Legal · Effective 10 August 2026
Privacy Policy – Freediving CO₂ Training Smart
This Privacy Policy explains how Neptune's Submerge Limited (“Neptune's Submerge”, “we”, “us” or “our”) collects, uses, stores and protects information when you use the Freediving CO₂ Training Smart mobile application (“the App”).
1. Information we may collect
The App provides personalised freediving, breath-hold and CO₂ training programmes and progress tracking. Depending on the features you use, we may collect or process:
Account and profile information
- Name or display name
- Email address
- Account identifiers
- Preferences and application settings
Training and fitness information
- Breath-hold times and personal bests
- CO₂ and other training-table results
- Training duration, frequency and history
- Recovery periods and training goals
- Self-reported experience level
- Progress, performance and other information you voluntarily enter
Technical and app information
- Device type and operating system
- App version
- Crash and diagnostic information
- Basic usage and performance information
- Security and fraud-prevention information
Training information may constitute health or fitness information and may receive additional protection under applicable data-protection law. We aim to collect only information reasonably necessary to provide and improve the App.
2. How we use your information
We may use your information to:
- Create and maintain your account.
- Provide personalised breath-hold and CO₂ training programmes.
- Adapt recommendations according to your progress and previous sessions.
- Display training history, personal bests and progress insights.
- Operate, maintain and improve the App and diagnose technical problems.
- Protect users and the App from fraud, abuse or security threats.
- Manage subscriptions or premium features.
- Respond to support requests and comply with legal obligations.
We do not sell personal health or fitness information to advertisers or data brokers.
3. AI and automated personalisation
The App may use algorithms or artificial intelligence to personalise training recommendations based on previous breath-hold performance, training history, goals and selected difficulty.
Recommendations support training and education. They are not medical diagnoses or treatment recommendations. The App does not make automated decisions intended to produce legal or similarly significant effects.
4. Health and safety
Freediving and breath-hold training involve inherent risks, including loss of consciousness. The App is for training, fitness, educational and wellbeing purposes and is not a medical device. It does not provide medical diagnosis, treatment or emergency advice.
- Never practise breath-holding in water alone.
- Use qualified supervision and recognised freediving safety procedures in water.
- Never intentionally hyperventilate before breath-holding.
- Stop if you experience pain, dizziness, unusual discomfort or other concerning symptoms.
- Seek medical advice before training if you have a relevant condition or concern.
Do not rely on the App in an emergency.
5. Legal basis for processing
Where UK data-protection law applies, we process personal information only with an appropriate lawful basis. Depending on the circumstances, this may include performance of a contract, consent, legitimate interests or legal obligation.
Where information constitutes special-category health data, we will process it only where an appropriate additional condition applies, which may include your explicit consent.
6. Sharing information
Trusted service providers may help with cloud hosting and storage, authentication, analytics and diagnostics, artificial-intelligence processing, customer support, security, and subscription or payment processing. They may process information only as necessary to provide services to us and subject to appropriate safeguards.
Google may process Google Play purchases and subscriptions. We do not normally receive complete payment-card information. We may disclose information where required by law or necessary to protect users, our rights or App security. We do not use health or fitness information for targeted advertising.
7. International data transfers
Some technology providers may process information outside the United Kingdom. We use appropriate safeguards where required by applicable data-protection law.
8. Data security
We use reasonable technical and organisational measures designed to protect information against unauthorised access, accidental loss, misuse, alteration, disclosure or destruction. Appropriate secure communication methods are used when information is transmitted.
No electronic system can guarantee absolute security.
9. Data retention
We retain personal information only as long as reasonably necessary to provide the App, maintain training history, comply with legal requirements and resolve disputes.
If you delete your account, associated information will be deleted or anonymised unless retention is legally required. Secure backup copies may remain temporarily until automatically overwritten or deleted.
10. Account and data deletion
Where the App allows account creation, you may request deletion of your account and associated personal information from within the App where available, or by following the instructions on our Freediving CO₂ Training Smart account and data deletion page.
Following a valid request, we will delete associated personal information unless retention is required by law.
11. Your privacy rights
Depending on applicable law, you may have rights to access, correct or delete information; restrict or object to processing; receive certain information in a portable format; and withdraw consent where processing relies on consent.
Withdrawal does not affect earlier lawful processing. UK users may complain to the Information Commissioner's Office (ICO). We encourage you to contact us first.
12. Children
The App is not intended to collect personal information from children without appropriate protections and legally required consent. Features intended for younger users will include the safeguards required by applicable law and Google Play policies.
13. Third-party links
The App may link to third-party websites or services. We are not responsible for their privacy practices; review their policies separately.
14. Changes to this policy
We may update this policy as the App develops or legal, technical or operational requirements change. The current version and effective date will appear here.
We will provide appropriate notice where material changes affect how personal information is used.
15. Contact us
