Privacy Policy

1. Controller

The controller within the meaning of Art. 4(7) GDPR is:

No data protection officer has been appointed; the conditions of Art. 37 GDPR and § 38 BDSG are not met. For any privacy question, write to the controller directly at the address above.

2. What the app processes

The app talks to exactly one server. Everything it sends there is listed below. Anything not listed here does not leave your device.

2.1 Device identifiers

On first launch the app generates a random identifier (a UUID) and stores it in your iPhone's Keychain. It holds nothing about you or your device and is not derived from any device characteristic. Because the Keychain survives a reinstall, this identifier is what finds your profile backup again.

For the Community the app uses a second identifier derived from it (an RFC 4122 v5 name-based UUID). It is stable but not reversible: the private identifier cannot be recovered from it. The private identifier is never sent to any publicly readable endpoint.

2.2 Your profile backup

So that your work survives a reinstall or a new device, the app keeps a copy of your profile on the server in the background, stored under the private device identifier from 2.1. That copy contains:

• your username and profile text, if you have set them;
• the date you joined;
• your whole exercise library — exercises you made, changed or downloaded, with their notes, syllables and categories;
• your routines, favourites and category order;
• the identifiers of the Community exercises you have liked or downloaded;
• your scores, with their dates, for every run that was graded;
• your practice calendar — how long you practised on which day;
• your settings — among them your voice type or custom vocal range, instrument, appearance, theme colour, and the names of the speaker and microphone you selected;
• your computed skill level.

This backup is not public: it can only be retrieved under the private device identifier, which does not leave your iPhone. On the first launch after a reinstall the app fetches it once and restores your profile. You can delete this backup from the server yourself at any time — see section 10.

2.3 Public profile

As soon as you give yourself a username, the app publishes a profile that every other user of the app can see. It contains your public identifier, your username, your profile text and — if you set one — your profile picture in two renditions. Your join date is published only if you turned that switch on in your profile; otherwise it is not sent at all.

Usernames are unique. If being recognised matters to you, pick a name that does not lead back to you, and do not write anything in the profile text you would not want to stand in public.

2.4 Shared exercises

Exercises are private to begin with. Only when you explicitly share one does the app upload it, where it becomes visible to everyone: its name, description, notes and syllables, the time it was published, and your public identifier, which is what shows your username on it. If you unshare or delete the exercise, the app deletes that record from the server, together with the likes, downloads and completed runs counted against it; the exercise then disappears from the Community.

2.5 Usage events

The app reports individual events to the server under your public identifier:

• when you like a Community exercise, or take the like back;
• when you download a Community exercise for the first time;
• when you sing an exercise through to its score — together with the score you got. This applies to every exercise, including the ones that ship with the app, and to every repeat.

The server counts these into the totals shown in the app and averages the scores into the difficulty rating displayed on each exercise. An individual run is therefore associated with a public identifier. You can object to this processing under Art. 21 GDPR — see section 10.

You can also delete these events again from within the app: taking a like back deletes the like, deleting an exercise's recorded scores under "Settings ▸ Reset ▸ Scores" deletes the runs reported for it, and "Delete Everything" removes every event you have ever reported. Only what came from you is deleted — other people's events remain, and the totals and averages are recalculated without yours.

2.6 Messages sent through the feedback form

If you send a message through "Request a new Feature/ Report a Bug", your message text, the type and area you chose and — if you enter one — your e-mail address are transmitted to the server and stored there under the private device identifier, so the report can be matched to your profile. The e-mail address is optional; without it your message is still read, you simply get no reply. Only write what is relevant to the matter into the message itself.

2.7 Microphone

The app needs microphone access to show you the note you are currently singing. The signal is analysed solely on your device and only while a run is in progress. It is not recorded, not stored and not transmitted. You can revoke access at any time in the iOS settings; the app will then no longer show pitch, but otherwise keeps working.

2.8 Photos

For a profile picture the app opens the iOS photo picker. It receives only the one image you choose — not your library. The image is scaled down and, as described in 2.3, published with your public profile.

3. Legal bases

• Art. 6(1)(b) GDPR (performance of a contract) for providing the app, backing up and restoring your profile (2.1, 2.2) and answering your message where you leave an e-mail address (2.6).
• Art. 6(1)(a) GDPR (consent) for everything you publish yourself: your public profile, your profile picture, your join date and every shared exercise (2.3, 2.4, 2.8). You give that consent by sharing or setting it, and can withdraw it at any time with effect for the future by unsharing.
• Art. 6(1)(f) GDPR (legitimate interests) for the usage events and the difficulty ratings computed from them (2.5), and for reading bug reports sent without a contact address (2.6). The legitimate interest is being able to rate exercises meaningfully and to improve the app.
• § 25(2) no. 2 TDDDG for storing the device identifier and your profile on your device: both are strictly necessary to provide the app you explicitly asked for, so no consent is required.

4. Who receives the data

Your data is not sold and not passed on for advertising. Only the following have access:

The operator of the backend server

Every transmission described in section 2 goes to an API under the domain echolex.api.phrase-by-phrase.com, which is operated by a third party:

The operator processes this data as a processor under Art. 28 GDPR — that is, only on instructions and for no purposes of their own. A data processing agreement is in place.

Google Cloud

The operator does not run this server on their own hardware but on Google Cloud. Google is therefore a sub-processor: it stores and processes the data technically, but does not analyse it and uses it for no purposes of its own.

The basis is the Cloud Data Processing Addendum the operator has entered into with Google, which incorporates the European Commission's standard contractual clauses. For the server location, see section 5.

Apple

The app is distributed through the App Store operated by Apple Inc. and Apple Distribution International Ltd. When you download or update the app, Apple processes data as its own controller, over which the controller named above has no influence. Apple's privacy policy applies.

This website's host

See section 8.

5. Transfers to third countries

The backend server runs in the Google Cloud region europe-west10 (Berlin, Germany). That is where your data is held.

Even with a region inside the EU, access from a third country cannot be ruled out entirely — for instance where Google accesses the systems for maintenance or troubleshooting. Such transfers rest on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR), which form part of the Cloud Data Processing Addendum, and on the European Commission's adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR), under which Google LLC is certified. You can request a copy of the safeguards at the address in section 1.

6. How long data is kept

• Profile backup (2.2): the server holds the most recently uploaded state. It is kept while the app is in use — until you delete it in the app ("Settings ▸ Reset ▸ Delete Everything") or ask for it to be deleted (section 10).
• Public profile and shared exercises (2.3, 2.4): until you unshare an exercise, delete it, reset your profile or delete everything; the record is then removed from the server.
• Usage events (2.5): until you delete them in the app (section 10); otherwise indefinitely, since the totals and averages are built on them.
• Messages (2.6): until the matter is dealt with, and at most until statutory retention periods expire. The deletion in the app does not cover them — see section 10.

7. Security

The connection to the server is encrypted end to end with HTTPS (TLS). The private device identifier is held in the iPhone's Keychain, protected by the operating system, and is used only for the profile backup and for your messages — never for the Community features, whose records are readable by anyone.

Please note: the profile backup is protected by knowledge of that identifier rather than by a password. It is a random value and is published nowhere — but there is no additional sign-in. For that reason, do not put anything in your profile beyond what practising requires.

8. The website

This website is purely informational. It sets no cookies, embeds no fonts, maps, videos or scripts from other servers, and contains no analytics or advertising tools. No cookie banner is therefore required, and no profile of your visit is built.

It is hosted by STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany. The host processes the data as a processor under Art. 28 GDPR on the basis of a corresponding agreement; the servers are located in Germany.

When you request a page, the host processes technically necessary access data in server log files — in particular IP address, time, the file requested, the amount of data transferred, browser type and operating system. The legal basis is Art. 6(1)(f) GDPR; the legitimate interest is the secure and trouble-free operation of the website. The host deletes these logs after seven days.

9. Children

The app is not directed at children. Art. 8 GDPR applies to consent for publishing a profile or an exercise (2.3, 2.4): below the age of 16, the consent of a parent or guardian is required. If the controller learns that a child has published something without it, the record will be removed.

10. Your rights

You have the following rights against the controller:

• Access to the data held about you (Art. 15 GDPR);
• Rectification of inaccurate data (Art. 16 GDPR);
• Erasure (Art. 17 GDPR);
• Restriction of processing (Art. 18 GDPR);
• Data portability (Art. 20 GDPR) — the app also has its own export of your library under "Settings ▸ Backup";
• Objection to processing based on Art. 6(1)(f) GDPR, in particular to the usage events in 2.5 (Art. 21 GDPR);
• Withdrawal of consent with effect for the future (Art. 7(3) GDPR).

How to delete your data. You can do this yourself in the app, without writing to anyone. "Settings ▸ Reset ▸ Delete Everything" clears your library, scores, practice calendar, settings and profile on the iPhone, and deletes from the server your profile backup (2.2), your public profile (2.3), every exercise you have shared (2.4) and every like, download and completed run you have reported (2.5). If you have no connection at the time, the app completes the server side at the next launch.

The same screen has smaller buttons for individual parts, and these take their server side with them: "Reset ▸ Scores" deletes recorded scores here and the runs reported for them, "Reset ▸ Settings ▸ Profile" deletes your public profile from the server. Taking a share back removes the exercise from the Community, taking a like back deletes the like.

Two things this does not reach. The random device identifier (2.1) is held in the iPhone's Keychain, which no app can clear — it holds nothing about you, but if you go on practising afterwards, the app writes a new backup under it. And messages you sent through the feedback form (2.6) are stored separately; to have those deleted — or to exercise any of the other rights listed above — write to contact@you-can-sing.net. Please include your username so the right record can be identified.

Independently of this, you have the right under Art. 77 GDPR to lodge a complaint with a supervisory authority, in particular in the member state of your residence or of the alleged infringement. The authority responsible for the controller is:

A list of all German supervisory authorities is published by the Federal Commissioner for Data Protection.

11. Changes to this policy

This policy will be amended when the app or the law changes. The version published here is the one that applies; the date at the top shows when it was last changed.

Impressum (legal notice)

Information required under § 5 DDG (German Digital Services Act):

Responsible for the content under § 18(2) MStV: Artöm Liebert, address as above.

The controller is neither willing nor obliged to take part in dispute resolution proceedings before a consumer arbitration board.

This is a translation for convenience; the German Impressum is the operative one.