Privacy Policy for VCEVE Inc. – iDiving App and Website

1. Scope and Overview

This Privacy Policy explains how VCEVE Inc. (VCEVE, we, us, or our) collects, uses, discloses, and protects information about users (you or your) of:

• Our mobile application iDiving (the App); and
• Our website at www.vceve.com and any linked pages we control (the Website).

By accessing or using the App or Website, you acknowledge that you have read and understand this Privacy Policy.

2. Information We Collect

We collect information in the following ways:

2.1 Information You Provide

• Contact and Account Information: name, email address, phone number, and other identifiers you submit when you contact us, sign up for communications, or create website account.
• Support Communications: content of messages, attachments, and related contact details when you request support or provide feedback.
• Dive-Related Inputs: information you manually enter into the App, such as dive plans, gas mixes, notes, and tags.

2.2 Information Collected Automatically

• Device and Usage Data (App): device model, OS version, App version, unique device identifiers (e.g., IDFV), language, time zone, crash logs, performance data, and in-App usage events.
• Device and Usage Data (Website): IP address, browser type, operating system, referring URLs, pages viewed, links clicked, and general interaction data.
• Cookies and Similar Technologies (Website): cookies, web beacons, pixels, and local storage to enable functionality, analytics, and preferences. See Section 7 for details.
• Location and Sensor Data (App) (if enabled): approximate location, motion/activity data, and other sensor readings used to support App features. You can control access via your device settings.

2.3 App-Specific Diving Data

• Dive Logs and Telemetry: dates and times, depth/time profiles, water temperature (if available), ascent/descent rates, configurations, and related metadata. These data may be stored locally on your device and, if you enable sync or backup features, may be transmitted to our servers or trusted service providers.

2.4 Information From Third Parties

• Apple App Store and Transactions: we receive limited transaction-related information (e.g., purchase confirmations, subscription status, or identifiers) from Apple necessary to activate features you purchase. We do not receive your full payment card details.
• Service Providers and Partners: analytics, crash reporting, and hosting providers may supply aggregated or pseudonymized reports.

3. How We Use Your Information

We use the information described above to:

• Provide and Operate the App and Website: deliver core features, process purchases through Apple, authenticate activity, and maintain functionality.
• Safety and Performance: support dive planning and logging features, provide warnings and notifications, troubleshoot issues, and improve reliability.
• Improve and Develop: analyze usage to enhance features, user experience, safety guidance, and performance; conduct research and quality assurance.
• Communicate: respond to inquiries, provide customer support, send service-related notices and updates; send marketing communications where permitted by law and your preferences.
• Legal, Compliance, and Security: prevent, detect, and investigate fraud, abuse, or security incidents; comply with legal obligations; enforce our terms and policies.

4. Legal Bases for Processing (EEA/UK/Switzerland)

Where applicable law (e.g., GDPR/UK GDPR) requires a lawful basis, we rely on:

• Performance of a Contract: to provide the App/Website and process transactions.
• Legitimate Interests: to secure and improve our services, analyze usage, and communicate about similar products or updates (balanced against your rights and expectations).
• Consent: for certain analytics, cookies, and access to device features (e.g., location) where required; you may withdraw consent at any time via device settings or cookie preferences.
• Legal Obligations: to comply with applicable laws, regulations, and lawful requests.

5. How We Share Information

We do not sell your personal information. We share information only as described below:

• Service Providers: with vetted vendors that perform services on our behalf (e.g., hosting, cloud storage, analytics, crash reporting, email delivery). They are bound by contractual obligations to protect your information and use it only for our instructions.
• Apple: to process purchases and manage entitlements, consistent with Apple's terms and privacy policies.
• Legal and Compliance: to comply with applicable law, legal process, or government requests; to enforce our agreements or protect the rights, property, or safety of VCEVE, our users, or others.
• Business Transfers: in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred to a successor or affiliate subject to this Privacy Policy or a successor policy with materially similar protections.

6. International Data Transfers

We are a global provider and may process information in countries other than where you reside, including the United States. Where required, we implement appropriate safeguards for cross-border transfers, such as standard contractual clauses approved by regulators. By using the App or Website, you understand that your information may be transferred to jurisdictions with different data protection laws.

7. Cookies and Tracking (Website)

• Types of Cookies: we may use strictly necessary cookies (essential for the site to function), performance/analytics cookies (to measure usage), and preference cookies (to remember settings).
• Your Choices: you can manage cookies through your browser settings and, where required by law, through our cookie banner or preference center. Disabling certain cookies may affect site functionality.
• Do Not Track: our Website does not currently respond to Do Not Track signals. You can use browser tools or industry opt-outs to manage certain tracking.

8. Your Choices and Controls

• App Permissions: you can enable/disable location, notifications, motion/sensor access, and similar permissions in your device settings.
• Marketing Communications: you may opt out of non-transactional marketing emails by using the unsubscribe link in the message or contacting us.
• Access and Deletion: you can request access to or deletion of your personal information by contacting us at info@vceve.com. We may need to verify your identity and request additional information to process your request securely.

9. Your Rights

Depending on your location, you may have the rights to:

• Access, correct, or delete personal information we hold about you;
• Object to or restrict certain processing;
• Withdraw consent where processing is based on consent;
• Data portability, to obtain a machine-readable copy of certain information;
• Appeal our decision if we decline your request, by replying to our response.

To exercise your rights, contact us at info@vceve.com. We will respond in accordance with applicable law. If you are in the EEA/UK/Switzerland, you also have the right to lodge a complaint with your local data protection authority.

10. California Privacy Notice (CPRA)

If you are a California resident, this section applies in addition to the rest of this Policy.

• Categories Collected: identifiers (e.g., name, email, device identifiers); internet/network activity (usage, logs, IP, cookies); geolocation (approximate, if enabled); inference and profile data (limited, for app functionality and improvements); commercial information related to Apple transactions (limited to confirmations/identifiers).
• Sources: directly from you, automatically through your device/browser, Apple, and service providers.
• Purposes: as described in Sections 3 and 5.
• Disclosure: we disclose personal information to service providers for business purposes. We do not sell or share personal information for cross-context behavioural advertising as those terms are defined by the CPRA.
• Sensitive Personal Information: we do not use or disclose sensitive personal information for purposes other than those permitted by CPRA.
• Your CPRA Rights: know/access, correct, delete, portability, and to not be discriminated against for exercising your rights. Submit requests at info@vceve.com. You may designate an authorized agent; we will require verification of both you and your agent.

11. Children's Privacy

Our App and Website are intended for adults and are not directed to children under 18. We do not knowingly collect personal information from children under 18. If you believe a child has provided us personal information, contact us and we will take appropriate steps to delete it.

12. Data Retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this Policy, comply with our legal obligations, resolve disputes, enforce agreements, and as otherwise permitted by law. Where feasible, we will anonymize or aggregate data so it no longer identifies you.

13. Security

We implement reasonable technical and organizational measures designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

14. Third-Party Links and Services

The Website and App may include links to third-party sites, services, or features that we do not control (e.g., Apple App Store pages). This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated Policy on the Website and/or within the App and update the Effective Date. If changes are material, we will provide more prominent notice as required by law. Your continued use of the App or Website after the Effective Date means you accept the updated Policy.

16. Contact Us

If you have questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at:

Email: info@vceve.com
Website: www.vceve.com

17. Controller Information

For purposes of data protection laws, VCEVE Inc. is the controller of your personal information processed under this Privacy Policy. If we appoint a data protection officer or EU/UK representative, we will update this Policy with their contact information.

18. Jurisdiction-Specific Terms

We may provide additional notices or rights depending on your jurisdiction (e.g., EEA/UK/Switzerland, Canada, Australia, Brazil). Where local law requires different or additional disclosures, those requirements will supplement or supersede this Policy to the extent of any conflict.

19. App Store and Apple Purchases

Purchases for iDiving are processed by Apple. Your interactions with Apple are governed by Apple's terms and privacy policies. We receive limited information from Apple needed to confirm your purchase and enable features; we do not receive your full payment card details.

20. No Sale or Targeted Advertising

We do not sell personal information and do not share personal information for cross-context behavioural advertising. We may use analytics to improve the App and Website in accordance with this Policy and your choices.

21. Additional Information for Users in the EEA/UK/Switzerland

• Transfers: when transferring personal data to countries without an adequacy decision, we use appropriate safeguards such as standard contractual clauses.
• Marketing: we will obtain consent for direct marketing communications where required by law. You can withdraw consent at any time via the unsubscribe link or by contacting us.
• Legal Requests: we will assess and respond to government or law enforcement requests consistent with applicable law and our commitment to protect user privacy.

By using iDiving or visiting www.vceve.com, you agree to the practices described in this Privacy Policy.