Privacy Policy

Medinsky books 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. You never give us your name, email or phone number.
• Reading happens on the device. Bookmarks, position and type size are stored locally and never sent to us.
• We do see: standard server logs when the app loads the news feed or catalogue, and the record of your book purchases through Apple.
• No analytics SDK, no ads, no selling of personal data.

• Books, bookmarks and reading position. Stored in the app's local storage on the device.

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

• Server logs: IP address, app version and the time of a feed or catalogue request — To serve the news feed and catalogue and keep the server secure. Basis: Our legitimate interests in security and reliability (Art. 6 of Federal Law No. 152-FZ). Kept: 30 days.
• Purchase records: the App Store receipts for the books you bought — To unlock the books you paid for and restore them 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.

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.
• Our hosting provider in the Russian Federation — serves the news feed and the book catalogue.

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. Medinsky books has no account to delete: uninstalling the app removes everything it stored on the device. Server logs expire after 30 days.

Personal data of citizens of the Russian Federation is recorded, stored and processed on servers located in the Russian Federation, as Federal Law No. 152-FZ requires. Some processors listed above operate outside Russia; they receive only the data named there. 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 the app's users beyond short-lived server logs, a request will usually have nothing to act on; we will tell you so.

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.

Medinsky books 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