Privacy Policy

Football Russia is published on the Apple App Store 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, and on Google Play by Highglossy FZE, a company registered in the United Arab Emirates, with its registered office at Al Shmookh Business Center, One UAQ, UAQ Free Trade Zone, Umm Al Quwain, U.A.E.. The company that distributes the copy you installed is the operator of your data and your counterparty under these documents; we refer to it as “we” or “us”. Both companies are part of the Highglossy group and apply this document in full. Each company is the operator of personal data within the meaning of Federal Law No. 152-FZ “On Personal Data” for the copies it distributes, and the data controller where the UK or EU General Data Protection Regulation applies.

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

• Matches, tables and live coverage need no account. Reading works without telling us who you are.
• Disputes need a profile. A nickname and a sign-in with an identity provider available in the app, so your coins and record stay with you.
• The free version shows ads. Ad networks may use your device's advertising identifier under their own policies; buy Remove ads to switch them off, or limit ad tracking in your device settings.
• Alerts for your clubs use a push token and the list of clubs you picked.
• No selling of personal data. Coins have no cash value and are never paid out.

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

• Profile (only if you join Disputes): nickname, avatar, the identifier your sign-in provider gives us and, where you share it, your email — To create your profile, keep your coins and record and let you sign in again. Basis: Contract. Kept: until you delete the account.
• Disputes: the disputes you start or answer, your answers and results, coin balance and history — To run the game and show the standings. Basis: Contract. Kept: until you delete the account.
• Favourite clubs and push tokens (only if you allow notifications) — To send goal and match alerts for the clubs you chose. Basis: Consent. Kept: until the token is revoked or goes stale.
• Purchase records: coin packs and Remove ads, store product and transaction identifiers — To credit what you paid for and restore Remove ads on a new device. Basis: Contract. Kept: life of the account or installation, then 7 years where tax law requires.
• Advertising identifier and ad interaction data (free version only, by the ad networks) — To show and measure ads. Governed by the networks' own policies; limited by your device's tracking settings. Basis: Consent. Kept: set by the ad network; we keep none of it.
• Usage statistics: which sections are opened, on which device model and OS version, under a random installation identifier — To understand what fans use and improve the app. Basis: Legitimate interests. Kept: 14 months.
• Crash and error reports: stack traces, device model, OS version, app version — To find and fix defects. Basis: Legitimate interests. Kept: 90 days.
• Support correspondence: your email address and what you write to us — To answer you. Basis: Legitimate interests. Kept: 24 months.

Outside the ad networks in the free version, we do not track you across other apps or websites. Buying Remove ads removes the ad SDKs' activity from your installation.

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.

• Ad networks (free version only) — show ads in the app and may use the advertising identifier for that, under their own privacy policies. You control this with your device's tracking settings and by buying Remove ads.
• Sign-in providers — authenticate you when you create a profile; they tell us only that it is you and the identifier.
• Apple and Google — payment processing for in-app purchases. They take the payment; we never see your card number or billing address. Your relationship for the payment itself is with the store, under its own privacy policy.
• Google Firebase Analytics — anonymous usage statistics (which features are used, on which kind of device). We have disabled the collection of the advertising identifier in it; it identifies the installation with a random identifier that is reset when you reinstall the app.
• Google Firebase Cloud Messaging / Apple Push Notification service — delivery of push notifications. Receive the notification token and the notification text.
• Crash reporting (Sentry, hosted in the European Union) — receives stack traces, device model, OS and app version. Crash reports carry no IP address and no user identifier.
• Our hosting providers — run the servers holding profiles, disputes and match data; see the next section for where.

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.

Other users see your nickname, avatar and your public record in Disputes.

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. When you delete your account or ask us to, we delete the records that identify you; backups are purged on a rolling 30-day cycle. We keep purchase records where tax or accounting law obliges us to, and aggregated statistics that no longer identify anyone.

Copies distributed by Sport Star Management LLC store personal data on servers in the Russian Federation, as Federal Law No. 152-FZ requires; copies distributed by Highglossy FZE may be served from the United Arab Emirates and the European Union. Processors listed above may operate outside your country and receive only the data named there. Where personal data leaves the UK or the EEA, the transfer relies on the Standard Contractual Clauses, the UK International Data Transfer Addendum or an adequacy decision, as applicable.

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. You can do this yourself in the app; we will also do it on request.
• 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).

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, except that the ad networks in the free version may qualify as “sharing” under the CCPA; you can opt out by removing ads or by limiting ad tracking in your device settings. 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.

Football Russia is not directed to children and is not intended for anyone under 18. We do not knowingly collect personal data from children under 18. 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

Highglossy FZE, Al Shmookh Business Center, One UAQ, UAQ Free Trade Zone, Umm Al Quwain, U.A.E.

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