Privacy Policy

At Torny, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your data when you use the Torny iOS application for lawn bowls training and analytics.

By downloading, installing, or using the Torny app, you consent to the practices described in this Privacy Policy. If you do not agree with any part of this policy, please do not use the Torny app.

1. Information We Collect

1.1. Personal Information

• Account Information: Name, email address, password, and profile details when you register
• Profile Data: Skill level, experience, training goals, club affiliations, and avatar customization
• Contact Details: Information you provide for communication purposes

1.2. Training and Performance Data

• Training Sessions: Shot types, accuracy metrics, distance measurements, session duration and intensity
• Performance Analytics: Success rates, improvement trends, personal records, and comparative statistics
• Session Notes: Any notes or observations you add to training sessions

1.3. Device and Usage Information

• Device Data: iOS version, device model, unique device identifiers, and app version
• Usage Analytics: App interactions, feature usage, session frequency, and navigation patterns
• Performance Data: App crashes, loading times, and technical performance metrics

1.4. Location Information (Optional)

• Approximate Location: General location data (if you choose to enable location services) to enhance club discovery and regional comparisons
• We do not collect precise GPS coordinates or track your real-time location

2. How We Use Your Information

2.1. Core App Functionality

• Provide training session recording and performance analytics
• Generate personalized insights and progress reports
• Maintain your training history and achievements
• Enable profile customization and club affiliations

2.2. App Improvement

• Analyse usage patterns to improve app performance and user experience
• Identify and fix technical issues or bugs
• Develop new features based on user behavior and feedback

2.3. Communication

• Send important app updates, feature announcements, and service notifications
• Respond to your support requests and feedback
• Share relevant training tips or content (if you opt-in)

2.4. Legal and Safety

• Comply with applicable laws and regulations
• Protect against fraud, abuse, or security threats
• Enforce our Terms & Conditions

3. Data Sharing and Disclosure

3.1. No Sale of Personal Data

We do not sell, rent, or lease your personal information to third parties for commercial purposes.

3.2. Service Providers

We may share information with trusted third-party service providers who assist us in:

• Cloud data storage and backup services
• Analytics and app performance monitoring
• Customer support and communication tools All service providers are bound by strict confidentiality agreements.

3.3. Apple Integration

As an iOS app, certain data may be processed through Apple’s systems:

• App Store Connect for app distribution and updates
• iOS system features you choose to enable
• Apple’s analytics services (if you haven’t opted out in iOS settings)

3.4. Legal Requirements

We may disclose information when required by law, legal process, or to:

• Protect our rights and property
• Ensure user safety and security
• Comply with government requests or court orders

3.5. Aggregated Data

We may share aggregated, anonymized data that cannot identify individual users for:

• Industry research and analytics
• App performance benchmarking
• General lawn bowls training insights

4. Data Security and Storage

4.1. Security Measures

• Industry-standard encryption for data transmission and storage
• Secure authentication and access controls
• Regular security audits and vulnerability assessments
• Prompt security updates and patches

4.2. Data Storage

• Your data is stored securely on cloud servers located in jurisdictions with strong privacy laws
• We implement backup and disaster recovery procedures to protect against data loss
• Data retention follows industry best practices and legal requirements

4.3. Data Breach Response

In the unlikely event of a security breach affecting your personal information, we will:

• Promptly investigate and contain the incident
• Notify affected users and relevant authorities as required by law
• Take immediate steps to prevent future occurrences

5. Your Privacy Rights and Choices

5.1. Data Access and Control

• View Your Data: Access your personal information and training data through the app
• Update Information: Modify your profile, preferences, and account details
• Data Export: Request a copy of your training data in a portable format
• Data Deletion: Request deletion of your account and associated data

5.2. iOS Privacy Controls

You can control data collection through iOS settings:

• App Permissions: Manage location, notification, and other app permissions
• Analytics: Opt-out of sharing analytics with Apple and app developers
• Advertising: Limit ad tracking and reset advertising identifiers

5.3. Communication Preferences

• Opt-out of promotional emails and notifications
• Choose which types of app notifications to receive
• Update your communication preferences in app settings

6. Children’s Privacy (COPPA Compliance)

6.1. Age Requirements

• Torny is suitable for users 13 years and older
• Users under 18 should have parental consent to use the app
• We do not knowingly collect personal information from children under 13

6.2. Parental Controls

Parents can:

• Review their child’s account and data
• Request deletion of their child’s information
• Disable certain features or data collection

6.3. If We Learn of Underage Use

If we discover that a child under 13 has provided personal information without parental consent, we will:

• Delete the information immediately
• Terminate the account
• Notify the parents if reasonably possible

7. International Data Transfers

7.1. Cross-Border Processing

Your information may be processed in countries other than New Zealand, including:

• Countries where our cloud service providers operate
• Jurisdictions with adequate privacy protections
• Locations necessary for app functionality and support

7.2. Data Protection Safeguards

For international transfers, we ensure:

• Adequate data protection standards in destination countries
• Appropriate safeguards like Standard Contractual Clauses
• Compliance with applicable privacy laws and regulations

8. Data Retention

8.1. Retention Periods

• Account Data: Retained while your account is active and for a reasonable period after deletion
• Training Data: Kept to provide ongoing analytics and progress tracking
• Usage Analytics: Typically retained for 12-24 months for app improvement purposes
• Legal Requirements: Some data may be retained longer to comply with legal obligations

8.2. Data Deletion

When you delete your account:

• Personal information is deleted within 30 days
• Training data is permanently removed from our systems
• Some anonymized analytics may be retained for app improvement

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to Know: Request information about personal data collection and use
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of any sale of personal information (note: we don’t sell personal data)
• Non-Discrimination: We won’t discriminate against you for exercising your privacy rights

10. European Privacy Rights (GDPR)

If you are in the European Union, you have rights under the General Data Protection Regulation:

• Legal Basis: We process your data based on legitimate interests, contract performance, or consent
• Access and Portability: Request access to and transfer of your personal data
• Rectification: Correct inaccurate or incomplete information
• Erasure: Request deletion of your personal data
• Objection: Object to certain types of data processing

11. Changes to This Privacy Policy

11.1. Policy Updates

We may update this Privacy Policy to reflect:

• Changes in app features or functionality
• New legal requirements or regulatory guidance
• Improvements to our privacy practices

11.2. Notification of Changes

When we make material changes:

• Updated policy will be posted in the app and on our website
• We’ll notify you via email or in-app notification
• Continued use of the app constitutes acceptance of changes

11.3. Version History

You can review previous versions of this policy by contacting us.

12. Third-Party Services and Links

12.1. Third-Party Integrations

The app may integrate with third-party services:

• Cloud storage providers for data backup
• Analytics platforms for app improvement
• Social media platforms (if you choose to share content)

12.2. Third-Party Privacy Policies

These services have their own privacy policies:

• We encourage you to review their practices
• We are not responsible for third-party privacy practices
• Your interactions with third parties are governed by their terms

13. Contact Us

13.1. Privacy Questions

If you have questions about this Privacy Policy or our privacy practices:

• Email us through the app’s contact feature
• Reach out via our support channels
• Contact our privacy officer for specific privacy concerns

13.2. Data Subject Requests

To exercise your privacy rights:

• Use the data export/deletion features in the app
• Contact us directly for complex requests
• We’ll respond within the timeframes required by applicable law

13.3. Complaints

If you have concerns about our privacy practices:

• Contact us first to resolve the issue
• You may also file complaints with relevant privacy authorities
• For EU residents, contact your local Data Protection Authority

14. Effective Date and Governing Law

This Privacy Policy is governed by New Zealand law and is effective as of September 24, 2025.

By using Torny, you acknowledge that you have read and understood this Privacy Policy. We’re committed to protecting your privacy while helping you improve your lawn bowls game through data-driven training insights.

Last updated: September 24, 2025