I. What data is processed in relation to the use of PocketBook e-readers?

(1) When you use your PocketBook Reading Device, PocketBook collects and processes certain data. The types of data collected depend on the actions you take and the services you use.

(2) The following data is collected on the servers of PocketBook Reading Devices infrastructure.

a. OTA server

• Estimated volume:

185 bytes per request from one device to the server OTA
Average logs – 56GB

• Collection frequency

Each time the device goes online, but not more than 1 per day

• Data being collected

Date/time; IP address; Serial number; Current FW version; New FW version (if available)

• Purposes for which product data / related service data are used

Analytics based on the quantity of devices being online by country, by model, by FW version, by partner
Knowledge of the FW version of the user’s device when a user calls for support

b. Server of TTS packages

• Estimated volume:

~515 bytes per request from one device to the server with TTS packages
Average logs – 50GB

• Collection frequency

Each time the device requests a TTS package to download and install

• Data being collected

Date/time; Serial number; Current FW version; TTS voice name; TTS voice package version; TTS voice vendor; TTS file package name; TTS voice language; IP address

• Purposes for which product data / related service data are used

Analytics based on the quantity of TTS packages downloaded and installed by country, by model, by FW version

c. Dictionaries server

• Estimated volume:

~150 bytes per request from one device to the server with TTS packages
Average logs – 50GB

• Collection frequency

Each time the device requests a dictionary package to download and install

• Data being collected

Date/time; Serial number; dictionary name; IP address

• Purposes for which product data / related service data are used

Analytics based on the quantity of dictionary packages downloaded and installed by dictionary, by country, by model

d. Legal server

• Estimated volume:

~150 bytes per request from one device to the server with TTS packages
Average logs – 1GB
Size of database - 790MB

• Collection frequency

Each time a user consents to a legal document from a device

• Data being collected

Date/time; Serial number; legal document type; legal document name; legal document version; IP-address

• Purposes for which product data / related service data are used

Collect users' consents with the legal documents for devices and services

e. Auth server

• Estimated volume:

~300 bytes per request from one device for authorization to the Pocketbook service (Send-to-Pocketbook, Pocketbook Cloud, Pocketbook Notes)
Log size 630 MB and database 1.7 GB

• Collection frequency

Each time a user authorizes the Pocketbook service (Send-to-Pocketbook, Pocketbook Cloud, Pocketbook Notes)

• Data being collected

Date/time; Serial number; legal document type; legal document name; legal document version; IP-address

• Purposes for which product data / related service data are used

providing an automatic authorization to any of the above-mentioned Pocketbook services if the user has access to any of them using a single Pocketbook account
When a user logs in or registers with the PocketBook store, a callback is sent to the auth.pocketbook-int.com server with the following parameters:
id(user ID in the store), email, firstname, lastname, device_id(device ID, if it is E-Ink, then its serial number), access_token, refresh_token, expires_in which, subsequently, are recorded in the database.
The database contains tokens for PocketBook services (Send-to-PocketBook, Pocketbook Cloud, Pocketbook Notes)

f. Server Send-to-Pocketbook

• Estimated volume:

~500 bytes of logs per request from one email to a device for delivering a book
Log size 630 MB and database 1.7 GB

• Collection frequency

Each time a user authorizes the Pocketbook service (Send-to-Pocketbook, Pocketbook Cloud, Pocketbook Notes)

• Data being collected

• Files of user books

The server serves to store custom files that users send via email to their devices. It also serves as a mailbox processor, where letters with attached files are received from users of E-Ink devices, with further transfer of data (as a URL to the file) to the server sync.pocketbook-int.com for delivery to the registered user's device.
Size of the userfiles directory where custom files are stored - 1.4 Terabytes. Storage period is 1 month or until the moment of downloading the file by the device.

• Log files

user(user ID in sync.pocketbook-int.com), serial number of e-Ink device; filename (name of file in attachment of electronic letter); format(file format); size (file size in bytes); url (https link to a file for downloading to e-Ink device)
Size of logs ~ 400 Bytes per user’s email with a book delivered to the device
mailbox parser logs for successful/failed mail processing: from(sender address), to(recipient email address of E-Ink device (alias)
The total size of log files ~750Gb

• Purposes for which product data / related service data are used

For debugging purposes, answering users' requests in cases where a book was not delivered for some reason

g. Sync

• Estimated volume:

1.8 GB for log files

• Collection frequency

Each time the device requests books from the server for downloading

• Data being collected

Date/time; IP address; Serial number; count for links for books downloading
Date/time; Serial number; email; purpose of email rejection
timestamp(date and time of request), ip, language, email, password hash, salt, device(serial number), deviceAlias(alias/electronic address of e-Ink devices), trusted senders emails (trusted senders) and service fields: action, nonce, signature, token

• Purposes for which product data / related service data are used

For debugging purposes, answering users' requests in cases where a book was not delivered for some reason

h. Notes server

• Estimated volume:

50 MB

• Collection frequency

Each time a user shares his note to an email recipient

• Data being collected

Date/time; Email of recipient; attachment file name; subject of email; other technical info

• Purposes for which product data / related service data are used

For debugging purposes, answering users' requests in cases where a book was not delivered for some reason

i. PINs server

• Estimated volume:

50 MB

• Collection frequency

Each time a user creates a PIN code for his device

• Data being collected

Date/time; Serial number; user’s email; locale; status

• Purposes for which product data / related service data are used

For debugging purposes, answering users' requests in cases where a book was not delivered for some reason

j. Server of devices’ configs

• Estimated volume:

335 GB
api-config.log

• Collection frequency

Each time the device goes online

• Data being collected

api-config.log: Date/time; Serial number; IP-address; technical data

api-partner.log:

• Collection frequency

Each time a partner device launches Store app

• Data being collected

Date/time; Serial number; IP-address; e-mail; password; book_shop_id;

api-store.log

• Collection frequency

Each time the Pocketbook device launches the Store app

• Data being collected

Date/time; Serial number; Ip-address; book_shop_type (magento 2.2 or magento 2.4)

redirect.log;

• Collection frequency

Each time device launches the Browser app

• Data being collected

Date/time; Serial number; IP-address; browser user agent; redirect url

(3) The following Data is stored on your PocketBook Reading Device:

1. Preinstalled Files (factory-installed by the company)

• E-books (in EPUB, PDF, and other formats)
• Audiobooks
• Music files
• Photos
• Coloring pages (only for color-capable devices)
• Dictionaries
• TTS (Text-to-Speech) packages (voice data)
• Logos and other images/icons (e.g., PowerOff screen, BootLogo); may also be retrieved from the server of config for partners
• User manuals

2. User-Downloaded or Purchased Files
Files that the user can purchase in the e-book store, download via online services, or obtain by other means:

• E-books (EPUB, PDF, and other formats)
• Audiobooks
• Dictionaries
• TTS (Text-to-Speech) packages

3. User-Transferred Files
Files that were manually transferred by the user to the device, for example:

• Downloaded via a web browser
• Transferred via USB connection
• Received from Cloud, Send-to-Pocketbook

4. User-Generated Files (created directly on the device)

• Drawings created in the Scribble app
• Colored images created in the Coloring app (color-capable devices only)
• News files generated via the RSS News app

5. Other Files

• Firmware update packages
• Optimized e-books (EPUB) – system creates temporary copies of files of books with optimized structure for more quick opening of books (removed automatically after 10 books have been opened).

6. User Data Created During Reading/Listening

• Bookmarks
• Notes
• Comments
• Handwritten notes
• Screenshots of pages made by the user
• Reading position
• Database of books and audiobooks stored on device
• List of books marked as favorites
• Book collections

7. System-Generated or Collected Metadata
Information gathered during filesystem scanning or generated during file rendering, required for app display:

• Metadata of e-books, audiobooks, and music (title, author, other descriptive data in DB stored on device in the user space)
• Cache of book covers and image thumbnails

8. Authorization and Account Data
Protected data related to user accounts:

• Email address and password (for specific services)
• Access tokens and refresh tokens for various services
• Book encryption keys (stored for certain partners to decrypt DRM-protected books, e.g., Legimi, Empik, LCP-DRM)
• Other authorization credentials (Adobe account, selected e-book store, etc.)
• Cookies, browsing history, and other web browser data
All security-sensitive information is securely stored using encryption.

9. Network Data

• Configuration and data of connected Wi-Fi networks
• Configuration and data of connected Bluetooth devices

10. Settings

• Global device settings (language, key mapping, gesture controls, etc.)
• Application-specific settings (reader preferences, library display, service folders)
• Device PIN code (used to restrict access to the device)

11. Caches

• Cached book covers from the store (OPDS)
• Cached store pages (OPDS)
• Cached book covers from the cloud service
• Search queries (store, library, and others)

12. Overdrive (Libby) app

• Added libraries
• Authorized library card data
• Borrowed books list

13. Onleihe app

• List of libraries
• Authorized library

14. Browser app

• Surfing history
• Downloads history
• Cookies

15. Partners’ Stores apps (Zeitfraht, Umbreit, Buchmedia, Buchzentrum, Legimi, Empik)

• Books available (Zeitfraht, Umbreit, Legimi, Empik)
• Books reading positions (Legimi, Empik)
• Books reading statistics (Legimi, Empik)
• Authorization tokens
• Borrowed books list (Legimi, Empik)

16. Usage statistics

II. What data is processed in relation to the use of PocketBook Cloud?

(1) When you use PocketBook Cloud Service, Pocketbook processes the following data:

(a) Product data /includes the data generated directly by the user’s interaction with PocketBook devices or apps/:

- Uploaded content.
• List of books and documents uploaded.
• File metadata: format (EPUB, PDF, FB2, etc.), author, title, file name, genre (if available), tags (if available), and short description (if available).

- Data about the reading activity:
• Last reading position in a book.
• Bookmarks and their positions.

- Device usage data:
• Device used for reading or synchronization
• Device serial number
• Device IP address.

(b) Related service data /includes the data generated as a by-product of using PocketBook services, including Cloud and Stores provides/:

- User account information: email address, registered store, registration date and time, login history.
- Cloud synchronization data: timestamps of synchronization, devices used.
- Service usage data: books accessed or read, notes and highlights (if stored in Cloud).

(2) Estimated data volume:

• Average user uploads: up to 5Gb per user for e-books, audiobooks.
• Metadata per book: ~1–5 KB (title, author, ISBN, format, tags, description).
• Synchronization logs (reading progress, bookmarks, device info, IP): ~5–10 KB per sync per device

(3) Data collection frequency:

• File uploads: whenever the user uploads a new book or file
• Reading progress/bookmarks: each time the user reads or modifies bookmarks (near real-time)
• Synchronization events: each time the user syncs a device with the Cloud by opening an e-book, closing e-books, tapping by Sync button, making notes in e-book,

III. What data is processed in relation to the use of PocketBook e-commerce Stores?

(1) When you use our online store, we may process the following data (including the data collected and/or generated in connection with and generated by users’ interactions with the store):

Customer’s Account Data (the data collected when a user registers or logs in to the store):

• Email address
• User consent for personal data processing
• Acceptance of the Privacy Notice and Terms of Use
• IP address used during registration or login

Purchase and Order Data (the data related to the user’s transactions, purchases, and orders):

• Email address
• Registration source (country/region)
• User consent for personal data processing
• Acceptance of the Privacy Notice and Terms of Use
• IP address used during registration or login
• Newsletter consent
• Billing information: billing address, contact details
• Shipping information: shipping address, delivery details
• Purchased products:
 Physical items (PocketBook devices, other devices and accessories)
 Serial numbers of purchased devices
 Digital content (e-books, audiobooks)
• Purchased e-books/audiobooks metadata:
 Author, title, ISBN, unique book ID
 Transaction details for each book purchased
• Transaction information:
 Purchase date and time
 Payment method and payment system
 Transaction number
• Email history:
 Subject email
 Data and time
 Status of delivery
Note: e-books and audiobooks purchased by the customer are uploaded to PocketBook Cloud and not stored by the online store.

(2) Estimated data volume:

• User account and consent info: ~1–2 KB per user
• Purchase/order records: 2–10 KB per transaction, depending on number of items
• Billing/shipping data: ~1–3 KB per transaction
• Purchased content metadata: ~1–5 KB per e-book or device

(3) Data collection frequency:

• Registration/account data: once per user at registration
• Transactions/purchases: each time a purchase is made
• Updates to consent or profile: whenever the user modifies their preferences

IV. For what purposes does PocketBook process the data?

(1) PocketBook uses the data for the following purposes:

– to fulfill agreements with you;
– to provide support and services you ask for;
– to keep the PocketBook Reading Device working well and safely;
– for analytical purposes to make your PocketBook Reading Device better;
– to support the personalization features, such as bookmarks, notes, selected fonts, and interface settings;
– for the synchronization and user progress tracking: to allow users to continue reading on any device from where they left off.

(2) We also use the data processed via PocketBook e-commerce Stores for the following specific purposes:

• orders and sales processing – delivering purchased content or devices, issuing invoices, and providing after-sales and warranty services
• performance of contractual obligations – storing purchase history, serial numbers of devices, and relevant transaction information
• analytics and store improvement – aggregation of data about purchases, popular books/devices, and optimization of product offerings.
• security and fraud prevention – protecting customers’ accounts and transactions, detecting unauthorized or suspicious activities

V. With whom may PocketBook share your data?

(1) PocketBook may share the data with other companies if they're only helping PocketBook in achieving the purposes permitted under this section.

(2) PocketBook may use and share your personal information with other companies if we have a legal ground to do so, as specified in our respective Privacy Notice and as allowed by privacy laws like GDPR and the e-Privacy Directive.

VI. How is your data protected?

(1) PocketBook will take reasonable steps to protect your data. This means we will use security measures that are appropriate for the situation, based on current technology, the potential risks to you if your data is lost or shared, and the cost of those security measures. You are not allowed to change or delete the technical protections unless PocketBook agrees in writing beforehand. All the data are securely stored on our dedicated servers. Metadata necessary to interpret and use the data is included. Users can download, retrieve, and, where relevant, erase their data.

(2) If you sell a connected PocketBook device or grant the right to use a connected PocketBook device to someone else (the 'new user'), you must:

– ensure that the new user cannot use the initial user’s account;
– notify PocketBook about such a transfer.

VII. What rights do you have under the EU Data Act, and how to exercise them?

(1) You have the following rights referred to the user’s data processing:

– Access: You can request all product and related service data, including metadata, in a computer-friendly format.
– Portability: You can ask for a transfer of your data to another service provider or device.
– Control: You can ask for your personal data to be deleted or erased.
– Transparency: You have the right to request what data is collected, how much, how often, and what it's used for.
– Third-party sharing: You can ask for your data to be shared with another company and stop that sharing later if you want.

(2) We encourage users to contact our customer support with all requests to exercise their rights regarding the data. You may contact our customer support at help@pocketbook-int.com or find the contact details on the website of the respective PocketBook store. All the data will be given for free, in a computer-friendly format, and include everything needed to understand it. The data will be provided within the statutorily established terms.