Privacy Policy

Scubra Dive Log is a logbook that works without an account. Most of what you put into it never leaves your phone. This page says exactly what happens to the rest.

You can use the app without giving us anything

You do not need an account to log dives. Install the app and start logging — your dives, photos and computer profiles are written to a database on the phone, and that database is the real logbook. We receive nothing until you sign in and turn on Cloud sync.

If you never sign in, this policy has almost nothing to describe. The rest of this page is about what changes when you do.

What stays on your phone

These never reach our servers, on any tier:

What we receive when you sign in

AI features are off until you turn them on

Two features send data to a third party, and each has its own consent toggle in your account settings. Both are Cloud tier only, and both are off by default.

Turning a feature off stops the transfer for everything after it. We never use AI to generate dive-planning, decompression or gradient-factor advice — that is a product line we don’t cross.

Device permissions

PermissionWhat it’s forLeaves the phone?
BluetoothFinding and downloading from your dive computerNo
CameraTaking a photo for a diveOnly if you upload it
Photo libraryAttaching existing photos to a diveOnly if you upload it
MicrophoneVoice-logging a diveOnly with voice consent on
LocationCentring the map on a dive siteNo
ContactsSpelling buddies’ names correctlyNo
Face IDConfirming it’s youNo

Analytics, and what we don’t do

We count aggregate usage with GoatCounter, self-hosted on our own EU infrastructure. A hit is an event name and nothing else — no identifier, no profile, nothing that points back at you.

We have never shipped a third-party tracking SDK, and we don’t intend to: no Google Analytics, no Facebook SDK, no advertising identifier, no ad networks. We do not sell your data and we do not share it for advertising.

Who else touches your data

Every service that stores or processes your information is listed below. Your data goes nowhere else.

Sub-processors used by Scubra Dive Log, with region and purpose
ServiceRegionPurposeDataStatus
Railwayeu-west (Amsterdam)Application hosting (incl. self-hosted authentication service)account, auth metadata, sync metadata Active
Cloudflare R2EU JurisdictionPhoto + export storagephotos, export bundles Active
Anthropic (Claude Vision)US (DPF + SCC)Marine-life identification (Cloud-tier opt-in)photos when consented Active
SpeechmaticsEUCloud voice transcription (Cloud-tier opt-in)audio when consented Active
AppleglobaliOS in-app purchase (StoreKit)billing Active
ResendEUTransactional emailemail address Active

Where your data lives

In the EU. Application hosting and authentication run on Railway eu-west (Amsterdam). Photos and export bundles live in Cloudflare R2 EU Jurisdiction. Email goes through Resend EU. Voice transcription is Speechmatics EU. Apple handles iOS payments.

The one exception is marine-life identification: Anthropic (Claude Vision) is US-based, covered by the Data Privacy Framework plus Standard Contractual Clauses, and only ever receives a photo you consented to send.

We do not route data through US regions to keep the service up. If our EU region is unavailable, the cloud tier degrades to read-only instead.

How long we keep it

Payments

iOS purchases are handled by Apple. We never see your card details. We receive a transaction identifier and whether your Cloud entitlement is active.

Your rights

You can ask for access, correction, a portable copy, deletion, restriction, or object to processing. Submit a request from the account screen in the app, or email us. You can also delete your account outright from within the app.

We respond within 30 days. At our current size the founder reads each request personally.

Lawful basis

We process your data to deliver the service you asked for (contract), on your explicit consent for the AI features, on legitimate interest for keeping the service secure and free of abuse, and on legal obligation for billing records.

Children

Scubra Dive Log is not directed at children under 16, and we don’t knowingly collect their data.

While the app is in public beta

The beta is distributed through Apple TestFlight. Apple passes us the email address you used to join, along with any feedback, screenshots and crash logs you choose to send. Apple’s own handling of that is covered by Apple’s privacy policy, not this one.

Breach notification

We commit to a 72-hour breach notification window under GDPR Article 33, and maintain an internal incident-response runbook covering detection, containment and notification.

Changes to this policy

If we change it, we update this page and the date below. Anything material gets announced in the app rather than quietly edited in.

Contact

Email privacy@scubra.com for anything on this page, including data-subject requests.

Read the full DPA · Read the data-permanence pledge


Last updated: 15 August 2026