Data Deletion Policy - Spearo Tracker
Last Updated: December 3, 2025
Effective Date: December 3, 2025
1. Overview
This Data Deletion Policy explains how Spearo Tracker handles user requests to delete personal data. We respect your right to control your data and make it easy to delete your information.
This policy complies with:
GDPR (General Data Protection Regulation) - European Union
CCPA (California Consumer Privacy Act) - California, USA
Google Play Store data deletion requirements
COPPA (Children's Online Privacy Protection Act) - United States
Spearo Tracker is developed by Visivo, LLC, and we are committed to transparency in how we handle data deletion requests.
2. Your Right to Delete Data
2.1 What You Can Delete
You have the right to delete:
Your Entire Account:
All dive logs (dates, depths, times, notes, conditions)
All dive spots (names, GPS coordinates, descriptions, ratings)
All catch records (species, weights, measurements, photos)
Your profile information (name, email, photo, weight, experience level)
Training history (breath-hold sessions, tables, progress)
Custom training tables you created
AI coaching analyses and recommendations
All photos and media uploads
Cloud backups and synced data (Pro users)
Notification preferences and settings
App preferences and customizations
Individual Items (Without Deleting Account):
Specific dive logs (swipe to delete or tap delete icon)
Specific dive spots (long press or delete from spot detail)
Specific catch records (delete from catch detail screen)
Individual photos (tap photo > delete icon)
Individual training sessions
Specific AI coaching analyses
2.2 What Cannot Be Deleted Immediately
Some data must be retained for legal compliance:
Purchase Records:
Retention Period: 7 years
Why: Tax law and financial regulations require us to maintain transaction records
What's Retained: Purchase date, amount, subscription type, transaction ID, payment method type
What's NOT Retained: Your dive data, photos, personal notes, or location data
Your Rights: You can request a copy of your purchase history
Fraud Prevention Data:
Retention Period: 5 years
Why: To prevent abuse of free trials and detect fraudulent activity
What's Retained: Hashed device identifiers, hashed IP addresses
What's NOT Retained: Your actual device ID or IP address (only hashes)
Note: This data cannot be used to identify you personally
Aggregated Analytics:
Retention Period: Indefinitely
Why: To improve app performance and features
What's Retained: Anonymous, aggregated statistics (e.g., "X users logged dives this month")
What's NOT Retained: Any data that could identify you individually
Note: This data is fully anonymized and cannot be linked back to you
Legal Hold Data:
If we are involved in litigation or legal proceedings, we may be required to retain certain data until the matter is resolved
3. How to Delete Your Data
3.1 Delete Entire Account (In-App Method)
Step-by-Step Process:
Open Spearo Tracker App
Make sure you're logged in to your account
Navigate to Account Deletion
Tap the menu icon (hamburger menu or profile)
Go to: Settings > Legal & Account > Delete Account
Export Your Data First (Highly Recommended)
Before deletion, tap "Export My Data"
Choose your format: CSV, PDF, or JSON
Save the export to your device or cloud storage
This is your last chance to keep your dive history!
Review What Will Be Deleted
Read the complete list of data that will be permanently removed
Understand this action cannot be undone after the recovery window
Type "DELETE" to Confirm
Type the word "DELETE" in ALL CAPITAL LETTERS
This prevents accidental deletions
Tap "Delete My Account Forever"
Final confirmation dialog will appear
Tap "Delete Forever" to proceed
Deletion Processing Begins
You'll be logged out immediately
Your account enters "soft deletion" state
24-hour recovery window begins
Permanent deletion completes within 30 days
3.2 Recovery Window (24 Hours)
Changed Your Mind?
If you accidentally deleted your account or changed your mind:
Contact us within 24 hours: info@visivoagency.com
Subject Line: "Account Recovery Request - URGENT"
Include: Your registered email address
We'll attempt to restore your account and data
After 24 hours:
Recovery becomes increasingly difficult
After 7 days, recovery is impossible
Your data is overwritten with random data for security
3.3 Delete Individual Items
To Delete a Single Dive:
Open the dive from your dive list
Tap the three-dot menu (top right)
Select "Delete Dive"
Confirm deletion in the dialog
Dive is deleted immediately (no recovery)
To Delete a Dive Spot:
Open the spot detail screen
Tap the three-dot menu (top right)
Select "Delete Spot"
Confirm deletion
Note: Associated dives are NOT deleted (spot reference is removed)
To Delete a Catch Record:
Open the dive containing the catch
Find the catch in the catch list
Swipe left or tap delete icon
Confirm deletion
To Delete a Photo:
Open the dive or catch with the photo
Tap the photo to view full-screen
Tap the trash icon
Confirm deletion
Photo is removed from cloud backup (Pro users)
To Delete Training Data:
Go to Training section
Find the session or custom table
Swipe to delete or use menu option
Confirm deletion
To Delete AI Coaching Analyses:
Go to AI Coaching history
Find the analysis to delete
Tap delete icon
Confirm deletion
3.4 Delete Data via Email Request
If you cannot access the app (lost device, forgotten password, etc.):
Send Email to: info@visivoagency.com
Subject Line: "Data Deletion Request"
Include in Your Email:
Your registered email address
Type of deletion requested (full account or specific data)
Reason for request (optional, helps us improve)
Any additional verification info (approximate signup date, last dive date, etc.)
Verification Process:
We'll send a verification email to your registered address
Click the secure link to confirm your identity
If you can't access your email, we may ask security questions
Processing Time:
We acknowledge your request within 10 business days
Deletion completes within 30 days of verification
You'll receive confirmation when deletion is complete
4. Deletion Timeline
4.1 Immediate Actions (Within 24 Hours)
Happens immediately upon account deletion:
Your access is revoked (logged out of all devices)
Active sessions on all devices are terminated
Cloud sync stops (Pro users)
Your profile becomes invisible
You cannot log back in
4.2 Short-Term Deletions (Within 7 Days)
Deleted within 7 days:
All dive logs from active databases
All dive spots and GPS coordinates
All catch records and measurements
All photos from cloud storage (Pro users)
Your profile information
AI coaching analyses and history
Training history and custom tables
Notification tokens
App preferences and settings
4.3 Long-Term Deletions (Within 30 Days)
Deleted within 30 days:
All database backups containing your data
Cached data on servers
Log files containing your activity
CDN (content delivery network) cached content
Disaster recovery copies
4.4 Retained Data (Legal Requirements)
Data retained despite deletion request:
Data Type Retention Period Reason Purchase records 7 years Tax law compliance Fraud prevention (hashed) 5 years Abuse prevention Anonymized analytics Indefinitely App improvement Legal hold data Until resolved Legal proceedings
5. What Happens to Your Subscription
5.1 Active Subscriptions
If you delete your account with an active subscription:
Pro Monthly / Pro Yearly:
Your subscription continues until the current billing period ends
You will NOT be charged for the next period
Auto-renewal is automatically cancelled via Google Play
No refund for the remainder of the current period
You lose access to Pro features immediately upon deletion
Pro Lifetime:
Your lifetime purchase is forfeited upon account deletion
No refund is available (except within 7-day window)
The license cannot be transferred to a new account
Consumable Credits (AI packs, photo packs, etc.):
Unused credits are forfeited
No refund for unused consumable credits
Credits cannot be transferred
5.2 Recommended Steps Before Deletion
To avoid losing paid features:
Cancel subscription first (via Google Play)
Wait for subscription to expire
Export all your data (CSV, PDF, JSON)
Use remaining consumable credits (or accept loss)
Then delete your account
5.3 Refund Considerations
Before deleting, consider:
Request refund through Google Play if within refund window
Monthly/Yearly subscriptions: 48-hour refund window
Lifetime purchase: 7-day refund window
Refunds are handled by Google Play, not us
6. Data Recovery
6.1 Can Deleted Data Be Recovered?
Recovery Windows:
Timeframe Recovery Possible? How 0-24 hours Yes Email info@visivoagency.com 24 hours - 7 days Maybe Best effort, no guarantee After 7 days No Data permanently overwritten After 30 days Impossible All copies destroyed
6.2 Before Deleting: Export Your Data
We strongly recommend exporting your data before deletion:
Export Formats Available:
CSV: Spreadsheet format (Excel, Google Sheets compatible)
PDF: Printable dive log report with photos
JSON: Machine-readable format for developers
What's Included in Export:
All dive logs with full details
All dive spots with coordinates
All catch records
Your profile information
Training history and statistics
AI coaching analyses (text only)
Photo locations (photos must be saved separately)
How to Export:
Go to Settings > Account > Export My Data
Select format (CSV, PDF, or JSON)
Tap "Generate Export"
Wait for export to complete (may take a few minutes for large datasets)
Share via email, save to device, or upload to cloud storage
Photo Export:
Photos are NOT included in CSV/JSON exports
PDF export includes photo thumbnails
For full-resolution photos, manually save from each dive before deletion
7. GDPR-Specific Rights (EU/EEA/UK Users)
7.1 Right to Erasure ("Right to be Forgotten")
Under GDPR Article 17, you have the right to request deletion if:
Your data is no longer necessary for the purposes it was collected
You withdraw consent for data processing
You object to data processing and we have no overriding legitimate interest
Your data has been unlawfully processed
We are legally required to delete it
The data was collected when you were a child
How to Exercise:
Use the in-app deletion process (fastest)
Or email: info@visivoagency.com with subject "GDPR Right to Erasure"
Include your registered email and specific request
7.2 Exceptions to Right to Erasure
We may refuse or delay deletion if:
Retention is required by law (tax records, legal hold)
Necessary for exercising freedom of expression
Necessary for public health purposes
Necessary for archiving in the public interest
Necessary for establishing, exercising, or defending legal claims
If we refuse: We'll explain the specific reason in writing.
7.3 Right to Data Portability
Before deletion, you can request:
A copy of all your data in a structured, machine-readable format
Transfer of your data to another service (where technically feasible)
How to Exercise: Settings > Account > Export My Data
7.4 Supervisory Authority
If you're unsatisfied with our response:
You have the right to lodge a complaint with your local data protection authority
EU: Find your authority at https://edpb.europa.eu/about-edpb/board/members_en
UK: Information Commissioner's Office (ICO) at https://ico.org.uk/
8. CCPA-Specific Rights (California Users)
8.1 Right to Delete
Under CCPA, California residents can request deletion of:
Personal information we collected from you
Personal information our service providers hold on our behalf
How to Exercise:
Use in-app deletion (fastest)
Email: info@visivoagency.com with subject "CCPA Deletion Request"
Call: (leave voicemail at our business number)
8.2 Verification Process
We must verify your identity before processing:
We send a verification email to your registered address
Click the secure link to confirm
For sensitive requests, we may ask security questions
If verification fails, we cannot process the request
8.3 CCPA Timeline
Acknowledgment: Within 10 business days
Completion: Within 45 calendar days
Extension: Up to 45 additional days if needed (we'll notify you)
8.4 Non-Discrimination
We will NOT discriminate against you for exercising CCPA rights:
No denial of services
No different pricing or service levels
No suggestion that you'll receive different treatment
9. Children's Data (COPPA)
9.1 Children Under 13
Spearo Tracker is not intended for children under 13:
We do not knowingly collect data from children under 13
If we discover an account belongs to a child under 13, we delete it immediately
No parental consent mechanism is available (the app is not designed for children)
9.2 Parental Requests
If you are a parent or guardian:
You can request deletion of your child's account
Email: info@visivoagency.com
Include: Child's email, your email, proof of guardianship
We'll verify and delete within 30 days
9.3 Users Age 13-17
For teenage users:
Parental consent is recommended
Parents can request account deletion on behalf of minors
Same deletion process and timeline applies
10. Third-Party Data
10.1 Data We Cannot Delete
Some data is controlled by third parties:
Service Data They Hold How to Delete Google Play Purchase history Contact Google Play Support Firebase/Google Analytics data Deleted when we delete your account OpenAI AI query logs Automatically purged per OpenAI policy OpenWeather API request logs Automatically purged after 24 hours
10.2 Google Play Purchases
Google Play maintains its own records:
We cannot delete your Google Play purchase history
Contact Google Play Support for those records
Google's data deletion: https://support.google.com/accounts/answer/465
11. Data Deletion for Deceased Users
11.1 Requesting Deletion
If a Spearo Tracker user has passed away:
Next of kin or estate executor can request account deletion
Email: info@visivoagency.com
Subject: "Deceased User Account Request"
11.2 Required Documentation
Please provide:
Death certificate (copy)
Proof of relationship or legal authority
User's registered email address
Description of request (deletion, data export, or both)
11.3 Processing Time
We handle these requests with sensitivity and priority
Typical processing: 14-30 days
We may request additional verification
12. Contact Us
For Data Deletion Questions:
Email: info@visivoagency.com
Subject: "Data Deletion Inquiry"
Response Time: Within 30 days (GDPR requirement)
Mailing Address:
Visivo, LLC
6501 Arlington Expressway, B105 #2026
Jacksonville, FL 32211
United States
Business Hours:
Monday - Friday, 9 AM - 5 PM Eastern Time
(Excluding US federal holidays)
13. Summary
Topic Details What You Can Delete All dives, spots, catches, photos, profile, training data How to Delete Settings > Legal & Account > Delete Account Recovery Window 24 hours (contact info@visivoagency.com) Timeline 7 days (active data), 30 days (all backups) Legal Retention Purchase records (7 years), fraud data (5 years) Export First CSV, PDF, or JSON formats available Contact info@visivoagency.com
We respect your right to delete your data and make it easy to do so.
This Data Deletion Policy is effective as of December 3, 2025.