Privacy policy

1Who we are

ClearyKeys is a trade name of Lorcan Cleary, a sole trader based in Amsterdam and registered with the Netherlands Chamber of Commerce (KvK) under number 90984757. In this policy, “we” and “us” mean Lorcan Cleary trading as ClearyKeys.

For the personal data described below, we are the controller under the General Data Protection Regulation (GDPR). You can reach us at clearykeys@gmail.com.

2What the app keeps on your phone

To plan your practice, ClearyKeys stores the following inside the app’s own storage on your device:

• the name you ask it to call you, and the level you chose
• your pieces, their status and the passages you mark
• your practice days, plan, scale routine and goals
• the sessions you practise, their length and tempos, and your practice diary
• your answers and scores in the drills and courses
• recordings you make, and your settings

We never receive any of this and can’t see it. It stays on your device until you change or delete it.

You can edit or delete anything in the app. Settings → Your data → Start over wipes everything, and uninstalling the app removes all of it, recordings included. Save a backup creates a file with everything except your recordings, saved wherever you choose. If you keep it in a cloud service such as Google Drive, that service’s own terms apply to the file.

3The microphone

ClearyKeys uses the microphone only when you press record. Android asks your permission the first time, and you can refuse or withdraw it at any time in your phone’s settings. Everything else in the app works without it.

Recordings are saved on your device only. With Premium you can save them as MP3 files to a place you choose.

4No advertising, no tracking

ClearyKeys contains no advertising, no analytics and no tracking tools, and it doesn’t send information about your practice anywhere. It works offline. The one connection it makes is to Google Play, when you subscribe to Premium or when it checks that your subscription is active.

5Your Google account and Premium

There’s no separate ClearyKeys account. Premium is bought through Google Play with the Google account on your phone, which is how your subscription follows you to a new device. Google handles your payment details and your account under Google’s privacy policy. We never see your card or bank details, and we don’t receive your Google password.

Google shares limited information about each order with us, such as an order number, the subscription bought, the price, the date, the status of the order and the country it came from. We use it to provide Premium, to deal with refunds and questions, and to keep the accounting records Dutch law requires.

Legal basis: performing our contract with you (article 6(1)(b) GDPR) and meeting a legal obligation (article 6(1)(c) GDPR). How long: seven years, as Dutch tax law requires for business records.

6Downloading from Google Play

When you use the Play Store, Google collects data under its own privacy policy. If you’ve allowed your phone to share usage and diagnostics with Google, Google gives us anonymous crash reports and statistics, such as the number of installs by country and device model. We can’t identify you from them, and we use them only to find and fix problems.

Legal basis: our legitimate interest in keeping the app working (article 6(1)(f) GDPR).

7When you email us

If you write to us, we receive your email address, your name if you give it, and whatever you write. We use it to reply and to help with your question. Our email is provided by Google (Gmail).

Legal basis: our legitimate interest in answering you (article 6(1)(f) GDPR). How long: we delete correspondence two years after the matter is closed, unless we need it for a legal claim.

8This website

clearykeys.com sets no cookies and uses no analytics or tracking. The fonts and images are served from our own site, so visiting it doesn’t send your data to font or image services. The demos on the home page run in your browser, and what you play in them isn’t stored or sent anywhere.

The site is hosted by Cloudflare. To deliver pages and protect the site against attacks, Cloudflare processes technical data such as your IP address, browser type and the time of your visit, and keeps it for a short time under Cloudflare’s privacy policy.

Legal basis: our legitimate interest in running a secure website (article 6(1)(f) GDPR).

9Our social media pages

ClearyKeys has pages on Instagram, TikTok and Facebook. When you visit or follow them, the platform processes your data under its own policy: Instagram, TikTok and Facebook.

Meta gives page owners anonymous statistics about visits. For those statistics, Meta and we are joint controllers under Meta’s Page Insights Controller Addendum, and Meta has taken on the main responsibility for them. We see only these statistics, plus any comments and messages you send us.

Legal basis: our legitimate interest in presenting ClearyKeys and talking to the people who use it (article 6(1)(f) GDPR).

10Children

ClearyKeys is made for pianists of every age, including children. Because the app doesn’t send personal data to us, we don’t collect data from the children who use it.

Premium is bought through a Google account, and Google’s family tools let a parent approve purchases. If you’re a parent and think your child has emailed us personal information, contact us and we’ll delete it.

11What we hold, and for how long

12Who else is involved

• Google, for Google Play, payments and email
• Cloudflare, for hosting this website
• Meta and TikTok, for our social media pages

We don’t sell personal data, and we don’t share it for advertising.

Some of these companies process data outside the European Economic Area, mainly in the United States. Where that happens, the data is protected by the EU–US Data Privacy Framework or by standard contractual clauses approved by the European Commission.

13Your rights under the GDPR

You have the right to access the personal data we hold about you, to have it corrected or deleted, to restrict or object to how we use it, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time.

Most of your data never leaves your phone, so you can use these rights yourself: edit or delete anything in the app, save a backup to take your data elsewhere, or uninstall. For the data we do hold, such as order information and emails, write to clearykeys@gmail.com and we’ll reply within one month.

If you’re unhappy with how we handle your data, you can complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens, or to the authority in the country where you live. We’d be glad to hear from you first.

14Security

Your practice data is protected by your phone’s own security, including its screen lock and Android’s separation between apps. The data we hold is kept in accounts protected by strong passwords and two-step verification, and only Lorcan Cleary has access to it.

15Changes to this policy

If we change this policy, we’ll update the date at the top. If a change affects how your data is handled, for example if we add a way to sign in or to sync between devices, we’ll update this policy and tell you in the app before the change takes effect.

16Contact