Privacy Policy

1. Introduction

This privacy policy explains how MTE Software Limited ("we", "our", "us"), company number 16983418, registered at 71-75 Shelton Street, London WC2H 9JQ, collects, uses, stores, and protects your personal data when you use the Shootly platform, including the iOS app, web app at www.shootly.co.uk, and the Ground Portal.

We are registered with the Information Commissioner's Office (ICO) under registration number ZC093445. We are the data controller for the personal data we process through Shootly.

2. Data We Collect

We collect the following categories of personal data:

Account information:

• Name and email address provided via Sign in with Apple (Apple may hide your email — we respect this choice)
• Display name and CPSA number (if you choose to provide them)
• Device tokens for push notifications

Shooting data you enter:

• Clay pigeon scores, disciplines, and competition/practice flags
• Game day records including quarry types, bag totals, peg numbers, gun records, and weather conditions
• Coaching notes and personal observations
• Kit information (guns, cartridges, and their specifications)
• Estate notes and personal venue reviews

Documents and images:

• Shotgun certificate details (certificate number, holder name, dates, issuing force, conditions)
• Photographs of score cards, game cards, shotgun certificates, and membership cards submitted for AI scanning
• Game day photographs you choose to upload
• Membership details (organisation, membership number, expiry)

Technical data:

• Device information (device model, operating system version, app version) when submitting bug reports
• Browser and screen information for the web app
• IP address and access logs

Subscription data:

• Subscription tier (Free or Pro), payment platform (Apple or Stripe), and subscription period dates
• We do NOT store your credit card or payment details — these are handled entirely by Apple (via StoreKit) or Stripe

3. Lawful Basis for Processing

We process your data under the following lawful bases under UK GDPR:

• Contract: Processing your shooting data, scores, and account information is necessary to provide the Shootly service you have signed up for
• Legitimate interest: Sending you service notifications (shoot invites, reminders, score updates), improving the platform, and preventing fraud
• Consent: Marketing communications (you can opt out at any time)

4. How We Use Your Data

• Provide the Shootly platform — storing your scores, organising your shoots, and calculating classification bands
• Process AI scanning of score cards, game cards, and shotgun certificates using the Anthropic (Claude) API to extract structured data from your photographs
• Enable you to invite other shooters to your shoots and manage RSVPs
• Send push notifications about invites, shoot reminders, certificate renewal reminders, and subscription status
• Provide subscription services including free trials and Pro features
• Respond to bug reports and support tickets you submit
• Generate aggregated, anonymised analytics to improve the platform

5. AI Processing

When you use the score card scanning, game card scanning, or shotgun certificate scanning features, your photographs are sent to the Anthropic API (Claude) for processing. Anthropic processes this data solely to extract the structured information you have requested. Anthropic does not use your data for training purposes. The extracted data is returned to Shootly and stored in your account. You can delete this data at any time.

6. Data Sharing

We share your data with the following third parties only as necessary to operate the service:

• Render: Cloud hosting provider (EU — Frankfurt region) for our servers and database
• Anthropic: AI processing for score card and certificate scanning
• Apple: Authentication (Sign in with Apple) and in-app subscription payments
• Stripe: Web subscription payment processing
• Apple Push Notification service (APNs): Delivering push notifications to your device

We do NOT sell your personal data to third parties. We do NOT share your shooting data, scores, or personal records with other users, shooting grounds, or organisations unless you explicitly choose to do so (e.g. by sharing an invite link or using the public profile feature).

7. Data Storage and Security

Your data is stored on servers hosted by Render in the EU (Frankfurt, Germany). Data is encrypted in transit using TLS and at rest using AES-256 encryption. Our database is PostgreSQL with automated backups. Access to production data is restricted to authorised MTE Software personnel only.

On iOS, your data is also stored locally on your device using SwiftData for offline access. Local data is protected by your device's security (passcode, Face ID, or Touch ID).

8. Data Retention

• Account data: Retained for as long as your account is active. Deleted within 30 days of account deletion.
• Shooting data: Retained for as long as your account is active. You can delete individual records at any time.
• Scanned images: Processed and discarded after extraction. We store the extracted text data, not the original photographs (except game day photos you explicitly upload).
• Bug reports and support tickets: Retained for 2 years after resolution for quality and legal purposes.
• Subscription records: Retained for 7 years to comply with UK tax and accounting obligations.

9. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of access: Request a copy of all data we hold about you
• Right to rectification: Correct inaccurate data via your profile or by contacting us
• Right to erasure: Delete your account and all associated data from Profile > Delete Account
• Right to data portability: Request your data in a machine-readable format (Pro subscribers can export as CSV/PDF)
• Right to restrict processing: Request that we limit how we use your data
• Right to object: Object to processing based on legitimate interest
• Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, contact us at privacy@shootly.co.uk. We will respond within one month as required by UK GDPR.

10. Cookies

The Shootly web app uses essential cookies only for authentication and session management. We do not use tracking cookies, advertising cookies, or third-party analytics cookies. No cookie consent banner is required as we only use strictly necessary cookies.

11. Children

Shootly is not intended for use by anyone under the age of 16. We do not knowingly collect personal data from children under 16. If you believe a child under 16 has created an account, please contact us at privacy@shootly.co.uk and we will delete the account.

12. International Transfers

Your data is primarily stored in the EU (Frankfurt, Germany). Some data is processed by Anthropic (based in the US) for AI scanning features. This transfer is covered by Standard Contractual Clauses (SCCs) as approved by the UK ICO. Stripe (based in the US) processes payment data under their own SCCs and Privacy Shield certification.

13. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of significant changes via push notification or email. The "last updated" date at the top of this page indicates when the policy was last revised.

14. Contact Us

For privacy queries, data requests, or complaints:

• Email: privacy@shootly.co.uk
• Post: MTE Software Limited, 71-75 Shelton Street, London WC2H 9JQ
• ICO registration: ZC093445

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.