Privacy Policy
Last updated: 2026-08-13
This policy explains what personal information SurfPath - AI Surf Coach (the “Service”) collects, where it is stored, who processes it, and what you can do about it. It applies to every user, and sits alongside our Terms of Service (Australia) and CGU (France).
1. Who is responsible for your data
The data controller is Pierre-Alexis Thoumieu, trading as Thoumieu Consulting, established in France, a sole trader (entreprise individuelle), SIRET 952 576 981 00023, registered address 38 rue Rosenwald, 75015 Paris, France. Contact for any privacy question or request: contact@surfpath.ai.
Because the operator is established in the EU, the EU General Data Protection Regulation (GDPR) applies to all processing described here. For users resident in Australia, the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) apply in addition. Where the two differ, we apply whichever gives you the stronger protection.
2. What we collect
You give us directly
- Account details: email address, password, display name, country of residence, interface language, and which edition of our terms you accepted, with the date.
- Surfer profiles: a name, self-declared level and stance (regular/goofy) for yourself and for anyone else you create a profile for.
- Videos and photos you upload of surf or surfskate sessions, including any other person visible in them.
- Session context: spot name, free-text notes, and the wave direction you declare.
- Journal entries: whatever you choose to log — dates, spots, conditions, how a session felt, difficulties, learnings — plus your board quiver.
Generated about you
- AI coaching output: scores, written assessments, suggested drills, and periodic level assessments built from your analysis history.
- Usage counters: number of analyses and uploads per day, total analyses, and your remaining credit balance.
- Technical logs: server logs recording requests and errors, which include your account identifier.
Measured in your browser
Every page of the Service loads Umami, a privacy-preserving analytics script, so we can see how many people visit and which pages they read. It records the page viewed, the site that referred you, your browser, operating system, device type and country — no more. It sets no cookies, stores no identifier on your device, and does not follow you across other websites, so it cannot tell that two visits came from the same person, and it never learns which account you are signed in as. Because it stores nothing on your device and identifies nobody, no consent banner is required for it and there is nothing for you to switch off.
Anti-abuse checks in your browser
When a page talks to our servers it first loads Google reCAPTCHA Enterprise, which checks that the request comes from a real browser using the app and not from an automated script. It runs in the background — there is nothing for you to click. To make that judgement it reads technical signals: your IP address, your browser and device characteristics, and how the page is being interacted with. It also stores a cookie on Google's own domainfor the same purpose. We receive only the verdict — a short-lived token saying "this really is the app" — and never the signals behind it, and Google is never told which account you are signed in as. It is used for security alone: not for advertising, not for audience measurement, and not to build any profile of you. Because protecting the Service against abuse is strictly necessary to run it, this one needs no consent banner (see section 3 — legitimate interest); if you block it, signing in and requesting an analysis may be refused.
Beyond that we use no tracking cookies and no advertising identifiers, and we do not sell or rent personal information to anyone.
3. Why we process it, and on what legal basis
- To deliver the coaching you asked for — uploading, analysing, storing and displaying your videos and reports. Legal basis: performance of our contract with you (GDPR art. 6(1)(b)). Sending your video to the AI model is an inseparable part of the service you requested, not a separate optional use.
- To manage your account — authentication, language, country, terms acceptance. Legal basis: performance of the contract.
- To take payment for credit packs. Legal basis: performance of the contract, and legal obligation for accounting records.
- To keep the Service working and secure — error logs, abuse prevention, quota enforcement, and quality monitoring of the AI output. Legal basis: our legitimate interest (GDPR art. 6(1)(f)) in operating a reliable and safe service.
- To meet legal obligations — for example retaining transaction records. Legal basis: legal obligation (GDPR art. 6(1)(c)).
We do not use your videos, photos, journal entries or reports to train our own models, and we do not use them for any purpose unrelated to coaching you.
4. Artificial intelligence: which model, and what happens to your video
Your coaching analysis is produced by Google Gemini, accessed through Google Vertex AI. When you request an analysis, the video (or photo) and the accompanying prompt are sent to that model, which returns the written assessment you then see in the app.
Google Vertex AI operates under enterprise data terms: content you submit is not used to train or improve Google's foundation models, is not reviewed by humans for model improvement, and is not retained by Google beyond what is needed to return the response and meet abuse-detection requirements. Google acts as our processor for this, not as an independent controller.
The AI output can be wrong. It is generated automatically, but it does not produce any legal or similarly significant effect about you within the meaning of GDPR art. 22 — it is recreational coaching feedback that you are free to ignore. No decision about your access to the Service, your pricing, or anything else is taken automatically on the basis of your analyses.
5. Where your data is stored, and which services process it
The Service runs on Google Cloud Platform. Most of your data sits in Australia (australia-southeast1) — including for French users, which is a transfer outside the EEA (see section 7).
- Videos and session photos — Google Cloud Storage, region australia-southeast1. Files staged during an upload but never attached to an analysis are automatically deleted after 24 hours.
- Account profile, surfer profiles, quiver, analyses, reports and journal entries — Google Cloud Firestore, region australia-southeast1.
- Email address, password and display name — Google Identity Platform (Firebase Authentication). Passwords are stored only as salted hashes by Google; we never see or store your password. Google operates this service from its global infrastructure, including the United States.
- Video analysis — Google Vertex AI (Gemini), served from Google's global endpoint, which may process the request in any Google region including the United States and the EU.
- Quality monitoring — Langfuse Cloud, hosted in the European Union. Langfuse receives the prompt, the model's written output, your account identifier, and a reference (link) to the stored video. The video file itself is never sent to Langfuse, and neither is your name or your email address — the account identifier is all that links a record to you.
- Payments — Stripe. Stripe collects your card details directly; they never reach our servers. We store only the fact of a purchase and your resulting credit balance.
- Audience measurement — Umami Cloud, which operates servers in the European Union and the United States. It receives the anonymous page-view data described in section 2, and nothing that identifies you: no account identifier, no name, no email, no cookie, no device identifier.
- Abuse prevention— Google reCAPTCHA Enterprise, served from Google's global infrastructure. It receives the browser signals and IP address described in section 2 and returns a verdict; it is never told which account you are signed in as, and nothing you upload ever reaches it.
- Application logs — Google Cloud Logging, region australia-southeast1, retained for 30 days.
- Backups — Google Cloud Firestore scheduled backups, stored in the same region (see section 6 for what this means for deletion).
Each of these is a processor acting on our instructions under a data processing agreement. We do not disclose your personal information to anyone else except where the law requires it.
6. How long we keep it — and what deletion really means
Your account data, videos, analyses and journal entries are kept for as long as your account is in use, and for at most two years after you last use it. If nobody signs in to an account for two years, we erase it in full — the same deletion described below, run automatically. Signing in resets that clock, so an account you keep using is never swept. You control this directly:
- Deleting a single analysis removes the record and its video from storage immediately.
- Deleting a journal entry removes it and its photo immediately.
- Deleting your account (the bin icon in the app header) erases, in one operation, every analysis and video, every journal entry and photo, your surfer profiles, quiver, usage counters and credit balance, and then the authentication account itself. It is irreversible and requires no email exchange with us.
Backups are the honest exception. Our database is backed up on a schedule, and those backups cannot be edited to remove one person's records. Data you delete therefore survives in backups for up to 14 weeks, after which the backups expire and it is gone. During that window the backups are only ever used to recover from a failure of the Service as a whole — never to restore an individual account. Server logs mentioning your account identifier expire after 30 days. Transaction records required for accounting are kept for the period the law requires, independently of your account.
7. International transfers
If you are in the EU/EEA, your data is transferred to Australia and the United States. Neither Australia nor the United States benefits from a general EU adequacy decision covering these transfers, so they rely on Standard Contractual Clauses adopted by the European Commission, entered into with Google Cloud and Stripe, together with the technical measures those providers maintain (encryption in transit and at rest, access controls). Quality-monitoring data stays in the EU and is not a third-country transfer. Audience measurement (Umami) may be handled on servers in the EU or the United States, but the data it holds identifies nobody, so nothing about you personally is transferred through it.
If you are in Australia, APP 8 applies: by using the Service you are informed that your personal information is disclosed to overseas recipients — principally in the United States (Google Identity Platform, Vertex AI, reCAPTCHA Enterprise, Stripe) and in the EU, where the operator is established and quality monitoring (Langfuse) is hosted. We take reasonable steps to ensure those recipients handle it consistently with the APPs, but you should be aware that overseas recipients may be subject to foreign lawful-access requirements.
8. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you (art. 15);
- have inaccurate data corrected (art. 16);
- have your data erased (art. 17) — the in-app account deletion does this;
- restrict or object to processing based on legitimate interest (arts. 18, 21);
- receive your data in a portable format (art. 20);
- lodge a complaint with a supervisory authority — in France, the CNIL (www.cnil.fr).
Under the Australian Privacy Principles you have the right to access your personal information (APP 12) and to ask us to correct it (APP 13). If you are not satisfied with how we handle a request or a complaint, you may complain to the Office of the Australian Information Commissioner (www.oaic.gov.au).
Most of these you can exercise yourself in the app, without asking us and without waiting:
- Access and portability — the download icon in the app header produces a JSON file containing everything we hold on your account: your profile, surfer profiles, quiver, every analysis and its report, every journal entry, and your record of credit purchases. Videos and photos are included as download links rather than embedded files; those links expire 12 hours after the export, so save anything you want to keep.
- Rectification — your profile, surfer profiles and journal are editable in place.
- Erasure — the bin icon deletes the account and everything in it (see section 6).
For anything the app doesn't cover — restriction, objection, or a complaint — write to contact@surfpath.ai. We will respond within one month (GDPR) or 30 days (APP 12), and we do not charge for a request.
9. Other people in your videos
If someone else appears in a video or photo you upload, you are responsible for having their consent before uploading — this is a condition of using the Service. Their image is processed exactly like yours and deleted with the file. If someone who appears in your content contacts us to have it removed, write to [contact email] and we will act on it.
10. Children
The Service is not intended for anyone under 16, and you must confirm you are at least 16 to create an account. We do not knowingly collect personal information from children under 16; if we learn that we have, we delete it.
11. Security
Data is encrypted in transit and at rest by our infrastructure providers. Storage buckets block all public access, and every read and write goes through our backend, which checks that the record belongs to you; the database's own rules deny anything that would reach it from a browser directly. Access to production data is limited to the operator. No system is perfectly secure; if a breach affects your personal data and is likely to put you at risk, we will notify you and the competent authority as the GDPR and the Notifiable Data Breaches scheme require.
12. Changes to this policy
We may update this policy as the Service changes. Material changes will be notified to you, and the “last updated” date above always reflects the current version.
13. Contact
Any privacy question, request or complaint: contact@surfpath.ai. We have not appointed a Data Protection Officer, as we are not required to.