PoolShot Privacy Policy

PoolShot Privacy Policy

Effective Date: December 12, 2025

Welcome to PoolShot (hereinafter referred to as "the App"), developed by EMERALD VALLEY ENTERPRISES INC (hereinafter referred to as "we", "us", or "our"). This App is only available to users who are 18 years of age or older. You must confirm that you are at least 18 years old before using the App. We take your privacy seriously, and this Privacy Policy is designed to clearly inform you about how we collect, use, store, share, and protect your personal information when you use the App, as well as the rights you have with respect to your personal information—including, in particular, your rights under the Virginia Consumer Data Protection Act (VCDPA). Please read and understand the entire content of this Privacy Policy before using the App. If you do not agree to this Policy, please do not use the App; your use of the App constitutes your full understanding and acceptance of all terms of this Policy, as well as your confirmation that you are at least 18 years old.

1. Scope of Application

This Privacy Policy applies to all services provided by the App that you use in any manner, including but not limited to video upload and viewing, community interaction, private messaging, and topic discussions. Please note that the App may contain links to or services from third parties (such as third-party payment processors or third-party video playback components). Third-party privacy policies are not governed by this Policy, and we recommend that you carefully read the privacy policies of such third parties.

2. Information We Collect

To provide you with high-quality services and ensure service security, we collect relevant information about you in accordance with the principles of "legality, legitimacy, and necessity". The specific categories of information are as follows:

2.1 Information You Voluntarily Provide

￮ Content Creation and Interaction Information: When you upload videos, post text updates, add images, comment on content, or participate in topic discussions, we collect the content you upload (including video files, text, images, audio, etc.), posting time, and interaction data (such as the number of likes, comment content, reply records, etc.). If the content you post contains information about others, you must ensure that you have obtained the legal authorization of such individuals.

￮ Communication and Contact Information: When you communicate with other users via private messages or contact us through customer service channels, we collect your communication content and contact information (such as the email address or phone number you provide) to handle your inquiries, complaints, or requests.

￮ Other Voluntarily Provided Information: For example, when you participate in online or offline tournaments organized by us or fill out questionnaires, you may need to provide your name, contact information, and address (if tournament prizes need to be mailed).

￮ Permission-Related Information: To enable functions such as video shooting and uploading, image selection, audio recording, and content storage, we collect necessary information corresponding to the relevant permissions after obtaining your explicit authorization. The specific details are as follows:

Camera Permission: Only used for you to directly shoot billiards-related videos or images and upload them to the platform. It will not be used to shoot irrelevant content or run in the background.

Photo Permission: Only used for you to take photos of billiards scenes (such as shot layouts, game results) directly through the App and upload them, or access photos stored in your device's photo library that are related to billiards for uploading. We will not access or collect photos unrelated to billiards, nor will we run the permission in the background.

External Storage Permission (Album/File Storage): Used for you to select existing billiards videos or images from your device for uploading, and to store necessary temporary files generated during the operation of the App (such as video editing caches). We will not access or read files unrelated to the App.

Microphone Permission: Used for you to record audio synchronously when shooting videos or to record audio content such as billiards technique explanations independently. It will not be used to monitor your voice in the background. If you refuse to provide the above permissions, only the corresponding functions will be affected, and other core functions will remain usable normally.

2.2 Information Automatically Collected When You Use the Services

￮ Device and Identifier Information: To ensure the stable operation of the App, service security, and function implementation, we automatically collect the following device-related information: 1. Basic Device Information: Including device model, operating system version, network type, IP address, browser type, etc.; 2. Unique Device ID: Such as Android ID, OAID, etc. We only use these identifiers for device recognition, abnormal login detection, and service adaptation. We will encrypt them to avoid direct identification of individuals and will not associate them with other personal information; 3. Advertising IDs: If you have not disabled the advertising IDs function in your device settings, we will collect this identifier to push personalized advertisements related to billiards. You can reset or delete the advertising IDs through the "Settings > Privacy > Ads" path on your device. After disabling it, we will no longer push personalized advertisements based on this identifier, but may still display non-personalized advertisements; 4. App Log Information: Including functions used, operation records, error logs, access duration, etc., which are only used for troubleshooting and service optimization.

￮ Content Usage Information: To implement personalized recommendations and optimize the service experience, we collect data about your content usage behaviors, including the types of videos you watch, viewing duration, liked, saved, commented on, and shared video records, as well as search history.

￮ Location Information (Optional): If you use functions such as "Nearby Players", "Offline Matchmaking", or "Local Tournament Registration" in the App, we will collect your approximate location information (such as regional information based on IP address) or precise location information (such as obtained through device GPS) after obtaining your explicit authorization. If you refuse to provide location information, only the above-mentioned related functions will be affected, and other core functions will remain usable normally.

2.3 Information Provided by Third Parties and VCDPA Compliance Statement

The App does not support third-party login. If you use third-party payment services, participate in third-party cooperative activities, or obtain information about the App through third-party advertising services, we will obtain relevant information about you from third parties in accordance with cooperative agreements and your authorization (such as payment order information, event registration information). The specific scope of information is subject to what is provided by the third party, and we will conduct compliance checks on the information provided by third parties. For users in Virginia, in accordance with the Virginia Consumer Data Protection Act (VCDPA), we confirm that you, as a consumer, have the rights to access, correct, delete, and port data, as well as the right to object to automated decision-making. The methods for exercising these rights are detailed in the "6. Your Rights" section of this Policy, and we will provide rights response services that comply with VCDPA requirements for users in Virginia.

3. Purposes of Information Use

The information we collect will only be used for the following legitimate purposes. If it is necessary to use the information for other purposes, we will obtain your explicit authorization separately:

￮ To provide you with core services, including video upload and playback (supported by camera, album, and microphone permissions), community interaction (comments, private messages, topic discussions, etc.), personalized content recommendations (based on your viewing history, interests, preferences, etc.), and tournament information pushes;

￮ To optimize products and services, analyze user behavior patterns based on collected usage data, improve App function design, enhance video playback fluency, and optimize the accuracy of recommendation algorithms;

￮ To ensure service security and protect user rights, identify and prevent fraudulent and non-compliant behaviors, handle user complaints and disputes, and protect the legitimate rights and interests of users;

￮ To push relevant service information to you, such as tournament event notifications and function update reminders; if you do not wish to receive such pushes, you can disable them through the App settings;

￮ To conduct market research and data analysis. After anonymization and de-identification, the information will be used to analyze user needs, optimize operation strategies, or shared with partners as anonymized data (which cannot identify individuals);

￮ To comply with laws, regulations, and regulatory requirements, or to use relevant information to perform legal duties and protect public interests.

4. Information Sharing and Disclosure

We strictly protect your personal information and adhere to the principle of "minimum necessity" for data sharing. We will not arbitrarily share or disclose your personal information to third parties unless it falls under the following circumstances, and all sharing activities will comply with the VCDPA and other relevant laws and regulations:

￮ Obtaining Your Explicit Authorization: With your explicit consent, we will share information with third parties designated by you, such as when you authorize us to provide your registration information to a tournament organizer.

￮ Necessary for Service Provision: We will share necessary information with third-party service providers that support the provision of the App's services. Specifically: 1. Video storage service providers: Only share the video files you upload for storage and playback; 2. Payment service providers: Only share your payment amount, order number, and other payment-related information to complete transactions; 3. Advertising service providers: Only share your advertising ID and anonymized content preference data to push personalized advertisements (which you can disable at any time); 4. Data analysis service providers: Only share anonymized and de-identified user behavior data for service optimization. We will sign strict confidentiality agreements and data processing agreements with all third-party service providers, clarify the scope of their information use and confidentiality obligations, require them to take security protection measures equivalent to ours, and conduct regular compliance checks on them.

￮ Compliance with Laws, Regulations, and Regulatory Requirements: When we receive legitimate requests from judicial authorities, regulatory agencies, and other competent authorities (such as subpoenas, investigation orders), we will legally provide necessary information to perform legal duties, protect public interests, or safeguard the legitimate rights and interests of others.

￮ Protection of Our Legitimate Rights and Interests: We may share necessary information within a reasonable scope to respond to public health emergencies, prevent fraudulent behaviors, handle violations of the App's User Agreement, or protect the property and personal safety of us and our users.

￮ Corporate Mergers, Acquisitions, or Asset Transfers: In the event of corporate mergers, acquisitions, asset transfers, bankruptcy liquidation, and other situations, your personal information may be transferred as part of the assets. We will notify you in advance and ensure that the transferee continues to fulfill the privacy protection obligations stipulated in this Privacy Policy.

￮ Sharing of Anonymized or De-Identified Information: We may share information that has been anonymized or de-identified (and can no longer identify individuals) with partners for purposes such as market analysis and academic research. Such sharing does not require additional authorization from you.

5. Information Storage and Protection

5.1 Information Storage

￮ Storage Location: Your personal information will be stored on our servers or the servers of third-party service providers entrusted by us. The servers may be located within or outside of China. If the information is stored outside of China, we will ensure compliance with relevant laws and regulations on cross-border data transmission to protect information security.

￮ Storage Period: We will store your personal information in accordance with the principles of "minimum necessity" and "the shortest period necessary to achieve the purpose". During your use of the App, we will continuously store your information to provide services; after you cancel your account, we will delete your personal information within a reasonable period or anonymize/de-identify it, unless otherwise specified by laws and regulations (such as retention for compliance audits, dispute resolution, etc.).

5.2 Information Protection

We have adopted a series of technical and management measures to protect the security of your personal information:

￮ Technical Measures: Encryption technologies (such as SSL encrypted transmission) are used to protect the security of information during transmission; sensitive information (such as passwords) is stored in encrypted form; firewalls, intrusion detection systems, etc., are deployed to prevent cyber attacks; regular security inspections and vulnerability repairs are conducted on the system.

￮ Management Measures: A strict information access permission control system is established, and only authorized personnel are allowed to access personal information; privacy protection training is provided to employees to clarify confidentiality obligations; a data security incident emergency response plan is formulated to promptly respond to potential information security risks.

Please note that there are certain uncertainties in Internet services. Although we have taken sufficient protection measures, we cannot completely avoid the risk of information leakage caused by factors beyond our control, such as force majeure, cyber attacks, and malicious acts by third parties. In the event of an information security incident, we will notify you in a timely manner in accordance with legal requirements and take remedial measures.

6. Your Rights

In accordance with relevant laws and regulations such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Virginia Consumer Data Protection Act (VCDPA), you have full control over your personal information. We have established a sound rights response mechanism to provide you with convenient channels to exercise your rights. The following are your core rights and specific methods of exercising them:

￮ Right to Know: You have the right to fully understand the types, specific content, collection sources, purposes of use, sharing recipients, and data storage periods of the personal information we collect. You can exercise this right in the following ways: 1. Directly review this Privacy Policy to obtain basic information; 2. Contact customer service or the Data Protection Officer (DPO) to submit a detailed inquiry. We will inform you of the inquiry results in writing (including electronic form) within 10 working days, including the specific processing scenarios and basis of the information.

￮ Right to Access and Inquiry: You have the right to obtain a copy of the personal information about you that we have collected and processed. Specific methods of exercise: 1. Access to Basic Information: Directly view the videos, updates, comments, and interaction records you posted through functions such as "Personal Homepage - My Content" and "Settings - Personal Information" in the App; 2. Inquiry of Full Information: Contact customer service or the DPO to submit an application. After verifying your identity (the verification method will be notified to you through the contact information you provided), we will provide a copy of your full personal information (including device information, behavior data, etc.) in a structured, machine-readable format (such as CSV, JSON) within 15 working days. Additional Rights for Specific Regions: Users in California may apply for full information inquiry twice a year for free in accordance with the CCPA; reasonable cost fees may be charged for additional inquiries. Users in Virginia may apply for free at any time in accordance with the VCDPA, and we will give priority to processing such applications.

￮ Right to Correct and Supplement: If you find that your personal information is incorrect (such as wrong tournament registration information) or incomplete (such as missing personal profile), you have the right to request correction or supplementation. Methods of exercise: 1. Independent Correction: Directly modify the information that can be edited independently through functions such as "Personal Homepage - Edit Profile" and "My Updates - Edit"; 2. Assisted Correction: For information that cannot be modified independently (such as incorrect association of system-recorded device information), you can contact customer service or the DPO and provide relevant supporting materials. We will complete the correction and notify you of the result within 7 working days after verification. Additional Rights for Specific Regions: Users in the European Union may request us to conduct retrospective correction of incorrect information in accordance with the GDPR, i.e., notify third parties who have received the information to make synchronous corrections (such as incorrect information provided to tournament organizers).

￮ Right to Erasure (Right to Be Forgotten): You have the right to request us to delete your personal information. We will initiate the deletion process after verifying your identity. Methods of exercise: 1. Independent Deletion: Directly delete the content and interaction records you posted through functions such as "My Content - Delete" and "Comment Management - Delete"; 2. Application for Full Deletion: Contact customer service or the DPO to submit a deletion application. We will complete the full information deletion (including server and backup data) within 15 working days and issue a deletion completion certificate to you. Exceptions: In accordance with legal requirements, we may refuse to delete in the following circumstances: (1) Necessary for fulfilling contractual obligations (such as information related to unpaid tournament prize settlements); (2) Necessary for diagnosing security incidents and repairing system vulnerabilities; (3) Necessary for protecting freedom of speech or the legitimate rights and interests of others; (4) Necessary for conducting academic research for public interests where personal information cannot be separated; (5) Compliance with other legal obligations. Additional Rights for Specific Regions: Users in California may request us to notify third-party service providers to synchronously delete your information in accordance with the CCPA; users in the European Union may request us to explain the specific legal basis for refusing deletion in accordance with the GDPR.

￮ Right to Data Portability: You have the right to transfer your personal information from our system to other service providers. Method of exercise: Contact customer service or the DPO to submit an application and specify the information of the target service provider. After verifying your identity, we will provide your personal information to the target party in a common format through API interface or encrypted file transmission within 15 working days to ensure that the information can be directly read by the other party's system. Additional Rights for Specific Regions: Users in the European Union may request us to directly connect with other data controllers for data transfer in accordance with the GDPR; users in Virginia may request us to provide this service for free without unreasonable fees in accordance with the VCDPA.

￮ Right to Withdraw Consent and Right to Object to Automated Decision-Making: You may withdraw your consent to various permissions and information processing activities at any time, and this will not affect the legality of processing activities conducted before the withdrawal. Specific methods of exercise: 1. Withdrawal of Permissions: Disable permissions such as camera, microphone, external storage, and location through the "Settings > Apps > PoolShot > Permissions" path on your device; 2. Objection to Automated Decision-Making: Disable personalized content recommendations through "Settings > Privacy > Personalized Recommendations" in the App, or disable the advertising ID through "Settings > Privacy > Ads" on your device to object to personalized advertisements.Additional Rights for Specific Regions: Users in the European Union may request manual review if automated decisions such as personalized recommendations have a significant impact on you (such as account permission restrictions) in accordance with the GDPR. We will arrange for a dedicated person to conduct the review and feedback the result within 10 working days.

￮ Right to Opt-Out of the Sale of Personal Information: You have the right to request us not to sell your personal information. We promise not to actively sell your personal information. If business adjustments involve information sales in the future, we will set up a "Do Not Sell My Personal Information" option in a prominent position in the App in advance, and you can enable this option at any time to opt out of sales. Additional Rights for Specific Regions: Users in California may exercise the opt-out right at any time through this option in accordance with the CCPA. We will immediately stop the relevant sales activities, record your choice, and will not discriminate against you (such as increasing service prices or reducing service quality) for exercising this right.

￮ Right to Opt-Out of Marketing Communications: You have the right to refuse to receive our marketing information. Methods of exercise: 1. In-App Settings: Disable pushes through "Settings > Notification Management > Marketing Notifications"; 2. Unsubscribe Link: Click the "Unsubscribe" link in marketing emails or text messages to complete the operation; 3. Contact Customer Service: Inform customer service that you refuse to receive specific types of marketing information (such as tournament promotions, equipment advertisements). We will activate your settings within 24 hours and will no longer send you the marketing content you have refused.

￮ Right to Complain and Appeal: If you believe that our information processing activities infringe on your privacy rights, you may file a complaint through the following channels: 1. Contact customer service or the DPO first. We will provide a handling plan within 15 working days; 2. File a complaint with a regulatory authority. Additional Rights for Specific Regions: Users in the European Union may file a complaint with the data protection authority of their member state (such as the German Federal Commissioner for Data Protection and Freedom of Information); users in California may submit an appeal to the California Attorney General's Office; users in Virginia may file a complaint with the Virginia Office of Consumer Protection. We will actively cooperate with regulatory authorities in their investigation and handling work.

￮ Right to Initiate Individual Litigation: Additional Rights for Specific Regions: Users in California may initiate civil litigation in accordance with the CCPA if your personal information is subject to unauthorized access, disclosure, or theft due to our failure to take reasonable security measures, and you may claim statutory damages of $100 to $750 per security incident; users in the European Union may initiate a damages claim lawsuit in court if our illegal acts cause harm to you in accordance with the GDPR.

7. Protection of Minors' Privacy

Since this App is exclusively for adult users aged 18 and above, we explicitly do not provide services to any minors under the age of 18 and will not actively collect any personal information of minors. If we discover through age verification or other means that a user is a minor, we will immediately stop providing services to them and delete any collected relevant information (if any). If a guardian discovers that a minor has used the App without authorization, they may contact our customer service or Data Protection Officer for handling, and we will cooperate in verifying the situation and deleting the information.

8. Updates to the Privacy Policy

We will update this Privacy Policy in a timely manner in accordance with updates to laws and regulations, adjustments to product functions, or operational needs. The updated Privacy Policy will be notified to you through pop-ups, announcements, and other means in the App. If you continue to use the App after the Policy is updated, it constitutes your acceptance of the updated Policy content. We recommend that you review this Privacy Policy regularly to stay informed of the latest privacy protection instructions. Previous versions of the Privacy Policy can be obtained by contacting customer service.

9. Data Protection Officer (DPO) Responsibilities and Contact Information

To ensure the compliance of personal information processing activities and protect users' privacy rights, we have officially designated a Data Protection Officer (DPO) who is fully responsible for the supervision, coordination, and implementation of privacy protection work. The following are the core responsibilities and working mechanisms of the DPO:

9.1 Core Responsibilities of the Data Protection Officer (DPO)

￮ Compliance Supervision: Supervise the entire process of personal information collection, use, sharing, storage, and other activities of the App to ensure compliance with the GDPR, CCPA, VCDPA, and other relevant laws and regulations. Conduct internal privacy compliance audits regularly (at least once a quarter) and submit compliance reports to the company's management.

￮ Rights Response: Coordinate the handling of users' personal information rights requests (such as access, deletion, and correction applications), coordinate technical, operational, and other departments to give priority to processing, ensure responses are completed within statutory time limits, and record the processing process. Provide special support for rights requests from users in specific regions such as the European Union, California, and Virginia.

￮ Risk Management: Identify and assess privacy risks in information processing activities (such as data sharing risks, system security risks), formulate risk prevention measures and emergency response plans, and conduct Data Protection Impact Assessments (DPIA) in advance for high-risk activities (such as cross-border data transmission).

￮ Communication and Coordination: Serve as the primary contact with regulatory authorities and cooperate with data protection authorities in investigations and inspections; at the same time, act as an exclusive channel for user privacy inquiries, answer users' questions about the Privacy Policy and information processing, and establish a trusted communication mechanism with users.

￮ Training and Advocacy: Organize regular privacy protection training for company employees (mandatory for new employees upon onboarding, and refresher training for existing employees every six months) to improve employees' awareness of privacy protection and compliance operation capabilities, and ensure that front-line employees master the user rights response process and risk prevention points.

￮ Policy Optimization: Track updates to global privacy laws and regulations (such as CCPA revisions, new state privacy laws), and in conjunction with adjustments to the App's business, take the lead in revising the Privacy Policy and internal data processing specifications in a timely manner to ensure the accuracy and timeliness of the Policy content.

10. Contact Information

If you need to exercise your personal information rights, consult about privacy-related issues, file a privacy complaint, or communicate with the DPO, you can contact us through the following methods:

￮ Data Protection Officer (DPO) Exclusive Contact Information: Email: partheniaterbush3@gmail.com

￮ Company Address: 636 Hathburn Dr, Rockwood, TN 37854, Roane County, USA

(Written requests for rights or complaint materials can be mailed to the above address. We will confirm receipt within 15 working days after receiving them.)

To facilitate the efficient handling of your request, we recommend that you provide the following information when contacting us: 1. Your name and usual contact information; 2. The specific type of request (such as "Access Personal Information" or "Delete Full Data"); 3. Relevant supporting materials (if required, the specific list will be notified to you after you submit the request). We will strictly keep your identity information and request content confidential and only use them for handling your matter.