Privacy Policy

1. Introduction

Welcome to VirtuosoPro. We are committed to protecting your privacy and ensuring transparency about how we collect, use, and safeguard your personal information. This Privacy Policy explains our data practices and your rights under applicable privacy laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other privacy regulations.

VirtuosoPro is a multiplatform music collaboration application that helps musicians manage songs, sets, events, chord charts, and collaborate with team members across Android, iOS, Web, Windows, Mac, and Linux platforms.

2. Data Controller and Contact Information

Data Controller:

Contact Information:

For questions about this Privacy Policy or to exercise your privacy rights, please contact us using the information above.

3. Information We Collect

3.1 Information You Provide Directly

Account Information:

• Email address
• Password (stored securely using industry-standard encryption)
• First name and last name
• Display name
• Profile photo
• @username (for easy identification within the app)
• Phone number (optional)
• Location (optional, user-provided city/region, not GPS coordinates)
• Website (optional)
• Musical instrument (optional)
• Experience level (optional)
• Biography (optional)

User-Generated Content:

• Songs (titles, artists, lyrics, chords, sections, keys, tempo, time signatures, capo positions)
• Song metadata (copyright information, license types, CCLI numbers, YouTube URLs, notes, book references)
• Sets (collections of songs with performance details)
• Events (event details, venues, addresses, dates, times, descriptions)
• Tags and categories for organizing content
• Chat messages within shared sets
• Team member information (names, emails, access levels, roles)
• Groups and collaboration settings
• Notes and annotations

Preferences and Settings:

• Last viewed songs and sets
• Recently viewed content history
• Favorite items
• Notification preferences
• Print and format options
• Metronome settings
• Biometric authentication preferences
• Privacy settings for profile information sharing

3.2 Information Collected Automatically

Device Information:

• Device type (phone, tablet, desktop, laptop)
• Operating system and version
• Platform name (Android, iOS, Windows, macOS, Linux, Web browser)
• Device model and manufacturer
• MAC address (where technically accessible and permitted by platform)
• Device serial number (where accessible)
• Product name
• Up to three registered devices per account

Usage Information:

• Login timestamps and authentication method used
• Last active timestamps
• Content access patterns (which songs, sets, events you view)
• Feature usage within the app
• Page views and navigation patterns (via Google Analytics)
• Feature interactions and user flows (via Google Analytics)
• Session duration and frequency (via Google Analytics)
• Advertising interactions (ad views, clicks, conversions)

Technical Information:

• IP address (temporarily for authentication and security)
• Browser type and version (web platform)
• Local storage data for app preferences and offline functionality
• Crash logs and error reports (via Firebase Crashlytics)
• Stack traces and technical diagnostics for debugging (via Firebase Crashlytics)
• App version and build information
• General location (city/country level from IP address, not precise GPS)

Advertising and Marketing Data:

• Advertising cookies and tracking pixels
• Mobile advertising identifiers (IDFA on iOS, AAID on Android)
• Cross-site tracking data (activity across our websites and apps)
• Remarketing tags and conversion tracking
• Hashed email addresses for audience matching
• Inferred interests and demographics
• Ad engagement metrics (impressions, clicks, conversions)

3.3 Information from Third-Party Services

When you use third-party authentication services, we receive:

Google Sign-In:

• Email address
• Display name
• Profile photo URL
• Google user ID

Facebook Login:

• Email address
• Display name
• Profile photo URL
• Facebook user ID

We do not receive your Google or Facebook passwords. Authentication is handled securely through their respective platforms.

4. How We Use Your Information

We use your personal information for the following purposes:

4.1 Service Delivery (Legal Basis: Contract Performance)

• Create and manage your account
• Provide access to VirtuosoPro features across all platforms
• Sync your data across devices in real-time
• Enable collaboration with team members
• Store and retrieve your songs, sets, events, and other content
• Process your preferences and settings

4.2 Communication (Legal Basis: Contract Performance & Legitimate Interest)

• Send service-related notifications
• Notify you of team invitations and collaboration requests
• Deliver in-app chat messages
• Send push notifications
• Send email notifications
• Respond to your support requests
• Send important updates about VirtuosoPro updates and services

4.3 Security and Fraud Prevention (Legal Basis: Legitimate Interest & Legal Obligation)

• Authenticate your identity
• Prevent unauthorized access
• Detect and prevent fraud or abuse
• Enforce our Terms of Service
• Comply with legal obligations

4.4 Service Improvement (Legal Basis: Legitimate Interest)

• Understand how users interact with VirtuosoPro through analytics
• Measure feature usage and user engagement
• Identify and fix technical issues through crash reporting
• Diagnose and resolve app crashes and errors
• Develop new features and improvements based on usage patterns
• Optimize performance across platforms
• Improve app stability and reliability

4.5 Advertising and Marketing (Legal Basis: Consent or Legitimate Interest)

• Show you relevant advertisements for VirtuosoPro features and services
• Remarket to users who have visited our websites or used our apps
• Measure advertising campaign effectiveness
• Create custom audiences and lookalike audiences for advertising
• Track conversions and user acquisition sources
• Optimize advertising spend and targeting
• Promote VirtuosoPro on third-party websites and apps
• Send marketing communications (with your consent)

Note: For users in the EEA, UK, and Switzerland, we rely on your explicit consent for advertising cookies and tracking. You can withdraw consent at any time through our cookie settings.

4.6 Legal Compliance (Legal Basis: Legal Obligation)

• Comply with applicable laws and regulations
• Respond to legal requests and prevent harm
• Protect our rights and property

5. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide VirtuosoPro services you've requested
• Consent: Where you have given explicit consent (e.g., optional profile information, marketing communications, Newsletters)
• Legitimate Interests: Processing necessary for our legitimate business interests (e.g., security, service improvement), balanced against your rights
• Legal Obligation: Processing required to comply with applicable laws

You have the right to withdraw consent at any time when we rely on consent as the legal basis. To withdraw consent, please navigate in the app to the Account > Privacy & Security > Notification Settings.

6. Data Sharing and Disclosure

6.1 Within VirtuosoPro

Team Collaboration:

• Users can search for you to add them to their team, shared sets, chats, and events. To do this, they search for info that you provide to them, such as your email address and/or @username.
• We are not responsible for unsolicited notifications from users that you do not know, who have found your information publicly available on the internet, e.g., your email address or @username.
• When you invite team members to join shared sets, your profile information (name, email, photo, @username) is shared with those team members.
• There is optional profile information that can be shared with team members, such as your phone number, location, website, instrument, experience level, and bio. You have direct control over what profile information is shared through your privacy settings on the Profile screen. By default, these optional settings are all disabled.
• The same is true in reverse; when a team member joins a shared set with you, their profile information is shared with you and the rest of the team members, but you have direct control over what profile information is shared through your privacy settings on the Profile screen
• Songs, sets, and events you share with team members are accessible to them based on assigned access levels of either Member or Group Admin
• Chat messages within shared sets are visible to all set members
• You control what profile information is shared through privacy settings on your Profile screen

6.2 Third-Party Service Providers

We use the following third-party services to operate VirtuosoPro:

Firebase (Google Cloud Platform):

• Purpose: Authentication, cloud database (Firestore), file storage, real-time synchronization
• Data Shared: All user data and content stored in VirtuosoPro
• Location: Data stored on Google Cloud servers (may include servers in the United States and other regions)
• Privacy Policy: https://firebase.google.com/support/privacy

Google Sign-In:

• Purpose: Third-party authentication
• Data Shared: Authentication tokens only
• Privacy Policy: https://policies.google.com/privacy

Facebook Login:

• Purpose: Third-party authentication
• Data Shared: Authentication tokens only
• Privacy Policy: https://www.facebook.com/privacy/explanation

Google Analytics:

• Purpose: Usage analytics and service improvement
• Data Shared: Anonymized usage patterns, device information, general location (city/country level)
• Location: Data processed by Google and stored on Google servers
• Privacy Policy: https://policies.google.com/privacy

Firebase Crashlytics:

• Purpose: Crash reporting and error diagnostics
• Data Shared: Crash logs, device information, app version, stack traces (no PII)
• Location: Data processed by Google Firebase and stored on Google servers
• Privacy Policy: https://firebase.google.com/support/privacy

Google Ads:

• Purpose: Advertising, remarketing, conversion tracking, audience targeting
• Data Shared: Hashed email addresses, device identifiers, browsing activity, ad interactions, conversion events
• Location: Data processed by Google and stored on Google servers
• Privacy Policy: https://policies.google.com/privacy
• Ads Policy: https://policies.google.com/technologies/ads

Facebook Pixel / Meta Ads:

• Purpose: Advertising, remarketing, conversion tracking, custom audiences, lookalike audiences
• Data Shared: Hashed email addresses, device identifiers, browsing activity, ad interactions, conversion events
• Location: Data processed by Meta and stored on Meta servers
• Privacy Policy: https://www.facebook.com/privacy/policy
• Cookies Policy: https://www.facebook.com/privacy/policies/cookies/

Other Advertising Networks:

We may use additional advertising networks and partners. Current partners are disclosed in our cookie consent banner on our websites.

6.3 Legal Requirements

We may disclose your information if required by law, legal process, or government request, or if we believe disclosure is necessary to:

• Comply with legal obligations
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or the public
• Prevent fraud or abuse
• Respond to emergencies

6.4 Business Transfers

If VirtuosoPro is involved in a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred as part of that transaction. We will notify you via email and/or prominent notice in the app before your information is transferred and becomes subject to a different privacy policy.

6.5 Sharing Personal Information for Advertising

What We Share:

We share the following categories of personal information with advertising partners for targeted advertising purposes:

• Identifiers (hashed email addresses, device IDs, advertising IDs)
• Internet/network activity (browsing behavior, ad interactions)
• Geolocation data (general location from IP address)
• Inferences (interests and preferences derived from your activity)

Who We Share With:

• Google Ads (for remarketing and conversion tracking)
• Facebook/Meta (for custom audiences and lookalike targeting)
• Other advertising networks (as disclosed in our cookie consent banner)

Your Right to Opt-Out:

California residents have the right to opt out of the "sale" or "sharing" of personal information. You can opt out by:

• Clicking "Do Not Sell or Share My Personal Information" in our website footer
• Adjusting cookie preferences in our cookie consent banner
• Adjusting your cookie preferences in the app Settings > Privacy & Security > Cookies Preferences
• Emailing privacy@virtuosopro.app with your opt-out request
• Using the Global Privacy Control (GPC) signal in your browser

We Do NOT:

• Sell your personal information for monetary consideration. However, we do share or disclose personal information that could be considered a 'sale' under CCPA.
• Share your song, sets, events, tags, team members, groups, chats, profile, or private content with advertisers
• Share your credit card information with advertising partners
• Sell data to data brokers

7. International Data Transfers

VirtuosoPro operates globally and uses Firebase (Google Cloud Platform) for data storage and processing. Your information may be transferred to and processed in countries other than your country of residence, including the United States.

For EEA, UK, and Swiss Users:

• We rely on Google's compliance with EU-US Data Privacy Framework and UK Extension, Swiss-US Data Privacy Framework, and Standard Contractual Clauses (SCCs) for international transfers
• Google Cloud Platform maintains appropriate safeguards for international data transfers
• You can learn more at: https://cloud.google.com/privacy/gdpr

8. Data Retention

We retain your personal information for as long as necessary to provide VirtuosoPro services and fulfill the purposes described in this Privacy Policy.

Retention Periods:

• Active Accounts: Data retained while your account is active
• Deleted Accounts: You can delete your account at any time by navigating to Account > Privacy & Security > Delete Account. Upon account deletion, this immediately deletes all of your data, except data in backup systems, which is deleted within 90 days, except where retention is required by law. When you delete your account, we add your User ID to a suppression list so that in the case we have to restore a backup, your account cannot be re-created or resurrected.
• Soft-Deleted Content: Content marked as deleted (songs, sets, events, tags, team members, groups) is automatically and permanently removed after 30 days
• Hard-Deleted Content: Content permanently deleted in the Trash by the user is removed immediately and permanently
• Backup Systems: Data in backup systems is deleted within 90 days
• Legal Holds: Data subject to legal holds or investigations is retained until the matter is resolved
• Deletion Feedback: If you provide feedback during account deletion, we retain that feedback anonymously for service improvement purposes.

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

9.1 Rights for All Users

Regardless of your location, you have the following rights:

• Access: View and download your personal information
• Correction: Update or correct inaccurate information
• Deletion: You can delete your account at any time by navigating to Account > Privacy & Security > Delete Account, or request deletion of your account and personal data using the contact information above.
• Data Portability: Export your data in a structured, machine-readable format, e.g., JSON and CSV
• Opt-Out: Unsubscribe from marketing communications by navigating to Account > Notification Settings and click unsubscribe for the type of communication you wish to unsubscribe from.

9.2 Additional Rights for EEA, UK, and Swiss Users (GDPR)

In addition to the rights above, you have:

• Right to Restriction: Request restriction of processing in certain circumstances
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time (where consent is the legal basis)
• Right to Lodge a Complaint: File a complaint with your local data protection authority

• EU Data Protection Authorities: https://edpb.europa.eu/about-edpb/board/members_en
• UK Information Commissioner's Office: https://ico.org.uk/
• Swiss Federal Data Protection Authority: https://www.edoeb.admin.ch/

9.3 Additional Rights for California Residents (CCPA/CPRA)

California residents have the following rights:

• Right to Know: Request disclosure of personal information collected, used, disclosed, or sold in the past 12 months
• Right to Delete: Request deletion of personal information (subject to certain exceptions)
• Right to Opt-Out of Sale/Sharing: Opt out of the sale or sharing of personal information for targeted advertising (see Section 6.5 for instructions)
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit Use of Sensitive Personal Information: Request limitation on use of sensitive personal information (we do not use sensitive personal information beyond what is necessary to provide services)

Authorized Agents: California residents may designate an authorized agent to make requests on their behalf. We may require verification of the agent's authority.

9.4 How to Exercise Your Rights

To exercise any of these rights:

• In-App Settings: Access your profile and privacy settings within VirtuosoPro
• Manage Notifications: Navigate to Account > Notification Settings and click unsubscribe for the type of communication you wish to unsubscribe from.
• Email Request: Contact privacy@virtuosopro.app with your request
• Account Deletion: Use the "Delete Account" feature by navigating to Account > Privacy & Security > Delete Account.

Verification:

To protect your privacy, we will verify your identity before processing requests. We may ask for additional information to confirm you are the account holder.

Response Time:

We will respond to verified requests within:

• 30 days for GDPR requests
• 45 days for CCPA requests (with possible 45-day extension if needed)

No Fee:

We do not charge a fee to process privacy rights requests unless they are excessive, repetitive, or manifestly unfounded.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

Security Measures:

• Industry-standard encryption for data in transit (TLS/SSL)
• Encryption for data at rest in Firebase Cloud Firestore and Storage
• Secure authentication using Firebase Authentication with password hashing
• Optional biometric authentication (fingerprint, Face ID, Passkeys) on supported devices
• Access controls and user authentication requirements
• Regular security assessments and updates
• Firestore security rules to prevent unauthorized access
• Limited employee access to personal data on a need-to-know basis

Your Responsibility:

• Keep your password secure and confidential
• Enable biometric authentication for additional security
• Log out from shared devices
• Report any unauthorized access immediately

No Guarantee:

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

11. Children's Privacy

VirtuosoPro is not intended for children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children under these ages.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@virtuosopro.app. We will promptly delete such information from our systems.

Age Verification:

By using VirtuosoPro, you represent that you are at least 13 years old (or 16 in the EEA), or that you have parental consent to use the service.

12. Cookies and Tracking Technologies

12.1 Cookies and Local Storage

VirtuosoPro uses cookies and local storage mechanisms to provide functionality, improve your experience, and deliver personalized advertising.

Essential Cookies and Storage (Always Active)

Platform-Specific Storage:

• Web (Browser): HTML5 localStorage, session cookies
• Android: SharedPreferences
• iOS: NSUserDefaults
• Desktop: Local properties files

Information Stored Locally:

• Authentication state (to keep you logged in)
• Last viewed songs and sets
• Recently viewed content
• User preferences and settings
• Biometric authentication preferences
• Offline data cache for improved performance

Purpose: This local storage is essential for app functionality, offline access, and user experience.

Advertising and Marketing Cookies (Requires Consent in EU/UK)

On Our Websites (virtuosopro.app and cloud.virtuosopro.app):

First-Party Cookies:

• Session tracking cookies
• User preference cookies
• A/B testing cookies
• Conversion tracking cookies

Third-Party Advertising Cookies:

• Google Ads: Remarketing, conversion tracking, audience targeting
• Facebook Pixel: Remarketing, custom audiences, conversion tracking
• Other Ad Networks: As disclosed in our cookie consent banner

Cookie Duration:

• Session cookies: Deleted when you close your browser
• Persistent cookies: Typically 30 days to 2 years (varies by provider)

What These Cookies Do:

• Track your visits across our websites and apps
• Remember your advertising preferences
• Show you relevant ads on other websites
• Measure ad campaign effectiveness
• Create custom and lookalike audiences
• Prevent showing you the same ad repeatedly

Mobile Advertising Identifiers:

• iOS: Identifier for Advertisers (IDFA)
• Android: Google Advertising ID (AAID)
• Purpose: Track app usage for advertising and analytics
• Reset: You can reset these identifiers in your device settings

12.2 Third-Party Analytics and Crash Reporting

We use the following third-party services to improve VirtuosoPro and fix technical issues:

Google Analytics:

• Purpose: Understand how users interact with VirtuosoPro, measure feature usage, and improve user experience
• Data Collected: Anonymized usage patterns, page views, feature interactions, device type, operating system, general location (city/country level, not precise GPS)
• Data Shared: Analytics data is processed by Google and stored on Google servers
• Opt-Out: You can opt out of Google Analytics tracking through your device settings or browser extensions
• Privacy Policy: https://policies.google.com/privacy

Firebase Crashlytics:

• Purpose: Detect and diagnose app crashes and technical errors to improve stability and performance
• Data Collected: Crash logs, device information, operating system version, app version, stack traces, and technical diagnostics
• Data Shared: Crash data is processed by Google Firebase and stored on Google servers
• No Personal Information: Crashlytics does not collect personally identifiable information (PII) such as names, emails, or user content
• Privacy Policy: https://firebase.google.com/support/privacy

12.3 Managing Cookies and Advertising Preferences

On Our Websites:

Cookie Consent Banner: When you first visit https://virtuosopro.app or https://cloud.virtuosopro.app, you'll see a cookie consent banner. You can accept all cookies, reject non-essential cookies, or customize your preferences. You can change your cookie preferences at any time by clicking the "Cookie Settings" link in the footer.

Browser Settings:

• Chrome: Settings > Privacy and security > Cookies and other site data
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Edge: Settings > Cookies and site permissions > Manage and delete cookies

In Mobile Apps:

iOS (iPhone/iPad):

• Settings > Privacy & Security > Tracking > Toggle off "Allow Apps to Request to Track"
• Settings > Privacy & Security > Apple Advertising > Toggle on "Personalized Ads" (to opt out)
• Reset Advertising Identifier: Settings > Privacy & Security > Apple Advertising > Reset Advertising Identifier

Android:

• Settings > Google > Ads > Opt out of Ads Personalization
• Settings > Google > Ads > Reset advertising ID
• Some Android versions: Settings > Privacy > Ads > Delete advertising ID

Universal Opt-Out Options:

• Digital Advertising Alliance: http://optout.aboutads.info/
• Network Advertising Initiative: http://optout.networkadvertising.org/
• European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
• Google Ads Settings: Visit https://adssettings.google.com/ to control Google ad personalization
• Facebook Ads Settings: Visit https://www.facebook.com/ads/preferences/ to control Facebook ad preferences

Do Not Track (DNT):

We honor Do Not Track signals for advertising purposes on our websites. Enable DNT in your browser settings.

13. Third-Party Links

VirtuosoPro may contain links to third-party websites or services (e.g., YouTube URLs for songs). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notification of Changes:

We will update the "Last Updated" date at the top of this policy. For material changes, we will notify you via:

• Email to your registered email address
• In-app notification
• Prominent notice on our website or app

Your Continued Use:

Your continued use of VirtuosoPro after changes become effective constitutes acceptance of the updated Privacy Policy.

Review Regularly:

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Do Not Track and Global Privacy Control Signals

Do Not Track (DNT):

We honor Do Not Track signals for advertising purposes on our websites (https://virtuosopro.app and https://cloud.virtuosopro.app). When DNT is enabled:

• We will not load third-party advertising cookies
• We will not share your data with advertising partners
• You will still see ads, but they will not be personalized

Global Privacy Control (GPC):

We recognize and honor the Global Privacy Control signal as a valid opt-out request for the sale/sharing of personal information under CCPA. When GPC is enabled:

• We treat it as an opt-out of targeted advertising
• We will not share your data with advertising partners for cross-context behavioral advertising
• Your preference is applied automatically without requiring manual opt-out

How to Enable:

• DNT: Enable in your browser settings (varies by browser)
• GPC: Install a GPC-enabled browser or extension (e.g., Privacy Badger, DuckDuckGo Privacy Essentials)

Note: DNT and GPC only apply to our websites. For mobile apps, use the device-level advertising opt-out settings described in Section 12.3.

16. Your Choices and Controls

You have control over your information in VirtuosoPro:

Profile Privacy Settings:

• Control which profile fields are shared with team members
• Choose what information is visible to collaborators
• Manage your @username visibility

Notification Settings:

• Control which notifications you receive
• Manage notification preferences per platform
• Opt out of non-essential notifications

Data Management:

• Export your data at any time
• Delete individual songs, sets, events, or tags
• Remove team members from your collaborations
• Unregister devices from your account. You can have VirtuosoPro on an unlimited number of devices but only be signed in on three devices at a time. You can unregister devices you no longer use to keep your account clean by navigating to Settings > Privacy & Security > Connected Devices. When you unregister a device, you will be signed out of that device.

Account Deletion:

• Permanently delete your account and all associated data
• Provide optional feedback about your deletion reason
• Data is instantly removed from our database and permanently removed from backups within 90 days

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Response Time:

We aim to respond to all privacy inquiries within 5 business days.

18. Specific Disclosures for California Residents (CCPA)

Categories of Personal Information Collected (Last 12 Months)

The following table summarizes the categories of personal information we collect:

Category	Examples	Collected	Shared With
Identifiers	Name, email, user ID, device ID, MAC address, advertising IDs (IDFA/AAID), hashed email	Yes	Firebase (Google), Google Ads, Facebook/Meta
Personal Information	Name, email, phone, address (for events)	Yes	Firebase (Google)
Commercial Information	Subscription status (if applicable)	Yes	Firebase (Google)
Internet/Network Activity	Usage patterns, device information, IP address, page views, feature interactions, crash logs, ad interactions, browsing behavior, cookies	Yes	Firebase (Google), Google Analytics, Firebase Crashlytics, Google Ads, Facebook/Meta
Geolocation Data	User-provided event addresses, general location from IP (city/country level)	Yes	Firebase (Google), Google Ads, Facebook/Meta
Sensory Information	Profile photos, audio (for pitch detection, processed locally)	Yes	Firebase (Google) for photos only
Professional/Employment Information	Musical instrument, experience level	Yes	Firebase (Google)
Inferences	Interests and preferences derived from activity	Yes	Google Ads, Facebook/Meta

Business Purposes for Collection

We collect personal information for the following business purposes:

• Providing VirtuosoPro services and features
• Account creation and authentication
• Real-time collaboration and data synchronization
• Communication with users
• Security and fraud prevention
• Service improvement and debugging
• Analytics and usage measurement
• Advertising and marketing
• Remarketing and conversion tracking
• Legal compliance

Sale and Sharing of Personal Information

We DO share/sell personal information for advertising purposes:

• Categories Shared: Identifiers (hashed emails, device IDs, advertising IDs), Internet/Network Activity (browsing behavior, ad interactions), Geolocation Data (general location), Inferences (interests and preferences)
• Shared With: Google Ads, Facebook/Meta, other advertising networks
• Purpose: Targeted advertising, remarketing, custom audiences, lookalike audiences, conversion tracking

Your Right to Opt-Out:

You have the right to opt out of the sale/sharing of your personal information. See Section 6.5 for opt-out instructions.

We do NOT:

• Sell personal information for monetary consideration. However, we do share or disclose personal information that could be considered a "sale" under CCPA.
• Share your songs, sets, events, tags, team members, groups, chats, profile, or private content with advertisers
• Share your credit card information with advertising partners
• Process sensitive personal information beyond what is necessary to provide services

Retention Period

We retain personal information as described in Section 8 (Data Retention) of this Privacy Policy.

19. Business Purposes for Collection

We collect personal information for the following business purposes:

• Providing VirtuosoPro services and features
• Account creation and authentication
• Real-time collaboration and data synchronization
• Communication with users
• Security and fraud prevention
• Service improvement and debugging
• Analytics and usage measurement
• Advertising and marketing
• Remarketing and conversion tracking
• Legal compliance

20. Sale and Sharing of Personal Information

We DO share/sell personal information for advertising purposes:

• Categories Shared: Identifiers (hashed emails, device IDs, advertising IDs), Internet/Network Activity (browsing behavior, ad interactions), Geolocation Data (general location), Inferences (interests and preferences)
• Shared With: Google Ads, Facebook/Meta, other advertising networks
• Purpose: Targeted advertising, remarketing, custom audiences, lookalike audiences, conversion tracking

Your Right to Opt-Out:

You have the right to opt out of the sale/sharing of your personal information. See Section 6.5 for opt-out instructions.

We do NOT:

• Sell personal information for monetary consideration. However, we do share or disclose personal information that could be considered a "sale" under CCPA.
• Share your songs, sets, events, tags, team members, groups, chats, profile, or private content with advertisers
• Share your credit card information with advertising partners
• Process sensitive personal information beyond what is necessary to provide services

21. Retention Period

We retain personal information as described in Section 8 (Data Retention) of this Privacy Policy.

20. Specific Disclosures for EEA, UK, and Swiss Users (GDPR)

Data Controller

VirtuosoPro is the data controller for your personal information.

Legal Bases for Processing

As described in Section 5, we process your data based on:

• Contract performance
• Consent
• Legitimate interests
• Legal obligations

International Transfers

Your data may be transferred to the United States and other countries where Firebase operates. We rely on:

• EU-US Data Privacy Framework
• UK Extension to EU-US Data Privacy Framework
• Swiss-US Data Privacy Framework
• Standard Contractual Clauses (SCCs)

Your Rights

As described in Section 9.2, you have extensive rights under GDPR, including access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with your supervisory authority.

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

20. Accessibility

We are committed to making this Privacy Policy accessible to all users. If you need this Privacy Policy in an alternative format, please contact us at privacy@virtuosopro.app.

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