This Privacy Policy explains how Lights Out Global Ventures Private Limited (“we”, “us”, “our”) collects, uses, shares and protects personal data when you use Paddock360 across Steam, our iOS and Android apps, and our website (together, the “Service”). We are the data controller / data fiduciary for that data.
01 Who we are & how to contact us
- ▸ Controller: Lights Out Global Ventures Private Limited, a company incorporated in India (Registrar of Companies, September 2025), registered office in Gurugram, Haryana, India.
- ▸ Privacy / support contact: support@paddock360.com
- ▸ Grievance Officer (India, DPDP Act): Shshank Mattoo, sm@paddock360.com. We respond to grievances within the timelines required by applicable law.
02 Who this policy applies to
This policy applies to everyone who uses Paddock360. The Service is intended for users aged 18 and over. We do not knowingly create accounts for, or collect personal data from, anyone under 18. See Section 12.
03 The data we collect
Data you give us
- ▸ Account & profile: display name/handle, email address, date of birth or age confirmation, password (stored only in hashed form), driver profile details and any bio/“mantra” you add.
- ▸ Community content: posts, club activity, messages, likes, shares, competition entries, and any content you submit.
Data we collect when you use the Service
- ▸ Virtual telemetry: lap, sector, timing and input data from sim-racing games you choose to connect (for example Assetto Corsa, F1, Le Mans Ultimate, iRacing). You control which games you connect.
- ▸ Real-world location (mobile only): if you use real-world track features in our mobile app, we collect precise GPS/location telemetry — only with your device permission, and only while you use that feature. This is not collected on Steam.
- ▸ Derived performance data: skill scores, consistency, racecraft and similar metrics we calculate from your telemetry.
- ▸ Device & technical data: device identifiers, IP address, app and operating-system information, and diagnostic/crash data.
- ▸ Website cookies & analytics: see Section 11.
Data we receive from third parties
- ▸ Sign-in identifiers from Steam, Apple or Google when you authenticate through them.
- ▸ Subscription status from Steam, Apple or Google. Payments are processed by those platforms — we do not receive or store your full card or bank details.
04 Why we use your data & our legal bases
We use your data to provide and improve the Service. Depending on your location, we rely on one or more of these legal bases: performance of our contract with you; your consent; our legitimate interests; and compliance with law.
| Purpose | Typical legal basis |
|---|---|
| Create and run your account and unified profile | Contract |
| Capture virtual telemetry from games you connect | Consent |
| Capture real-world GPS telemetry (mobile feature) | Consent |
| Calculate performance metrics and skill scores | Legitimate interests / consent |
| Operate social features, clubs and community | Contract / consent |
| Keep the Service secure and prevent abuse | Legitimate interests / legal obligation |
| Send service and (optional) marketing messages | Contract / consent |
| Comply with legal and tax obligations | Legal obligation |
Where we rely on consent, you can withdraw it at any time (Section 9). We do not use your data for behavioural advertising.
05 How we share your data
We do not sell your personal data. We share it only as follows:
- ▸ Distribution & sign-in platforms (Steam/Valve, Apple, Google) for authentication and, where you subscribe, billing.
- ▸ Service providers (processors) who host and support the Service — for example cloud infrastructure, analytics, crash reporting and email delivery — under contracts that restrict their use of your data.
- ▸ Sponsors and competition partners: only aggregate or anonymised results by default; personal details are shared only with your consent (for example to deliver a prize you have won).
- ▸ Other users: your profile, activity and content are visible according to your privacy settings.
- ▸ Legal, safety and corporate reasons: to comply with law, enforce our terms, protect users, or in connection with a corporate transaction.
06 International data transfers
We operate globally and process data in India and in other countries where we or our providers operate. Where we transfer personal data across borders (for example from the EEA, UK or other regions), we use appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms required by law.
07 How long we keep your data
We keep personal data for as long as your account is active and as needed to provide the Service, then for a limited period to meet legal, tax, security and dispute-resolution needs. Raw telemetry and location data are kept only as long as necessary for the features you use and are then deleted or anonymised. You can ask us to delete your data (Section 9).
08 Security
We use technical and organisational measures to protect your data, including encryption in transit and at rest, access controls, and keeping personal data out of logs and URLs. No system is perfectly secure, but we work to protect your data and will notify you and the relevant authorities of a breach where the law requires.
09 Your rights
Depending on where you live, you may have the right to access, correct, delete, port or restrict your data, object to certain processing, and withdraw consent. To exercise any right, contact support@paddock360.com. We may need to verify your identity and will respond within the timeframes required by law. You can also complain to your local data-protection authority.
Region-specific rights
- ▸ EEA / UK (GDPR): the rights above, plus the right to lodge a complaint with a supervisory authority.
- ▸ India (DPDP Act): rights of access, correction, erasure and grievance redressal; you may nominate another person to exercise your rights.
- ▸ California / US states: rights to know, delete and correct; the right to opt out of “sale”/“sharing”; and to not be discriminated against for exercising rights. We do not sell your data and we honour recognised opt-out (e.g. Global Privacy Control) signals.
10 Deleting your account and data
You can delete your account and associated personal data at any time from within the app, or by contacting support@paddock360.com. Some data may be retained where the law requires.
11 Cookies & similar technologies
Our website uses strictly-necessary cookies and, with your consent, analytics cookies. You can accept or reject non-essential cookies through our cookie banner and change your choice at any time. Our apps use device identifiers and diagnostics as described above rather than website cookies.
12 Children
Paddock360 is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a person under 18 without the required consent, we will delete it. If you believe a minor has provided us data, please contact us.
13 Third-party games, services and links
The Service integrates with third-party games and platforms and may link to third-party sites. Their data practices are governed by their own policies, not this one. We are independent of, and not endorsed by, the game publishers whose titles you connect.
14 Changes to this policy
We may update this policy. We will post the new version with an updated effective date and, for material changes, provide additional notice. Continued use of the Service after changes means you accept the updated policy.
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