Legal
Privacy Policy
In short
- We process only what Psalmo needs to work: your account, what you practise and learn, payments and, for schools, who is in which class.
- Data lives in the European Union (Supabase, EU region). We do not sell data, show ads or use tracking tools.
- Your school’s teachers and admins see only what they need to help you: your recordings, progress and assignments in their classes.
- You can delete your account at any time from Profile; the data is deleted at once, with the legal exceptions described below.
- For any question or request about your data, write to [contact email address].
1. The data controller
The controller of your data, within the meaning of Regulation (EU) 2016/679 (GDPR), is:
- Operator
- [Company name]
- Tax ID (CUI)
- [Tax ID (CUI)]
- Trade register
- [Trade register no.]
- Registered office
- [Registered address]
- [contact email address]
Data protection officer: [Data protection officer, if appointed]. For any request about your data, use the email address above. The Romanian version of this policy is the binding one; this translation is provided for convenience.
2. What data we process
| Category | What | Where it comes from |
|---|---|---|
| Account | email address, name, password (kept only as a cryptographic hash, by the authentication service), creation date, chosen language and theme, app settings (e.g. MIDI latency, volumes, practice goals) | from you, at sign-up and in Profile / Settings |
| Consents | what you accepted at sign-up (the terms, the age confirmation), the version of the texts, the moment; for teachers, the confirmation of parental consent when creating a class | from you, in the app’s forms |
| Piano practice | the recording of each practice session: piece, mode, hands, tempo, duration, scores and stars, and the raw MIDI events (every key pressed, with its moment and velocity), so that you and your teacher can play them back; sight-reading test results | generated while you practise, from your keyboard |
| Progress | minutes practised per day, the day streak, XP, level, badges, challenges, goals, path level, favourite pieces; on Courses: lessons watched and how much of each, quiz answers, certificates | computed from your activity |
| School and class | your organisation and your role in it (admin, teacher, student), the classes you are in, the seat you hold, assignments received, the teacher’s comments on your recordings, teacher invites (the invited email address) | from your school and from you (the class code) |
| Payments and invoices | plan, period, amount, invoices; for organisations, billing details (name, tax ID, address). Card details reach only the payment processor; we never see them. | from you and from the payment processor |
| Technical data | IP address, browser type and time of requests, in the technical logs of the hosting services, for short periods, for security and debugging | generated automatically when you use the service |
| Correspondence | the emails you send us and our replies | from you |
We do not ask for or process special categories of data (e.g. religious beliefs): the fact that you use an app for church music is not recorded as such and is not used in any way.
3. Purposes and legal bases
| Purpose | Data | Basis (art. 6 GDPR) |
|---|---|---|
| Providing the service: the account, practice with evaluation, progress, courses, classes | account, practice, progress, school and class | performance of the contract with you (point b) |
| Collecting payments and issuing invoices | payments and invoices | performance of the contract (point b) and the legal obligation to keep fiscal records (point c) |
| Proving that you accepted the terms and confirmed your age (and teachers, the parents’ consent), and when | consents | our legitimate interest (point f) in being able to prove that the contract was concluded and the rules for minors respected |
| Keeping the service secure and working: authentication, abuse prevention, debugging | technical data, account | our legitimate interest (point f) in protecting the service and its users |
| Improving Psalmo | aggregate statistics, without identification (e.g. how many students reach level 3) | our legitimate interest (point f) |
| Sending account emails: confirmation, password reset, payments, changes to the terms | email address | performance of the contract (point b) |
| Sending news about Psalmo | email address | only with your consent (point a), if you subscribe; you can unsubscribe at any time. We send no such emails today. |
The evaluation of your playing (correct notes, rhythm, stars) is done automatically by the app from the MIDI events. It is educational feedback, shown to you at once and repeatable at will; it produces no decisions with legal effects on you and is not used for profiling.
4. Schools, churches, teachers: who sees what
- When you join a class with the code you received, the class teacher sees your name, email, recordings (including playback of the notes you played), progress (minutes, streak, level, skills) and assignments, and can comment on your recordings. Teachers see only the students of their own classes.
- The organisation’s admin sees the students holding a seat (name, email, classes, last activity), the teachers, the classes and the invoices; on Psalmo Courses they see the course progress of members with a seat, but never their quiz answers.
- When a seat is released or you leave the organisation, the school no longer sees your data; your progress stays in your account.
- The class’s weekly leaderboard (XP) is visible to students only if the teacher left it on.
- We are the controller for the data on Psalmo; the school, church or studio is an independent controller for its educational relationship with its students and is responsible for informing them and their parents and, for students under 16, for obtaining parental consent (see § 10).
5. Who else receives the data (processors)
We do not sell or rent data. We use a small number of providers, under data processing agreements, each only for what is needed:
| Provider | For what | Where |
|---|---|---|
| Supabase, Inc. | the database, authentication (email and password), files (scores, MIDI recordings, invoices) and the functions of our server | European Union (project hosted in the EU region) |
| Cloudflare, Inc. | delivery of the site’s and the apps’ pages (static hosting, protection) | global network; receives the IP address on every visit; standard contractual clauses |
| Stripe Payments Europe, Ltd. | card payments, Apple Pay / Google Pay, subscription billing — once real payments are active. Card details go straight to Stripe, on its payment page. | Ireland (EU); Stripe may transfer data to the US under standard contractual clauses |
| The email service | account emails (address confirmation, password reset, invites, payments): Resend, Inc. or our domain’s own mail server, once activated | EU / US, under standard contractual clauses |
| BunnyWay d.o.o. (Bunny Stream) | storing and streaming the videos of Psalmo Courses, through time-limited links; receives the IP address of the playing device | Slovenia (EU), video library in the EU region |
| Anthropic, PBC | the artificial-intelligence model used by content admins in the “Creator” tool to draft arrangements. It receives only the admin’s request text and the score; never students’, teachers’ or schools’ data, and does not train models on it. | US, under standard contractual clauses |
The pages’ font (Plus Jakarta Sans) is loaded from the Google Fonts servers (Google LLC, US): when you open the site or the apps, Google receives your device’s IP address and the technical data of the request, nothing about your account. Apart from the font and the providers in the table above, we load no third-party scripts or other resources in our pages and use no traffic-analytics or advertising services. We disclose data to authorities only where the law obliges us.
6. Transfers outside the European Union
Your data is stored in the European Union. The only transfers outside the EU go to the providers in the table above with offices or servers in the United States (Cloudflare, Stripe, the email service, Anthropic) and to Google Fonts (the pages’ font), under the European Commission’s standard contractual clauses and, where applicable, their certification under the EU–US Data Privacy Framework. We can give you a copy of the safeguards on request.
7. How long we keep data
- While you have the account: all the data above, so you can see your history and progress at any time.
- When you delete your account (Profile › “Delete account”) or ask us to: we delete at once the profile, the recordings and MIDI events, progress, favourites, subscription, school seat, class memberships and the teacher invites sent to your address. Classes you created as a teacher stay with the school, without your name, archived.
- What remains after deletion: invoices (unlinked from your account), for as long as the accounting and tax laws require (currently 5 years from 1 July of the year after issue); the record of consents, without your identification; the names of content admins in the internal publishing log of the pieces.
- Technical logs of our providers: days, under their policies.
- Free accounts unused for 3 years may be deleted, after a warning email sent 30 days in advance.
- Database backups are kept for at most 30 days; deleted data disappears from them within that time.
8. Your rights
You have the right:
- of access: to learn what data we hold about you and to receive a copy;
- to rectification: change your name in Profile; for anything else, write to us;
- to erasure: from Profile › “Delete account”, or by asking us;
- to restriction of processing and to object to processing based on legitimate interest;
- to portability: on request, we send you your account data (profile, recordings, progress) in a structured, commonly used, machine-readable format;
- to withdraw consent at any time where processing relies on it, without affecting what was processed before;
- not to be subject to a decision based solely on automated processing with legal effects: we make no such decisions.
Write to [contact email address] from your account’s address; we answer within 30 days. If you are not satisfied with our answer, you can lodge a complaint with the Romanian supervisory authority, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), B-dul G-ral. Gheorghe Magheru 28–30, Sector 1, Bucharest, dataprotection.ro, or with the authority of your country, and you can go to court.
9. How we protect the data
- Every connection is encrypted (HTTPS). Passwords are never stored in clear; authentication is handled by our provider’s dedicated service.
- The database is not reachable from the browser: every request goes through our server, which checks who you are and what you may see. Files (recordings, scores) are downloaded only through signed, short-lived links.
- We never keep card details.
- The team’s access to data is limited to what operating the service requires.
- If a security breach that may affect your rights occurs, we notify you and ANSPDCP within the legal deadlines.
10. Children and young people under 16
An individual Psalmo account is for people aged 16 and above; you confirm your age at sign-up, and under 16 you cannot create an account yourself. Younger students can use Psalmo only if their school, church or teacher enrols them, being responsible for the consent of a parent or guardian and confirming it when creating the class they invite them into. We process these students’ data strictly for practice and progress, as described here. If you are a parent and want to see, correct or delete your child’s data, write to us; if we learn that an account was created by a child under 16 without consent, we delete it.
11. Test versions
On versions marked “test version”, account data may be kept only in your browser (it never reaches our servers) and payments are simulated. You can delete it at any time by clearing the site’s data in your browser.
12. Changes to this policy
When something important changes (a new provider, a new purpose), we update this page, change its version and tell you in the app or by email before the change applies. The current version is at the top of the page.