✓ Designed with GDPR Principles in Mind
Rhythmica™ is designed with GDPR principles and privacy-by-design in mind. We collect minimal non-identifying data for analytics and do not collect personally identifiable information (PII) through our analytics systems.
1. Scope of this Policy
This Privacy Policy applies to information collected through Rhythmica™ websites, mobile applications, and related online services (collectively, the "Service"). By using the Service, you agree to the collection and use of information in accordance with this Policy.
2. Data Controller
The data controller responsible for your personal information is Rhythmica LLC, the owner and operator of Rhythmica™ (referred to as "we," "us," or "our" in this Policy).
If you have questions about this Policy or our data practices, you can contact us at:
Email: rob@rhythmica.app
Address: Rhythmica LLC, 312 W. 2nd St Suite 4209, Casper, WY 82601, USA
3. What Data We Collect
3.1 Non-Identifying Analytics Data
We collect non-identifying usage analytics to understand how users interact with our apps and improve the Service. We design our analytics to be non-identifying and do not associate analytics data with real-world identities or accounts.
| Data Point | What We Collect | Purpose |
|---|---|---|
| Client ID | Random UUID generated on device | Track unique devices (not users) |
| Session ID | Random UUID per session | Track individual sessions |
| App Version | e.g., "1.2.3" | Track which app version is being used |
| Platform | "ios" or "web" | Understand platform usage |
| Session Duration | Number of seconds | Understand engagement patterns |
| Actions Per Session | Count of user interactions | Measure engagement |
| Songs Started | Count of songs played | Content usage analytics |
| Onboarding Status | Boolean (completed or not) | Track onboarding completion |
| Audio Load Errors | Count of errors | Technical debugging |
3.2 Anonymous Feedback Data
When you submit feedback through the app, we collect:
- Feedback type: bug, feature, improvement, general, or content_issue
- Message: Your feedback text (5-5000 characters)
- App version, platform, OS version: Technical context
- Content path: Which content you were viewing (e.g., "en/es/verbs/hablar")
- Rating: Optional 1-5 star rating
- Sentiment: positive, neutral, or negative
- Screen/feature: Where you were in the app
- Locale/timezone: For context only (not precise location)
Note: Feedback is not linked to personally identifiable information. We do not collect names, email addresses, or other direct identifiers with feedback submissions.
4. What Data We DON'T Collect
❌ No Personal Identification
We explicitly do NOT collect:
- Names – We never ask for or store your name
- Email addresses – No email is required to use the app
- Phone numbers – We don't collect phone numbers
- Physical addresses – No home or mailing addresses
- IP addresses – We do not intentionally log or retain IP addresses for analytics or user identification
- Device identifiers – No IDFA, Android Advertising ID, or device serial numbers
- Precise location data – No GPS coordinates or precise geolocation
- Payment information – Payments are processed by third-party payment providers (e.g., Apple App Store), and we do not store credit card numbers or payment details on our servers
- Biometric data – No fingerprints, face scans, or other biometrics
- Social media profiles – No social media account linking or data collection
- Contact lists – We never access your contacts
- Photos or camera – We don't access your camera or photo library
5. How We Use Your Information
We use the non-identifying data we collect for:
- Improving the Service: Understanding usage patterns, identifying bugs, and developing new features.
- Technical debugging: Identifying and fixing technical issues like audio loading errors.
- Content optimization: Understanding which songs and languages are most popular.
- User experience: Measuring engagement, session duration, and feature usage.
- Security: Detecting unusual patterns that might indicate abuse or technical issues.
Because our analytics data is designed to be non-identifying, we cannot use it to:
- Identify individual users
- Track users across different apps or websites
- Build user profiles for advertising
- Sell or share data with third parties for marketing
6. Legal Bases for Processing (GDPR)
For users in the European Economic Area (EEA), UK, and Switzerland, we process your data under the following legal bases:
- Legitimate interests: We process non-identifying analytics data based on our legitimate interest in operating, improving, and securing the Service. This processing does not override your rights and freedoms because the data is designed to be non-identifying.
- Consent: Where required by law, we obtain your explicit consent before processing certain data (e.g., optional cookies or tracking).
- Contract: To provide the Service and fulfill our obligations under our agreement with you.
9. Data Retention
We retain non-identifying analytics and feedback data for:
- Analytics data: Up to 2 years for trend analysis and service improvement
- Feedback data: Indefinitely, as it contains no identifying information and supports long-term product improvement
- Aggregated data: We may retain aggregated, non-identifiable data indefinitely for statistical purposes
When we no longer need data, we will delete or anonymize it.
10. Data Security
We use industry-standard security measures to protect your information:
- HTTPS encryption for all data transmission
- Secure database hosting with Supabase
- API key authentication to prevent unauthorized access
- Regular security updates and monitoring
However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.
11. Your Rights (GDPR & Privacy Laws)
Depending on your location, you may have the following rights:
- Right to access: Request access to data we hold about you (note: our analytics is anonymous)
- Right to rectification: Request correction of inaccurate data
- Right to erasure: Request deletion of your data
- Right to restriction: Request limitation of processing
- Right to data portability: Request a copy of your data in a portable format
- Right to object: Object to processing of your data
- Right to withdraw consent: Withdraw consent at any time (where consent is the legal basis)
- Right to lodge a complaint: Contact your local data protection authority
Important: Because our analytics data is designed to be non-identifying (using random UUIDs instead of user accounts), we cannot identify specific users to fulfill data access or deletion requests related to analytics. Where data cannot be linked to an individual, certain rights may not be technically applicable. However, you can delete the app to stop any further data collection.
To exercise your rights or ask questions, contact us at rob@rhythmica.app.
12. Children's Privacy
The Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 (or under the minimum age of digital consent in your jurisdiction) without appropriate parental consent.
Our analytics system does not differentiate between children and adults, as it's entirely anonymous. If you believe a child has provided feedback that includes identifiable information, please contact us at rob@rhythmica.app.
13. International Data Transfers
Rhythmica™ is operated from the United States. If you access the Service from outside the United States, your anonymous data may be transferred to, stored in, and processed in the United States or other countries.
For EU users: We rely on Standard Contractual Clauses (SCCs) and other appropriate safeguards when transferring data from the EU to third countries. Because our analytics data is designed to be non-identifying, the risk of cross-border data transfers is minimal.
14. Third-Party Services
We use the following third-party services:
- Supabase: Database hosting for anonymous analytics (Privacy Policy: supabase.com/privacy)
- Vercel: App hosting and CDN (Privacy Policy: vercel.com/legal/privacy-policy)
We do not use:
- Google Analytics
- Facebook Pixel or other social media tracking
- Advertising networks
- Cross-site tracking cookies
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. Material changes will be communicated via email or in-app notification.
Your continued use of the Service after any changes constitutes acceptance of the updated Policy.
16. Data Protection Officer
For GDPR-related inquiries, you can contact our Data Protection Officer at:
Email: rob@rhythmica.app
Subject: "GDPR Request" or "Data Protection Inquiry"
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:
Email: rob@rhythmica.app
Address: Rhythmica LLC, 312 W. 2nd St Suite 4209, Casper, WY 82601, USA