Spearo Privacy Policy

Last Updated: July 19, 2026
Effective Date: July 19, 2026

1. Introduction

This Privacy Policy covers the Spearo family of apps published by Visivo, LLC:

  • Spearo Tracker — dive logging, catches, training and AI coaching

  • Spearo Vision — dive condition forecasts, spots and community visibility

  • Spearo Apnea — breath-hold training (phone and smartwatch)

One policy covers all of them because they share a single account and a common
backend. Not every app collects everything listed below — where a feature or
data type belongs to a specific app, we say so.

Visivo, LLC ("we," "us," or "our") is a Florida-based company building tools that
help divers track their progress, improve their skills, and stay safe in the water.

By using a Spearo app, you agree to this Privacy Policy.

2. Information We Collect

2.1 Information You Provide

Account information (all apps):

  • Email address (required to create an account)

  • Name and display name

  • Profile photo (optional)

Diver profile (Spearo Tracker):

  • Diver experience level

  • Body weight, where you choose to enter it — used only for performance
    calculations such as metabolic rate

  • Unit preferences (depth, weight, temperature)

Dive logs (Spearo Tracker):

  • Dive dates, times and durations

  • GPS coordinates of dive locations

  • Maximum depth, bottom time, descent/ascent speeds, surface intervals

  • Water temperature, visibility, and sea conditions

  • Your own notes and observations

  • Dive type (recreational, spearfishing, training)

Catch records (Spearo Tracker):

  • Species, weight and length

  • Photos of catches

  • Technique and time of catch

Dive spots (Spearo Tracker, Spearo Vision):

  • Spot names, GPS coordinates, depth and bottom composition

  • Descriptions, ratings and photos

  • Community visibility reports you submit (Spearo Vision)

Training data (Spearo Apnea, Spearo Tracker):

  • Breath-hold training tables and session history

  • Static/dynamic apnea times and distances

  • Personal bests, progress and custom table configurations

Heart-rate data (Spearo Apnea watch app only):

  • Heart rate measured during a training session, used to calculate your dive
    reflex and recovery. Collected only while you are running a session.

2.2 Information Collected Automatically

Device information:

  • Device type, model and operating system version

  • Push-notification token (used to deliver alerts you have enabled)

  • Language, locale and time zone

Location:

  • Approximate and precise (GPS) location, used to show conditions for your
    location and to save dive spots

  • Location is never collected in the background

  • You can decline the permission, revoke it at any time, or enter coordinates
    manually

Subscription information:

  • Plan or product purchased, purchase and transaction identifiers

  • Subscription/purchase status and renewal dates

  • A shared "Spearo Pro" entitlement record that unlocks Pro across the Spearo apps

We do not use analytics or advertising SDKs. The Spearo apps contain no ads and
no third-party analytics or ad tracking.

3. How We Use Your Information

  • Store, display and organise your dives, catches, spots, training and preferences

  • Calculate metrics, scores, analytics and progress

  • Fetch weather, marine, tide and dive-condition data for your locations

  • Provide AI Coaching analysis and personalised feedback (Spearo Tracker)

  • Sync your data across devices and back it up to the cloud

  • Create and maintain your account and verify your Pro entitlement

  • Process purchases through Google Play or the Apple App Store

  • Send condition alerts, safety reminders and service messages you have enabled

  • Diagnose problems and improve the apps

4. How We Share Your Information

4.1 We do not sell your data

We never sell, rent or trade your personal information.

4.2 Service providers

We use trusted providers who process data on our behalf:

Firebase (Google Cloud) — cloud database, authentication, storage and push
messaging. Receives your account information and app data. Stored in the United
States and European Union. https://firebase.google.com/support/privacy

Google Play Billing / Apple App Store — process purchases and verify
subscriptions. Receive transaction data. We never see or store your card
details.
https://policies.google.com/privacy · https://www.apple.com/legal/privacy/

Open-Meteo — weather and marine forecasts. Receives only GPS coordinates
when conditions are requested. No account information. https://open-meteo.com/en/terms

NOAA (Tides & Currents) — tide predictions. Receives the nearest tide-station
location only. https://www.weather.gov/privacy

OpenAI — Spearo Tracker AI Coaching only (not used by Spearo Vision or Spearo
Apnea) — generates coaching analysis. Receives your dive performance metrics
(depth, times, frequency) and any notes you have written on the dive being
analysed
. Your name, email address, and the names of any dive buddies are never
sent. https://openai.com/policies/privacy-policy

Because dive notes are free text, please avoid entering information you would
not want processed by an external service.

4.3 Legal requirements

We may disclose information where required by law — subpoenas, court orders or
legal process; to prevent fraud or security threats; to enforce our Terms; or to
protect our rights, property or safety.

4.4 Business transfers

If Visivo, LLC is acquired or merges, your information may transfer. We will notify
you before your data becomes subject to a different privacy policy.

5. Your Rights and Choices

5.1 Access and export

You can view your data in the app. In Spearo Tracker, export it from
Settings → Export My Data (CSV, PDF or JSON). You may also request a copy by
emailing info@visivoagency.com.

5.2 Update

You can edit your profile and change or remove your dives, spots, catches, training
records and preferences at any time in the app.

5.3 Delete

Deletion is immediate and permanent — there is no recovery window. Export
anything you want to keep first.

  • In the app: Settings → Legal & Account → Delete Account, then confirm.

  • If you have uninstalled: email info@visivoagency.com with the subject
    "Data Deletion Request" from your registered address. Completed within 30 days.

Full details: https://spearotracker.com/data-deletion-policy

Deleted: account and profile, dive logs, spots, catches, photos, training
history, AI coaching analyses, cloud backups, smartwatch sync data, leaderboard
entries and your Pro entitlement record.

Retained: purchase records (7 years, tax compliance); hashed fraud-prevention
identifiers (5 years); aggregated anonymised analytics (indefinitely, cannot
identify you).

Deleting your account does not cancel a Google Play or Apple subscription.
Cancel those in the Play Store or App Store separately.

5.4 Marketing

Marketing emails are opt-in only and can be turned off in Settings or via the
unsubscribe link. Transactional messages (password resets, receipts) cannot be
opted out.

5.5 Location permission

You control location access and can revoke it at any time in your device settings.
The apps work without it, using manually entered coordinates.

6. Data Retention

Your data is kept until you delete it. Deleted accounts are erased promptly and
purged from backups within 30 days, except the limited records listed in §5.3.
After a long period of inactivity we may delete an account after giving you notice
by email.

7. Data Security

  • All data transmitted over HTTPS/TLS

  • Cloud data encrypted at rest (AES-256)

  • Local databases protected by device encryption

  • API keys and secrets held server-side, never shipped inside the apps

  • Google Sign-In and Sign in with Apple use OAuth 2.0

  • Access to user data is limited to authorised staff, logged and audited

  • We will notify affected users within 72 hours of discovering a breach

8. International Data Transfers

Data is stored on your device and, for cloud backup, on Firebase servers in the US
and EU. Transfers rely on the EU-US Data Privacy Framework, Standard Contractual
Clauses, and GDPR-compliant processing agreements.

EEA/UK users have rights to erasure, portability, restriction and objection, and
may complain to their supervisory authority. Email info@visivoagency.com with the
subject "GDPR Data Request."

9. Children's Privacy

The Spearo apps are not intended for children under 13. We do not knowingly
collect data from children under 13 and will delete any such account we discover.
Users aged 13–17 must have parental consent. Where required we rely on the app
stores' age-signal mechanisms to support age-appropriate access.

10. California Privacy Rights (CCPA)

California residents may know what we collect, access it, request deletion, opt out
of any sale (we do not sell data), and receive equal service. Email
info@visivoagency.com with the subject "CCPA Data Request." We respond within 45
days.

Categories collected in the last 12 months: identifiers (email, device ID);
personal information (name, profile); geolocation (dive spot and dive coordinates);
health/fitness activity (dive and training records); photos; internet activity
(app usage); inferences (AI coaching recommendations, Spearo Tracker only).

11. Changes to This Policy

For significant changes we will notify you in-app on next launch and by email if you
have opted in, update the "Last Updated" date, and give 30 days' notice for material
changes. Minor clarifications may be made without notice.

12. Contact Us

Email: info@visivoagency.com (privacy responses within 30 days per GDPR)

Visivo, LLC
6501 Arlington Expressway, B105 #2026
Jacksonville, FL 32211
United States

Support hours: Monday–Friday, 9:00 AM – 5:00 PM Eastern Time

13. Consent

By using a Spearo app you consent to the collection and use of information as
described here, to processing by the service providers listed in §4.2, and to
storage in the United States and European Union. You may withdraw consent by
deleting your account or emailing info@visivoagency.com.

14. Summary

What we collect Why Who sees it Email, name, profile photo Account management You and our team Dives, spots, catches, training Core app features You (cloud backup for Pro) Photos Attach to dives, catches, spots You Location (when allowed) Conditions and saving spots You; coordinates only to Open-Meteo/NOAA Heart rate (Apnea watch) Training metrics You Dive metrics + notes AI coaching (Tracker only) OpenAI (no name or email) Push token, device info Notifications, diagnostics You and our team Purchase records Unlock and verify Pro Google Play / Apple

No ads. No third-party analytics. We do not sell your data.
Your rights: access, export, update and delete at any time.
Contact: info@visivoagency.com