1 · WHY THIS POLICY EXISTS
Most of what the Service holds has nothing to do with health. One thing can: an incident record written by a dealer's staff after something happened at a range may describe an injury.
Washington and Nevada regulate information of that kind separately and more strictly than general privacy law. Washington's My Health My Data Act (RCW 19.373) reaches any information that identifies a person's past, present, or future physical or mental health status, and it gives individuals rights that other state laws do not. This policy says what we do about that.
2 · WASHINGTON — WE DO NOT COLLECT IT THERE
Incident records are not available in any tenant that has a location in Washington — in every location of that tenant, not only the Washington one, because a business with a Washington location is regulated for all of its records, wherever they were made. The feature is switched off, and there is no configuration that turns it on.
Why we made that choice rather than complying around it. The My Health My Data Act gives a person the right to have health-related data deleted, and — unlike every comparable state law — it provides no exception for retaining information to establish or defend a legal claim. Deletion must reach archived and backup systems, within six months at the outside.
The whole point of an evidentiary record is that it cannot be deleted. We built storage where the application's key can add a record but cannot erase one, and we told every dealer that this is permanent for ten years. We are not going to weaken that to open one state, and we are not going to promise a Washington resident a deletion we cannot perform. So the feature does not exist there.
Everything else in the Service works normally in Washington: loyalty, booking, messaging, training, check-in, and signed waivers. Incident records are the only place in the Service with a free-text field in which an injury could be described. A waiver records a signature, not an account of events; there is no notes field on a booking, a check-in, or a training record. Turning off incident records therefore turns off the only field that could hold health-related information.
If this changes, it will be because the law changed or because we found a design that honors both obligations. This policy will say so before the feature appears in a Washington tenant.
3 · OUTSIDE WASHINGTON — WHAT WE COLLECT
Outside Washington, where a dealer enables incident records, the following may be collected on that dealer's behalf and may qualify as consumer health data. Nevada regulates it under a law of its own (SB 370); other states reach it, if at all, as sensitive data under their general privacy laws, and the dealer's notice must follow the law of the state where it operates:
| What | Where it comes from | Why |
|---|---|---|
| A staff-written account of a safety-related event, which may describe an injury | Entered by the dealer's staff | To establish a record of what occurred at the dealer's venue |
| Photographs attached to that account | Taken or uploaded by the dealer's staff | Evidentiary value; embedded time and location metadata is preserved deliberately |
| The identities of people involved or present, which may include individuals with no account | Entered by the dealer's staff | The record is not usable without them |
We collect nothing else that bears on health. There is no field in the Service for a diagnosis, a medication, a treatment, a health condition, a biometric identifier, a genetic marker, reproductive or sexual health information, or the fact that someone sought health care. We do not infer health status from anything else we hold. We do not use precise location to determine that anyone visited a health care facility, and we do not operate, and will not operate, a geofence around any health care facility.
4 · WHO IS RESPONSIBLE FOR WHAT
The dealer decides. The dealer chooses whether to use incident records, what its staff writes in them, and who is named. Under the My Health My Data Act and its Nevada equivalent, the dealer is the regulated entity for that data.
TacApp is a processor. We hold and protect the data, on the dealer's instructions, under our Data Processing Addendum. We do not decide what goes into an incident record, we do not read incident records except where necessary to operate or support the Service or where required by law, and we do not use them for any purpose of our own.
Notice is the dealer's to give. A person named in an incident record — including someone who has no account with the dealer — is owed notice by the dealer. Section 5 of the Terms of Service places that obligation on the dealer, and we publish a notice template dealers may adapt.
5 · HOW IT IS SHARED — AND HOW IT IS NOT
We do not sell consumer health data. We have never sold it, and the Service has no mechanism through which it could be sold.
We do not share it with manufacturers, advertisers, data brokers, or any other dealer. It is disclosed only:
- to the dealer that owns the tenant, and to that dealer's authorized staff according to role permissions;
- to the service providers on our subprocessor list — the categories are in Section 8 of the Privacy Policy, and the names are provided to any dealer on request — which host and protect the Service and are bound not to use the data for anything else;
- where required by law or valid legal process;
- on the dealer's written instruction, where the dealer releases its own records — and every such release is itself recorded.
Entry restrictions and incident records never leave the tenant that created them. We do not aggregate them across dealers and we do not operate a shared or industry-wide list.
6 · HOW LONG IT IS KEPT
Incident records and their photographs are evidentiary records. They are held in write-once storage for at least ten (10) years from the creation of the record — longer where the record concerns a minor — and they cannot be deleted or altered during that period, including by TacApp, except where deletion is compelled by a court order, by binding legal process, or by applicable law. Where that occurs we notify the affected dealer unless we are prohibited from doing so, and the deletion itself is recorded.
Retention may run longer where an incident involves a minor, because limitation periods in many states begin at the age of majority.
Everything else about the same individual — loyalty balances, bookings, messages, activity logs — follows the ordinary retention in Section 9 of the Privacy Policy and is deleted normally on request.
We state this plainly because it is the part people are most likely to be surprised by: a request to delete personal information does not reach an incident record within its retention period, outside Washington, where the feature is not offered at all.
7 · YOUR RIGHTS
If you are a customer or visitor of a range, store, or training business that uses TacApp, contact that business first — it is the regulated entity for its records, and it can act on them directly.
You may also write to privacy at tacapp.io. We will pass your request to the dealer promptly, tell you that we have done so, and assist the dealer in answering it.
Depending on where you live, you may have the right to:
- confirm whether we hold consumer health data about you;
- access it, together with a list of the third parties and affiliates with which it has been shared, and contact information for each;
- withdraw consent to its collection and sharing;
- have it deleted, subject to Section 6 above and to the exceptions in applicable law.
We will not discriminate against you for exercising any of these rights.
If we or the dealer say no, you will be told which exception applies. You may appeal by writing to privacy at tacapp.io with "Appeal" in the subject line; we respond within 45 days and, if the appeal is denied, we will tell you how to contact your state attorney general.
8 · SECURITY
Consumer health data is held under the measures described in Section 10 of the Privacy Policy and Section 6 of the Data Processing Addendum. Evidentiary storage is separate from operational data, and the application's key to that storage can add records but cannot read or delete them.
9 · CHANGES
We will update this policy when what we collect changes, and — for anything affecting Washington — before it changes. The "Last updated" date will change.
10 · CONTACT
TacApp Technologies LLC · 8735 Dunwoody Place, STE N, Atlanta, GA 30350, United States · (770) 268-8830
privacy at tacapp.io for anything in this policy · contact at tacapp.io if you are not sure. Section 25 of the Terms of Service lists every address and what each is for.