Privacy Policy

Your privacy is important to me. It is Goodwhale EURL’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Tortuba, and its associated services.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.

In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app.

This policy is effective as of 12 September 2026.

Last updated: 12 September 2026

The Short Version

Tortuba is an offline logbook. Your dives, the species you met, and the photos you attached to them are stored on your device and nowhere else. There is no Tortuba account, no Tortuba server, and no analytics or advertising code inside the app. We cannot read your logbook, because we never receive it.

The rest of this policy sets out the detail, including the limited cases where we do hold personal information about you — essentially, when you email us, and when you visit our website.

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using our app and its associated services.

“Automatically collected” information refers to any information automatically sent by your device in the course of accessing our app and its associated services.

Your Logbook Stays on Your Device

Everything you record in Tortuba — your dives, dive sites, trips, buddies and guests, signatures and stamps, species encounters, notes, tanks, certifications, and the photos you attach — is stored in a database on your device.

Tortuba has no account and no login. There is no Tortuba server that receives this data. Earlier versions of the app could sync with a web service at tortuba.com; that service closed, and version 4.0 removed the sync entirely. Data that had previously synced stayed on the device that held it.

We therefore never see your logbook. We cannot read it, search it, export it, or restore it for you.

Device Permissions

Tortuba asks your permission for three things, each used only on your own device:

• Camera — to photograph a species, a dive site, or a buddy’s stamp for your logbook.
• Photo library — to import pictures you have already taken into your logbook.
• Location, while you are using the app — to help you place a new dive site. Tortuba does not track your location in the background.

Nothing captured through these permissions is transmitted to us. You can withdraw any of these permissions at any time in your device’s Settings; the corresponding feature will stop working, but the app will continue to run.

iCloud and Device Backups

If you use iCloud Backup, your device backup includes Tortuba’s data in the same way it includes other apps’ data. That backup lives in your own iCloud account, is handled by Apple under Apple’s terms and encryption, and we have no access to it whatsoever. Managing or deleting it is a matter between you and Apple.

Analytics and Error Reporting

Tortuba contains no analytics software, no advertising software, and no crash-reporting software. We do not measure what you do in the app, and when the app misbehaves we do not find out unless you tell us.

Apple provides us with the aggregate App Store statistics it provides to every developer — download and update counts, and, where you have chosen to share diagnostics with developers, crash reports. That information reaches us from Apple, already aggregated or anonymised, and we cannot connect it to you.

Our Website

tortuba.com is a static website. It uses Ahrefs Web Analytics, which is cookieless: it counts page views without setting cookies, without assigning you a persistent identifier, and without following you to other websites. The dive calculators and the fish quiz run entirely inside your browser — the numbers and answers you enter are never sent anywhere.

Collection and Use of Information

We may collect personal information from you when you do any of the following:

• Use a web browser to access our website, in the limited form described above
• Contact us via email, social media, or on any similar technologies
• When you mention us on social media

Because the app has no account and no sync, there is no other route by which information about your use of Tortuba reaches us.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

The security of the logbook itself is in your hands, since it lives on your device: the device passcode, biometric lock, and backup settings you choose are what protect it.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information such as an email address when contacting us about a specific enquiry, we may retain this information for the duration of your enquiry remaining open as well as for our own records so we may effectively address similar enquiries in future. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Your logbook is not subject to any retention period of ours, because we do not hold it. It remains on your device until you delete it or delete the app.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary, or affiliate of our company
• third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, maintenance or problem-solving providers, professional advisors, and payment systems operators
• our employees, contractors, and/or related entities
• our existing or potential agents or business partners
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
• an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

• Apple — distributes Tortuba through the App Store, and holds your device backup if you use iCloud. Your relationship with Apple is governed by Apple’s own privacy policy.
• Ahrefs — provides the cookieless web analytics on tortuba.com described above.

We do not sell personal information, and we do not share it with advertisers or data brokers.

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Access to your logbook: We do not provide a means of downloading your logbook from us, because we do not hold it. It is already on your device, and deleting the app deletes it.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information. Your logbook would not be among those assets, since it is not ours to transfer.

Limits of Our Policy

Our app and our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here and on our website.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, Goodwhale EURL, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.

We are not a controller or a processor of the contents of your logbook. That data is created and held by you, on your own device, without passing through us.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, you may consent to your name and email address being used so we can respond to your enquiry. While you may request that we delete your contact details at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. This basis rarely applies to Tortuba, which is free, requires no account, and is distributed to you by Apple rather than by us.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. For example, we count page views on our website in order to understand which of our guides are useful and which are not. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party. In practice this will amount to little more than our email correspondence with you, as we hold nothing else.

Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our app, website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

Additional Disclosures for California Compliance (US)

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals. The analytics on our website do not track you across websites in the first place.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

CCPA-permitted financial incentives

The CCPA permits certain financial incentives that can result in different prices, rates, or quality levels for the goods or services we provide. We do not offer any such incentive. Tortuba is free, and we do not vary what you receive on the basis of the personal information you share with us.

California Notice of Collection

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

Arnaud Joubay
https://sowenjub.me