We may collect, use, store, and transfer the following categories of personal data, depending on how you use the Services:

• Identity Data: name, email address, account information, and support communications.
• Location Data: GPS coordinates from your device and, when enabled, from Apple Watch during surf sessions.
• Technical Data: device type, operating system version, app version, diagnostics, connectivity and mobile network information, IP address, and device status.
• Usage Data: interactions with the app, session start and stop events, button presses, camera status, pairing status, and feature usage.
• Media Data: video recordings, clips, timestamps, and related surf-session metadata created during recording.
• Workout and Health Data: workout session information and related activity metrics made available through HealthKit or Apple Watch only if you choose to grant that permission.

We do not knowingly collect personal data from users under 13.

We use your personal data to:

• Provide, operate, and maintain the Services, including synchronizing recording and control between devices.
• Enable surfer detection, tracking, framing, lens selection, zoom control, and clip generation using on-device processing.
• Use location data to determine surfer position, improve camera framing and zoom, and associate recordings with a surf session.
• Support surfing workout features, including Apple Watch and HealthKit integrations, when you enable them.
• Provide customer support, troubleshoot issues, maintain service security, and prevent fraud or abuse.
• Improve app stability, reliability, and performance through limited diagnostics and service improvement activities.
• We do not sell or rent your personal data.
• We do not send your video recordings or other personal data to third-party AI providers for AI processing.
• We do not use your video recordings to train third-party AI models.
• If we ever want to use your personal data for a materially different purpose, we will provide any additional notice and obtain any consent required by law.

We may share personal data only in the following limited circumstances:

• With infrastructure and service providers that process data on our behalf to support connectivity, security, diagnostics, account services, storage, customer support, or relay functionality.
• With legal, regulatory, or law enforcement authorities when required by applicable law or to protect rights, safety, and security.
• With a buyer, investor, successor, or other third party in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality and legal safeguards.
• We do not share personal data with third-party AI providers for AI processing.
• We do not sell personal data or share personal data for third-party advertising.

• Each surf session recorded using the Surflens app may include session start and stop time, GPS location, device status, watch connection status, and recorded video or clips.
• When recording is initiated via a connected device, such as Apple Watch, Surflens synchronizes commands between devices and may transmit GPS coordinates and control signals through relay infrastructure solely to operate the requested feature.
• In AI Mode, the app can operate fully offline on the beach-camera iPhone. In Watch Mode and Relay Mode, connectivity may be required for command relay, but video processing and AI analysis remain on-device.
• Use of user-generated content, including ownership, licenses, or public sharing rights, is governed by the Terms of Use. Surflens does not use recorded videos for third-party AI processing, and does not use recorded videos for public marketing without a valid legal basis and any consent required by applicable law.

CATEGORIES OF PERSONAL INFORMATION SHARED

• Identity Data — Source: directly from user. Purpose: account creation, communication, customer support. Shared with third parties: only with service providers when necessary to provide the Services.
• Location Data — Source: mobile device and, when enabled, Apple Watch. Purpose: GPS-based camera control, framing, zoom, session coordination, and session association. Shared with third parties: only with service providers or relay infrastructure when necessary to operate the Services.
• Technical Data — Source: device, app, browser, and service environment. Purpose: security, performance, diagnostics, debugging, and service delivery. Shared with third parties: only with service providers acting on our behalf.
• Usage Data — Source: app interactions and session events. Purpose: feature operation, reliability, support, and service improvement. Shared with third parties: only with service providers acting on our behalf.
• Media Data — Source: device camera and related session metadata. Purpose: local recording, on-device AI processing, playback, editing, and user-requested sharing or export. Shared with third parties: not with third-party AI providers; otherwise only if required to provide a feature you request or when you choose to share or export content.
• Workout and Health Data — Source: HealthKit and Apple Watch, if enabled by the user. Purpose: recording and supporting surfing workout features. Shared with third parties: only as necessary to provide the feature and in accordance with your permissions and applicable law.