Strilets Logo

Privacy Notice

Last updated: September 9, 2024




Intro

Strilets (“we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our website (“Website”) and mobile application (“App”) available in the App Store and Google Play.

The Privacy Notice describes which of your personal data the Website and the App collect, how store, process, and use it, and what happens when you use the Website and App.




Content




About us

We are the controller of your personal data processed through the Website and App. This means that we determine the purposes and means of personal data processing.


Name

Sole entrepreneur Dmytro Tsapko Vasylovych

Registration number

321620657

Address

52030, Ukraine, Dnipropetrovsk region, Obukhivka, Kharkivska str, building 186

Email

contacts@strilets.tech – for general inquiries

contacts@strilets.tech – for privacy inquiries




About you

When you visit the Website or App, you become our user (“User”).


We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.


Type of User

Description

Communications User

A User who contacts us via messengers and email.

App User

A User who has installed the App and uses its functionality.

Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.




Personal data



Sources of data

We receive your data when you visit the Website or App and interact with it, depending on your actions on the Website and App.

You can change your personal data by exercising your right to rectification or by the Website and App functionality. Please note that the same lawful basis and storage terms apply to the changed data.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.


Lawful bases for processing

To process your personal data, we rely on the following lawful bases:



If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.

When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.




Users’ data

When you visit the Website, we collect some data automatically. We collect some technical data about the Users to optimize performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.

Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.


Data

Reasons for processing

Lawful basis

Information about the coarse location (IP address, country)

The optimization of the performance, debugging, enhancement of the features’ proper functioning, administering and improvement of the Website

Legitimate interest

Technical device information and network information (including IP address, HTTP user agent, browser type, Internet Service Provider (ISP))

Data storage

We store the data for 3 years from its collection.


We also need cookies to operate, support, and improve the Website’s functionality.


Data

Description

Reasons for processing

Lawful basis

Necessary cookies

Information that is necessary for the operation of the Website

Improving your experience of using the Website

Performance of the contract

Marketing cookies

Marketing information used to match relevant advertising to you

Marketing

Consent

Data storage

We store the data during the expiry period provided in our Cookie Notice.




Communications Users’ Data

We collect your personal data when you contact us via messengers (Telegram, Facebook, or Instagram) or email.


Data

Reasons for processing

Lawful basis

Contact details

To provide you with a response to your request

Performance of the contract

Message text, attachments to the text

Data storage

We store the data for 3 years since the last communication.




App Users’ Data

We collect your personal data when you download the App, pay for a subscription, and use its functionality.


Data

Reasons for processing

Lawful basis

Technical data of the device (operating system, model, language of the device, date and time of the first installation of the application, information about the Internet connection)

The optimization of the performance, debugging, enhancement of the features’ proper functioning, administering and improvement of the App

Legitimate interest

Subscription payment confirmation

To provide you with access to the functionality of the App

Performance of the contract

Data about your weapon

To make calculations for shooting

Data about your target

Data from geolocations, sensors, or connections to weather stations via Bluetooth connection (magnetometer, barometer, accelerometer)

To monitor weather conditions for shooting

Consent

Data storage

Data that is processed on the basis of consent.

Stored until you delete your account or until you withdraw your consent.

Data that is processed on the basis of the performance of the contract.

Stored until you delete your account.



Please note! We collect only anonymous data about the choice of weapon, targets, shooting results, and weather conditions. This information is used to create statistics and improve the functionality of the App. All collected information remains anonymous, does not contain personal data, and is not transferred to other parties.




Data received from third parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the lawful basis for processing are determined by the respective privacy documents of these third parties.


Category of data

Third party

Privacy documents

Confirmation of payment

Apple

Privacy Policy

Google

Privacy Policy

Technical data

Appsflyer

Privacy Policy

Firebase

Privacy Policy




Data sharing with third parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organizational and technical measures to ensure the security of personal data during data transfer to third parties.


Third parties

Description

Analytics tools

We use analytics tools to understand and promote our business.

Payment services

We use payment services to process your payments and other transactions.

Social networks

We use various social networks to spread information about our activities.

Messengers

We use messengers to communicate with you in ways that are convenient for you.

Data storage services

We use various cloud services that allow us to securely store data on remote servers.

Weather service

We use OpenWeather to obtain current weather conditions based on the User’s geo-coordinates and provide the full functionality of the App.

Contractors, service providers on the Website and App

We cooperate with service providers and contractors, in particular PE Kachilov Bogdan, to provide you with our services, to operate, develop, and improve the features and functionality of the Website and App, host the Website and App, complete payment transactions, etc.

State authorities, courts, law enforcement agencies, etc

We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies:


  • to comply with a government request, court order, or applicable law;

  • to prevent unlawful use of the Website and App;

  • to protect against claims of third parties;

  • to help prevent or investigate fraud.

To get a detailed list of the third-party recipients of your personal data, contact us.


To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.




Data protection

We apply a variety of security measures appropriate to the possible risks.


Organizational measures

Staff training

Internal policies and instructions

Non-disclosure agreements (NDA)

Transfer protection

Action plan in case of unauthorized access to personal data

Keeping records of operations related to the processing of personal data and access to them

Access control mechanism


Physical measures

Video monitoring

Signalling

Limited access to premises

Round the clock security


Technical measures

Two-factor authentication

Backups

Firewalls

Encryption of data

Implementation of HTTPS

End-to-end encryption




Data subjects rights

You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.

To exercise your rights, contact us.




Ukraine residents

Right

Description

The right to be informed

You have the right to know about the sources of collection, the location of your personal data, the purpose of their processing, the location of the owner or the place of residence of the owner or manager of personal data, or to give an appropriate order to receive this information.

The right to request information about the terms of disclosure

Upon request, you have the right to receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred.

Right of access

You can request access to and receive all of your personal data that we store.

Right to reply

You have the right to receive a response about whether your personal data is being processed and the content of such data.

Right to object to processing

You can send us a request with a reasoned request to object to the processing of your personal data.

Right to rectification or erasure

You may send us a request with a reasoned request to rectify or erase your personal data if the data is processed unlawfully or is inaccurate.

Right to data protection

You have the right to protect your personal data from unlawful processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or untimely provision, as well as to protect against the provision of information that is inaccurate or defamatory of your honor, dignity, and business reputation.

The right to complain

You may file a complaint regarding the processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights by emailing hotline@ombudsman.gov.ua or in court.

The right to apply for legal remedies

You may protect your personal data by means of remedies provided by law.

The right to make reservations

You may make reservations regarding the restriction of the right to process your personal data when providing consent.

Right to withdraw consent

You can withdraw your consent to the processing of personal data at any time. You can also make reservations regarding the restriction of the right to process your personal data when you give your consent.

Right to know the mechanism of automatic processing

You can send us a request to find out whether we are using automatic processing of personal data.

The right to be protected against an automated decision that has legal consequences for you

You can send us a request to challenge the results of an automated decision that has legal consequences for you.

Please note! We may ask you to verify your identity before responding to your request. We will process your request and respond to you within 30 days of receiving it.




European Economic Area and United Kingdom residents

Right

Description

Right to access

You can request information on whether personal data are being processed, and, where that is the case, access to this personal data and the information required by law.

Right to rectification

You can change the data if it is inaccurate or incomplete.

Right to erasure

You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.

Right to restrict the processing

You may partially or completely prohibit us from processing your personal data in cases provided by law.

Right to data portability

You can request all the data you provided to us and request to transfer data to another controller.

Right to object

You may object to the processing of your personal data that is collected on the basis of legitimate interest.

Right to withdraw consent

You can withdraw your consent at any time.

Right to file a complaint

If your request was not satisfied, you could file a complaint to the regulatory body.

For EEA residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.

For UK residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint at the Information Commissioner’s Office via number 0303-123-1113 or go online at www.ico.org.ukandconcerns.




Data transfer outside the EEA

We may share personal data with the recipients of other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation.

To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.

If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

You can read more detailed measures to protect your personal data here.




United States residents

Your rights vary depending on the state of your residency, as indicated below.


Right

Description

Area

Right to access

You can request an explanation of the processing of your personal data.

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Iowa;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Utah;

  • Virginia.

Right to correct

You can change the data if it is inaccurate or incomplete.

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Virginia.

Right to delete

You can send us a request to delete your personal data from our systems.

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Iowa;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Utah;

  • Virginia.

Right to portability

You can request all the data you provided to us and request to transfer data to another controller.

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Iowa;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Utah;

  • Virginia.

Right to opt out of sales

The right to opt out of the sale of personal data to third parties.

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Iowa;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Utah;

  • Virginia.

Right to opt out of certain purposes

The right to opt out of processing for profiling and targeted advertising purposes.

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Utah;

  • Virginia.

Right to opt out of the processing of sensitive data

The right to opt-out of processing of sensitive data.

  • California.

Right to opt in for sensitive data processing

The right to opt in before processing sensitive data.

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Virginia.

Right against automated decision-making

A prohibition against a business making decisions about a consumer based solely on an automated process without human input

  • California;

  • Colorado;

  • Connecticut;

  • Delaware;

  • Indiana;

  • Iowa;

  • Montana;

  • New Hampshire;

  • New Jersey;

  • Oregon;

  • Tennessee;

  • Texas;

  • Virginia.

Private right of action

The right to seek civil damages from a controller for violations of a statute.

  • California.

We will answer your request within 30 to 60 days, depending on the state and legislative requirements. If your complaint is not satisfied, you can submit a complaint to the Federal Trade Commission.

Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us.




Do not sell my personal information

California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by the CCPA.

We do not sell your personal information to anyone nor use your data as a business model.

However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us.




Do-not-track requests

California residents visiting the Website and App may request that we do not automatically gather and track information about their online browsing movements across the Internet.

Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.

We currently do not have the ability to honor these requests. We may modify this Privacy Notice as our abilities change.




Cookies

We use cookies that are needed for the Website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Notice.

If you want to turn off cookies, you can find instructions for managing your browser settings at these links:


Internet ExplorerInternet Explorer FirefoxFirefox ChromeChrome OperaOpera
Microsoft EdgeMicrosoft Edge VivaldiVivaldi SafariSafari BraveBrave



Privacy Notice updates

This Privacy Notice is developed according to the General Data Protection Regulation, the Law of Ukraine “On protection of personal data”, other applicable privacy laws, and best privacy practices.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website and App.

If there are material changes to the Privacy Notice or the Website and App that affect your data privacy rights, we will notify you by displaying information on the Website and App and, if necessary, ask for your consent.