Privacy policy

1. Data controller

The data controller is Jacques Billet — entrepreneur individuel — SIRET 104 846 639 00011, 67 avenue Louis Wallé, 94470 Boissy-Saint-Léger, France. Contact: contact@scubalia.com.

2. Data collected and purposes

• Account: email address, password (hashed) and language — the only data required — plus first name, last name and display name if you choose to give them — to create and secure your account (legal basis: performance of the contract).
• Diver profile: certification level, search preferences — to personalise recommendations (performance of the contract).
• Dive log: dives, species sightings, photos — for your personal logbook; aggregated, anonymised sightings refine the seasonality windows (legitimate interest).
• Subscription: subscription status and current plan — payment is handled by Stripe; Scubalia stores no banking data.
• MyClub listing checks: before publishing a listing, and before applying certain changes to a published listing (notably the website and the federation), we compare its information (name, town, website, federation) with public sources, including official club lists and the club's website, and submit it to automated checks; other changes, such as texts, times, prices, available places or trial sessions, are published directly. The email address displayed is checked before it is shown, and each photo is checked on our servers by artificial intelligence models, then compared with photos already removed. A photo in which a face is clearly detected is refused automatically, a photo may be hidden as soon as it is reported, and a photo that has been awaiting review for thirty days is erased. A check of the texts and contact details of published listings or listings awaiting publication also runs, with no effect on them, to test its rules. These checks may delay a publication pending the team's review; the final refusal or suspension of a listing is decided by a person on the team, except for the automatic suspension that follows the club's objection (the club replies that the request did not come from it), and you can ask for a person to review any measure taken automatically (legal bases: performance of the service requested; legitimate interest in the security and quality of the directory, in particular preventing impersonation of a club). The history of these checks is kept for twelve months; the latest result for each listing, for as long as the listing exists; that of a photo, for as long as the photo exists; the fingerprint of a removed photo (a few bytes, no image), for as long as the listing exists, fifty at most.
• Directory reports: when you report a listing or a photo, we keep the reason, your language and, only if you give it, your email address, in order to handle the report and reply to you; for a listing, we also keep your explanation if any, your declaration of good faith and, only if you give it, your name (legal basis: legal obligation, EU Digital Services Act). To limit abuse, we derive from your IP address a fingerprint computed with a secret key, without recording the address itself; it is erased after 48 hours for a listing report, and together with the report for a photo report. For a listing report, we also keep a fingerprint of your email address for 48 hours, to cap acknowledgements of receipt. The club learns neither your name nor your address, unless the law requires it. A report, and the email address you left in it, are erased twelve months after it has been handled. (Fingerprints: legal basis, legitimate interest in preventing abuse.)

Audience measurement — and why there is no banner

The site sets no measurement cookie and loads no third-party audience measurement script. Pages viewed are counted on our server only, in aggregate: the day's date, the page path, the reading language. This count keeps no IP address, creates no visitor identifier, follows no one from one site to another and links nothing to an account. No external audience measurement service is used.

What is counted are page views, not visitors: with no identifier, two readings by the same person count as two. Personal areas — account, dive log, club spaces — are excluded from measurement. It is because none of these measurements identifies anyone, follows anyone from one site to another, or serves any purpose beyond knowing which pages are read, that they fall under the exemption for audience measurement and that no consent banner is requested. Aggregated server-side data is kept for 25 months, then deleted.

In addition to these page views, our server keeps a few daily totals along the journey, to see at which step it stops: arrival on an entry page, sign-up sent, address confirmed, first dive logged, a club searched for or contacted and, on the club side, account created, listing published, club space opened, first member registered through the portal. Each step taken adds one to a daily total, broken down at most by originating campaign, country and language; nothing in it identifies who took the step — no IP address, no browser, no identifier, no account — and nothing is passed to a third party. It is the only measurement that touches personal spaces, and it falls under the same exemption. These totals are kept for 25 months, then deleted.

Where your MyClub account came from

If you open your MyClub account after clicking one of our social media ads, we attach the origin of that click to your account: the source (an ad), the area of the landing page, the campaign code and the ad variant. No cookie, no pixel, no click identifier: these details are read from the page address and recorded by our server when the account is opened. Purpose: measuring what each campaign brings, in aggregated figures, never for fewer than five accounts. Legal basis: our legitimate interest in measuring how well our ads work. Retention: the life of your account; these details are erased with it. Nothing is sent to the advertising platform. Only weekly totals that do not identify you remain in our statistics.

Targeting and what the platform does on its side

The targeting of our ads is set by us: a country, that country's language, an age range and, depending on the campaign, interests related to diving. The platform showing them applies it using its own data: it and we are joint controllers of this targeting (article 26 GDPR). We send it no data about you. You can exercise your rights with us as well as with it. If you open a MyClub account after clicking, we keep with that account three items read from the page address: the campaign code, the landing visual and the page area. They are erased with the account; only an anonymous aggregated counter remains, which does not identify you. If no account is opened, we keep nothing.

Getting news without creating an account

A form lets you leave an email address to be notified of service news, without creating an account. The purpose is narrow and closed: service opening, new destinations added to the catalogue, new safety advice. This address is not sold, not passed to any third party, not linked to an existing account, and is never used for individual commercial solicitation. The data collected is limited to the email address, the reading language and the page the sign-up came from. The legal basis is consent (GDPR article 6.1.a).

Sign-up happens in two steps (double opt-in): leaving an address is not enough — a confirmation message is sent, and only the click it contains makes the sign-up effective. No other message is sent to an unconfirmed address. This mechanism exists because a public form would otherwise let anyone sign up someone else's address and have messages sent to them in our name.

Every message, including the confirmation one, contains a removal link that works in one click, without logging in and without any further confirmation. A removed address cannot be put back on the list by a third party: a fresh confirmation from the person concerned is required. The rights of access, rectification, erasure and objection may also be exercised in writing with the controller named above.

An address left but never confirmed is deleted automatically after thirty days: keeping an address whose consent was never given would mean keeping a consent we do not have. Removed addresses, by contrast, are kept — precisely so that the removal cannot be undone by a re-registration coming from someone else.

Scubalia news and offers for club officers

A MyClub page officer can agree, by ticking a box, to receive Scubalia's news and offers for clubs by email, at their account address. The consent only counts once confirmed through a link received at that address. The legal basis is consent (article 6.1.a GDPR). We keep proof of the consent — the exact text accepted, its version, its language, its dates, and a fingerprint of the address, never the address in clear — while it is valid, then for three years after it ends. Messages are sent through our email delivery service, a processor already listed.

You can withdraw this consent at any time: from MyClub, or through the link in the messages sent under this consent, which opens a page where a button confirms the withdrawal. When your mailbox shows its own unsubscribe button, it withdraws the consent directly. Your rights of access, erasure and objection can also be exercised in writing with the controller named above.

3. Hosting: data stored in France

Data is hosted in France: Supabase database (AWS eu-west-3 region, Paris) and Scaleway application infrastructure and file storage (fr-par region, Paris).

4. Recipients and processors

Data is never sold or handed over. Technical processors: Supabase (database, authentication), Scaleway (hosting, file storage), Brevo (transactional email), Mistral, a company established in France (artificial intelligence: the Scuby assistant, translation, reading paper logbooks, moderation of public lounges, analysis of messages sent to the team and, for the team, summaries of public lounge messages without their authors' names or usernames, help in drafting our newsletters, and analysis of comments posted under our social media pages), Stripe (payment, forthcoming). Two services are called directly by your browser, with no account and no cookie: OpenFreeMap (map backgrounds) and Open-Meteo (city search and conditions). They receive your IP address for the time it takes to answer, and nothing else. The Base Adresse Nationale (a French public service) is queried from our servers, never by your browser, to suggest addresses while you type: it receives the typed text — or the postcode alone on a member record — and neither your IP address, nor your name, nor your account.

Supabase, Scaleway and Brevo process your data within the European Union. The requests we send to Mistral are run in data centres located in the European Union or in a European Free Trade Association country (Iceland, Liechtenstein, Norway, Switzerland). This commitment covers neither the operational data that accompanies them (account, access keys, billing, usage metrics and other metadata), which may be processed outside this area, nor the place where the content of the requests might, if applicable, be retained. Switzerland benefits from a European Commission adequacy decision. Stripe is also an exception: the contract is with Stripe Payments Europe (Ireland), but payment data may be transferred to Stripe, Inc. in the United States, framed by the European Commission's standard contractual clauses. We say so because it is true, and because a page claiming that «everything stays in Europe» would mislead you on these precise points.

Marketing tools, kept apart. To create and publish our posts, we use our post creation and publishing tools, separate from the application. These tools have no access to the application's data: no user data is passed to them.

5. Retention periods

Account data is kept for as long as the account is active, then deleted within 30 days of account deletion (excluding statutory retention obligations, notably accounting ones).

One exception deserves to be named rather than filed under “legal obligations”: the audit log, which records sensitive actions (consents, deletions, withdrawals, administrative acts), is kept for 5 years and survives the deletion of the account — this is what makes it possible to establish later who consented to what, and when. What survives in it no longer identifies you: your email address is not recorded in it, and IP addresses are reduced to their network prefix. One limit, which we prefer to state: the sealed copies of the log stored before this clean-up are locked for five years, can be neither modified nor erased before that term, and may still contain an email address or a full IP address.

Accounts without a paid plan. Opening an account no longer comes with a trial: a Free account has no end date. When a paid plan, or the Standard plan offered by a club, ends, the account returns to the Free plan and its data is kept: the dive log and photos remain viewable read-only and can be exported. You can delete your account at any time from your space. Storage limitation (art. 5.1.e GDPR): we may delete an account with no activity for 24 months. This deletion is not applied at present; on the day it is, we will warn you by email one month beforehand, never deleting less than 30 days after a delivered warning, and signing in will be enough to keep the account. An account linked to a club, or that has already paid, is not deleted automatically: it is reviewed by hand. An unconverted trial no longer leads to any deletion.

Former customers and accounts opened before the change of plans. When a subscription ends, the account returns to the Free plan; accounts opened under the former trial or the former free tier are on the Free plan. In every case, the dive log and photos are kept read-only and can be exported, and no account is deleted for lack of a subscription: only the inactivity rule above applies.

6. Your rights

You have the rights of access, rectification, erasure, portability, restriction and objection, which can be exercised by email at contact@scubalia.com. You may lodge a complaint with the supervisory authority of your country of residence (GDPR art. 77), and with ours, the French CNIL (cnil.fr).

7. Cookies

Scubalia sets only the cookies needed for the service you use, and no others. The login session, while you are signed in. The langue cookie, only when you choose a language or open a link that specifies one: it remembers that choice for one year. And two short-lived technical cookies, set only during the step that needs them: pw_recovery (15 minutes, the time to choose a new password) and portail_passage (4 hours, after entering the access code of your club's portal or scanning the QR code on its poster). All are exempt from consent. No measurement cookies, no advertising cookies, no third-party trackers, no ad network. The link in our campaign messages to clubs goes through a Scubalia address that records the date of the first click, without storing anything on your device: the origin of that click then travels in the page addresses, up to the trial it opens. In our campaign emails, the sending tool adds an open marker; it is set to anonymous mode: opens and clicks are counted overall, without being linked to your address.

The French version is the authoritative one; this translation is provided for information only.

Version of 2026-10-22.