Privacy Policy

Who We Are

CRL Sports Inc., a Delaware C-Corporation doing business as CTRL Vision, is the data controller responsible for your personal information as described in this Privacy Policy. We design, manufacture, and operate AI-powered camera systems for bowling alleys and snooker halls. Our systems record gameplay footage, process it using artificial intelligence, and deliver highlights and analytics through our platform at ctrl.vision.

Scope of This Policy

This Privacy Policy applies to all personal information collected through or in connection with:

• The CTRL Vision camera systems installed at participating venues (bowling alleys and snooker halls)
• The CTRL Vision mobile and web application
• The CTRL Vision website and platform at ctrl.vision
• Any communications between you and CTRL Vision, including email and support channels

This policy covers information collected from Venue Operators (businesses that purchase and operate our camera systems), End Users (individuals who are recorded by our cameras or use our platform to view footage), and website visitors.

This Privacy Policy should be read alongside our Terms of Service, which govern your use of the Services.

Information We Collect

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information We Do Not Collect

How We Use Your Information

We use the information we collect for the following purposes:

4.1 Providing and Operating the Services

• Processing and uploading footage from the camera system to our cloud infrastructure
• Generating AI-powered highlights and analytics from gameplay footage
• Managing your account and providing access to the platform
• Processing hardware orders and subscription payments
• Providing technical support and customer service

4.2 Improving Our AI and Technology

• Training and improving our machine learning models and algorithms (see Section 5 for details)
• Developing new features and capabilities
• Analyzing system performance and identifying technical issues
• Conducting internal research and development

4.3 Communications

• Sending service-related notifications, updates, and security alerts
• Responding to your inquiries and support requests
• Sending promotional communications (with your consent, where required by law)

4.4 Legal and Safety

• Complying with applicable laws, regulations, and legal processes
• Enforcing our Terms of Service and protecting our rights
• Detecting, preventing, and addressing fraud, abuse, and security issues
• Protecting the safety and rights of our users and the public

AI and Machine Learning

Transparency about how we use artificial intelligence is central to our privacy practices. This section explains what our AI does and does not do with your data.

5.1 What Our AI Analyzes

Our AI systems are designed to analyze game mechanics and outcomes. Specifically, our models are trained on and analyze:

• Ball trajectory and path
• Pin action and outcomes
• Table dynamics (for snooker)
• Gameplay patterns and statistics

The focus of our AI training is on the physics of the game, not on the identification, tracking, or profiling of individuals. End Users may be incidentally visible in footage used for AI training, but the models learn about ball paths and outcomes — not about people.

5.2 What Our AI Does Not Do

5.3 Opting Out of AI Training

You have the right to opt out of having your footage used for AI training purposes. To exercise this right, send an email to tom@ctrl.vision with the subject line "AI Training Opt-Out" and include your account information or sufficient details to identify your footage.

Upon receiving your request, we will:

• Exclude your footage from all future AI training activities
• Use commercially reasonable efforts to exclude your existing footage from current training datasets where technically feasible

Please note that AI models that were trained prior to your opt-out request may have incorporated patterns derived from your footage. Because our training focuses on ball physics and game outcomes rather than individuals, and because machine learning models do not store identifiable footage, complete retroactive removal from trained model weights is not technically feasible. Your opt-out will be honored prospectively and for existing datasets to the greatest extent possible.

How We Share Information

We do not sell your personal information. We share information only in the following circumstances:

6.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Our service providers are contractually obligated to use your information only for the purposes of providing their services to us and in accordance with this Privacy Policy.

6.2 Venue Operators

If you are an End User, your footage, highlights, and analytics are accessible to the Venue Operator at the location where the footage was captured. The Venue Operator's use of your information is governed by their own privacy practices, and we encourage you to review any privacy notices provided by the Venue.

6.3 Legal Requirements

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

6.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, reorganization, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

6.5 Aggregated and De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for any purpose, including research, analytics, and marketing.

Data Storage and Processing

7.1 Where Your Data Is Processed

Footage captured by the CTRL Vision camera system is stored locally on the camera device during gameplay and uploaded to Google Cloud Platform (GCP) infrastructure upon session completion. GCP data centers are located in various countries worldwide. While CTRL Vision primarily serves customers in the United States, your data may be processed in any jurisdiction where GCP operates.

7.2 Local Storage on Camera

During a game session, footage is captured and stored locally on the camera system's onboard storage. The footage remains on the device until it is successfully uploaded to our cloud infrastructure after the session ends. Local storage is temporary, and footage is deleted from the device after successful upload.

7.3 Security During Transfer

All footage uploads from the camera system to our cloud infrastructure are encrypted in transit. We use industry-standard encryption protocols to protect your data during transmission.

Data Retention

8.1 Footage and Highlights

End User footage and highlights are stored on the platform and remain accessible indefinitely, subject to:

• The End User's right to request deletion (see Section 10)
• The Venue Operator maintaining an active subscription (footage remains accessible for 90 days following subscription cancellation)
• CTRL Vision's right to remove content that violates our Terms of Service

8.2 Account Information

We retain account information for as long as your account is active and for a reasonable period thereafter to fulfill legal obligations, resolve disputes, and enforce our agreements. If you request account deletion, we will delete or anonymize your personal information within 30 days, except where retention is required by law.

8.3 Technical and Usage Data

Technical diagnostics and usage analytics are retained for up to 24 months from collection, after which they are aggregated or deleted.

8.4 Payment Records

Payment transaction records are retained for the period required by applicable tax and financial regulations, typically seven (7) years.

Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption of data in transit and at rest
• Access controls and authentication requirements for systems containing personal information
• Regular security assessments and monitoring
• Employee training on data protection practices
• Incident response procedures for potential data breaches

No method of data transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. If we become aware of a security breach that affects your personal information, we will notify you and applicable regulatory authorities in accordance with applicable law.

Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

10.1 Access and Portability

You have the right to request access to the personal information we hold about you and to receive it in a structured, commonly used, machine-readable format.

10.2 Correction

You have the right to request that we correct inaccurate or incomplete personal information.

10.3 Deletion

You have the right to request deletion of your personal information, including your footage and highlights. We will honor valid deletion requests within 30 calendar days. Upon deletion, your footage, highlights, and associated analytics will be permanently removed from the platform.

10.4 Blurring

As an alternative to deletion, you may request that your likeness be blurred in existing footage and highlights. We will process blurring requests within 30 calendar days.

10.5 Opt-Out of AI Training

You may opt out of having your footage used for AI model training by emailing tom@ctrl.vision. See Section 5.3 for details.

10.6 Withdraw Consent

Where we process your information based on consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

10.7 How to Exercise Your Rights

To exercise any of the rights described above, contact us at tom@ctrl.vision. We will verify your identity before processing your request. We will respond to all verified requests within the timeframes required by applicable law, and in no event later than 45 days from receipt of a verified request.

Children's Privacy

CTRL Vision takes the privacy of children seriously. Our Services are not directed at children under the age of 13.

11.1 COPPA Compliance

We do not knowingly collect personal information from children under 13 without verifiable parental consent. Our application includes an age verification step and a guardian consent workflow that requires a parent or legal guardian to provide affirmative consent before a minor under 18 can be recorded by the camera system.

11.2 Venue Operator Responsibilities

Venue Operators are contractually required to ensure that minors do not use the CTRL Vision system without appropriate parental or guardian consent. Signage at equipped lanes and tables includes notice that parental consent is required for individuals under 18.

11.3 Parental Rights

Parents and guardians may review, request deletion of, or withdraw consent for the collection of their child's personal information at any time by contacting us at tom@ctrl.vision. We will process such requests within 30 days.

11.4 Discovery of Unauthorized Collection

If we learn that we have collected personal information from a child under 13 without verified parental consent, we will take prompt steps to delete that information.

State-Specific Privacy Disclosures

12.1 California Residents (CCPA / CPRA)

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

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise your California privacy rights, contact us at tom@ctrl.vision. We will respond to verified requests within 45 days.

12.2 Virginia Residents (VCDPA)

Virginia residents have rights to access, correct, delete, and obtain a copy of their personal data, as well as the right to opt out of targeted advertising, the sale of personal data, and profiling. To exercise these rights, contact us at tom@ctrl.vision.

12.3 Colorado, Connecticut, Utah, and Other States

Residents of states with comprehensive privacy laws, including Colorado, Connecticut, Utah, and others that may enact such legislation, may have similar rights to those described above. We are committed to complying with all applicable state privacy laws. Contact us at tom@ctrl.vision to exercise any rights available to you under your state's law.

12.4 Illinois (BIPA)

Cookies and Tracking Technologies

13.1 What We Use

Our website at ctrl.vision uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze traffic, and improve your experience. The types of cookies we use include:

• Essential Cookies: Required for the platform to function, including authentication and security.
• Analytics Cookies: Help us understand how visitors interact with our website, allowing us to improve our services.
• Functional Cookies: Remember your preferences and settings to provide a more personalized experience.

13.2 Your Cookie Choices

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that disabling essential cookies may affect the functionality of the platform.

13.3 Do Not Track

Our website does not currently respond to "Do Not Track" browser signals, as there is no industry-standard protocol for this feature. We will update this policy if a standard is established.

Third-Party Links and Services

Our platform may contain links to third-party websites, applications, or services that are not operated by CTRL Vision. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you access through our platform. We are not responsible for the privacy practices of third parties.

International Data Transfers

CTRL Vision is based in the United States and primarily serves customers in the United States. Footage and personal information may be transferred to and processed in any country where Google Cloud Platform maintains infrastructure. By using our Services, you consent to the transfer of your information to the United States and other jurisdictions, which may have different data protection laws than your country of residence.

We take appropriate safeguards to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated Privacy Policy on this page with a revised "Last Updated" date
• Notify registered users via email where practicable
• Provide prominent notice on our platform for significant changes

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after any changes indicates your acceptance of the updated policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: