Privacy Policy
Last revised: March 10, 2021



Scope of this Privacy Policy

This Privacy Policy (the "Policy") applies to information collected by SportShooting, Inc., registered at 1906 El Camino Real, suite 201, Menlo Park, CA, 94027, ("Company" or "we"/"us"/"our") during your internet real-time communication with the application "SPOTTR" (the "Service" or "App"), which allows you ("users" or "you") to load / take pictures of shot targets, manage shooting setups and to further process of targets in order to determine and assess shooting data.

This Policy describes our information practices and the choices available to you regarding App's use of "personal information" determined as information about an identifiable individual as defined by applicable laws.

YOU UNDERSTAND THAT BY USING OUR SERVICE, YOU EXPRESSLY ACKNOWLEDGE AND AGREE TO THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY, PLEASE DO NOT USE OUR SERVICE.



Personal Information We Collect



The Company collects following information:

Information You Provide

Registration and Activity Information. When you download App and sign up an account, we ask for information such as your name, email address and password for creating your account. If you sign up using a social media account, we may also receive information from those social networking services, for example, your name or username. During your use of the App, we will ask you to provide information about your setup such as your weapon, caliber, shooting place, optics, bullet, bullet weight, powder type and weight and muzzle velocity.

Communications. If you contact us directly, we may receive additional information you provide, such as your name, email address and the contents of a message or attachments that you may send to us. You may also provide us with information if you subscribe to marketing communications from us or to obtain content such as product information, whitepapers and reports.

Information We Collect Automatically Through Our Services

Device Information. We may receive information about your operating system, device hardware, IP address, App version, device location, including a unique identifier for your device, Advertising ID, Mobile network carrier, device model, locale, and device resolution.

Information from Cookies and Similar Technologies. We collect information in App and in our emails using cookies, pixel tags, or similar technologies.

Activity and Usage Information in App. We also log which functions and features of application do you use, session duration, interactions with content and ads, settings and preferences. We may also receive your precise geolocation information.


Information Usage

Support, Maintenance and Fulfillment. We use your information to provide and maintain our Service, and to process and fulfill your requests;

Improvement of App and Service. We use your information to understand and analyze user behavior, to improve and enhance our Service, to develop new products, services, features and functionality; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use the Services; and for other customer service and support purposes;

Marketing and Promotions. We use your information for marketing purposes, including sending you emails and text messages about products, events, promotions and offers from Company or its partners or advertisers, and understanding the effectiveness of our marketing; responding to your inquiries; and for other informational, marketing, or promotional purposes.

Analytics and Performance. We use your information to measure performance and analyze key metrics relevant to our business; to analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.

Service Communication and Customer Care. We use your information to communicate with you, including sending you service information such as confirmations, notices, updates, security alerts, user surveys, and support and administrative messages; and to respond to your comments and questions and provide customer service;

Protect Company, our Users and Others. We use your information to enforce our terms and conditions or protect our business, partners or users; and

Security and Fraud Prevention. We use your information to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity.

Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.



Information Sharing

Analytics Providers. We use analytics services to collect and process certain analytical data for our Services. We also contract with third-party tracking technologies who use similar tracking tags on our Services via SDK, to collect information about your use of our Services, for advertising, analytics, and measurement purposes (namely, Firebase and Branch). We do not control these third parties' tracking technologies or how they may be used. If you have any questions about a third party's processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party's tools may be subject to their respective terms of use and privacy policies

Corporate Affiliates. We may share your information with our current or future "affiliates" (which means a parent company, any subsidiaries, joint ventures, or other companies under common control), which will adhere this Privacy Policy as strict as the Company.

Transferring of Assets and Rights. We may also share your information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

Legal Disclosures. We may also share your information (1) to comply with laws or to respond to lawful requests and legal process, (2) to protect the rights and property of the Company, our employees, agents, customers, and others, including to enforce our agreements, policies, and terms of use, (3) in an emergency to protect the personal safety of the Company, its employees or customers, or any person, or (4) to investigate, prevent, or take action regarding illegal or suspected illegal activities.

Anonymous or aggregated information. Aggregated or de-identified information (i.e., information that does not personally identify you directly) that does not identify you personally, like usage and metrics information, may be shared with others, including partners, developers, potential investors, marketers, and business partners for a variety of purposes, including for their own uses, for example, for improving their products and services for us and others, and to show you ads relevant to your interests.

We will share your personal information with third parties only if it is directed by you or is needed to provide you with a specific service or otherwise in accordance with applicable privacy laws. As a rule, we do not sell and will not sell, assign, distribute or disclose your personal information without first obtaining your consent or within the limits established by this Policy.



Children's Privacy

We adhere to the Children's Online Privacy Protection Act. Our Services not intended for children under age 13 (or up to age 16 in certain countries), or for anyone under age 18 without the involvement of a parent or guardian. We do not knowingly collect or distribute information from or about children under 13 (or up to age 16 in certain countries). If we are made aware that we have received personally identifiable information from someone under 16, we will use reasonable efforts to remove that information from our records.



Data Storage and Security

We use industry-standard methods of securing electronic databases of personal information. However, you should know that no company can fully eliminate security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same password to access your account in the App that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services.



Information Transfer

Company cannot guarantee or warrant the security of any information you transmit on or through the App and you do so at your own risk. Information may be transferred to and maintained on servers or databases located outside your country or to a jurisdiction where the privacy laws may not be as protective as those in your location. While such information is outside of your country of residence, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. We will protect all personal information we obtain in accordance with this Policy and take reasonable steps to ensure that it is treated lawfully.



Modifications

We may amend this Policy at any time by posting the amended version in the App or by providing such notice about or obtaining consent to changes as may be required by applicable law.



Spam

The Company's email direct marketing activities have not violated in any material respect, the CAN-SPAM Act or any other federal or state law or regulation applicable to electronic direct marketing.









Additional Notice for European Economic Area (EEA) Residents



Legal Basis for processing personal information

If you reside in the EEA, we will normally collect personal information from you (1) where we need the personal information to enter into or perform a contract with you, (2) where we have your consent to do so, (3) where the personal information is needed to comply with a legal obligation or requirement, or (4) where the processing is in our legitimate interests or the legitimate interests of others, and not overridden by your rights. These legitimate interests may include the operation, maintenance and improvement of our products, platform and services, offering a more tailored, personalized and efficient service for our users, communication with you as necessary to provide our services to you, fraud prevention and network and information security, undertaking marketing activities, and for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if we believe it is appropriate, we will inform you of what they are.

Data Controller

The data controller of your personal information is the Company.

Privacy Rights

As a resident of the EEA you have the following data protection rights:

The right to access, correct, update or request deletion of your personal information.

The right to object to processing of your personal information; ask us to restrict processing of your personal information or request portability of your personal information.

The right to opt-out of marketing communications we send you at any time.

The right to withdraw your consent at any time if we have collected and processed your personal information with your consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.


If you wish to exercise any of these rights, please contact us by email support@sportshooting.io. We may ask you to verify your identity, or ask for more information about your request.



'Sensitive' Personal Data

The Company does not collect any 'sensitive' personal data from its users.



Data Retention

The Company does not keep personal data any longer than is necessary for the purposes for which it is being processed or 2-years' period, whichever is lesser.



Transfer

For transfers of personal information to countries outside EU, we rely on the European Commission's adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en and their Standard Contractual Clauses, available here https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en



Opt-Out & Right to be Forgotten

You may submit a request to delete all your personal information by emailing the Company at support@sportshooting.io. However, please be ready that when you contact the Company with such a request, you consciously and voluntarily provide more personally identifying information, than the Company would have ever held prior to you sent your request.



DPO

We have assigned Data Protection Officer (DPO). Our DPO is tasked with ensuring that we acknowledge and abide our data protection responsibilities.

If you are staying in one of the countries of EEA and wish to access, amend, update, delete, transfer, don't store or don't process any Personal Data the Company holds about you, you may send such request to our DPO at support@sportshooting.io.

Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time. The Company will process your requests within 45 days. We will also notify you and a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.





California-specific description of consumers' privacy rights



Legal Basis For Processing Personal Information

The Company collects personal information for business and commercial purposes including: enhancing the Company's products and services; fraud prevention; analytics; advertising enhancement; any other purpose not prohibited by applicable laws or privacy regulations, including the CCPA.

Categories of personal information the Company collects

The Company has collected the following categories of personal information from users within the last twelve (12) months:

A. Identifiers. A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. NO

C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

E. Biometric information. Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. YES

F. Internet or other similar network activity. Browsing history and search history within our website; information on a consumer's interaction with a website and advertisement. NO

G. Geolocation data. Physical location or movements. YES

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO

K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

The Company has not disclosed and sold personal information to third parties for business and commercial purposes in the preceding twelve (12) months.

Your Rights and Choices

As a California resident you have certain rights with respect to the personal information collected by businesses.

Right to Access. You have the right to receive information about the types of personal information that the Company collects, uses, discloses, and sells. Specifically, this right allows you to ask the Company for the following information: (a) the categories of personal information that the Company collects about you; (b) the categories of sources from which the Company has obtained personal information about you; (c) the Company's business or commercial purpose for collecting or selling your personal information; (d) the categories of your personal information that the Company sells to third parties; (e) the categories of third parties that the Company sells your personal information to; and (f) the specific pieces of personal information that the Company has collected about you. The Company must disclose this information to you when you exercise your right to know, subject to proper verification of your request.

Right to be Forgotten. You have the right to request that the Company delete any personal information it has collected or maintains about you, subject to certain exceptions for business purposes outlined in the applicable law. Once the Company receives and confirms your verifiable consumer request, the Company will delete your personal information from its records, unless an exception applies.

Right to Non-Discrimination. You have the right to non-discrimination if you exercise any of your rights under the CCPA. If you exercise your rights under the CCPA, the Company, pertaining to its good and services, will not do any of the following: (a) deny you any goods or services; (b) charge you a different price or rate for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) provide to you a different level or quality of goods or services; or (d) suggest to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Opt-Out. You have the right to direct the Company to not sell your personal information to third parties at any time. The Company only shares information as outlined herein. If you choose to opt-out of the sharing of your personal information, the Company will no longer send your personal information to third parties. You can choose, at any time, to opt back in to the sale of your personal information.

Exercising your Rights

To exercise your rights to know, access, and be forgotten described above, please submit a verifiable consumer request to the Company by email support@sportshooting.io.

To exercise your rights to Opt-Out, alternatively you may use the "Do Not Sell My Personal Information" link in the registration field or on the screen while you entering into the App.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request to know or for access twice within a 12-month period. The verifiable consumer request must: (1) Provide sufficient information that allows the Company to reasonably verify you are (a) the person about whom the Company collected personal information or (b) such person's authorized representative. (2) Describe your request with sufficient detail that allows the Company to properly understand, evaluate, and respond to it.

We may require additional information to verify your requests to exercise your rights or understand the scope of your request, although you will not be required to create any account in the App to submit a request or have it fulfilled. The Company cannot respond to your request or provide you with personal information if the Company cannot verify your identity or authority to make the request and confirm the personal information relates to you. The Company will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We are permitted to reject your request if we reasonably determined that you are not a resident of the State of California.



Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.



Contact us

If you have any questions or concerns regarding this Privacy Policy, please email us to. support@sportshooting.io.

Alternatively, you may contact us at the address below:

SportShooting, Inc.

1906 El Camino Real, Suite 201,

Menlo Park, CA, 94027


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