This English version is a reference translation provided for convenience. The Japanese version is the governing text; in the event of any discrepancy, the Japanese version prevails.

Privacy Policy

This Privacy Policy (the “Policy”) sets out how the Operator handles the personal information of Users that it collects and uses in the Service (a smartphone app for sharing diving photos, videos, and logs; the “App”).

By using the App, a User is deemed to have agreed to this Policy.

Article 1 (Information We Collect)

In providing the Service, the Operator may collect the following information.

1. Information that Users register or enter

2. Information collected automatically through use of the Service

At present, the Operator does not collect information such as real names, addresses, or phone numbers.

Article 2 (Purposes of Use of Personal Information)

The Operator uses the personal information it collects within the scope of the following purposes:

  1. Providing, operating, and maintaining the Service
  2. User authentication, identity verification, and account management
  3. Improving the Service, enhancing its quality, and analyzing usage
  4. Preventing and responding to fraudulent activity
  5. Responding to inquiries from Users and to requests to add or correct dive site or marine life information
  6. Responding to violations of the Terms of Service and handling disputes
  7. Responding to requests to delete photos and videos kept when an account was deleted, and carrying them over when the same email address is used to register again

If the Operator uses personal information beyond the scope of these purposes, it will notify Users or obtain their consent in advance by appropriate means, except as provided for by laws and regulations.

Article 3 (Handling of Posted Content)

Photos, videos, text, location information, and other content that Users post to the Service may contain personal information.

Such posted content is used to provide, operate, and improve the Service within the scope set out in the Terms of Service.

The Operator creates observation records that do not identify the photographer (the date of the dive, the dive site and dive points, the conditions such as weather, air temperature, water temperature, and visibility, the dive type, and the species of marine life) from the marine life tags on photos and videos posted to the Service and from the marine life recorded in dive records, and uses them to provide and improve the Service. Observation records are also created from tags on private photos and videos, but they do not include information that identifies the person who took or recorded them (including the account’s internal ID number and the identifiers of photos and videos), and they are not shown to other users. While the original dive record exists, an observation record is kept linked to that dive record, and observation records are kept even after the photos, videos, account, or dive records are deleted. The retention period and exceptions are as set out in Account and Data Deletion.

The handling of posted content after an account is suspended or deleted follows the Terms of Service. However, the data deleted and the data that remains when Users delete their own account are as set out in Account and Data Deletion.

If a User chooses “Keep photos and videos for your dive buddies” when deleting their account, the Operator keeps the photos and videos that User posted (excluding private ones) and their tags, shown as posted by “退会したユーザー” (Japanese for “deleted user”) and without changing their visibility. The Operator also keeps a value made by converting the email address registered to the account, mixed with a value known only to the Operator, into a form that cannot be turned back into the address (a hash), together with its link to the kept photos and videos (the email address itself is not kept). This hash is used to verify the User’s identity when a request to delete the kept photos and videos is received, and to carry the kept photos and videos over when the same email address is used to register with the Service again, and it is deleted no later than the day after all of the kept photos and videos have been deleted. The retention period and how to request deletion are as set out in Account and Data Deletion.

Article 4 (Handling of Payment Information)

Payments for paid plans are made through external payment providers.

The Operator does not directly collect or hold payment information such as credit card numbers.

The privacy policies of the respective payment providers apply to personal information relating to payments.

Article 5 (Provision to Third Parties)

The Operator does not provide Users’ personal information to third parties except in the following cases:

  1. Where the User has consented
  2. Where provided for by laws and regulations
  3. Where personal information is provided to contractors to the extent necessary to provide the Service
  4. Where it is necessary to protect a person’s life, body, or property and it is difficult to obtain the person’s consent

To improve the Service and analyze how it is used, the Operator uses a usage analytics service (PostHog) and sends it the usage logs and device information described in Article 1 (such as the type and time of operations performed in the App, the App version, and the OS type). The only information sent to identify a User is an identifier derived from the internal ID number of the User’s account; email addresses, nicknames, and posted content are not sent. In addition, due to the nature of network communication, the IP address of the User’s device reaches the service. This transmission is made as provision to a contractor under item 3 of this Article.

To deliver the App’s push notifications, the Operator uses a push notification delivery service (Expo, through which Apple Push Notification service and Firebase Cloud Messaging are used) and sends it the identifier of the User’s device used as the destination for push notifications described in Article 1, together with the text of each notification (such as the nickname of the User who caused the event and the name of the tour). This transmission is made as provision to a contractor under item 3 of this Article.

To respond promptly to inquiries and reports, the Operator uses a work communication tool (Slack). When an inquiry arrives, the Operator sends the service a notification containing the inquiry type, the nickname of the User who sent it, whether the User has a paid plan, and the OS type and version; when a photo or video is reported, the Operator sends a notification containing the nicknames of the reporting User and the posting User. The body of inquiries, photos, and location information are not sent. This transmission is made as provision to a contractor under item 3 of this Article.

The Operator uses AI (Claude, provided by Anthropic, PBC) to help respond to inquiries. Only when a User consents in the App, the Operator sends Anthropic the content of the inquiry (the message text, the inquiry type, and the content of requests to add or correct dive sites or marine life, which may include the location of a dive site and, if the User entered their current location in the App, that location information; email addresses, phone numbers, and URLs are masked before sending), device information (app version, OS type and version, and device model), and whether the User has a paid plan, and uses them to prepare replies. The Operator may also send past replies to other Users who have likewise consented, as examples of how to write replies. The content sent is not used to train AI. Every reply is reviewed by a staff member before it is sent. Users can withdraw this consent at any time in the App’s settings, after which nothing new is sent. This transmission is made as provision to a contractor under item 3 of this Article.

If the Operator newly uses advertising services or similar services in the future, it will revise this Policy appropriately and inform Users as necessary.

Article 5-2 (Provision to Third Parties in Foreign Countries)

To the extent necessary to provide the Service, the Operator may entrust the handling of personal information to contractors located in foreign countries. The main contractors and the countries where they are located (with the main region where personal information is stored or processed in parentheses) are as follows.

In such cases, the Operator entrusts the handling after confirming that the contractor has established a system that conforms to the standards set forth in the Act on the Protection of Personal Information of Japan.

Article 6 (Security Measures)

The Operator takes reasonable and appropriate security measures to prevent the leakage, loss, or damage of personal information and otherwise to manage personal information securely.

Article 7 (Retention Period)

The Operator retains personal information for the period necessary to achieve the purposes of use or for the period prescribed by law, and then deletes or anonymizes it by appropriate means.

The data deleted when an account is deleted, and the data that remains after deletion and its retention periods, are as set out in Account and Data Deletion.

Article 8 (Users’ Rights)

In accordance with the Act on the Protection of Personal Information, Users may make the following requests regarding their own personal information:

  1. Disclosure
  2. Correction, addition, or deletion
  3. Suspension of use or erasure

To make such a request, please contact the Operator by the method it prescribes. The Operator will respond promptly to a reasonable extent.

Users can delete their account from the App at any time. For the steps, see Account and Data Deletion. Deletion of photos and videos kept when an account was deleted can also be requested by the method set out on the same page.

Article 9 (Changes to This Policy)

The Operator may change this Policy in response to changes in laws, changes in the content of the Service, or other reasons.

When making material changes, the Operator will inform Users through in-app notifications or other appropriate means.

Article 10 (Contact)

For inquiries about this Policy, please contact us through the inquiry contact point provided in the Service or via our Support page.