ELEMENT | 08
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Privacy Policy

Last updated: July 7, 2026

ELEMENT | 08 ("the App") is a freediving training and logging application. The App works fully offline and needs no account; an optional free account adds cloud backup and coach↔athlete features. This policy explains what data we collect, how it is used, where it is stored, and your rights under the EU General Data Protection Regulation (GDPR).

// CONTROLLER

The data controller responsible for your data is the operator named in our Impressum. For any privacy question or request, contact apnea.advantage@gmail.com.

// DATA COLLECTION

By default, your training data stays on your device: the App does not require an account and works fully offline. Data leaves your device only when you use a feature that needs it: in-app purchases, and, if you choose to create an account, cloud backup and coach↔athlete sync (see Cloud Account & Sync below).

  • Training sessions: Stored locally on your device. This includes timers, block timelines, contraction markers, ratings, and notes.
  • Dive logs: Imported from FIT/Garmin (and other supported) files you select. Parsed and stored locally.
  • Oximeter data: SpO2, heart rate, and perfusion index readings received via Bluetooth Low Energy (BLE) from your paired device. Stored locally as part of your training session.
  • App settings: Theme, audio preferences, units, and other configuration. Stored locally.

// BLUETOOTH

The App uses Bluetooth Low Energy (BLE) to connect to pulse oximeters and dive devices for real-time monitoring during training. BLE is only active when you initiate a scan or connect to a device, and communicates only with your own paired devices. No BLE data is transmitted to external services.

// ACCOUNTS

Accounts are optional: you can use the entire App without one. If you create a free account, you sign up with an email address and a password, and we store your email, a display name you choose, and a coach/athlete role flag. When you sign up you are asked to agree to this Privacy Policy and our Terms. We use Supabase, a hosting and authentication provider, to operate accounts; Supabase acts as our processor under a data-processing agreement.

// CLOUD ACCOUNT & SYNC

With an account you can use these features. They are off until you turn them on:

  • Cloud backup (Pro): a copy of your logbook is stored in your account so you can restore it on a new device.
  • Coaching: you connect with a coach (or, as a coach, with your athletes) using an invite code. While connected, a coach can assign you training plans, and the progress you choose to report (plan completions, notes, any logbook session you attach, and the PBs/goals in your athlete profile) is shared with that coach.

You control these connections and can disconnect, or delete your account, at any time, which stops further sharing. Access is enforced at the database level (row-level security): a coach can only ever see data for athletes connected to them, and never another coach's athletes.

// AI ASSISTANT

The App includes an optional AI assistant that answers questions about your own logged training and dive data in natural language. It is off until you open it, and the first time you use it you are asked to give explicit consent after a short summary of how it works. How your data is handled:

  • What is sent: the question you type, together with aggregated figures calculated on your device from your logs (for example averages, counts, and per-hold heart-rate and blood-oxygen statistics). Your raw dive logs, full depth-and-time profiles, GPS locations, and free-text notes never leave your device; only the summarised numbers needed to answer your question are sent.
  • Who processes it: the request is relayed through our server to Anthropic PBC (United States), which runs the language model that generates the answer. Anthropic acts as our processor under a data-processing agreement and does not use the data to train its models.
  • International transfer: because Anthropic processes the request in the United States, using the assistant transfers your data outside the EU. This transfer is safeguarded by the EU Standard Contractual Clauses in our agreement with Anthropic. Some of the aggregated figures can relate to your health (such as heart-rate and blood-oxygen values), so we ask for your explicit consent before the feature is used.
  • Retention: Anthropic retains the request only for a limited period for security and abuse-prevention and then deletes it. We do not store your conversations on our servers; our server logs record only anonymous usage counts, never the content of your questions or answers.
  • Your control: the assistant is available when you are signed in (free accounts include a small monthly question allowance, which Pro or the Assistant add-on raise), you choose when to use it, you can limit which categories of data it may use under Settings, and you can simply not use it. Declining consent leaves every other part of the App fully usable.

// WHERE YOUR DATA IS STORED

On-device data never leaves your device unless you use the cloud features above. Account and cloud data is stored on Supabase servers in the European Union (Frankfurt, Germany). The one exception is the optional AI assistant, which, when you use it, sends the data described under AI Assistant to Anthropic in the United States.

// PURCHASES & SUBSCRIPTIONS

When you buy a subscription or a one-time purchase, the transaction is processed by Apple or Google. We use RevenueCat, a subscription-management provider, to verify, deliver, and restore your purchases. For this purpose RevenueCat receives your purchase history along with an app-generated identifier and a device identifier. This information is used only to provide the features you bought. It is not used to track you across other apps or for advertising.

// ANALYTICS & TRACKING

The App uses no analytics services, advertising SDKs, or tracking pixels, and does not track you across other apps or websites. The only third parties are RevenueCat (purchases), Supabase (accounts and cloud storage, if you create an account), and Anthropic (only if you use the AI assistant), each described in this policy and used solely to provide the App.

// DATA SHARING

We do not sell your data and never share it for advertising. Data is shared only as needed to provide the App:

  • Apple / Google & RevenueCat: purchase and subscription data, to process and restore purchases.
  • Supabase: your account and cloud data, to provide accounts, cloud backup, and coaching (EU-hosted, as above).
  • Your coach: if you connect with one, the coaching data described under Cloud Account & Sync.
  • Anthropic: if you use the AI assistant, your question and the aggregated figures needed to answer it, to generate the response (United States, under Standard Contractual Clauses; see AI Assistant).

// LEGAL BASIS

Where the GDPR applies, we process your data on the basis of: providing the service you requested (Art. 6(1)(b)) for account and coaching features; your consent (Art. 6(1)(a)), which you give at sign-up and can withdraw at any time; and our legitimate interest in operating and securing the App (Art. 6(1)(f)). For the AI assistant, and specifically for any health-related figures it may include, we rely on your explicit consent (Art. 6(1)(a) and Art. 9(2)(a)), which you give before first use and can withdraw at any time by not using the feature.

// YOUR RIGHTS

You can exercise these rights at any time, directly in the App:

  • Access & portability: export your cloud-account data under Settings › Account › Export my data, and your on-device logbook under Settings › Backup & Data. Exports are provided in a standard machine-readable (JSON) format.
  • Erasure: permanently delete your account and all of its cloud data under Settings › Account › Delete account & data.
  • Rectification: edit your profile and entries within the App.
  • Withdraw consent: sign out, disconnect from a coach, or delete your account.

You also have the right to lodge a complaint with a data-protection supervisory authority.

// DATA RETENTION

On-device data is kept until you delete it or uninstall the App. Account and cloud data is kept until you delete your account, after which it is removed from our systems. Invite codes expire automatically. When you use the AI assistant, Anthropic retains the request only briefly for security purposes (see AI Assistant); we do not keep your conversations.

// DATA DELETION

  • On-device data: delete individual sessions in the App, or uninstall the App (removes all local data).
  • Account & cloud data: Settings › Account › Delete account & data permanently removes your account and everything stored for it on our servers. This cannot be undone.

// CHILDREN

The App is not directed at children under 16. We do not knowingly collect data from children under 16; if you are under 16, use the App only with the consent of a parent or guardian.

// CHANGES

We may update this Privacy Policy from time to time. Changes will be reflected on this page with an updated "Last updated" date.

// CONTACT

If you have questions about this Privacy Policy, contact us at apnea.advantage@gmail.com.

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