Privacy Policy

This translation is provided for convenience. In case of any discrepancy, the Ukrainian version prevails.

ShootingMind Privacy Policy

Effective date: 14.07.2026

This Privacy Policy (the "Policy") explains what personal data ShootingMind collects, how we use it, to whom we may transfer it, how long we retain it, and what rights users have.

By using the Service, you confirm that you have read this Policy.

1. Who Is the Personal Data Controller

The controller of personal data is:

FOP (Ukrainian sole proprietor) Oleksandr Sukach Orilska 29 Lviv, Ukraine Tax number: 1874908730 Phone: +380 731 202 525 E-mail: ceo@shootingmind.com

In this Policy, the terms "we", "us", "our", "ShootingMind", and "Operator" mean the sole proprietor Oleksandr Sukach.

2. What Data We Collect

Depending on how you use the Service, we may collect the following categories of personal data.

2.1. Account Data

• name;
• e-mail address;
• date of birth;
• profile photograph (optional);
• password (in encrypted form or via a third-party authentication provider).

2.2. Training Data

We may collect information about the user's sporting activity, in particular:

• exercise results;
• training history;
• statistics;
• notes;
• equipment used;
• weapon settings;
• timestamps;
• training location (if the user specifies it);
• other information that the user voluntarily adds.

2.3. Voice Data

If the user uses the voice input feature, we may process:

• audio recordings;
• automatically generated transcriptions;
• technical metadata necessary for the operation of the feature.

Audio recordings may be transferred to third-party providers of automatic speech recognition technologies.

2.4. Service Usage Data

We may automatically collect:

• device model;
• operating system;
• application version;
• IP address;
• time zone;
• device language;
• device identifiers;
• error logs;
• information about interaction with the features of the Service.

2.5. Location Data

If the user grants separate permission, we may use approximate or precise location for:

• finding the nearest shooting ranges;
• displaying local information;
• other features that require geolocation.

The user may revoke this permission at any time through their device settings.

2.6. Data Provided Voluntarily by the User

We may process any information that the user voluntarily submits through:

• the support service;
• e-mail;
• feedback forms;
• messages;
• comments;
• other features of the Service.

3. What We Use Personal Data For

We use personal data exclusively for lawful purposes, in particular:

• creating and maintaining the account;
• providing the features of the Service;
• synchronizing data between devices;
• analyzing sporting results;
• providing statistics;
• enabling the operation of voice input;
• improving the operation of the Service;
• ensuring information security;
• preventing fraud;
• technical support;
• complying with legal requirements;
• protecting our legitimate interests.

4. Legal Bases for Processing (GDPR)

If the EU General Data Protection Regulation (GDPR) applies to the processing of personal data, we carry out processing on one or more of the following bases:

• performance of a contract with the user;
• compliance with legal obligations;
• the legitimate interest of the Operator;
• the user's consent;
• protection of vital interests;
• other bases provided for by Article 6 of the GDPR.

5. To Whom We May Transfer Personal Data

We do not sell users' personal data.

We may transfer personal data only in the cases provided for by this Policy or by law.

Such recipients may include:

• cloud infrastructure providers;
• hosting service providers;
• backup service providers;
• authentication service providers;
• e-mail service providers;
• automatic speech recognition service providers;
• analytics service providers;
• error monitoring service providers;
• payment providers (in the event paid features are introduced);
• other providers of technical services necessary for the functioning of the Service.

Such persons process personal data exclusively in accordance with our instructions or as independent data controllers in cases provided for by law.

6. Transfer of Data to Coaches, Clubs, and Federations

ShootingMind may provide the user with the ability to voluntarily grant access to their training data to coaches, sports clubs, federations, or other organizations.

Such access is granted exclusively after obtaining the user's explicit consent (opt-in).

The user has the right at any time to change or revoke such access through the functionality of the Service, unless otherwise provided by law.

For users who have not reached the age of majority, certain sharing features may require additional confirmation from a legal representative.

7. Voice Input

If the user uses the voice input feature, audio recordings may be transferred to third-party providers of automatic speech recognition and transcription technologies.

The transfer is carried out exclusively for:

• converting speech into text;
• improving recognition quality;
• ensuring the operation of the relevant feature.

The specific providers of such technologies may change without amendments to this Policy.

Where the functioning of the relevant service allows, we strive not to retain audio recordings longer than is necessary for their processing.

8. De-identified and Aggregated Data

We may use information about users' training in de-identified or aggregated form.

Such data may be used for:

• statistical analysis;
• creating sports benchmarks;
• researching trends;
• improving algorithms;
• training machine learning models;
• preparing reports;
• publishing generalized statistics;
• developing the Service.

In the course of such use, we do not disclose information that allows a specific user to be identified directly or indirectly.

9. International Transfer of Personal Data

Some of our service providers may be located outside Ukraine or the European Economic Area.

In such cases, the transfer of personal data is carried out in accordance with applicable law and using appropriate safeguards, in particular:

• an adequacy decision (Adequacy Decision);
• the European Commission's standard contractual clauses (Standard Contractual Clauses, SCC);
• other mechanisms provided for by the GDPR or other applicable law.

10. Data Retention Periods

We retain personal data only for the period necessary to achieve the purposes of its processing.

In particular:

• account data — until the account is deleted by the user or by us;
• training data — until it is deleted by the user or the account is deleted;
• security logs — for the period necessary to ensure information security;
• technical logs — for a reasonable period in accordance with our internal procedures;
• information that we are required to retain by law — for the period established by such law.

After the relevant period expires, personal data is deleted, anonymized, or de-identified, unless otherwise required by law.

11. User Rights

Depending on applicable law, the user may have the right to:

• obtain information about the processing of their personal data;
• obtain a copy of their personal data;
• request the correction of inaccurate or incomplete personal data;
• request the deletion of personal data (the "right to be forgotten") if there are no lawful grounds for its further processing;
• request the restriction of the processing of personal data;
• object to the processing of personal data in cases provided for by law;
• withdraw previously given consent, if the processing is carried out on its basis;
• receive their personal data in a structured, commonly used, and machine-readable format, where provided for by law;
• lodge a complaint with the competent personal data protection authority.

The exercise of certain rights may be restricted in cases expressly provided for by law.

12. Security of Personal Data

We take reasonable organizational, technical, and administrative measures to protect personal data from:

• unauthorized access;
• accidental loss;
• destruction;
• alteration;
• unlawful disclosure;
• other unlawful actions.

Such measures may include, in particular:

• encryption of data in transit;
• access control to information systems;
• user authentication;
• backup;
• logging of security events;
• regular software updates;
• other technical and organizational measures.

At the same time, no method of transmitting or storing information can guarantee an absolute level of security, so we cannot guarantee complete protection against all possible threats.

13. Children's Privacy

ShootingMind is intended for users who have reached the minimum age defined by the Terms of Use and applicable law.

Persons who have not reached the age of majority may use the Service only with the consent of their parents or other legal representatives in cases where such consent is required by law.

If we become aware that personal data has been collected in violation of these requirements, we may delete the relevant account and the associated personal data.

14. Analytics and Technical Tools

To ensure the operation of the Service, we may use software components, SDKs, event logs, analytics tools, and other technologies that help:

• analyze use of the Service;
• detect technical errors;
• ensure stable operation;
• improve performance;
• protect the Service from abuse.

Such tools may collect technical information about the device and use of the Service in accordance with this Policy.

15. Account Deletion

The user may at any time delete their account using the corresponding feature in the Service or by contacting us.

After the account is deleted, we delete or anonymize the user's personal data, unless its further retention is required by law or is necessary for:

• compliance with legal obligations;
• resolution of disputes;
• ensuring information security;
• protecting our legitimate rights and interests.

16. Changes to This Policy

We may update this Policy from time to time.

In the event of material changes, we will notify users by means of:

• a notification in the Service;
• an e-mail;
• or another available method.

The new version of the Policy enters into force from the moment of its publication or from another date specified in the notification.

17. Contact Information

For all matters related to the processing of personal data, you can contact us:

FOP (Ukrainian sole proprietor) Oleksandr Sukach Orilska 29 Lviv, Ukraine Tax number: 1874908730 Phone: +380 731 202 525 E-mail: ceo@shootingmind.com

18. Final Provisions

If any provision of this Policy is found to be invalid or unenforceable, this does not affect the validity of the other provisions.

This Policy applies together with the Terms & Conditions and is an integral part of the rules for using the Service.

19. Automated Data Analysis and Artificial Intelligence

ShootingMind may use automated algorithms, machine learning, and artificial intelligence technologies for:

• analyzing training data;
• generating statistics;
• identifying trends;
• personalizing the operation of the Service;
• preparing recommendations;
• improving the functionality of the Service.

The results of such analysis are of an exclusively informational nature.

We do not use automated decision-making that in itself produces legal consequences for the user or otherwise significantly affects their rights or freedoms.

Any recommendations generated by automated algorithms or artificial intelligence systems are not professional consultation, a sporting assessment, or coaching instruction.

20. Cookies and Similar Technologies

The ShootingMind website may use cookies, browser local storage (Local Storage), mobile platform SDKs, and other similar technologies for:

• ensuring the operation of the Service;
• authenticating users;
• saving settings;
• analyzing use of the Service;
• improving performance;
• ensuring information security.

The user may manage the use of cookies through their browser settings. At the same time, disabling certain cookies or similar technologies may result in some features of the Service not working correctly.

21. Requests Regarding Personal Data

The user may contact us on any matters related to the processing of personal data, in particular regarding:

• obtaining information about processing;
• exercising their rights;
• correction or deletion of personal data;
• withdrawal of consent;
• reporting a possible breach of confidentiality;
• other matters related to the protection of personal data.

We consider such requests within a reasonable time and in accordance with the requirements of applicable law.

22. Security Breach Notification

If we become aware of a security breach that may create a high risk to the rights and freedoms of users, we will take the necessary measures in accordance with applicable law.

Where required by law, we will notify the competent personal data protection authority and/or the affected users within the time limits and in the manner prescribed by law.

23. Minimization of Personal Data

We strive to collect only the personal data that is necessary for the operation of the Service and the provision of its features.

We do not require the provision of personal data that is not necessary for the use of ShootingMind, unless expressly provided otherwise by law or by specific features of the Service.

24. Accuracy of Personal Data

The user is responsible for the accuracy of the personal data and other information they provide through the Service.

If personal data has changed, the user must update it in a timely manner through the functionality of the Service or contact us.

25. Links to Third-Party Resources

The Service may contain links to third-party websites, services, or resources.

We do not control such resources and are not responsible for their content, privacy policies, terms of use, or personal data processing practices.

We recommend reviewing the privacy policies of the relevant resources before starting to use them.

26. Communication with Users

We may use the user's contact details to send messages related to the operation of the Service, in particular regarding:

• registration confirmation;
• account sign-in;
• access recovery;
• changes to the Service;
• updates to the Terms of Use or this Policy;
• security notifications;
• technical notifications;
• responses to user requests.

Marketing or advertising messages are sent only in the cases and in the manner provided for by applicable law.

27. Data Protection by Default

In the development and evolution of ShootingMind, we strive to apply the principles of Privacy by Design and Privacy by Default, providing for the protection of personal data already at the stage of designing the Service's features.

We regularly assess the need to collect new categories of personal data and strive to minimize their volume as much as possible while ensuring the operation of the Service.

28. Data About Sports Equipment

The user may voluntarily add to the Service information about sports equipment, including sporting weapons, sights, accessories, gear, and other items used during training.

Such information is used exclusively to provide the functionality of the Service, maintain statistics, analyze results, and personalize the operation of the Service.

ShootingMind does not verify the legality of the possession of sports equipment, does not maintain a state or official register of such equipment, and does not use the specified information for any purposes not related to the operation of the Service.

Disclosure of such information is possible only in cases expressly provided for by applicable law or on the basis of a lawful request from a competent authority.