Personal data processing policy

1. General Provisions

This Personal Data Processing Policy (hereinafter referred to as the "Policy") determines how SHOOTING-SOFT LLC, EIN 36-5010659 (hereinafter referred to as the "Copyright Holder"), uses and protects the personal data of Users who provide such data by sending in the application form for obtaining the software, or which are otherwise obtained or generated by the Copyright Holder in connection with the use of the software by the User.
This Policy has been developed to comply with the requirements of the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and other laws of other countries regarding the protection and processing of personal data.
This Policy defines the procedure for collecting, storing, using, transferring and disclosing User data when using the Rightholder's software.
In order to develop, adapt, improve the quality and functional characteristics, increase the efficiency of the software, the Copyright Holder may collect personal and non-personalized data (hereinafter collectively referred to as the "Data"), as well as perform the functions of an operator in relation to the Users' personal data.
The Rightholder does not process "personal data of special categories" (information about race and ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political preferences, participation in trade unions, as well as information about the health of Users, genetic and biometric data).
The right holder does not make decisions based solely on automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests.
The copyright holder does not create publicly available sources of personal data.
2. Scope

This Policy applies to the Rightholder's software.
This Policy does not apply to third party websites, network resources and systems with which the software may be linked or used to access it. The User agrees that the Copyright Holder is not responsible for the security or privacy practices of such third party websites or resources. In some cases, the Copyright Holder may direct the User to a website controlled by its provider or partner. Even if the page on which the User provides data looks and functions similar to the Rightholder's resource, the collection of data on it may be governed by a different policy adopted by the provider or partner of the Rightholder.
3. Purposes of processing

The Rightholder may use the User's data for the following purposes:
  • Ensuring the fulfillment of contracts with counterparties, the implementation of the necessary services for Users;
  • Protecting Users from known threats to information security;
  • Improving the convenience of work and interaction with the software for Users, in particular, the modernization of interfaces and the provision of the necessary content;
  • For marketing purposes and to provide information about new products or updates to existing products of the Copyright Holder;
  • Provision of technical support in the framework of the use of the software by the Users, as well as improving the quality of the software;
  • Responding to Users' questions and interacting with them;
  • Ensuring software security, protection of Users and Rightholder from fraud.
The content and scope of the data processed by the Copyright Holder corresponds to the stated purposes of processing. The processed data is not redundant in relation to the stated purposes of their processing.
4. Legal basis

The Rightholder processes Users' data on the following grounds:
  • Compliance with the requirements of the current legislation regarding the processing of Users' data;
  • This processing is necessary to advance the legitimate interests of the Copyright Holder, unless these interests are overridden by the interests or fundamental rights and freedoms of Users that require the protection of personal data;
  • Providing effective and innovative products to Users;
  • Detect, prevent or otherwise address fraud or security issues in the use of the software;
  • Data processing necessary for the performance of a contract with the data subject or for the performance of the necessary steps to conclude a contract;
  • Special consent of the User to the processing of data for the specified purposes;
  • Processing necessary to comply with legal obligations.
    5. Volume and categories of processed data, storage periods

    In order to use the software and have access to all of its features, the User will be required to create a personal account. To do this, you must enter an email address (which will be used as a login to log in) and a password.
    Upon registration, the User is automatically generated and assigned a unique User ID, consisting of a random set of uppercase and lowercase Latin letters and numbers.
    The e-mail address is required to register the User's account, as well as to recover the password of the User's account by sending a password recovery code.
    The Copyright Holder undertakes to process and use this information only to provide the User with the functionality of the software. This information will be processed and used for other purposes only if the User gives his express consent to this (for example, to receive up-to-date news about the products and services of the Copyright Holder by e-mail).
    The Copyright Holder may provide Users with the opportunity to periodically receive news or marketing communications both about purchased products and services, and about products and services that may be of interest to Users. This functionality can be customized by the user. The Copyright Holder does not use Users' data to display third-party advertising.
    The main data of the account are the User's e-mail address and the password specified by the User during registration. The listed data in the aggregate does not allow to identify the subject of personal data.
    The User has the right to review, update and correct his account information and password, as well as delete his account at any time. The data is deleted 1 (one) calendar month after the account is deleted. During the specified period, the User can cancel the deletion of his account. The user can also send an appeal to the technical support service by e-mail: support@shooting-soft.com with a request to delete his data, in which case the data deletion period is 14 (fourteen) calendar days from the moment the request is received by the technical support service of the Copyright Holder. For other issues, the Copyright Holder provides technical support to Users by receiving requests by e-mail: support@shooting-soft.com.
    If the User does not want to provide the Copyright Holder with an email address, password, the Copyright Holder will not be able to provide him with the opportunity to use the software, since without providing an email address, the User will not be able to create an account.
      6. Procedure and conditions for data processing

      Data processing is carried out by the Copyright Holder using automation tools and without their use and includes the collection, recording, systematization, storage, clarification (updating, changing), extraction, use, transfer (provision, access), depersonalization, blocking, deletion and destruction of data .
      The Copyright Holder uses the Users' data in order to fulfill the agreement with the User on the use of the software. The Copyright Holder collects and processes only the data that is necessary to provide the User with the functionality of the software.
      The Copyright Holder does not use the Users' data to display advertisements of third parties and stores only the data that is necessary for the correct use of the software by the User, as well as the interaction between the Copyright Holder and the User in case of questions.
      The Copyright Holder processes the Users' data (e-mail address, password) only during the time of using the software.
      The Rightholder may process some of the Users' data on the basis of consent, which can be revoked at any time. The data is processed until the termination of the agreement, unless the User revokes his consent before that moment.
      In cases where, in order to achieve the goals specified in this Policy, it is necessary to transfer Users' data, including cross-border transfer of personal data, the Copyright Holder shall carry out such transfer:
      • In order to comply with the requirements in accordance with applicable laws, regulations;
      • Law enforcement or other state or government agencies based on legitimate requests;
      • On the basis of an agreement to which the subject of personal data is a party, and in the absence of such a contract - on the basis of consent to the processing of personal data - for the purpose of selling the Rightholder's products.
      The transfer of data that is not provided for by the requirements of the current legislation is carried out by the Copyright Holder on the basis of concluded contracts / agreements with third parties containing obligations to maintain confidentiality and ensure the security of the transferred data.
      The assignment of data processing to another person is carried out by the Copyright Holder with the consent of the subject of personal data, unless otherwise provided by law.
      Data processing is ordered by the Copyright Holder on the basis of a contract/agreement or an addendum to them, indicating the list of actions (operations) with personal data that will be performed by the person processing personal data and the purposes of processing, the obligations of such a person to maintain confidentiality and ensure the security of personal data when their processing, as well as an indication of the requirements for the protection of processed personal data.
      In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, information about Users, including their data, may be transferred to the legal successor or assignee of the Copyright Holder.
        7. Data security measures

        When processing data, the Copyright Holder takes all necessary legal, organizational and technical measures to protect them from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to them.
        Ensuring data security is achieved, in particular, in the following ways:
        • Appointment of a person responsible for organizing data processing, as well as a person responsible for ensuring data security;
        • Implementation of internal control and/or audit of compliance of data processing with the current legislation of the United States, the current legislation of the EU and the legislation of other countries of the world regarding the processing of personal data, requirements for the protection of personal data, local acts of the copyright holder;
        • Identification of threats to data security during their processing;
        • Application of organizational and technical measures to ensure the security of data during their processing;
        • Evaluation of the effectiveness of the measures taken to ensure data security;
        • Revealing the facts of unauthorized access to data and taking appropriate measures;
        • Recovery of data modified or destroyed due to unauthorized access to them;
        • Establishing rules for access to data, as well as ensuring the registration and accounting of all actions performed with data;
        • Control over the measures taken to ensure data security and the level of security.
        All data is stored in a highly encrypted form, so employees of the Copyright Holder or physical intruders cannot access them.
        The Copyright Holder does not use Users' data for advertising targeting or other commercial purposes. The copyright holder stores only the information that is necessary for him to fulfill his obligations under a sublicense agreement for granting a non-exclusive right to use the software.
        In the event that the Copyright Holder needs to transfer Users' data to a third-party service provider, then such provider will be required to take appropriate precautions to protect Users' data.
        The Rightholder has the right to disclose the Users' data to state authorities if an appropriate notification is received indicating the legal grounds.
        The user should be aware that Internet-enabled software and hardware is not inherently a secure environment and the security risks associated with it, as well as various technical and organizational industry standards for their control, are constantly evolving. In this regard, the Copyright Holder cannot guarantee the complete security of any data collected, stored or used by him.
          8. Rights of Users

          Users have the following rights in relation to the data stored by the Copyright Holder:
          • The right to receive information. The user has the right to receive clear, transparent and understandable information about how the copyright holder uses his data and about his rights;
          • Access right. This right allows the user to obtain a copy of the data processed by the right holder and verify that the processing is carried out in accordance with applicable law;
          • Right to make changes. The user can send a request to make changes to his data, which is processed by the copyright holder;
          • Right to erasure (right to be forgotten). This right allows the user to ask the right holder to delete or erase the data, unless the right holder has a good reason to continue processing it;
          • The right to restrict processing. This right allows the user to ask the copyright holder to suspend the processing of his data, for example, if the user wants the copyright holder to ascertain their accuracy or the reason for the processing;
          • Right to data portability. The user can ask the copyright holder to transfer his data. The right holder will provide the user or a third party chosen by the user with his data in a structured standard machine-readable format;
          • Right to object. The user may at any time object to the processing of his data if such processing is in the legitimate interests of the right holder;
          • The right to withdraw consent to data protection. If the user revokes his consent, the copyright holder will not be able to provide him with access to the functionality of the software. The right holder will inform the user about this in the event and at the time of withdrawal of consent;
          • The right to file a complaint. The user has the right to apply to the data protection authority of his country to challenge the data protection and privacy practices of the right holder.
          The user can exercise these rights by sending a corresponding request by e-mail: support@shooting-soft.com.
          As a rule, the User is not required to pay for access to his personal data (or the exercise of any other rights). However, except in the case of withdrawal of consent, the Copyright Holder has the right to charge a reasonable fee if the User's request is manifestly unfounded, repetitive or excessive, and the Copyright Holder has the right to refuse to comply with the User's request in such circumstances.
          The user can delete his account by going to the deactivation page.
            9. Age restrictions

            The Software is intended for persons over 18 (eighteen) years of age. The User, by downloading, visiting and/or using the software, confirms that he is over 18 (eighteen) years old and gives his consent to the collection and use of his data in accordance with this Policy. The copyright holder is not responsible if the software is used by a person under the age of 18 (eighteen) years.
            The copyright holder does not knowingly collect or store any personal data about children under 13 (thirteen) years of age living in the United States, as well as about children under/over the appropriate age adopted in other jurisdictions of their residence.
            Parents who believe that the Copyright Holder has inadvertently collected personal data about their child, or used such data in another way or for other purposes, may contact the Copyright Holder by sending an appropriate email to: support@shooting-soft.com.
            The copyright holder strongly recommends that parents instruct their children never to disclose their real names, addresses, phone numbers and other personal information online without parental permission. In addition, the Copyright Holder recommends that parents familiarize themselves with the parental control functions available on computers, tablets and other devices provided to children and accompany children when using the Internet.
              10. Privacy information relevant to individuals who live in California (USA)

              The Copyright Holder may collect data about Users belonging to the following categories:
              • Identifiers and contact/registration information: eg email address;
              • Helpdesk data: for example, user questions and other communications sent to the copyright holder.
              • Purposes of use:
              • Provision of services and personalization of the user's use of the software (creating an account);
              • Commercial purposes, including the purchase of the rights holder's products, the promotion of new products of the rights holder, or the notification of updates to existing ones;
              • Support for the functionality of the game;
              • Interaction with the support service;
              • Ensuring security and protection of software;
              • Solving the problems of control and maintenance of the quality of the right holder's products.
              The Rightholder processes the User's data in order to fulfill its legal obligations.
              The source of data is the User himself when registering his account, as well as in the process of using the software, sending requests to the Rightholder's technical support service. The right holder collects and processes the email address and the assigned identifier, which together do not allow to identify the subject of personal data.
              Identifiers, contact/registration data and technical support service data, the Copyright Holder may transfer to third parties for certain purposes in the following cases:
              • If required by applicable laws, regulations or legal process;
              • If it is necessary to exercise, establish or protect the legal rights of the right holder;
              • If it is necessary to protect the vital interests of any person;
              • In connection with the sale of the business or assets of the copyright holder.
              If the User resides in the state of California (USA), he has the right, subject to certain restrictions, to demand the disclosure of information about what personal data the Rightholder has collected about the User, the deletion of such data, and the prohibition of the sale of such data, without being discriminated against for exercising their rights. The User also has the right to appoint an agent to exercise such rights on his behalf.
                Privacy Rights of Users in the State of California (USA):
                • The right to request access to your personal data. As a California resident, a user has the right up to two times in a 12-month period to request disclosure of which categories of personal data the copyright holder collects, uses, and transfers. The user also has the opportunity to request certain personal data collected by the copyright holder about him. Certain types of data may be excluded from such requests in accordance with the laws of the State of California;
                • The right to request the deletion of your personal data. The user also has the right to send a request for the deletion of personal data received by the copyright holder from the user. Certain types of data may be excluded from such requests in accordance with California law. For example, we need certain types of data in order to provide the user with the functionality of the software. If they are removed, the user will lose access to the software and the ability to use it;
                • Exercise of access and deletion rights. As a California resident, the user may exercise their special privacy rights by sending an email request to: support@shooting-soft.com. If it is impossible to fulfill the user's request, the copyright holder will inform him of the reasons for such non-fulfillment;
                • The right to non-discrimination. If the user decides to exercise the rights described above, the right holder will not refuse service, change prices for the user, or provide products of a different quality;
                • Sale of personal data. The California Consumer Privacy Act (ccpa) gives California residents the right to prevent the sale of their personal information.
                The Copyright Holder does not sell data that allows to identify the User, including the e-mail address. The Copyright Holder also does not transfer personal data about Users to third parties in exchange for monetary or other remuneration.
                In addition to the opt-out options described above, in order to support the CCPA, Copyright Holder provides California residents with the ability to opt out of any future sale of their personal information. To take advantage of this opportunity, the User must send a corresponding request by e-mail: support@shooting-soft.com.
                The user may appoint an agent who will be able to submit requests to exercise his rights under the CCPA.
                Since 2005, California Civil Code Section 1798.83 allows Users who are residents of that state to request certain information regarding the disclosure of personal data by the Copyright Holder to third parties for their direct marketing purposes. The Copyright Holder does not transfer the personal data of Users to third parties for use in their own marketing purposes without the consent of the Users themselves.
                The Rightholder will provide, update or delete the data at the request of the User. Copies of data and / or materials deleted from the User's account may be stored in backup systems for about a month. The Copyright Holder may also store the User's data to resolve conflicts, enforce user agreements, and comply with legal requirements; in this case, the personal data of the Users will be blocked for use for any other purposes.
                  11. Privacy information relevant to individuals who live in the state of Nevada (USA)

                  The laws of the State of Nevada allow persons residing in this state who have obtained the Rightholder's products to prohibit the sale of "protected information" (as defined by Nevada law) for a monetary consideration to a person who may license or sell such information to others. "Protected information" includes first and last name, postal address, e-mail address, telephone number, and any identifiers that allow you to contact a specific person physically or on the Internet. The copyright holder collects and processes the email address, which in the aggregate does not allow identifying the subject of personal data.
                  The Copyright Holder may collect data about Users belonging to the following categories:
                  • Identifiers and contact/registration information: eg email address;
                  • Helpdesk data: for example, user questions and other communications sent to the copyright holder.
                  Purposes of use:
                  • Provision of services and personalization of the user's use of the software (creating an account);
                  • Commercial purposes, including the purchase of the rights holder's products, the promotion of new products of the rights holder, or the notification of updates to existing ones;
                  • Support for the functionality of the game;
                  • Interaction with the support service;
                  • Ensuring security and protection of software;
                  • Solving the problems of control and maintenance of the quality of the right holder's products.
                  The Rightholder processes the User's data in order to fulfill its legal obligations.
                  The source of data is the User himself when registering his account, as well as in the process of using the software, sending requests to the Rightholder's technical support service.
                  Identifiers, contact/registration data and technical support service data, the Copyright Holder may transfer to third parties for certain purposes in the following cases:
                  • If required by applicable laws, regulations or legal process;
                  • If it is necessary to exercise, establish or protect the legal rights of the right holder;
                  • If it is necessary to protect the vital interests of any person;
                  • In connection with the sale of the business or assets of the copyright holder.
                  The copyright holder does not consider that such transfer falls under the definition of "sale" under the laws of the State of Nevada. However, if the User resides in the state of Nevada and has purchased products from the Copyright Holder, he may notify the Copyright Holder of his ban by sending a request by e-mail: support@shooting-soft.com.
                    12. Privacy information relevant to individuals who live in the EEA and the UK

                    The Rightholder processes and transfers Users' data only where there are reliable legal grounds and protection measures for such processing and transfer. If the User is located in the EEA and the UK, he has additional rights in relation to his personal data.
                    The Copyright Holder may collect data about Users belonging to the following categories:
                    • Identifiers and contact/registration information: eg email address;
                    • Helpdesk data: for example, user questions and other communications sent to the copyright holder.
                    Purposes of use:
                    • Provision of services and personalization of the user's use of the software (creating an account);
                    • Commercial purposes, including the purchase of the rights holder's products, the promotion of new products of the rights holder, or the notification of updates to existing ones;
                    • Support for the functionality of the game;
                    • Interaction with the support service;
                    • Ensuring security and protection of software;
                    • Solving the problems of control and maintenance of the quality of the right holder's products.
                    The Rightholder processes Users' data in order to fulfill their legal obligations.
                    The source of data is the User himself when registering his account, as well as in the process of using the software, sending requests to the Rightholder's technical support service. The copyright holder collects and processes the email address, which in the aggregate does not allow identifying the subject of personal data. The Rightholder processes the personal data of Users on the basis of consent.
                    In addition to the rights to view, correct, update and request deletion of their personal data described above, Users have the following rights.
                    To access or delete their personal data, the User may also submit a request by e-mail: support@shooting-soft.com.
                    The User may object to the processing of his personal data on the basis of the legitimate interest of the Copyright Holder for reasons related to the specific situation of the User. The User may, in particular, control the limits of marketing communications of the Copyright Holder with him, and also has the right at any time to request a complete refusal to receive marketing communications from the Copyright Holder, if any. The user can use the methods described above.
                    Under certain circumstances, the User may require the Rightholder to transfer the personal data provided by him. The User can send his request by e-mail: support@shooting-soft.com .
                    In situations where the Rightholder processes the personal data of Users on the basis of consent, the User has the right to withdraw such consent at any time for the further use of his personal data. The User can send his request by e-mail: support@shooting-soft.com.
                    The Rightholder will satisfy the requests of the Users related to the processing of his personal data. However, if the User still has unresolved doubts, he is entitled to file a complaint with the competent data protection authorities. Such a complaint may be filed at the place of residence or work in the EEA state, as well as the place of the alleged violation of data protection laws.
                      13. Privacy information relevant to individuals who reside outside the US, EEA and UK

                      The Copyright Holder takes all commercially reasonable measures to protect the Users' privacy rights in accordance with this Policy. If the User does not agree to the collection, processing, storage and transfer of his data, he should not provide such data to the Copyright Holder and should refrain from using the software of the Copyright Holder.
                        14. Disclaimer

                        The Copyright Holder cannot guarantee the complete security of the data provided by the Users. It is the User's choice to provide the Copyright Holder with their data. If the User provides his data, he acknowledges that he performs these actions solely at his own discretion and at his own risk.
                        The Copyright Holder makes every effort to provide Users with accurate and reliable information, but at the same time does not exclude the possibility of errors. The software is a project with open content and subsequent content. The copyright holder does not make any representations or warranties with respect to the software and its contents, including, without limitation, with respect to timeliness, currency, accuracy, completeness, reliability, availability or suitability for any particular purpose, in relation to that when using the software there will be no errors, it will be uninterrupted.
                        The use of the software may be a violation of the laws of the country in which the User is located. The Copyright Holder disclaims liability if the use of the software violates human rights on the basis of sex or gender, race, nationality, offends the feelings of believers, or leads to any other direct or indirect discrimination in accordance with the current legislation of the User's country. The software is purely gaming in nature and cannot be interpreted as propaganda of violence, terrorism and extremism. When registering an account, the User independently assumes the risks of the legality of using this software.
                        All rights to materials contained in the software are protected in accordance with applicable law, including copyright and related rights. The logo, graphics, and illustrations contained in the software are protected by copyright.
                        If any terms are held to be invalid under applicable law, the remaining terms will remain in full force and effect.
                        By using the software, the User agrees with the "Disclaimer" and the established rules and accepts all responsibility that may be assigned to him.
                          15. Final provisions

                          Users are advised to regularly review the current version of this Policy in view of the fact that this Policy may be updated in accordance with amendments to the law or changes in connection with the internal processes of the Copyright Holder.
                          If the Copyright Holder makes significant changes to this Policy, the User will be notified of this in accordance with the requirements of the law. If the User continues to use the software after notification of changes or publication of such changes, this will be interpreted as the User's consent to the current version of this Policy and any subsequent changes to it.
                          If the User has any questions or comments about the Copyright Holder's Policy or desires to update the information provided earlier or send his preferences or any questions regarding the processing of the User's personal data, he can contact the Copyright Holder by sending an appropriate email to: support@shooting-soft .com.
                          If the User considers that the processing of data violates applicable data protection legislation, he has the right to lodge a complaint with the competent supervisory authority at any time. Which supervisory authority is competent to deal with a given complaint may depend on the User's country of residence.
                          If the User has any doubts regarding the provision of data to the Copyright Holder or their use in accordance with this Policy, he should not use the software.
                          The use of the software is also governed by a sublicense agreement with the end User of the Copyright Holder.
                          By sending an application for obtaining access to the software, the User accepts the Policy of the Copyright Holder and agrees with it.