Privacy Policy

Bulbes — lightbulbs memo is operated by Sport Star Management LLC (OOO «Sport Star Management», OGRN 1097746525898), a company registered in the Russian Federation, with its registered office at 34 Verkhnyaya Krasnoselskaya Street, Moscow, 107140, Russia (“we”, “us”). We are the operator of personal data within the meaning of Federal Law No. 152-FZ “On Personal Data”; where the UK or EU General Data Protection Regulation applies to you, we are the data controller.

Questions, requests and complaints: privacy@highglossy.com.

• No account, no server. Your catalogue is stored on your iPhone; we never receive it.
• Sync is yours. iCloud sync, if you turn it on, uses your own Apple account under Apple's policies.
• Reminders are local. The reminder to buy bulbs is scheduled by the operating system on the device.
• We do see: the record of your in-app purchases through Apple, and the email you send if you use the feedback form.
• No analytics SDK, no ads, no selling of personal data.

• Rooms, fixtures, bulbs and stock. Stored in the app's local storage on the device.
• iCloud. Optional; the app writes your catalogue to your own iCloud. We have no access to it.
• Feedback. The form opens your mail app with a message addressed to us; nothing is sent until you send it.

Every category we hold, why we hold it, the lawful basis and how long we keep it:

• Purchase records: the App Store receipts that remove the restrictions — To unlock what you paid for and restore it on a new device. We never see your payment details. Basis: Performance of the agreement with you (Art. 6 of Federal Law No. 152-FZ). Kept: life of the installation; Apple keeps its own record.
• Support correspondence: your email address and what you write to us — To answer you. Basis: Our legitimate interests in security and reliability (Art. 6 of Federal Law No. 152-FZ). Kept: 24 months.

We do not sell personal data and we do not use it for advertising or profiling.

We use a small number of processors. Each is bound by a data processing agreement and may use the data only to provide the service to us.

• Apple — payment processing for in-app purchases. Apple takes the payment; we never see your card number or billing address. Your relationship for the payment itself is with the App Store, under Apple's own privacy policy.
• Apple iCloud — only if you turn sync on, and under your own Apple account. It stores your catalogue for you, not for us.

We also disclose data where we are legally compelled to: to comply with a legal obligation, to protect our rights or property, to investigate possible wrongdoing in connection with the app, or to protect the safety of users or the public.

We do not sell personal data, and we do not share it for cross-context behavioural advertising.

The section above gives the retention period for each category. Bulbes has no account to delete: uninstalling the app removes everything it stored on the device. A catalogue in your iCloud is yours to delete there.

Bulbes has no servers of its own. Apple processes purchase and iCloud data under its own policies in its own regions. If you are located outside the Russian Federation and use the app, you consent to your data being transferred to and processed in the Russian Federation. Where the UK or EU GDPR applies, cross-border transfers rely on the Standard Contractual Clauses or an adequacy decision.

Wherever you live, you can ask us to:

• Give you a copy of the personal data we hold about you, in a portable format.
• Correct anything inaccurate.
• Delete your data.
• Restrict or object to processing we carry out on the basis of legitimate interests.
• Withdraw consent, for example for notifications by turning them off in your device settings, without affecting what we did before you withdrew it.

Write to privacy@highglossy.com. We respond within 30 days (within 10 business days where Federal Law No. 152-FZ requires it).

Since we hold no personal data about Bulbes users beyond support correspondence, a request will usually concern that correspondence only.

In the Russian Federation you may also complain to Roskomnadzor, the authority for the protection of the rights of personal data subjects. If you are in the UK or the EEA, you may complain to your data protection authority.

Under the CCPA as amended by the CPRA, in the last 12 months we collected the categories described above for the business purposes stated there, from you and from your device. We have not sold personal information and we have not shared it for cross-context behavioural advertising. We have no actual knowledge of selling the personal information of consumers under 16.

You have the right to know, delete, correct, and to be free from discrimination for exercising those rights. Exercise them at privacy@highglossy.com.

Bulbes — lightbulbs memo is not directed to children and is not intended for anyone under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with data, write to privacy@highglossy.com and we will delete it.

Data in transit is protected with TLS. Access to our systems is limited to the people who need it to run the service and is logged. No system is perfectly secure, and we will not claim otherwise; if a breach affects your personal data, we will notify you and the competent authority as the law requires.

We will update this policy when what we do changes. The date at the top always reflects the current version. If a change materially reduces your rights or widens what we collect, we will tell you in the app before it takes effect.

Sport Star Management LLC, 34 Verkhnyaya Krasnoselskaya Street, Moscow, 107140, Russia

Support: support@highglossy.com · Privacy: privacy@highglossy.com