Vibin Oy, Tallimestarinkuja 1 C9, 02940 Espoo, Finland ("Vibin", "us", "we", or "our") are committed to protecting and respecting your privacy. In this policy, we want to inform you about how we collect and process your personal data when you use our mobile application Songen, available for iOS, including data, associated media and services made available through the application ("App").

While your use of the App is on an “anonymous” basis in the sense that you are not able to create a user account, we may still collect and process information about you for the purpose of monitoring and improving the App.

Any changes we may make to our privacy policy in the future will, where appropriate, be displayed on-screen in the App. You may be required to read and confirm that you have read the updated policy in order to continue using the App.

Who is responsible for your personal data?
Vibin is responsible for the processing of your personal data (the “controller”). If you have any questions relating to this policy or our handling of personal data, please send an email to contact@songen.app.

What personal data do we process?
When you use the App, certain data such as your IP-address, unique device identifiers, device hardware and OS information, device state information and the physical location of your device are automatically collected and processed by us (“Automatically Generated Data”). If you contact us with any support questions, we will handle such personal data that you choose to share with us (“Support Data”).

For what purposes do we process your personal data?
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Monitoring the App
In order to monitor and improve the App, we may collect Automatically Generated Data that could potentially be used to identify you. This information will typically consist of information that cannot be used to identify you without additional information not available to us (e.g. your IP address). The legal basis for our processing of this information is our legitimate interest in maintaining and improving the App.

‍Customer Support
We process Support Data that you provide us with for the purposes of answering your questions, to provide customer support and for corresponding purposes. We are not able to respond to your requests unless you provide us the Support Data. The legal basis for our processing of Support Data is our legitimate interest in responding to your requests.

Newsletters
If you have signed up to our newsletter, we will use your email address to send you our newsletters via email. The legal basis for us to process your email is to send you our newsletter, which is not a requirement to use our App.

‍Who can gain access to your personal data?
Your Automatically Generated Data and Support Data will be processed by Vibin and our affiliates. In addition to this our external IT suppliers, as well as any other suppliers we engage may process all personal data that we process about you. The legal basis for this processing of your personal data is our legitimate interest in organising our business and IT systems in an efficient manner. External suppliers will only gain access to personal data about you to the extent necessary for them to fulfil their obligations in relation to us and such data will to the extent possible be replaced with random tokens.

Transfer of personal data to countries outside the EEA
By using the App you acknowledge and consent to that our suppliers and we may process your personal data on servers located in countries outside the EU/EEA in absence of an adequacy decision by the European Commission, meaning that the relevant countries may not provide adequate safeguards for personal data.

For how long do we process your personal data?
Automatically Generated Data is fully anonymized or deleted every 6 months (if processed by us directly) and/or in accordance with the standard terms of the respective analytics tools provider listed further below in this policy. Support Data will be erased on an ongoing basis and is generally not kept for longer than 6 months.

Please note that in some cases we may cease processing personal data for one specific purpose in accordance with the above paragraph but continue to process the same type of data for another purpose described in this policy.

Your personal data may be stored longer than the above, to the extent we are required to do so by EU Member State law, regulation or decisions made by authorities.

How can you affect our processing of your personal data?
At any given time you have the right to withdraw all or part of a given consent in relation to processing of personal data. The withdrawal of consent will however have no effect on our processing of your personal data for the period prior to the withdrawal.

As provided for under applicable data protection legislation, you are entitled:

to gain access to information about the personal data we process about you (free of charge);
to request rectification of inaccurate personal data;
to request that personal data about you be deleted or access to it be restricted; and
to object to our processing of your personal data that has its legal basis in our legitimate interests. Please note that certain processing of personal data about you is necessary to provide the App.
For these types of requests, you should contact us by sending an email to contact@songen.app.

You also have the right to submit a complaint to the Finnish Data Protection Authority or other authorised supervisory authority who is supervising companies’ processing of personal data.

What do we use Automatically Generated Data for?
Some Automatically Generated Data is collected through analytics tools that we use in the App. We use the following tools: Mixpanel and RevenueCat. We automatically collect information including unique device identifiers, IP address, device hardware and OS information, device state information and the physical location of your device. We anonymously track the ways in which you use and interact with our App, such as when and for how long you use the App, which screens your are viewing inside the App. No musical content is sent outside the App by the analytics tools. Automatically Generated Data helps us improve the App.