be sufficiently verified;
the request adversely affects the rights and freedoms of other persons;
retention of the data is necessary to comply with a legal obligation;
retention of the data is necessary for the security of the service;
retention of the data is necessary for the establishment, exercise or defence of legal claims;
the request concerns anonymised data that no longer makes it possible to identify the user.
In the event of refusal or limitation, Scubbl informs the user of the reasons for its decision, within the limits authorised by the applicable regulations.
16. Limited retention of data
Personal data is not retained indefinitely.
Scubbl determines retention periods according to the purposes pursued, applicable legal obligations, security needs, fraud prevention, dispute management and the normal operation of the service.
At the end of the applicable periods, the data is deleted, anonymised or archived where legally necessary.
Details of the retention periods or criteria are specified in the Privacy Policy.
17. Complaint to the CNIL
If the user considers that their rights are not respected or that the processing of their personal data does not comply with the applicable regulations, they may lodge a complaint with the French Data Protection Authority, the Commission nationale de l’informatique et des libertés (CNIL).
The user may contact the CNIL via its official website:
Before filing any complaint, the user is invited to contact Scubbl so that the request can be reviewed and an appropriate solution sought.
18. Contact
For any question relating to personal data or the exercise of GDPR rights, the user may contact Scubbl at the following address:
For any other general question concerning the application, website or Scubbl services, the user may contact Scubbl at the following address: