This is a translation of the Polish original. In case of any discrepancy between the two versions, the Polish text prevails.

1. What this document covers

This Policy describes the processing of data in two places:
- the Service — the pointmoa.eu website,
- the Application — the pointMoA Android app (package identifier pl.fatpirat.pointmoa), distributed through Google Play.
Sections 3–4 concern the Service only, section 5 the Application only, and the remaining sections both.
This document is also the privacy policy referenced in the Application's Google Play listing.

2. Data controller

The controller of personal data is Eryk Kozłowski, a natural person operating the pointmoa.eu website and publishing the Application, under the designation pointMoA.
Contact for data protection matters: kontakt@pointmoa.eu.
No data protection officer has been appointed — the conditions of Article 37 GDPR do not apply.
Neither the Service nor the Application provides user accounts. There is therefore no account deletion procedure and no separate address for such requests; deletion of Application data is described in §5.7.

3. The pointmoa.eu website

The Service is designed to collect as little data as possible. Using it requires no account and no name, surname or e-mail address.

3.1. Correspondence


Scope	e-mail address and message content
Purpose	replying to the message
Legal basis	Article 6(1)(f) GDPR — legitimate interest in conducting correspondence
Retention	until the matter is concluded, then 14 days at most

Correspondence is kept solely in the Google Workspace mailbox and only for as long as the matter lasts. Once it is concluded the message is deleted — within 14 days at the latest. A deleted message then sits in the mail provider's bin for 30 days, after which the provider erases it on its own. The Controller keeps no correspondence archive of its own and no copy outside the mailbox.

3.2. Server logs


Scope	IP address, date and time of request, page address, browser type
Purpose	operating and securing the Service, diagnosing errors
Legal basis	Article 6(1)(f) GDPR — legitimate interest in maintaining and securing the Service
Retention	at the hosting provider, in accordance with its own terms

Logs are created and kept solely by the hosting provider. The Controller keeps no log archive of its own, does not download them and cannot extend their retention period.

3.3. Data we do not collect

The Service does not carry out profiling or automated decision-making, does not use advertising or tracking tools, does not create user accounts and does not share data for marketing purposes.

4. Cookies in the Service

The Service stores one cookie, of a strictly necessary kind: it remembers the language chosen by the User so that the choice does not have to be repeated on the next visit.
A strictly necessary cookie does not require consent — it is essential to provide a service explicitly requested by the User.
The Service uses no analytics, advertising or third-party cookies. For this reason no consent banner is displayed.
Cookies can be deleted or blocked in browser settings. Blocking the language cookie does not prevent use of the Service.
The Application uses neither cookies nor advertising identifiers.

5. The pointMoA Application

5.1. Principle: the app collects and sends nothing

The Application runs entirely on the device. There are no accounts, no sign-in and no server for anything to be sent to.
The Application does not collect and does not share any data with the Controller or with third parties. It contains no analytics, telemetry, advertising, advertising identifiers, tracking tools or third-party SDKs performing such functions.
Consistently with this, the Data safety form in Google Play is completed as no data collected and no data shared. The store declaration and this Policy must agree — changing one requires changing the other.
The Application holds the INTERNET system permission, required by the web engine it is built on. Every feature — calculations, data storage, photographs and shot detection — works fully offline, and the Application connects to no server operated by the Controller, because no such server exists. In versions that introduce the Pro purchase, the only network request will be a check of the purchase status with the Google Play service (§5.9).

5.2. Data created by the User and kept on the device

The Application stores what the User enters into it. The data sits inside the app's private directory: the User's records in an IndexedDB database, and minor interface settings in the local storage of the web engine. None of it is sent anywhere.


Armoury	firearm, optic and ammunition profiles, individual firearms, ammunition products, ammunition purchases including prices
Shooting log	date, start and end time, range name and locality, training type, shot count, malfunctions, personal notes
Competitions	name, dates, ammunition preparation and consumption, notes
Targets	scores and groups, target photographs, photographs from range visits and competitions
Interface settings	chosen language, units, first-run state, unsaved Calculator form draft
Version counters	applies to versions with the Pro purchase (§5.9): use of Free-version limits and of the trial period, and whether Pro has been purchased
Where it lives	in device memory only, in the app's directory
Who can read it	the User alone. The Controller has no access — no channel exists through which it could be received

Log entries can indirectly reveal where and when the User was present (range name, locality, date and time). The User enters them, they are entirely optional, and the Application works without them.

Because this data never leaves the device and the Controller has no access to it, the Controller determines neither the purposes nor the means of its processing — and is therefore not its controller within the meaning of Article 4(7) GDPR. The User alone controls it.

5.3. Camera and photographs

Target photographs are taken through the system camera or the system photo picker. Android asks for consent and hands the Application only the image the User selected.
The Application declares no camera or gallery permission — it has no access to the device's photo collection and does not browse it.
A photograph taken this way is not saved to the device gallery; it goes only into the app's database.
The Application reads technical EXIF metadata from the file that is needed for measurement: focal length, frame orientation, declared image dimensions, exposure time, ISO sensitivity, camera designation and the capture date. This metadata is used only in memory, at the moment the photograph is attached, for calibration. It is not stored — only the calibration result reaches the database, expressed as fractions of the image dimensions.
The Application reads no geographic coordinates from metadata — it contains no code capable of recognising them.
Before being stored, the image is downscaled to 1600 pixels on its longer edge and re-encoded as JPEG. The re-encoding runs through a canvas, which removes all EXIF metadata, including any geographic coordinates recorded by the camera. What reaches the database is an image stripped of metadata.
The Application does not use device location — it reads neither GPS nor Wi-Fi nor cell towers. Nor does it access contacts, the list of installed apps, the microphone or device identifiers.

5.4. Shot detection

Analysis of a target photograph (shot-hole detection) runs entirely on the device, on a bundled model. The photograph is not sent anywhere for this purpose and is not used to train any model.

5.5. Google backup — the only automatic route off the device

🔴 This is the only mechanism that can move Application data off the device without a separate action by the User, which is why it is set out explicitly.

The Application has Android's system backup enabled (allowBackup). This means Application data — profiles, log, targets and photographs — may be copied into a backup tied to the User's Google account and restored after changing phones.
The backup is performed by Android and Google services, not by the Application. The controller has no access to it. Its retention is governed by Google's privacy policy.
The backup is encrypted, and on devices with a screen lock it is encrypted with a key tied to that lock.
Whether and when a backup is created is decided by the system, which applies its own size and frequency limits. With a large number of photographs the backup may not cover all the data, so it should not be relied upon as a dependable safeguard; the export in §5.6 serves that purpose.
The mechanism can be turned off in system settings (Backup / Google One), either globally or for the Application alone, and an existing backup can be deleted from the Google account.

5.6. Export, file backup and sharing

The Application can export data to a file (JSON, CSV, PDF). Export is started by the User only.
The file goes to the "Documents" directory or to the system share sheet, where the User chooses the destination (cloud drive, e-mail, messenger, cable).
From the moment a destination is chosen, the data is governed by the privacy policy of the service the User selected. The Controller has no influence over this.
The backup file contains all data, photographs included, and is not encrypted. It is worth treating like any document holding personal data.
The Application has no Google Drive integration or any other cloud integration — it signs in to no account.

5.7. How to delete Application data

Individual entries — deleted in the Application, in the module where they were created.
All data at once — System settings → Apps → pointMoA → Storage → Clear data.
Uninstalling the Application removes its directory together with the whole database.
Deleting data from the device does not delete the Google backup — that is removed separately, from the Google account (§5.5(5)) — nor any files the User exported earlier.
The operations in points 1–3 are irreversible: without a prior export the data cannot be recovered.

5.8. Google Play as distributor

The Application is distributed through Google Play. Downloading, installing and updating happen within Google's service, which processes data arising from this as a separate controller, under its own privacy policy.
Google Play services may — independently of the Application and outside its control — collect diagnostic data, including crash reports. In the Play Console the Controller sees only aggregated, statistical summaries that cannot be linked to an individual.
The Application contains no advertising and never will. In-app purchases are described in §5.9.

5.9. Purchasing Pro

⚠️ This section describes a future state. At the time of publication the Application is entirely free and contains no in-app purchases. The rules below take effect only with the version of the Application that introduces a one-off in-app purchase ("Pro"); earlier versions remain free without limitations. The section appears here in advance so that the change of model does not surprise the User.

The seller towards the User is Google. Payment takes place entirely within Google Play, on its terms and under its privacy policy.
The Controller receives no payment data — no card number, no billing address, no identity of the buyer. In the Play Console the Controller sees aggregated sales and settlement reports and the order numbers needed to handle a refund, from which no individual can be identified.
🔴 A purchase is the only Application function that contacts the network. The Application asks Google Play about the purchase state in order to know whether to unlock Pro features. The request goes to Google only and carries no data from the app's database — no log entries, no photographs, no firearm profiles.
Purchase state is tied to the User's Google account on the Store's side, which is how Pro returns after changing phones. That link is made by Google, not by the Application.
Limit and trial counters run on the device only and are never sent anywhere. Clearing the Application's data resets them — the Controller has no way to restore them.
A purchase creates no account in the Application and does not change the principle in §5.1: the Controller still receives no User data.

6. Recipients of data

Hosting provider (Service) — processes data only as necessary to provide hosting.
E-mail provider — handling correspondence sent to the contact address, under a data processing agreement concluded with that provider. Correspondence is stored in Google Workspace.
Google — as distributor of the Application (§5.8), seller of Pro (§5.9) and provider of Android's system backup (§5.5), in each case on its own terms.
The data described in §5.2 has no recipients — it does not leave the device.
Data may be transferred to third countries (outside the European Economic Area) in connection with the use of international providers' infrastructure. Such transfers take place on the basis of mechanisms provided for in Chapter V GDPR, in particular standard contractual clauses or an adequacy decision.

7. Rights of data subjects

In relation to data actually processed by the Controller — that is, the data in sections 3–4 and the order numbers referred to in §5.9(2) — Users have the right to:

access their data and obtain a copy (Article 15 GDPR),
rectify their data (Article 16 GDPR),
erase their data (Article 17 GDPR),
restrict processing (Article 18 GDPR),
data portability (Article 20 GDPR),
object to processing based on legitimate interest (Article 21 GDPR),
lodge a complaint with the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw, Poland.

To exercise these rights: kontakt@pointmoa.eu.

In relation to the data in §5.2, Users exercise these rights directly and themselves: viewing and correcting in the Application, portability through export to a file (§5.6), erasure as described in §5.7. The Controller has no access to this data and therefore cannot perform these actions on the User's behalf.

8. Voluntary nature of providing data

Providing data is entirely voluntary. Not providing an e-mail address only makes it impossible to reply to a message. Data entered into the Application is voluntary in full — the Application works even if the User fills in nothing beyond the calculation fields.

9. Security

The Service is delivered exclusively over an encrypted connection (HTTPS).
Application data is protected by the Android sandbox: the app directory is not accessible to other applications, nor to the device user without elevated privileges. On devices with a screen lock enabled, storage is additionally encrypted by the system.
The Application adds no encryption or password of its own to the database. Whoever has access to an unlocked phone has access to the log. A screen lock is recommended.
In relation to the data the Controller actually holds (sections 3–4), the technical and organisational measures applied are appropriate to the risk within the meaning of Article 32 GDPR, in particular: minimisation — the Service operates no accounts or forms and collects only what is described in §3; restriction of access to a single person; two-factor authentication on administrative accounts (hosting, domain, e-mail, Google Play Console); encryption in transit; a data processing agreement concluded with the e-mail provider; and deletion of data within the periods set out in §3.

10. Children's data

Neither the Service nor the Application is directed at children. Shooting subject matter carries an age restriction in Google Play, and the Application does not take part in the "Designed for Families" programme. The Application collects no data at all (§5.1), and the Controller does not knowingly collect data of persons under 16 years of age through the Service or correspondence either.

11. Changes to this Policy

This Policy may change, in particular in connection with the release of new Modules, the development of the Application, or changes in law. Amended text is published in the Service together with the date of update and the version. Any change to the scope of data processed by the Application is introduced together with an update of the "Data safety" declaration in Google Play.

This Policy was drawn up in Polish. In the event of any discrepancy between language versions, the Polish version prevails.