Privacy Policy
Effective date: 14 July 2025
Last updated: 14 July 2025
1. Who We Are
The Medisona mobile application (“App”) is developed and distributed by Sole Proprietor Y.A. Kuryanov .
Registered in: Russian Federation
Contact e-mail for data-protection matters: support@medisona.eu
2. Definitions
| Term | Meaning |
|---|---|
| User | An individual who uses the App |
| Personal data | Any information relating to an identified or identifiable User |
| Device | A smartphone, tablet, or other device on which the App is installed |
| Guest mode | Use of the App without registration and without transferring personal data |
3. Data We Collect
| Data category | Examples | Legal basis* | Purpose |
|---|---|---|---|
| Name (alias) | “Ivan,” “Ann Smith” | Contract, Consent | Personalising content, showing in profile |
| user@example.com | Contract, Consent | Account verification, purchase receipts, user support | |
| Device identifiers | IDFV, push-notification token | Legitimate interest, Consent | Authentication, fraud prevention, account recovery |
* Legal basis
- Contract – processing is necessary to perform the terms of use of the App (Art. 6 GDPR / Art. 6(5) Russian Law 152-FZ).
- Consent – the User voluntarily agrees on registration.
- Legitimate interest – ensuring the operability and security of our services.
3.1 Guest mode
When a User accesses free content in guest mode, no personal data are collected or transmitted. Functionality is limited and does not require registration.
4. How We Use Data
- Providing services – access to free and paid audio content, subscription management.
- Payment processing – purchase verification via the App Store.
- User support – responding to enquiries, restoring access.
- Security – detecting and preventing fraudulent activity.
- Communication – service e-mails (receipts, changes to terms, important notices).
We do not conduct behavioural advertising and do not profile Users.
5. Third-Party Recipients
| Service | Role | Data shared | Jurisdiction |
|---|---|---|---|
| RevenueCat, Inc. | Subscription management, purchase analytics | Receipt files, device ID, e-mail (if provided) | USA (EU-US Data Privacy Framework) |
| Apple App Store (Apple Inc.) | Payment processing | Transaction token, amount, currency | Territories where Apple operates |
We have signed Data Processing Agreements (DPA) with these companies and require them to comply with the GDPR and Russian Law 152-FZ.
6. Storage and Security
- Data are stored on secure cloud servers with encryption at rest and TLS in transit.
- Access is restricted on a need-to-know basis (least privilege).
- We carry out regular audits, use two-factor authentication, and maintain backups.
Retention period
Personal data are deleted or anonymised within 30 days after (i) the User deletes their account or (ii) three years of continuous inactivity—whichever comes first. System logs may be kept longer where required by law.
7. International Transfers
Data may be transferred outside Russia and the EEA (e.g. to the USA) only if:
- The destination offers an adequate level of protection (EU adequacy decision); or
- Standard Contractual Clauses (SCC) are in place; or
- The recipient participates in the EU-US Data Privacy Framework,
and in compliance with Art. 12 of Russian Law 152-FZ.
8. User Rights
Users have the right to:
- Obtain confirmation of processing and a copy of their data;
- Rectify inaccurate data;
- Erase data (“right to be forgotten”);
- Restrict or object to processing;
- Port data in a machine-readable format;
- Withdraw consent at any time (without affecting prior lawful processing);
- Lodge a complaint with a supervisory authority (Roskomnadzor or an EU DPA where they reside).
Requests should be sent to support@medisona.eu. We will respond within 30 days.
9. Children
The App is not intended for persons under 13 years of age (or the age defined by local law). We do not knowingly collect data from children. If you learn that a child has provided us with data without parental consent, please contact us and we will delete such information.
10. Changes to This Policy
We may update this Policy when laws or App functionality change. The new version will be published in the App; for material changes we will notify registered users by e-mail at least seven days before it takes effect.
11. Contact
E-mail: support@medisona.eu
If you have any questions or comments about this Policy, please contact us.
Thank you for choosing Medisona!