That's more like foam, but I guess we can consider it bubbles if we think of it as millions of very tiny bubbles

If a bubble bath is ok, why not these, just a shame they are a little OOF

Guilia, a bubble is a bubble, whether it is from soap or from motion-trapped gases. The guidelines even say that it can resemble bubbles, so they don't even have to be real.

Shaving cream is millions of bubbles too but I wouldn't enter a shot of shaving cream because you can't see the bubbles. IMO, this really doesn't match the theme for me.

I like the contrast of this.....Smooth and Rough water. Bubbles, not so sure, and yes it's a little OOF. And a crop across the top of the foam/bubbled water would improve it IMO.
GL

Crop done, jbillteri, thanks

Well done..

HOW CUTE!!!! I Love the DOF in the background and such a pretty model!