Chuluu Archery

Privacy Policy

Last updated: March 30, 2026

This Privacy Policy explains how personal data of users of the Chuluu Archery mobile application is processed.

This Policy is based on the current functionality of the App, the Operator's legal documents, and the actual user flows implemented in the current version of the product.

1. Operator and Scope

Data Controller / Operator:
Individual Entrepreneur Kudrina Tatyana Egorovna
E-mail: kudrinmv@mail.ru

This Policy applies to the processing of personal data of users of the Chuluu Archery mobile application, which is designed for:

  • account registration and sign-in;
  • user profile management;
  • archery training tracking and analysis;
  • training plans and task management;
  • sports equipment management;
  • subscription features;
  • user ratings / leaderboard functionality;
  • synchronization of data across devices.

2. What Data We Process

2.1. Registration and Authentication Data

We may process:

  • phone number;
  • one-time verification codes;
  • data received from social login providers (Yandex, VK), including the provider account identifier and the data that the user provides or authorizes the provider to share, such as name, e-mail address, or phone number.

2.2. Profile Data

We may process the following profile data:

  • first name;
  • last name;
  • e-mail address;
  • date of birth;
  • sports rank / category;
  • club;
  • achievements;
  • phone number linked to the account;
  • avatar image.

2.3. Training and Sports Statistics Data

The App allows users to store and synchronize training-related data, including:

  • training title;
  • training date;
  • distance;
  • sports rank associated with the training;
  • training type;
  • user comments;
  • total score;
  • training status;
  • environment information, including location, weather, wind speed and wind direction;
  • equipment information used in a training;
  • templates, series, shots, and shot coordinates;
  • derived statistics and analytics calculated from the data entered by the user.

2.4. Plans and Task Data

The App allows users to manage training plans and related tasks. For this purpose we may process:

  • task and plan titles;
  • task descriptions;
  • repeat days;
  • task items;
  • daily and weekly completion state;
  • service timestamps for creation and update.

2.5. Sports Equipment Data

The App allows users to store information about sports equipment, including:

  • bow data: title, type, manufacturer, characteristics, description, image;
  • arrow data: title, quantity, material, characteristics, comments, image.

2.6. Images and Files

If a user uploads images through the App, we may process:

  • profile photo / avatar;
  • photos of bows, arrows, and other equipment;
  • technical file data required for upload, local storage, and synchronization.

2.7. Subscription and Payment Data

If a user purchases a paid subscription, the App may process subscription-related data such as:

  • active subscription status;
  • subscription expiration date;
  • service data required to confirm payment and grant access to paid features.

Full bank card details are processed by the payment provider rather than by the Operator.

2.8. Notifications

If the user grants notification permission, the App may display local service notifications on the user's device.

This version of the Policy does not declare collection of push token / device token for remote push notifications.

2.9. Public Data in Ratings / Leaderboards

When the user participates in rating functionality, part of the user's data may be visible to other users of the App. This may include:

  • first name;
  • last name;
  • club;
  • sports rank;
  • avatar;
  • rating position and score.

3. Purposes and Legal Bases

We process personal data for the following purposes:

  • registration, sign-in, and user identity confirmation;
  • performance of the user agreement and provision of App functionality;
  • storage, display, and synchronization of profile data, trainings, tasks, equipment, and related information;
  • display of user ratings / leaderboards;
  • subscription functionality and confirmation of paid access status;
  • upload and display of images;
  • processing user requests, including account deletion, data update, and support requests;
  • data security and compliance with legal obligations.

Legal bases for processing include:

  • user consent;
  • performance of a contract with the user;
  • compliance with obligations established by applicable law.

We do not declare use of personal data for third-party advertising targeting.

4. Local Storage, Remote Storage, and Synchronization

To operate correctly, the App may store data both locally on the user's device and remotely on servers used to support the service.

Local device storage may include:

  • secure key-value storage for auth tokens, profile data, and settings;
  • a local SQLite database for application data, including trainings, tasks, equipment, and sync state;
  • local image files prepared for upload or stored for offline use.

Remote storage and synchronization are used for:

  • backup of user data within the service;
  • access to the same data across multiple devices;
  • data restoration after sign-in;
  • exchange of data between the client and the App backend.

5. Data Sharing

Personal data may be shared with third parties only to the extent necessary for operation of the App and performance of obligations to the user, including:

  • payment providers involved in subscription and payment processing;
  • hosting and infrastructure providers;
  • processors acting on behalf of the Operator within the scope of the processing purposes;
  • public authorities where required by law.

We do not sell personal data to third parties.

6. Payments and Subscription

In the current version of the App, subscription payment functionality uses YooKassa integration.

Payment data is processed by the relevant payment provider in accordance with that provider's own privacy policy and service terms.

The Operator does not store the full set of the user's bank card details.

7. International Transfers

As a general rule, the Operator does not aim to carry out cross-border transfers of personal data.

If such transfer becomes necessary for operation of the service or compliance with law, it will be performed in accordance with applicable data protection requirements.

8. Data Retention

Personal data is retained no longer than necessary for the purposes of processing, unless a longer retention period is required by applicable law or by a contract with the user.

In general, data may be retained:

  • for the lifetime of the user's account;
  • for the duration of the subscription and settlement of related payments;
  • for the period necessary to fulfill the Operator's legal obligations;
  • until account deletion, withdrawal of consent, or achievement of the processing purposes, unless longer retention is required by law.

9. User Rights

The user may:

  • request information about processing of their personal data;
  • request correction, update, or clarification of data;
  • request blocking or deletion of data where permitted by law;
  • withdraw consent to processing of personal data;
  • submit a request to stop processing of personal data to the extent permitted by law;
  • contact the Operator regarding personal data processing at kudrinmv@mail.ru.

10. Account Deletion

The user may initiate account deletion:

  • through the built-in account deletion functionality available in the user's profile inside the App;
  • by sending a request to kudrinmv@mail.ru.

To confirm an account deletion request, the App or the Operator may request information sufficient to identify the user, such as the e-mail address or phone number linked to the account.

After account deletion, user data is deleted or anonymized unless continued retention is required by law, for performance of obligations, or for resolution of disputes and claims.

11. Children's Data

The App is intended for users aged 14 and older.

The Operator does not knowingly collect personal data of persons under 14 years of age. If the Operator becomes aware that such data has been provided without proper legal basis, steps will be taken to stop the processing and delete the data in accordance with applicable law.

12. Special Categories and Biometric Data

The Operator does not declare processing through the App of:

  • special categories of personal data as defined by applicable personal data laws;
  • biometric personal data;
  • data about health, political views, religious beliefs, or intimate life of the user.

13. Security Measures

The Operator applies legal, organizational, and technical measures to protect personal data, including:

  • access limitation and access control;
  • use of secure storage and information security measures;
  • separation of roles and access rights;
  • measures aimed at preventing unauthorized access, modification, deletion, copying, or disclosure of data;
  • internal procedures related to protection and updating of personal data.

14. Changes to This Policy

The Operator may update this Policy if the App functionality, categories of processed data, processing methods, or legal requirements change.

The current version of the Policy should be published in the App and/or on the official page used for publication of the service legal documents.

15. Contact Information

For questions related to personal data processing, the user may contact:

E-mail: kudrinmv@mail.ru