Privacy Policy

This Privacy Notice for Salty Seas Software LLC (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://reefly.app or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Reefly), or any other application of ours that links to this Privacy Notice
• Use Reefly — a pre-launch landing page for an upcoming SCUBA dive app. Visitors can join a waitlist with their email address and submit free-form feedback through a contact form. No paid product or account is offered yet.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hi@reefly.app.

Summary of key points

This summary provides key points from our Privacy Notice. You can find more detail on any topic by jumping to its full section below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some information may be considered “special” or “sensitive” in certain jurisdictions, for example racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

In shortWe collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

• email addresses
• names

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in “How do we handle your social logins?” below.

Application Data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

• Geolocation information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile device access. We may request access or permission to certain features from your mobile device, including bluetooth, sensors, storage, reminders, contacts, camera, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile device data. We automatically collect device information (such as mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In shortSome information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches, and other actions taken), device event information (such as system activity, error reports, and hardware settings).

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In shortWe process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To respond to user inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In shortWe only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law — with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may send users information about special offers and discounts on our products and services, and understand how our users use our products and services so we can improve user experience.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent — including for investigations and fraud prevention, for business transactions, to identify injured or deceased persons, in response to a subpoena or court order, or where the information is publicly available and specified by the regulations.

4. When and with whom do we share your personal information?

In shortWe may share information in specific situations described in this section and/or with the following third parties.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. We obtain and store on your device (“cache”) your location. You may revoke your consent anytime by contacting us at the details below.
• Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity.

5. What is our stance on third-party websites?

In shortWe are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. Any data collected by third parties is not covered by this Privacy Notice. You should review the policies of such third parties directly.

6. Do we use cookies and other tracking technologies?

In shortWe may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising. To the extent these online tracking technologies are deemed to be a “sale” or “sharing” under applicable US state laws, you can opt out as described in “Do United States residents have specific privacy rights?” below.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. You can opt out of being tracked by Google Analytics at tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, visit the Google Privacy & Terms page.

7. How do we handle your social logins?

In shortIf you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services.

8. How long do we keep your information?

In shortWe keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than three (3) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In shortWe aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk.

10. Do we collect information from minors?

In shortWe do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at hi@reefly.app.

11. What are your privacy rights?

In shortDepending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. You can make such a request by contacting us using the contact details below.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us. This will not affect the lawfulness of the processing before its withdrawal.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us. You will then be removed from the marketing lists. We may still communicate with you for service-related messages necessary for the administration and use of your account.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, email us at hi@reefly.app.

12. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. Do United States residents have specific privacy rights?

In shortIf you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent.

Categories of personal information we collect

We have not collected personal information in any of the following statutory categories in the past twelve (12) months: Identifiers; California Customer Records personal information; protected classification characteristics; commercial information; biometric information; internet or other similar network activity; geolocation data; audio, electronic, sensory, or similar information; professional or employment-related information; education information; inferences drawn from the above; or sensitive personal information.

We may collect other personal information outside of these categories through interactions with you in person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys or contests, and facilitation of the delivery of our Services and responding to your inquiries.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include:

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling

How to exercise your rights

To exercise these rights, contact us by emailing hi@reefly.app or by referring to the contact details at the bottom of this notice. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hi@reefly.app. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” law

California Civil Code Section 1798.83 permits California residents to request, once per year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact details below.

14. Do we make updates to this notice?

In shortYes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hi@reefly.app or contact us by post at:

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. To request to review, update, or delete your personal information, email hi@reefly.app.