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Privacy Policy

Privacy Policy

Effective May 12, 2026

Our Privacy Policy has been updated. 

 

Table of Contents

1. Who We Are

Calahonda Divers S.L., acting under the commercial name “Diving With Nic” (abbreviated “DwN” and hereinafter referred to as “we”, “us”, or “our”) acts as the Data Controller for your personal data. Calahonda Divers S.L. are a Sociedad Limitada registered in Spain.

❖ Legal Form: Sociedad Limitada (S.L.)

❖ Registration Number: B93628048

❖ Registered Office: Mijas, provincia de Málaga, Calle Córdoba de Calahonda, número 44, Urbanización Sitio de Calahonda

❖ Contact: +34 697 14 17 59

2. Personal Data We Collect

  • When completing and signing the DwN dive forms, we process the following categories of data directly from you:
  • Identification Data: Name, address, email address, phone number, and date of birth.
  • Financial Data: Payment information for course, training and membership fees. Note that we use secure third-party processors and do not store your full payment details.
  • Communication Data: Emails, messages, and forms you submit to us.
  • Participation Data: Details regarding your involvement in our events, volunteering, or diving trips.
  • Health Data: Health data is strictly limited to information necessary to assess your fitness to safely participate in diving activities.
  • Pictures and videos of participants: Pictures and videos of participants for internal documentation and, subject to your consent, for promotional purposes (e.g. website, social media, newsletters).

This data is accessed only by authorised and trained personnel and handled with strict confidentiality.

Failure to provide accurate health information may result in refusal of participation for safety reasons.

  • Technical Data: IP address and cookies (please refer to our Cookie Policy).

Health data is processed solely on the basis of your explicit consent (Art. 9(2)(a)) and is strictly necessary to assess your fitness to safely participate in diving activities.

Please note that providing health information and consent is a mandatory condition for participation in diving activities. If you do not provide consent, we will not be able to allow you to participate for safety reasons.

3. Why We Process Your Data (Purpose & Legal Basis)

 

We only process data where we have a lawful basis under GDPR Articles 6 and 9:

Purpose

Legal Basis

Provision of diving services

Art. 6(1)(b) – Contract

Fitness-to-dive & safety assessment (health data)

Art. 9(2)(a) – Explicit consent

Insurance administration

Art. 6(1)(c) / 6(1)(f)

Accounting & tax

Art. 6(1)(c)

Legal claims

Art. 6(1)(f), Art. 9(2)(f)

Customer communication

Art. 6(1)(b)

Marketing/newsletters

Art. 6(1)(a) – Consent

Pictures and Videos

Art. 6(1)(a) – Consent

Our legitimate interest under Art. 6(1)(f) includes ensuring safe operations, managing liability, and maintaining customer relationships.

Processing is based on explicit consent and is necessary for safety and participation in diving activities.

Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal. (Art. 9.2 (a)). You may withdraw your consent at any time by contacting us using the details provided below.

4. Photos and Videos

DwN may take photographs and videos during diving activities for the following purposes:

  • Internal records and documentation of activities;
  • Promotion of our services (e.g. website, social media, newsletters).

Where images are used for promotional purposes, this processing is based on your explicit consent (Art. 6(1)(a) GDPR).

You will be asked to provide this consent through a separate opt-in declaration.

You may withdraw your consent at any time by contacting us using the details provided below, after which no further use of your images will be made. Withdrawal does not affect prior lawful use.

We will take reasonable steps to ensure that images are respectful and do not negatively impact your privacy.

Where possible, images that do not allow identification of individuals may be used without requiring consent, based on our legitimate interest (Art. 6(1)(f)).

5. Additional Information

  • DwN does not carry out automated decision-making.
  • Personal data is collected directly from you.
  • Providing health data is mandatory for safety reasons.
  • No Data Protection Officer is appointed (if applicable).

6. Data Sharing and International Transfers

Data Sharing

We do not sell or rent your data. We may share data with:

  • Service Providers: Third-party vendors (e.g., IT services, payment processors) acting as Data Processors under our instructions.
  • Dive certification organisations (e.g. PADI, SSI, etc.).
  • Insurance providers.
  • Diving instructors and operational partners.
  • Boat operators and other dive operators where required for the activity.
  • Authorities: Spanish public authorities, if required by law.

International Transfers

We primarily store data within the EEA. However, essential services (e.g., Google Workspace) may involve transfers to the United States. These transfers are protected by:

  • The EU-US Data Privacy Framework (DPF) adequacy decision, or
  • Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Data Retention

We retain personal data only as long as necessary:

  • Participant Data: Participation in activity + 3 years (to manage potential claims).
  • Membership Data: Duration of membership + 3 years (to manage potential claims).
  • Health Data: Participation in activity + 3 years (to manage potential claims).
  • Financial/Accounting Data: 10 years (as required by Spanish tax/accounting law).
  • Communication Data: Up to 3 years from the last contact.

We implement appropriate technical and organisational measures, including restricted access, confidentiality obligations, and secure storage systems to protect your personal data, particularly health data.

8. Your Rights

Under the GDPR, you have the right to:

  • Access your data (Art. 15).
  • Rectify inaccurate data (Art. 16).
  • Erase your data (“Right to be forgotten”) (Art. 17).
  • Restrict processing (Art. 18).
  • Object to processing (Art. 21).
  • Data Portability (Art. 20).

9. Contact Us

While you can contact us to exercise these rights, you also have the right to lodge a complaint with the Agencia Española de Protección de Datos (AEPD) at C/ Jorge Juan, 6. 28001 – Madrid (www.aepd.es).

If you have any questions about this Privacy Policy or our privacy practices or wish to withdraw consent given hereunder, please contact us at info@divingwithnic.com or our registered address mentioned above.