Privacy Policy
Last updated:
This Privacy Policy explains how personal data is processed when you visit this website, when you contact us, and when you use the ARC Proficiency app during its pilot. Personal data is processed in accordance with the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).
1. Who is responsible
The person responsible for data processing (the "controller") is:
Reto Haeni, Switzerland
Email: hello@arcproficiency.com
ARC Dynamix GmbH is being incorporated; once registered, the company becomes the controller and this policy is updated accordingly. We have not appointed an EU representative, on the basis that processing through this website and the pilot app is occasional and low-risk.
2. This website
a. Technical access data. When you visit the site, our hosting provider automatically processes the technical data required to deliver it securely — your IP address, browser type and the date and time of the request — and retains it for a short period (typically up to 90 days).
b. No analytics, no cookies, no forms. This website sets no cookies, runs no analytics and has no contact form. If you e-mail us at hello@arcproficiency.com, we process what you send us to reply to you.
3. The ARC Proficiency app (pilot via TestFlight)
a. Your data stays on the device unless you send it. Everything you enter or record in the app — shooters, teams, weapons, drills, sessions, results, and sensor recordings you choose to make — is stored on the iPad. The pilot version has no user account. Nothing is uploaded, synchronised or shared automatically: data leaves the iPad only when you tap Send in Feedback or Upload on a recording (see d and g). Deleting the app deletes the data on it.
b. Bluetooth. With your permission the app connects to nearby shot timers and BlazePod training lights to run drills. It does not use your location.
c. Microphone and speech. With your permission the app uses the microphone for voice guidance and voice commands during a drill. Speech is recognised on the iPad itself where the device supports on-device recognition; where it does not, the audio is processed by Apple's speech-recognition service under Apple's privacy terms. Voice features can be switched off in the app's Settings.
d. Feedback you send us. When you use the Feedback button, the app collects your text, an optional picture of the app screen, the screen name and the build number — nothing else. On an iPad the ARC team has set up for direct delivery, tapping Send transmits the entry over an encrypted connection to our own storage (Cloudflare R2 in the European Union — see 5 and 6); on every other iPad the app opens a pre-filled e-mail in your Mail app and you decide whether to send it to our feedback mailbox hello@arcproficiency.com, hosted by Microsoft 365 (Microsoft Ireland Operations Ltd.; mailbox data stored in Switzerland). Feedback is used only to improve the app. We keep it for up to 12 months after the pilot ends, and uploaded feedback for at most 18 months after upload.
e. TestFlight. The app is distributed through Apple's TestFlight. Apple collects crash reports and usage statistics about beta apps and makes them available to us in aggregated or pseudonymised form, as described in Apple's TestFlight terms; you control the sharing of analytics in your device's privacy settings.
f. Optional online features. Accounts, cloud sync and sharing with an academy are switched off in the pilot. Should a later version offer them, this policy is updated before they are enabled and you are asked before any data leaves the device.
g. Sensor recordings you upload. When the Recorder is switched on in Developer setup, the app can store the motion-sensor and timer data of a drill as a recording on the iPad. A recording leaves the iPad only when you tap Upload on it (or Upload all); it is then transmitted over an encrypted connection to our own storage (Cloudflare R2 in the European Union), where we use it to verify and improve shot recognition. Uploads are identified by a random identifier of the app installation and the build number, not by your name or Apple ID; a recording may contain the shooter names entered in the app for that drill. A few days after a successful upload the recording is removed from the iPad to free space. Uploaded recordings are deleted from our storage at the latest 18 months after upload.
4. Why we process it, and on what basis
We process contact and feedback data to answer you and to improve the app, which is in our legitimate interest and, where relevant, a step you request before any contract (GDPR Art. 6(1)(b) and (f)). We process technical access data to operate and secure the website (GDPR Art. 6(1)(f)). Under the FADP this processing is justified by these purposes.
5. Who we share it with
Only with service providers who process data on our behalf: Cloudflare, Inc. (website hosting and delivery; storage of uploaded recordings and feedback in its European Union region), Apple Inc. (TestFlight distribution; speech recognition where it is not on-device) and Microsoft 365 (Microsoft Ireland Operations Ltd.; mailbox data stored in Switzerland) (our e-mail). We do not sell personal data and disclose it to authorities only where the law requires.
6. Transfers abroad
These providers are based in, or process data in, the United States; uploaded recordings and feedback are stored by Cloudflare in the European Union (R2 jurisdiction EU), while Cloudflare, Inc. remains a US company. Where data is transferred to a country without an adequate level of data protection we rely on appropriate safeguards — the EU Standard Contractual Clauses with the Swiss addendum and/or the providers' certification under the EU–US and Swiss–US Data Privacy Framework.
7. How long we keep it
Only as long as necessary: e-mail correspondence and feedback for up to 12 months after our last contact or the end of the pilot; technical access logs as stated above; uploaded recordings and feedback for at most 18 months after upload; app data for as long as it is on your device.
8. Your rights
Subject to the FADP and the GDPR you have the right to access your personal data, to have it corrected or deleted, to restrict or object to its processing, to receive it in a portable format and, where processing is based on consent, to withdraw that consent. Requests are free of charge and answered within 30 days: hello@arcproficiency.com.
9. Complaints
You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, if the GDPR applies to you, with the data-protection authority of your country of residence.
10. Data security
We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. No method of transmission over the internet is completely secure.
11. Changes to this policy
We update this policy as the website or the app changes. The current version, with its "last updated" date, is always published at arcproficiency.com/privacy.