Privacy Policy

Last updated: January 11, 2022

Our Privacy Policy

Vibin Oy, Isonjärvenranta 1 C, 02940 Espoo, Finland ("Vibin", "us", "we", or "our") are committed to protecting and respecting your privacy. This policy explains how we collect and process personal data when you use our mobile application Songen for iOS, including associated data, media and services ("App"). Although App usage is "anonymous" without user accounts, we may collect information for monitoring and improving the App. Future policy changes will be displayed in-App where appropriate, requiring confirmation before continued use.

Who is responsible for your personal data?

Vibin is the data controller. For questions about this policy or data handling, email contact@songen.app.

What personal data do we process?

We automatically collect IP addresses, unique device identifiers, device hardware and OS information, device state information, and device physical location ("Automatically Generated Data"). We also process personal data shared during support inquiries ("Support Data").

For what purposes do we process your personal data?

Monitoring the App: We collect Automatically Generated Data for App monitoring and improvement. This information typically cannot be used to identify you without additional data we lack. Our legitimate interest justifies this processing.

Customer Support: We process Support Data to answer questions and provide customer support based on our legitimate interest in responding to requests.

Newsletters: If subscribed, we use your email address to send newsletters. This is optional and not required for App use.

Who can gain access to your personal data?

Vibin and our affiliates process data, along with external IT suppliers and other service providers. External suppliers access only necessary information, with data replaced with random tokens where possible.

Transfer of personal data to countries outside the EEA

By using the App you acknowledge and consent that our suppliers and we may process your personal data on servers located in countries outside the EU/EEA without European Commission adequacy decisions.

For how long do we process your personal data?

Automatically Generated Data is anonymized or deleted every 6 months (or per analytics provider terms). Support Data is erased on an ongoing basis, generally within 6 months. Longer retention occurs when required by EU law or authority decisions.

How can you affect our processing of your personal data?

You may withdraw consent at any time, though this does not affect prior processing. You have the right to access information about your personal data, request corrections, request deletion or access restriction, and object to processing based on legitimate interests. Contact contact@songen.app for these requests. You may also file complaints with the Finnish Data Protection Authority or other supervisory authorities.

What do we use Automatically Generated Data for?

We use analytics tools (Mixpanel and RevenueCat) that collect unique device identifiers, IP addresses, device hardware and OS information, device state, and physical location. We anonymously track usage patterns including when and for how long you use the App and which screens you are viewing inside the App. No musical content is transmitted externally. This data improves the App.