Diving Assist – Privacy Policy

Version 1.0

This Privacy Policy explains how Emerson Warwick Limited (we, us, our) processes personal data when you use the Diving Assist mobile application (the App).

We are committed to protecting your privacy and handling data responsibly.

If you do not agree with this Privacy Policy, you must not use the App.

1. Who we are

Emerson Warwick Limited
Data Controller for the App.
Contact: privacy@divingassist.app

2. What the App does

The App provides video-based coaching support for the sport of Diving.
It allows users to:

record video on their own device;

review video for training purposes;

store and manage video files locally.

The App does not upload, transmit, or store video files on external servers.

3. Personal data we process

The App is intentionally designed to process as little personal data as possible.

3.1 Video recordings

All video files remain on your device.

We do not receive, access, collect, or store these recordings.

You are responsible for how video files are shared, stored, backed up, or distributed.

Video recordings may contain images of individuals, including minors, which may constitute personal data under GDPR.
You are responsible for ensuring that recording complies with applicable laws and safeguarding rules.

3.2 Technical data

During normal operation, the App may process limited technical data, including:

device type and operating system;

temporary data generated while recording or reviewing video.

Such temporary data is deleted as soon as practicable, and typically on restarting the App.
This data is not transmitted to us.

3.3 No accounts or registration

The App does not create or require user accounts.
We do not collect names, email addresses, contact details, or location data.

4. Legal basis for processing

Under GDPR, the legal basis for processing technical data is:

Legitimate interest: enabling the App to function correctly and securely.

Where you record individuals, including minors, you are responsible for the lawful basis of recording (for example, consent or legitimate interest), as you are the person controlling the recording activity.
We do not act as a controller for video content stored on your device.

5. How long we keep data

We do not store any personal data from within the App.

Any temporary files created during recording or playback are deleted as soon as practicable or when the App restarts.

Full video recordings remain only on your device until you decide to delete them.

6. Sharing of data

We do not:

upload or transmit video files;

share any personal data with third parties;

use analytics SDKs or advertising frameworks;

store information on external servers.

Your video files remain entirely under your control.

7. Security

The App operates locally on your device.
We recommend that you use your device’s built-in security features, such as:

passcodes;

biometric authentication;

encrypted backups.

You are responsible for the security of any video files stored on your device or shared outside the App.

8. Your responsibilities when recording

You must ensure that:

you have lawful permission to record any individual;

recordings of minors are made only by qualified coaches or by parents or legal guardians;

recording complies with safeguarding rules, club policies, and national regulations;

recordings are used appropriately and stored securely.

We are not responsible for misuse of video recordings by users.

9. Your data protection rights

Depending on your location, you may have rights under GDPR or equivalent laws, including:

the right to access personal data;

the right to request correction or deletion;

the right to restrict processing;

the right to object to processing;

the right to lodge a complaint with a supervisory authority.

Because we do not store or access your video recordings, we are unable to modify or delete video content on your device.

If you contact us about your rights relating to technical data processed within the App, we will assist wherever possible.

10. Children

The App may be used to record children for legitimate coaching purposes.
We do not process children’s data ourselves.

It is the responsibility of the coach, parent, or legal guardian to ensure that:

recording is lawful;

all safeguarding rules are followed;

recordings are handled securely;

no recordings are shared without appropriate consent.

11. Third-party services

The App does not integrate third-party analytics, social media tools, or external data processors.
Your use of the App may be subject to the terms of the App Store from which it was downloaded.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect legal or technical developments.
Changes take effect when published within the App.

13. Contact us

If you have any questions about this Privacy Policy or about how data is processed, you can contact us at:
privacy@divingassist.app

End of Privacy Policy