Privacy Policy

Last updated: 22 October 2026

This policy explains what personal data Scuba Manager handles, why, for how long, who else touches it, and what rights you have. It is written for dive centre owners, staff and instructors, and for the divers whose details a dive centre keeps in Scuba Manager.

Privacy Policy - Scuba Manager

1. Who we are

Scuba Manager is run by PANCHENKOV & LAHAV Ο.Ε. (a Greek general partnership), trading as Cookie Tech. Promitheos 2, 166 73 Voula, Attica, Greece. VAT EL802636558. General Commercial Registry (ΓΕΜΗ) 179986658000.

Privacy contact: hello@cookie-tech.com

We have not appointed a Data Protection Officer because the law does not require one for our activity. Write to the address above with any privacy question.

2. Two roles: controller and processor

Scuba Manager holds two kinds of personal data, and our role is different for each.

We are the controller for data about the people who use Scuba Manager: dive centre managers, staff and instructors with an account, people who contact us, visitors to our website, and billing contacts. This policy covers that data fully.

We are a processor for data a dive centre enters about its own clients (divers): names, contact details, certifications, equipment sizes, bookings, notes, and any medical or waiver flags. For that data the dive centre is the controller. It decides what to collect and why, and it answers its divers' requests. We only process it on the centre's instructions, under our Data Processing Addendum (scuba-manager.com/dpa). If you are a diver, please contact your dive centre first. If you contact us, we will pass your request to the centre.

3. What we collect about account holders and visitors

DataWhere it comes from
Name, email, phone, role, language and unit preferencesYou, when you sign up or are invited
Dive centre details (name, address, business details)You
Certifications and professional qualifications, profile and job board details (instructors)You
Files you upload (avatar, documents)You
Billing contact, Stripe customer ID, subscription status and planYou and Stripe. We never see or store your full card number or CVC.
Sign-in records, security and audit logs (for example role or billing changes)Our systems, automatically
Messages to us (contact form, email)You
Website usage statistics (pages viewed, device type, approximate location)Google Analytics, only if you click Accept on the cookie banner

4. Why we use it and our legal basis

PurposeLegal basis (GDPR art. 6)
Create and run your account, provide the Service, support youPerformance of our contract with your dive centre or with you (6(1)(b))
Take payment, issue invoices, keep accounting recordsContract (6(1)(b)) and legal obligation under Greek tax law (6(1)(c))
Service emails: welcome, account, security and billing noticesContract (6(1)(b))
Occasional product updates to account holdersOur legitimate interest in telling customers about the Service they use (6(1)(f)). You can opt out in any email.
Keep the Service secure, prevent abuse, keep audit logsLegitimate interest (6(1)(f))
Website analyticsYour consent (6(1)(a)), which you can withdraw any time via "Cookie settings" in the footer
Answer legal claimsLegitimate interest (6(1)(f))

We do not sell personal data, we do not use it for advertising profiles, and we do not make automated decisions that have legal or similar effects on you.

5. Health and medical information

A dive centre may record medical or waiver flags about its divers. This is sensitive data (GDPR art. 9). The dive centre is responsible for having a lawful basis, usually the diver's explicit consent, and for recording only what it needs. We recommend storing a simple flag (for example "medical form received, cleared") rather than medical details.

6. Cookies and similar storage

  • Essential (always on): your sign-in session, and your cookie choice saved in your browser's local storage. The Service cannot work without these.
  • Analytics (only after Accept): Google Analytics 4 cookies that tell us how the website is used. If you click Decline, or make no choice, they are not set.
  • You can change your choice any time with "Cookie settings" in the footer.

7. Who else handles the data (sub-processors)

We use these providers to run the Service. Each processes data only to provide its service to us, under a data processing agreement. Our terms with dive centres for divers' data are in our Data Processing Addendum.

ProviderWhat it doesData involvedWhereTransfer safeguard
SupabaseDatabase, sign-in, file storage, server functionsAll Service dataEU (Frankfurt, Germany, AWS eu-central-1)Data stored in the EU. Supabase is a US company; any access from outside the EU is covered by its DPA and Standard Contractual Clauses.
Lovable (with Cloudflare)Hosting and delivery of the web appTechnical data such as IP addressGlobal networkDPA; EU-US Data Privacy Framework or Standard Contractual Clauses
StripeSubscription payments, invoices, tax calculationBilling contact, card and payment data, IP addressEU and USStripe Payments Europe (Ireland); transfers under the Data Privacy Framework and Standard Contractual Clauses
ResendSending emailsName, email address, email contentSent via AWS eu-west-1 (Ireland); Resend is a US companyDPA; Data Privacy Framework or Standard Contractual Clauses
Google (Google Analytics 4)Website statistics, only after consentPseudonymous identifiers, device data, approximate locationEU and USGoogle Ireland; Data Privacy Framework and Standard Contractual Clauses
AnthropicAI assistance used by our team for support and maintenanceData viewed during a support or maintenance taskUSDPA and Data Privacy Framework or Standard Contractual Clauses

Integrations you choose. If your dive centre connects a booking engine (for example FareHarbor), data flows between Scuba Manager and that provider on your instructions. That provider works for your dive centre under its own terms, not as our sub-processor.

We will update this list before adding a new sub-processor and tell dive centres in advance, as set out in our Data Processing Addendum.

8. Transfers outside the EU

We keep the Service database in the EU. Some providers above are based in, or may access data from, the United States. Where that happens we rely on the EU-US Data Privacy Framework for certified providers, or on the European Commission's Standard Contractual Clauses.

9. How long we keep data

DataHow long
Account and dive centre dataWhile the subscription is active. After cancellation or account deletion: 30 days in which you can export, then deleted within a further 30 days. Audit records of deleted items, which may include a copy of the deleted record, are kept for security and dispute purposes.
Backup copiesWe do not currently guarantee backups. If our database provider holds any backup copy, deleted data may remain in it until it is overwritten.
Invoices and billing recordsAs long as Greek tax and accounting law requires (at least 5 years)
Security and audit logsCurrently kept without a fixed end date, for security and dispute purposes. Records of deleted items may include a copy of the deleted record.
Messages to usUp to 24 months after the conversation ends
Analytics dataAs configured in Google Analytics (we use the shortest practical retention)
Divers' data (we are processor)As the dive centre decides. Deleted when the centre deletes it, or within 60 days after the centre's account ends.

10. Your rights

You can ask us to:

  • give you a copy of your data (access) and receive it in a portable format;
  • correct it;
  • delete it, unless we must keep it by law (for example invoices);
  • restrict or object to its use, including any use based on legitimate interest;
  • withdraw consent (for analytics) at any time, without affecting what happened before.

Write to hello@cookie-tech.com. We answer within one month, and tell you if we need more time (up to two further months for complex requests). We may ask you to confirm your identity.

If you are unhappy with our answer, you can complain to the Hellenic Data Protection Authority (www.dpa.gr), or to the authority in the EU country where you live or work.

11. Security

We use encryption in transit (HTTPS) and at rest, database-level separation between dive centres, role-based access, audit logs of critical actions, and signature-verified payment webhooks from Stripe. Platform API keys are kept in server-side secret storage, never in the app's code. No system is perfectly secure. If a personal-data breach affects you, we will tell you and the authorities as the law requires. For divers' data, we tell the dive centre without undue delay so it can do the same.

12. Children

Scuba Manager accounts are for adults working in or with dive centres. Dive centres may record details of divers under 18 (for example junior courses). The centre is responsible for any parental consent required.

13. Changes

We will post changes here and update the date at the top. If a change is significant, we will tell account holders by email before it takes effect.