PRIVACY POLICY FOR THE GARMIN DIVE MOBILE APPLICATION

Last updated: May 12, 2020

Your privacy is important to Garmin. We developed this Privacy Policy to provide you with information on how we process your personal data when you use the Garmin Dive™ mobile app.

Other Garmin websites, apps and products that do not include a link to this Privacy Policy and include a link to a different Garmin privacy policy are governed by that privacy policy. For example, we have a separate privacy statement that applies to our Garmin Connect™ service.

“Personal data” is information relating to an identified or identifiable natural person.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by Garmin

Personal data that is processed when you create a Garmin account:

When you create a Garmin account, we ask you to provide your email address and name. You can choose to provide only your first name or a nickname instead of your full name if you wish.

PURPOSES AND LEGAL GROUNDS:

(a) Garmin processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Garmin’s legitimate interest in protecting the security of your account.

(b) Garmin also processes your email address for the purpose of sending you important information about your Garmin products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile and displayed when you interact with the dive community. The legal ground for processing your email address and name for these purposes is Garmin’s legitimate interest in providing you important safety or other information about your Garmin products, apps or account or material changes to this Privacy Policy, and in providing you an opportunity to engage with other Garmin users.

(c) If you provide your opt-in consent to receiving marketing information from Garmin, Garmin will also process your email address for the purpose of sending you marketing information about Garmin products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your Garmin account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Garmin are based on the preferences you provide in your Garmin account, the locale indicated by your Internet Protocol (IP) address, the types of Garmin devices you have added to your Garmin account, and any subscriptions included in your Garmin account. The legal ground for processing this data for this purpose is Garmin’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) If you provide your opt-in consent, Garmin will process your email address for the purpose of sending you notifications (e.g., reports you’ve signed up for, etc.). The legal ground for processing your email address for this purpose is your consent. You can withdraw this consent at any time by opting out of receiving such notifications.

(e) Garmin also processes your email address to associate it with your Garmin account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

Personal data that is processed when you sign in to your Garmin account with Social Media Credentials if you choose (China only):

If you live in China, you may choose to sign in to your Garmin account using your social media sign-in credentials (e.g., your WeChat or QQ sign in credentials). If you choose this method, the first time you sign in, you will be asked whether you agree to the social media provider delivering certain information to Garmin, such as your name, email address, profile photo, posts, comments and other information associated with your social media account.

All of this information is made available to Garmin by the social media provider due to the way the social sign-on configuration works. However, the only information Garmin retains and processes is your email address. If you do not want your information to be shared with Garmin by the social media provider, then you can simply sign in to your Garmin account using your Garmin account credentials instead of your social media account credentials.

PURPOSE AND LEGAL GROUND:

Garmin associates the email address provided by the social media provider with your Garmin account so that you can use your email address to sign in to your Garmin account in the future if you no longer wish to sign in using your social media account credentials. The legal ground for processing this information for this purpose is Garmin’s legitimate interest in providing you an alternative sign-in method and in securing your account.

Personal data that is processed when you choose to upload your dive activity data to Garmin:

You can choose to upload dive activity data from your device to your Garmin account. This data may include dive type, location, date, start and end times, entry and exit points, water type and temperature, current, surface conditions, visibility, depth, heart rate, pulse oximetry, ascent and descent time, bottom time, surface interval, number of dives, private notes, dive tank information, dive buddy name(s), and other dive-related metrics or data points. You can use your device without providing your consent to upload your activities to Garmin. If you choose to upload your dive activities to Garmin, you control whether others can see your dive activity data by selecting the privacy level at the time of upload. Additionally, you can change the visibility of your dive activity data by managing the privacy settings in your Garmin account.

PURPOSES AND LEGAL GROUNDS:

(a) If you choose to upload dive activity data from your Garmin device to your Garmin account, Garmin processes it so you can analyze your dive activity data and, if you wish, share your activity data with others. If you reside in the European Economic Area, U.K. or Switzerland, the legal ground for this processing is your consent, which you can withdraw at any time by deleting the dive activity data from your Garmin account.

(b) If you choose to upload dive activity data from your Garmin device to your Garmin account, then the dive-related data will be anonymized, aggregated and used to compile averages for dive sites. Other users will see this anonymized, aggregated data when they view the dive site in the app. The legal ground for processing this data for this purpose is our legitimate interests in providing accurate information about dive sites to the dive community.

(c) If you choose to upload dive activity data from your Garmin device to your Garmin account, it will be aggregated to analyze usage and trends and to develop or improve features and services. The legal basis for this processing is Garmin’s legitimate interest in providing relevant and quality features and services.

(d) If you choose to upload your dive activity data to Garmin and you are opted in to product improvement, Garmin will process your uploaded dive activity data for research and development purposes. It will be used internally to help us build better and more relevant products and services. If you reside in the European Economic Area, U.K. or Switzerland, the legal ground for processing this data for this purpose is your explicit consent, which you can withdraw at any time in your Garmin account.

Personal data that is processed when you choose to associate a photo with your dive activity or a dive point of interest (POI):

When you choose to upload a photo and associate it with a dive activity or a dive POI, we process the photo and make the requested association.

PURPOSE AND LEGAL GROUND:

The photo is processed for the purpose of associating it with your dive activity or the selected POI. The legal ground for processing this information for this purpose is your consent. You can withdraw this consent at any time by deleting the photo or removing the association to your activity or the selected POI.

Personal data that is processed when you add a Garmin device to your Garmin account:

When you add certain Garmin devices to your Garmin account, we ask for additional information, such as display settings, sync interval choices and information about your dive preferences and persona — such as favorite dive spot or type, bottom time and dive number.

PURPOSE AND LEGAL GROUND:

Settings information is processed to update your device with your preferred settings. The legal ground for processing this information for this purpose is our legitimate interests in allowing you to easily customize your settings and keep them synced. Dive-related information is processed to be used when you interact with the dive community within the app. The legal ground for processing this information for this purpose is your consent. You can withdraw your consent at any time by deleting this information from your profile.

Personal data that is processed when you sync your Garmin device:

When you sync your device through the Garmin Dive mobile app, we log data about the transmission, such as the IP address used when syncing, the sync time and date, crash/diagnostic logs, geographic location of the device, information about your device, information about the network used to sync (e.g., Wi-Fi® or cellular) and device battery level. For compatible products, we will also gather analytics on how you configure and use certain features (e.g., Garmin Pay™, Connect IQ™, music features, etc.).

PURPOSE AND LEGAL GROUND:

We process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is Garmin’s legitimate interest in resolving errors or syncing issues and providing quality product support. We also process this information to analyze usage and trends and develop or improve features and services. The legal basis for this processing is Garmin’s legitimate interest in providing relevant and quality features and services.

Personal data that is processed when you communicate with Garmin:

When you interact with our customer support representatives via email, telephone, online or in person, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences; and information about the Garmin products you own, such as their serial numbers and dates of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue.

PURPOSE AND LEGAL GROUND:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Garmin’s legitimate interests in providing quality product support. The legal ground for signing in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

Categories of Recipients of Personal Data

Other Garmin Dive app users:

If you choose to upload your dive activities to Garmin, you control whether others can see your dive activity data by selecting the privacy level at the time of upload. Additionally, you can change the visibility of your dive activity data by managing the privacy settings in your Garmin account. You may decide to allow others to view your dive activity data by changing the privacy settings in your Garmin account. If you choose to associate one of your photos with a POI, the photo will be visible to all users in the dive community and your name will be shown as the contributor.

Other service providers:

Garmin uses cloud services from third parties such as Adobe and Emarsys to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. Garmin uses this data to analyze the level of engagement with its emails. Garmin uses third-party service providers to help us better understand usage of Garmin Express and the Garmin Connect website and app, and for related purposes.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Garmin’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Transfers of Personal Data

Garmin is a global business. To offer our products, apps and services, we may need to transfer your personal data to other Garmin companies in other countries. View Garmin-owned companies. For customers outside of China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin International Inc.’s servers in the U.S. and Garmin (Europe) Ltd.’s servers in the U.K. For customers in China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin China Shanghai RHQ Co. Ltd.’s servers in China.

Personal data regarding individuals who reside in a country in the European Economic Area ("EEA"), the United Kingdom ("U.K.") or Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. comply with the EU-U.S. and Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing and retention of personal information from the EEA, U.K. and Switzerland, as described in our EU-U.S. Privacy Shield certification and Swiss-U.S. Privacy Shield certification. Learn more about Privacy Shield.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. are subject to the oversight of the U.S. Federal Trade Commission and remain responsible for personal data transferred to third parties that process it on our behalf. If you have a complaint about our Privacy Shield compliance, please contact us at [email protected]. You can also refer a complaint to our chosen independent dispute resolution body, JAMS, and in certain circumstances, invoke the Privacy Shield arbitration process.

All Garmin companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies

Garmin Dive mobile app and Garmin Express:

We also collect data from users about their usage of the Garmin Dive mobile app and Garmin Express. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. Garmin uses this data to improve the quality and functionality of the Garmin Dive mobile app, Garmin Express and other Garmin apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps and websites so we can enhance the user experience and functionality of our products, apps and websites. Here are examples of third-party providers of analytics and similar services we currently use:

ANALYTICS SERVICES:

  • Azure Application Insights: Azure Application Insights is used to help us better understand usage of Garmin Express to improve user experience. Azure Application Insights is a Microsoft service.
  • HockeyApp; Firebase (Crashlytics): HockeyApp, which is a Microsoft service, Firebase (Crashlytics), which is a Google service, are used to help us better understand usage of Garmin apps to improve user experience and to identify and resolve the root causes of app crashes.

APPLICATION PERFORMANCE MONITORING:

Garmin uses AppDynamics to analyze and monitor the performance of our complex ecosystem. To provide such services, AppDynamics receives basic request information, including IP address, necessary to detect and diagnose anomalous errors and response times.

Children

We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to Garmin. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Garmin websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your personal data as long as your Garmin account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

If you reside in a country in the EEA, U.K. or Switzerland, personal data is controlled by Garmin Würzburg GmbH — located at Beethovenstraße 1a+b, 97080 Würzburg, Germany. The company's EU Data Protection Officer is located at the same address and can be reached by email at [email protected]

If you reside in China, personal data is controlled by Garmin China Shanghai RHQ Co. Ltd. — located at 37F, Tower A, New CHJ International Business Center, No 391, Guiping Road, Xuhui District, Shanghai 200233, China. You can contact them by email at [email protected]

If you reside outside of the EEA, U.K., Switzerland, and China, then the personal data is controlled by Garmin International, Inc., 1200 E. 151st St., Olathe, Kansas 66062, which you can contact by email at [email protected]

Your Rights

If you reside in the European Union or U.K., you have the right, subject to the conditions set out in the General Data Protection Regulation (GDPR) or U.K. Data Protection Act 2018 to request from Garmin access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages. If you reside outside of the European Union and U.K., you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your Garmin account, visit Account Management Center.

If you live in the European Union or U.K. and you wish to exercise your right to restriction of processing or your right to object to processing, please contact the company's EU Data Protection Officer at Garmin Würzburg GmbH at Beethovenstraße 1a+b, 97080 Würzburg, Germany, or by email at [email protected].

If you live in China and you wish to exercise any of your data subject rights, please contact Garmin China Shanghai RHQ Co. Ltd. at [email protected].

If you do not live in the European Union, U.K., or China, but you believe you have a right to exercise these or any other rights under your local laws, please contact Garmin International, Inc. at [email protected].

Notice for California Residents of Privacy Practices and Rights

If you are a California resident, California law may provide you with additional rights regarding your personal data. To learn more about your California privacy rights, visit the CCPA Privacy Notice.

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