Dolphin – Privacy Policy

Last updated: 2026-09-19

What Is the Privacy Policy?

Swid Technology Ltd., company no. 516959251 (the "Service Operator" or "we") respects the privacy of the users of "Dolphin" - an online service in the field of diving, which includes a digital dive log, information about various businesses operating in the diving field, and additional services – which we operate through an application (app) for smart end devices, as well as through a website operating at divedolphin.com, or at any additional address at the Service Operator's discretion (the application and the website, including the services provided through them, shall hereinafter be referred to collectively as: the "Service"). The privacy policy of the Service (the "Policy") is intended to inform you and explain the manner in which we collect, manage, process and use personal information that you provide to us through the Service, or that we collect automatically when you use the Service. You should always exercise extra caution and judgment when providing personal information that may identify you or others. The Policy is an integral part of the Terms of Use of the Service. The Service Operator may update the Policy from time to time, as set out in detail in the Terms of Use of the Service. The term "personal information" means any data relating to an identified person or to a person who can be identified, with reasonable effort, directly or indirectly, including identifying details such as name, address and contact details, information about dives, an online identifier, or one or more data items relating to a person's physical, health, economic, social or cultural condition. This Policy is written in the masculine form for convenience only and applies equally to all genders. Your use of the Service constitutes your consent to the Policy.

Contact Us on Any Privacy Matter

For any question, request, complaint, or any other inquiry regarding privacy or this Policy, please contact the Service Operator at the following email address: support@divedolphin.com. We are at your disposal and will endeavor to respond to your inquiry as soon as possible.

Providing Details and Personal Information to the Service Operator

Use of the full features of the Service requires registration, providing the information requested during registration, and your consent to the terms of the Binding Documents (including this Policy). The full features of the Service cannot be used without completing the registration process. If you choose not to register for the Service, you will be able to view only some of the Service's content, but not to use its full range of features. After registering for the Service, you may update your personal details at any time through your personal account and the Service interface. In addition, you may delete your account at any time through the settings area of the Service. Use of the Service, including registration to it, is permitted only to adult users aged 18 and over, or to any registered corporation or other lawful legal entity. Use of the Service is not permitted to minors under the age of 18. If you are under the age of 18, you are requested to refrain from using the Service and not to provide any personal information to the Service Operator. Providing personal information during the registration process - In the registration process for the Service, you will first be required to enter your full name, date of birth, your phone number and email address, and to choose a password that you will use to access the Service. For verification and identification purposes, we may send you verification messages using the contact details you have provided to us. Later in the registration process, we will ask you to set up your diving profile, and you will be asked to enter personal details relating to you as a diver, such as: your diving level (number of stars, Master Diver, Assistant Instructor, etc.), specialties (photography, Nitrox, buoyancy, and more), weights, fin size, wetsuit size, profile picture, and similar details. You may also register for the Service through your account on social networks and third-party services such as Google and Apple. When you register for the Service through your account on such a third-party service, you allow us access to your basic personal information on that service, such as your name, your email address, your picture, and any other information and content available for viewing in your account on that service. Our access to such personal information and content is limited to the information and content that the operator of the third-party service allows us to access, in accordance with your privacy settings on that third-party service, which you may change from time to time through the interface that service makes available to you. Your use of those third-party services is, of course, subject to the privacy policies of those services and not to this Policy. You may be required from time to time to enter within the Service the registration details you provided to the Service Operator, for the purpose of logging in to the Service again in the event of logging out or disconnecting from it. Providing personal information while using the Service - The Service allows you to set up (and update) your diving profile, to log your dives and experiences, to upload accompanying documents (such as insurance documents, certifications and licenses), and more. In addition, you may upload a profile picture that will represent your account in the Service, and update it. The dive log allows you to record the dive sites you have visited, the dates of your dives, the diving clubs whose services you have used, and more. If you wish the diving club where you dived to approve your dive in the digital log, we will ask you to approve sharing with the diving club, for a limited period (30 days), your dive-related details, including your name, phone number, date of last dive, diving profile details and certifications, documents such as insurance documents and diving license, and your dive history at that club. During this period, the club will be permitted to view your details in order to approve and record your dives – as stated, only if you approve this. Such diving club will not be exposed to dives you made at other clubs. You may cancel the information sharing at any time, in the list of diving clubs. Providing personal information when contacting us - When you contact us through the various means of contact, such as in writing, by email, through our social media channels, or by any other means - we will usually collect your name, your contact details (such as email and phone), and the content of your inquiry and the details included in it. The information fields that are mandatory will usually be explicitly marked wherever you are able to provide us with personal information. Without providing the requested information in the mandatory fields, you will not be able to complete the registration process or the relevant action. Naturally, providing personal information in fields that are not mandatory is voluntary, and you will be able to complete the requested action even without providing the personal information requested in those fields. You must provide only true, accurate and complete details, and you hereby confirm the accuracy of the details you have provided. You are not legally required to provide us with personal information, and doing so depends on your will and consent. However, incorrect details, or failure to provide all of the personal information required for the requested action, may prevent you from being able to use the Service, impair the quality of the service provided to you, including impairing the ability to contact you when necessary. If and when you provide us with personal information of a third party, you represent and confirm that you have obtained that party's informed consent to providing their personal information to the Service Operator, for the purpose of using their personal information in accordance with this Policy.

Location-Based Information We Collect

The settings area of the Service also includes location-based services, which use GPS technology to determine your location as a user of the Service, through your end device, for example in order to use your location to mark in the Service the dive site where you dived, for the dive log, or to display diving clubs, emergency numbers and benefits suited to your location. Not all features of the Service can be provided without your consent to the use of this technology. The Service Operator may also use information about your location in order to create anonymous aggregate information, and it will use such information in accordance with this Policy.

Information We Collect Automatically When You Use the Website

When you use the Service, even without registration, the Service Operator may collect information about your practices in relation to its use, including information, content or advertisements you have read, the pages and services you have viewed, the offers and services that interested you, the computer's location and the internet address data (IP address) through which you accessed the Service, the type of operating system you use, the type of end device you have, and additional similar technical information. In addition, the Service Operator may collect, and make use of the services of third parties in order to collect and analyze, anonymous, statistical or aggregate information in connection with the use of the Service, including information relating to your details and your activity in it. Information of this type will usually not allow us to identify you, but only to analyze trends in the use of the Service.

How Do We Use Personal Information?

The details and personal information you provide, and the details collected about your practices during your use of the Service, will be stored in the Service Operator's databases. The personal information in the database will be used in accordance with the provisions of this Policy and the Binding Documents, or in accordance with the provisions of any law, for the following purposes – • To enable you to use the Service, including to view its content, use the dive log and log dives, keep track of your certifications in the field, enjoy various benefits that may be available to registered users, and more; • To identify you or verify your identity during your repeat visits to areas requiring registration, such as the dive log, and to sometimes spare you from entering your details each time, where this is possible; • To improve and enrich the Service and the content we offer in the Service, including creating new services and content suited to users' requirements and expectations, as well as changing or discontinuing existing services and content. The information the Service Operator will use for this purpose will be mainly statistical information that does not personally identify you; • To enable you to adapt the Service to your preferences; • To send you from time to time information regarding the services and content of the Service, advertising materials, direct mail messages, surveys, newsletters and the like. Such information may be advertising in nature and may be sent to you in writing, by text messages (SMS), by email messages, or by any other means, as set out in detail in the Terms of Use of the Service. We will usually request your explicit consent for this purpose, except where we are not required to do so by law, or in the case of service messages and operational messages; • To contact you when the Service Operator believes there is a need to do so, among other things following your inquiry to us through the contact mechanisms, for administrative purposes, and more; • For the proper operation and development of the Service, identification of malfunctions and technical support; • To enforce the terms of the Binding Documents, in order to comply with the requirements of any law, regulation or other legislation, and in order to assist competent authorities and courts, or any third party, when the Service Operator believes in good faith that it must do so;

Disclosure of Information to Third Parties

Except as set out in this Policy, the personal information you provide to us, or that we collect about you, will not be disclosed, sold or shared with third parties without your consent, except in the following cases - • With diving clubs, for a limited period, if you have explicitly approved this as set out above in this Policy, and for the purposes of the dive log. • To the extent necessary for the proper provision of the Service - we may, and are likely to, share personal information with third parties on our behalf who assist us in operating the Service, managing our business or providing the services provided to you, such as suppliers and subcontractors (for example, website hosting providers, information security providers, and others). These third parties may use and process your personal information only to the extent necessary to perform the services they provide to us and in accordance with our instructions, and they must take information security measures in order to protect and safeguard your personal information; • If you breach the provisions of the Terms of Use of the Service, or any of the Binding Documents, or if you perform, through the Service or in connection with it, actions that the Service Operator reasonably deems to be unlawful, or attempt to perform such actions, we will be entitled to share your personal information with parties who assist us in handling or preventing such actions; • If the Service Operator receives a judicial order, or a demand from an authority competent to do so, instructing it to disclose your details or your personal information to a third party, or to that court or authority; • In any dispute, claim, lawsuit, demand or legal proceedings, if any, between you and the Service Operator or anyone on its behalf, to the extent required for the clarification or resolution of the matter at hand; • In any case in which we believe that disclosure of the personal information is necessary to prevent serious harm to your body or property, or to the body or property of a third party; • The Service Operator will be entitled to transfer your details and the personal information collected as a result of your use of the Service to other companies or organizations related to the Service Operator, provided that they use such personal information only in accordance with the provisions of this Policy; • The Service Operator may disclose and share anonymous, aggregate and statistical information with other companies or organizations related to it, as well as with suppliers, business partners, advertisers and any third party, at its sole discretion, but it will not knowingly or intentionally disclose your identity to them without your consent; • If the Service Operator organizes its activity or the activity of the Service within another legal framework, and if it changes its legal structure or merges with another entity, or merges the activity of the Service with the activity of a third party - it will be entitled to transfer to the new entity a copy of the personal information in the Service Operator's database, provided that such corporation undertakes toward you the provisions of this Policy.

Where Is Personal Information Stored?

The personal information we collect is stored in our databases, which are stored locally and with server hosting and data backup providers, which may also be located outside the borders of Israel. Additional personal information, as set out in this Policy, is collected and stored by other companies (such as statistics companies and online advertising companies). They, too, may store the information outside the borders of the country. Your consent to this Policy also constitutes consent to the storage of personal information abroad and to its transfer outside the borders of Israel for the purpose of its use in accordance with the provisions of this Policy.

Cookies

We may use 'cookies' and additional data analysis tools in the Service. In such a case, as part of the use of the Service (even without registration), we will collect information about you through various collection tools, including Web Beacons, Pixel files and Cookies. Such information may also include information about the end device from which you browsed (including Device ID) and IP address, as set out above in this Policy. A 'cookie' is a piece of information that is sent from the website to the computer (or other end device) of the visitor/user and is stored on your end device. Cookies may contain a variety of information as set out above in the section of the Policy dealing with automatic information collection. The use of cookies serves a number of purposes, among others, tracking repeat visits to the website, for measurement and statistical purposes, including analyzing the nature of the use of the website and measuring marketing campaigns, to the extent we choose to use such tools. In addition, the information we collect through these tools may be used for marketing purposes, including displaying advertisements and offers for various services, including personalized advertisements, during your visit to the Service or to various online services. Some of the cookies we may use are our own (first-party cookies) and some are of third parties (third-party cookies), as they may be from time to time. In this context and for the purposes set out above, we may transfer information about you to those third parties. These third parties will use collection tools such as cookies in order to collect information about you from the Service and from other places on the internet, for their own purposes, in accordance with their privacy policies or other documents that may apply to you, for example because you have opened a user account with them. If you prefer that Cookies not be stored on your computer or end device, you may change the settings of your browser or end device in order to reject certain types of Cookies, or remove them manually.

Information Security

We attach great importance to information security in our systems. In order to safeguard and protect information, including personal information, we operate information security systems, applications and procedures, designed to minimize the risks of theft, damage, loss or unauthorized access to personal information. However, there is no certainty that all of these will absolutely ensure that personal information will not be exposed or leak from the databases. Therefore, the Service Operator does not undertake, and you cannot reasonably expect, that the Service and the information systems we use will be immune to unauthorized access to the information stored in them. By the very use of the Service, you are aware of and agree to these limitations.

Social Networks

The Service also includes referrals to various social media channels of the Service Operator, such as the Service Operator's page on Facebook, Instagram, and other similar services. The use of these online services is at your sole responsibility and is, by its nature, subject to the privacy practices of those channels and to the legal agreements (such as the privacy policy) governing the activity of each of these platforms (which are not on behalf of the Service Operator or under its control).

Right to Review Information

Under section 13 of the Protection of Privacy Law, 5741-1981, every person is entitled to review, personally, or through a representative authorized in writing or through a guardian, the personal information about them that is held in a database. In addition, under section 14 of that Law, a person who has reviewed the personal information about them and found that it is not correct, complete, clear or up to date, may apply to the controller of the database, and if the controller is a foreign resident – to the holder of the database, with a request to correct the personal information or to delete it. If the owner of the database refuses, it must notify the applicant thereof in the manner and form prescribed in the regulations under the Protection of Privacy Law. The applicant for the personal information may appeal against a database owner's refusal to allow review and against a notice of refusal to correct or delete information. To become familiar with the full arrangement on this matter, it is recommended to review the provisions of the Protection of Privacy Law. If the personal information in our databases is used for the purpose of approaching you personally, based on your belonging to a population group determined according to one or more characteristics of persons whose names are included in the database ("direct mail approach"), then you are entitled under the Protection of Privacy Law to demand in writing that the information relating to you be deleted from the database. In such a case, the Service Operator will delete information that it requires solely in order to approach you by direct mail as stated above. Please note that deletion of information may prevent you from continuing to receive various services. Information that the Service Operator requires for the management of its business - including statistical, anonymous or aggregate information for purposes of statistical analysis and documentation of actions you performed in the Service - will continue to be retained by the Service Operator in accordance with the law, but will no longer be used for the purpose of approaching you by direct mail.