Privacy Policy

Zavidovo Resort 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.

The Zavidovo resort (“the resort”) is the operator of the data in the loyalty programme; the resort's own rules govern membership, points and offers. We process that data on the resort's behalf and are the operator only of the data needed to run the app itself: device, usage and crash data.

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

• The guide needs no account. Activities, restaurants, hotels, events, weather and offers are readable without telling us who you are.
• The loyalty programme is the resort's. Your membership, points and spending are records in the resort's loyalty system; the app shows and updates them. We process them on the resort's behalf.
• Location is used for routes, only while you follow one and only with the permission you grant; it is not stored.
• Calls and bookings go to the venue. Tapping a phone number or booking link hands you to the restaurant, hotel or the resort's booking site.
• We do see: push tokens, usage statistics and crash reports. No ads SDK, no selling of personal data.

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

• Loyalty account: name, phone number, email, date of birth where the programme asks for it, loyalty card number — To sign you in and show your points. The resort is the operator; we process it on its behalf. Basis: Contract. Kept: while you are a member, then as the resort's rules require.
• Loyalty activity: points earned and spent, purchases at the resort that earned them, completed routes — To run the resort's loyalty programme. Basis: Contract. Kept: while you are a member.
• Location (only if you grant the permission, and only while following a route) — To guide you along walking and cycling routes. Basis: Consent. Kept: not stored; used in the moment.
• Push tokens (only if you allow notifications) — To tell you about events and offers. Basis: Consent. Kept: until the token is revoked or goes stale.
• Usage statistics: which sections are opened, on which device model and OS version, under a random installation identifier — To understand what guests 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.

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.

• Zavidovo resort and its loyalty system — the resort is the operator of the loyalty account, points and spending; the app reads and writes those records on your instruction.
• Map and weather providers — receive the map area and the location you are viewing in order to draw the map and show the forecast, under their own policies.
• 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 the guide content and loyalty integration; 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.

Restaurants, hotels and other venues you call or book through the app receive only what you give them yourself.

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. Deleting the loyalty account from the app's settings removes what identifies you from our systems and asks the resort to do the same; the resort keeps the records its rules and the law require.

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).

Requests about the loyalty programme we forward to the resort, which is its operator, and help it respond.

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.

Zavidovo Resort 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

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