Last revised: March 10, 2021
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.
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
Support, Maintenance and Fulfillment. We use your information to
provide and maintain our Service, and to process and fulfill your requests;
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
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.
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
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
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
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,
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.
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
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
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.
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
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
Additional Notice for European Economic Area
Legal Basis for processing personal information
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.
The data controller of your
personal information is the Company.
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.
have the right to complain to a data protection authority about our collection and use of your
If you wish to exercise any of these rights, please contact us
by email firstname.lastname@example.org
. 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.
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.
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
. 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.
We have assigned Data Protection Officer (DPO). Our DPO is tasked
with ensuring that we acknowledge and abide our data protection responsibilities.
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 email@example.com
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
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
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
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).
D. Commercial information. Records of personal property, products
or services purchased, obtained, or considered, or other purchasing or consuming histories or
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
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
The Company has not disclosed and sold personal
information to third parties for business and commercial purposes in the preceding twelve (12)
Your Rights and Choices
As a California resident you have certain
rights with respect to the personal information collected by businesses. Right
. 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
. 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 firstname.lastname@example.org.
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
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
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.
email us to. email@example.com.
Alternatively, you may contact us at the address below: SportShooting,
Inc. 1906 El Camino Real, Suite 201, Menlo
Park, CA, 94027