Privacy Policy - Spearo Tracker


Last Updated: December 3, 2025
Effective Date: December 3, 2025


1. Introduction

Welcome to Spearo Tracker, the ultimate dive logging app for freedivers and spearfishers. We are committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your personal information.

Spearo Tracker is developed and operated by Visivo, LLC ("we," "us," or "our"), a Florida-based company dedicated to creating tools that help divers track their progress, improve their skills, and stay safe in the water.

By using Spearo Tracker, you agree to this Privacy Policy.

2. Information We Collect

2.1 Information You Provide

Account Information:

  • Email address (required for account creation)

  • Display name (how you appear in the app)

  • Profile photo (optional)

  • Diver experience level (beginner, intermediate, advanced)

  • Body weight (used for performance calculations like metabolic rate)

  • Preferred units (metric/imperial)

  • Emergency contact information (optional, for safety features)

Dive Log Data:

  • Dive dates, times, and durations

  • GPS coordinates of dive locations

  • Maximum depth achieved

  • Bottom time (time spent at depth)

  • Descent and ascent speeds

  • Recovery times between dives

  • Surface intervals

  • Water temperature readings

  • Visibility conditions

  • Weather and sea conditions (waves, current, wind)

  • Personal notes and observations about each dive

  • Dive type (recreational, spearfishing, training)

Catch Data (Spearfishing):

  • Fish species caught

  • Weight and length measurements

  • Photos of catches

  • Hunting techniques used

  • Time of catch during dive

Dive Spot Data:

  • Custom spot names

  • GPS coordinates (latitude/longitude)

  • Water depth information

  • Bottom composition (sand, rock, reef)

  • Spot descriptions and personal ratings

  • Photos of dive locations

  • Weather patterns and best conditions

Training Data:

  • Breath-hold training tables (O2 and CO2 tables)

  • Static apnea times

  • Dynamic apnea distances

  • Training session history

  • Personal bests and progress tracking

  • Custom training table configurations

AI Coaching Data:

  • Dive performance metrics submitted for analysis

  • AI-generated feedback and recommendations

  • Training suggestions based on your progress

2.2 Information Collected Automatically

Device Information:

  • Device type and model (e.g., Samsung Galaxy S23)

  • Operating system version (e.g., Android 14)

  • Unique device identifiers (for app functionality)

  • Screen size and resolution

  • Language and locale settings

  • Time zone

Usage Information:

  • App opens and session duration

  • Features used and frequency

  • Navigation patterns within the app

  • Crash reports and error logs

  • Performance metrics

Location Information:

  • GPS coordinates (only when you explicitly add a dive spot or log a dive)

  • Location is NEVER tracked in the background

  • Requires explicit permission each time

  • You can deny location access and manually enter coordinates

Subscription Information:

  • Subscription plan type (Free, Pro Monthly, Pro Yearly, Pro Lifetime)

  • Purchase date and transaction IDs

  • Subscription status (active, expired, trial)

  • Renewal dates

  • Consumable credit purchases (AI packs, photo packs)

3. How We Use Your Information

Core App Functionality:

  • Store, display, and organize your dive logs

  • Calculate dive metrics (average depth, total bottom time, dive frequency)

  • Generate analytics and performance trends

  • Save and organize your dive spots on the map

  • Track your catches and fishing success

  • Provide customized breath-hold training plans

  • Deliver AI Coaching analysis and personalized feedback (Pro feature)

  • Sync data across your devices (Pro feature)

Account Management:

  • Create and maintain your user account

  • Authenticate your login (email/password or Google Sign-In)

  • Verify your subscription status

  • Process purchases through Google Play

  • Send password reset emails

Cloud Backup (Pro Users):

  • Automatically backup dive logs to Firebase cloud storage

  • Sync data seamlessly across multiple devices

  • Enable data recovery if you lose your phone

  • Provide secure, encrypted storage

Weather & Conditions:

  • Fetch current weather data for your dive spots

  • Display tide predictions and moon phases

  • Show water temperature forecasts

  • Help you plan dives during optimal conditions

Communication (With Your Consent):

  • Send diving tips and safety reminders

  • Notify you about new features and updates

  • Alert you about subscription renewals or expirations

  • Provide customer support responses

App Improvement:

  • Analyze aggregate usage patterns

  • Identify and fix bugs and crashes

  • Optimize app performance

  • Develop new features based on user needs

  • Improve AI coaching accuracy

4. How We Share Your Information

4.1 We DO NOT Sell Your Data

We never sell, rent, or trade your personal information to third parties for marketing purposes.

4.2 Service Providers

We work with trusted service providers who help us operate Spearo Tracker:

Firebase (Google Cloud):

  • Purpose: Cloud database, user authentication, analytics, crash reporting

  • Data Shared: Account information, dive logs (Pro users), usage analytics

  • Privacy Policy: https://firebase.google.com/support/privacy

  • Data Location: United States and European Union

Google Play Billing:

  • Purpose: Process subscription and in-app purchase payments

  • Data Shared: Transaction data, purchase receipts, subscription status

  • Privacy Policy: https://policies.google.com/privacy

  • Note: We never see or store your credit card information

OpenAI (ChatGPT):

  • Purpose: AI coaching analysis and personalized dive feedback

  • Data Shared: Anonymized dive metrics only (depth, time, frequency)

  • Privacy Policy: https://openai.com/privacy

  • Note: No personally identifiable information is sent to OpenAI

OpenWeather:

4.3 Legal Requirements

We may disclose your information if required by law:

  • Compliance with subpoenas, court orders, or legal processes

  • Protection against fraud or security threats

  • Enforcement of our Terms of Service

  • Protection of our rights, property, or safety

4.4 Business Transfers

If Visivo, LLC is acquired or merges with another company, your information may be transferred. We will notify you before your data is subject to a different privacy policy.

5. Your Rights and Choices

5.1 Access Your Data

You can:

  • View all data we store about you within the app

  • Download your complete dive history

  • Export your data in multiple formats (CSV, PDF, JSON)

How to Access:
Settings > Account > Export My Data

5.2 Update Your Data

You can update:

  • Profile information (name, photo, weight)

  • Individual dive logs and catch records

  • Dive spot details and locations

  • Training preferences and goals

How to Update:
Settings > Profile > Edit Profile
Or edit any dive/spot directly in the app

5.3 Delete Your Data

Full Account Deletion:

  1. Go to Settings > Legal & Account > Delete Account

  2. Review the list of data that will be deleted

  3. Optionally export your data first (recommended!)

  4. Type "DELETE" to confirm

  5. 24-hour recovery window (contact info@visivoagency.com to cancel)

  6. Permanent deletion begins after 24 hours

  7. Complete removal within 30 days

What Gets Deleted:

  • All dive logs, spots, catches, and photos

  • Profile and account information

  • Training history and analytics

  • AI coaching analyses

  • Cloud backups (Pro users)

What We Must Retain (Legal Requirements):

  • Purchase records (required by tax law for 7 years)

  • Aggregated, anonymized analytics (cannot identify you)

  • Fraud prevention data (hashed identifiers, 5 years)

5.4 Marketing Communications

Email Preferences:

  • Marketing emails are opt-in only

  • Opt-out anytime via Settings > Notifications

  • Unsubscribe link in every marketing email

  • Transactional emails (password reset, purchase receipts) cannot be opted out

5.5 Location Permissions

You Control:

  • When we can access your location

  • Which dive spots use GPS coordinates

  • You can revoke permission anytime

  • Android Settings > Apps > Spearo Tracker > Permissions > Location

6. Data Retention

Active Accounts:

  • Dive logs: Stored indefinitely (or until you delete them)

  • Photos: Stored indefinitely (or until you delete them)

  • Analytics: Rolling 2-year window

  • AI coaching analyses: 1 year

Deleted Accounts:

  • 24-hour recovery window (soft deletion)

  • Active data deleted within 7 days

  • Backups purged within 30 days

  • Purchase records: Retained 7 years (tax law requirement)

  • Fraud prevention data: 5 years (hashed only)

  • Aggregated analytics: Indefinitely (fully anonymized)

Inactive Accounts:

  • After 4 years of inactivity, we may delete your account

  • You'll receive 30 days email notice before deletion

  • Simply log in to keep your account active

7. Data Security

Encryption:

  • All data transmitted over HTTPS (TLS 1.3)

  • Cloud data encrypted at rest (AES-256)

  • Local database protected by device encryption

  • API keys stored securely, never in client code

Authentication:

  • Password hashing using secure algorithms

  • Google Sign-In uses OAuth 2.0 industry standard

  • Session tokens expire after 30 days of inactivity

  • Failed login attempt protection

Access Controls:

  • Only authorized team members can access user data

  • Access is logged and audited

  • Principle of least privilege enforced

Breach Notification:

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

  • Notification via email and in-app alert

  • We'll explain what data was affected and remediation steps

8. International Data Transfers

Primary Storage:

  • Local Device: Your Android phone or tablet

  • Cloud Backup (Pro): Firebase servers in US and EU regions

Transfer Mechanisms:

  • EU-US Data Privacy Framework compliance

  • Standard Contractual Clauses (SCCs) with service providers

  • GDPR-compliant data processing agreements

Your Rights (EEA/UK Users):

  • Right to erasure ("right to be forgotten")

  • Right to data portability

  • Right to restrict processing

  • Right to object to processing

  • Right to lodge a complaint with your supervisory authority

To Exercise These Rights:
Email: info@visivoagency.com
Subject: "GDPR Data Request"

9. Children's Privacy

Spearo Tracker is NOT intended for children under 13.

  • We do not knowingly collect data from children under 13

  • If we discover a child's account, we will delete it immediately

  • Parents: Contact us if you believe your child has created an account

  • Users aged 13-17 must have parental consent

10. California Privacy Rights (CCPA)

California residents have the right to:

  • Know what personal information we collect

  • Know if your personal information is sold or disclosed

  • Say no to the sale of personal information (N/A - we don't sell data)

  • Access your personal information

  • Request deletion of your personal information

  • Equal service and price (no discrimination)

How to Exercise CCPA Rights:
Email: info@visivoagency.com
Subject: "CCPA Data Request"

We'll respond within 45 days.

Categories of Data Collected (Last 12 Months):

  • Identifiers (email, device ID)

  • Personal information (name, profile)

  • Geolocation data (dive spot coordinates)

  • Internet activity (app usage, crash reports)

  • Inferences (AI coaching recommendations)

11. Changes to This Privacy Policy

If we make significant changes:

  • In-app notification upon next app open

  • Email notification to registered users (if opted in)

  • Updated "Last Updated" date at the top

  • 30-day notice period for material changes

Minor changes (typos, clarifications) may be made without notice.

12. Contact Us

12.1 General Inquiries

Email: info@visivoagency.com
Response Time: Within 48 hours (business days)

12.2 Privacy-Specific Questions

Email: info@visivoagency.com
Subject: "Privacy Inquiry"
Response Time: Within 30 days (GDPR requirement)

12.3 Mailing Address

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

13. Consent

By using Spearo Tracker, you consent to:

  • Collection and use of information as described in this Privacy Policy

  • Transfer of your data to service providers listed above

  • Storage of your data in the United States and European Union

  • Processing of anonymized dive metrics for AI coaching

You can withdraw consent at any time by:

  • Deleting your account (Settings > Account > Delete Account)

  • Emailing info@visivoagency.com with your request

14. Summary

What We Collect Why Who Sees It Email, name, profile Account management Only you and our team Dive logs, spots, catches Core app features Only you (cloud backup for Pro) Photos Attach to dives/catches Only you Device info, usage data Bug fixes, improvements Aggregated analytics only Location (when you allow) Save dive spots Only you, OpenWeather (for forecasts) Dive metrics (anonymized) AI coaching OpenAI (no personal info) Payment info Process purchases Google Play (we never see card details)

Your Rights: Access, export, update, delete your data anytime
Security: HTTPS, AES-256 encryption, secure data centers
Contact: info@visivoagency.com

We respect your privacy and are committed to protecting your data.

This Privacy Policy is effective as of December 3, 2025.