Privacy Policy

Last updated: 8 June 2026

1. Introduction & Scope

This Privacy Policy explains how HOTDIVE, operated by Narwhal Technology (Dongguan) Co., Ltd., registered in Mainland China, collects and processes your personal data when you visit our website or place an order. By using our website, you acknowledge the practices described here.

2. Data Controller & Contact

The data controller is Narwhal Technology (Dongguan) Co., Ltd., Mainland China, email privacy@hotdivescuba.com.

As required under Article 27 GDPR for controllers outside the EU, our EU representative is to be appointed (we are in the process of establishing an EU entity; in the meantime, please contact us at privacy@hotdivescuba.com). You can contact our Data Protection Officer at privacy@hotdivescuba.com.

3. Personal Data We Collect

• Identity & contact details (name, email, phone, billing and shipping address);
• Order and transaction data (your full card number is handled by our payment provider, not stored by us);
• Account details, if you create an account;
• Technical and usage data (device, browser, IP, cookies);
• Customer-service communications and marketing preferences.

4. How We Collect It

Directly from you (when you order, register or contact us), automatically (through cookies and similar technologies), and from third parties such as payment, shipping and analytics providers.

5. Purposes & Legal Basis

• Performance of a contract — to process orders, payments, delivery and returns;
• Legal obligation — to keep tax and accounting records;
• Legitimate interests — to prevent fraud, secure accounts and improve our website;
• Consent — for marketing emails and non-essential cookies (you can withdraw consent at any time).

6. Cookies & Tracking

We use necessary, analytics and marketing cookies. Necessary cookies are required for the site to work; analytics and marketing cookies are used only with your consent. You can manage your preferences through our cookie banner or your browser settings.

7. How We Share Your Data

We share data with service providers acting as processors on our behalf, including: our e-commerce platform (Shopify), payment providers (e.g. Shopify Payments, Stripe or PayPal), shipping carriers (e.g. DHL/UPS/FedEx), email/marketing tools (e.g. Klaviyo or Mailchimp) and analytics providers (e.g. Google Analytics). We have data-processing agreements in place and do not sell your personal data.

8. International Data Transfers

Your data may be processed outside your country, including in jurisdictions whose laws differ from your own. Where personal data is transferred out of the EEA, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy/data-privacy-framework mechanism.

9. Data Retention

We keep personal data only for as long as necessary for the purposes described, including legal, tax and accounting requirements (at least 5 years for order records), after which it is deleted or anonymised. Marketing data is kept until you withdraw consent.

10. Data Security

We use appropriate technical and organisational measures, including TLS encryption and access controls, to protect your data against unauthorised access, loss or misuse.

11. Your Rights — EU/EEA (GDPR)

You have the right to access, rectify, erase, restrict or object to processing of your data, to data portability, to withdraw consent, and not to be subject to solely automated decision-making. To exercise these rights, contact privacy@hotdivescuba.com. You also have the right to lodge a complaint with your local supervisory authority.

12. Your Rights — California (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, to delete it, to correct it, to opt out of any "sale" or "sharing" of personal information, to limit the use of sensitive personal information, and to non-discrimination for exercising these rights. Where applicable, you can use our “Do Not Sell or Share My Personal Information” link. We disclose the categories of personal information collected in the preceding 12 months in this policy.

13. Children's Privacy

Our website is not directed at children under 16. We do not knowingly collect their data; if we learn we have, we will delete it.

14. Changes to This Policy

We may update this policy from time to time. The "last updated" date above reflects the latest version, and material changes will be communicated where appropriate.

15. How to Contact Us

For any privacy question or request, email privacy@hotdivescuba.com.