Gituru Privacy and Cookie Statement – version 1.0, December 2020
This privacy statement is based on European and Dutch data protection laws. If you think your rights under your country’s legislation are not covered by this statement, please email us at [email protected] before you use Gituru.
To provide you with our service, to support every Gituru user as best we can and to achieve our goals, we store and process some of your personal data. We take your privacy very seriously and only use your information where necessary and provided that we have a legal basis to do so in accordance with European data protection law, in particular the General Data Protection Regulation (“GDPR”). In this privacy statement, we explain as clearly as possible why and how we process your personal data. We will assist you personally if you have any questions. For assistance, please contact us on [email protected]
- Who we are
We are Chordify, provider of Gituru: a musical chatbot application that teaches beginners how to play the guitar (hereafter also referred to as: the “Service”). Gituru is a part of Chordify BV, Zuiderpark 14, (9724 AG) Groningen. Our growing team, which is committed to making the learning of music easier and more fun, consists of a varied range of music lovers. They have diverse skills in areas such as music and software technology, graphic and interactive design, content creation, and sales and business development. This privacy statement applies to all our processing operations.
- Which personal data do we process?
We process the following personal data: first and last name, email address, profile information (shared by yourself in the community) (bio, favourite songs, play-along history) and profile picture, gender, age (to make sure that you are above 12 years old and to understand if parental consent may be required for certain processing activities), participation details (of events, memberships and/or (winning) promotions), areas of interest (for example, ‘guitar’ or ‘newbie’), contact history, IP address, social ID, Apple ID, cookie ID (you can read more about cookies in our cookie statement), internal account ID and user behaviour. To record your music during the lessons, we process all sounds that are in your surroundings and recorded by your phone on your instruction.
If you contact us on your own initiative, we process personal data about you which you provide to us. You can reach us through many different channels, like email, Twitter, LinkedIn, Instagram and Facebook. To make this possible, we also process certain personal data, such as your social media name and any personal information provided with your message to us.
3.1 Payment details
The Gituru services payment process is entirely outsourced to Apple. We therefore only store your payment details that we receive back from your chosen payment provider, including personal data mentioned above. This doesn’t include your bank account number.
- Why do we process personal data?
Personal data may be processed for different purposes and on several legal bases.
4.1 Purposes of processing
We process different categories of personal data for the following purposes:
- Membership administration and services
We keep track in our membership records of people who are Gituru members. We keep various personal details in order to authenticate you when you register an account and use the Service, to make sure you are eligible and able to receive the Service, to make sure that you receive the correct version of the Service and to be able to reach you for information about or Service and about related products or services that we provide. We also process information to understand your areas of interest so we can provide you with the best possible information and appealing content and we process personal data for our market research.
- Newsletters and mailings
You can sign up for different types of newsletters from us. Sometimes personalised, and sometimes not. If you no longer wish to receive newsletters, you can unsubscribe in every email, and in your account settings, and you can indicate your preferences of the type of newsletters that you wish to receive in your account settings.
- Legal obligations
A part of our processing is required by law. This mainly concerns information necessary for our (financial) administration, and to comply with our tax and accounting obligations.
Chordify is a growing company and anticipates market developments. We therefore constantly recruit new members, (industrial) partners, musicians, music teachers and sometimes new colleagues too. We may process your personal data if you contact us, or if we contact you, for such any these purposes.
Please note: the above opt-out doesn’t necessarily mean you’ll never get to see Gituru ads again, because we also focus ads on general target groups of which you might be part of.
- Improving Gituru services
We keep personal data for the improvement of our Service. For example, we ‘log’ clicking behaviour on the website to analyse which lessons or numbers are most popular or played along with, which articles are read the most, and open rates to see if our newsletters are relevant.
- Information we share with other Gituru users
The default setting of your Gituru account will be private, which means that other users of the Gituru app will not be able to see your personal profile or any of your personal information. Only if you choose to do so, your personal profile in the Gituru app can be made ‘public’ to other users of the app, for example in case you [post a comment in the Gituru Community or ….]. We may also process your gender and your photos shared in the Gituru app, in case you choose to enrich your personal profile with this information. This is optional and you are not under any obligation to share this information. These processing operations are (obviously) not used for any other purpose. Once again, if you have any questions, please let us know!
- External single sign-on service
If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.
Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
- Technical and customer support
We further use the information about in order to provide technical and customer support to you.
4.2 Legal grounds for personal data processing
We may process your personal data on the following legal grounds:
- For the performance of a contract with users (subscription or event);
- Because of a legal obligation;
- Because we have a legitimate interest;
This means we may process your data because it is necessary for our business activities (or in the business interest of one of our other Chordify entities or partners).
- Because you gave us consent to do so.
We process some data with your consent: for example in case of online tracking methods. You can always withdraw that consent.
- Do we share your personal data with third parties?
We share personal data with our IT provider (TransIP). Besides that, Gituru shares data with Facebook and Apple, if you login through their services as explained above. Data is shared with Google Analytics for improving our services, to analyse user information and to be able to show you personalised content. With all these parties, Gituru has concluded a data processing agreement.
Unless stated otherwise, children are not allowed to use the Service, and we do not collect personal data from them. We define “children” as follows:
Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
Residents of other regions: anyone under 13 years old.
In case a child wishes to use the Service, we will only process their personal data based on verified parental consent. Once verified, a parent can consent to their child accessing and using the Service and the above processing of personal data that requires consent.
If you think we have collected personal data of a minor without parental consent, please contact us at [email protected]
- How long do we store your personal data?
Gituru Does not store your data for longer than necessary for the purposes for which we have collected it, unless the law requires us to keep it longer (for example, for our accounting). This means that, after you delete your Gituru account, data will be deleted after 7 days. The sound recordings are deleted seconds after the recording, unless you choose to save or share the recordings.
- Data transfers outside the EEA
Gituru does not transfer any data to parties outside the EEA.
- Security measures
Gituru has taken appropriate technical and organisational measures to secure your personal data. Measures taken by us include encryption of server connections and password storage, VPN-connections and physical security at the TransIP data storage centres.
- Your rights under the GDPR
Under the GDPR, everyone has a number of rights. We do our very best to comply with this as much as possible. If you have any tips or comments, please let us know!
You can exercise the following rights:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to request for erasure or limitation of processing;
- The right to transferability: It is a right under the GDPR to transfer your personal data, or to have it transferred. You can read how you can download your own information under the above heading ‘Information and inspection’.
To enforce your rights, please contact us on [email protected] We ask you to specify as much as possible in your request what personal data it entails. We will respond to your request within four weeks. In case of a request for deletion, we will remove the relevant personal data as soon as possible, unless, and to the extent that the law requires us to keep the relevant personal data, and whether there are other urgent reasons that oppose removal. We will send you a confirmation message after a request for deletion has been carried out. If we haven’t removed the relevant personal data (or only did so partially), we will send you a message in which we explain why your request couldn’t (fully) be met. If we are not, or not completely able to determine to what personal data your request relates to, we may ask you to specify your request in more detail. We will then suspend the execution of the request until you have provided us with further details.
You also have the right to file a complaint with the Personal Data Authority (PDA) in your jurisdiction or in the Netherlands: If you believe we do not act in accordance with privacy laws, we would like to hear it. You can also submit a complaint with the PDA in this regard. Finally, you always have the right to go to court to deal with your complaint.
- Cookie statement
Gituru uses Analytics cookies to examine the use of the Gituru. We place a persistent cookie on your computer or your mobile device, so we can understand how and how often Gituru is used. Based on this information we can make adjustments if necessary, to ensure Gituru works optimally.
Name: NID Sender.google.com Duration: 7 months Name: _ga Sender: .chordify.net Duration: 2 years Name: _gat Sender: .chordify.net Duration: 1 hour Name: _gid Sender: .chordify.net Duration: 1 day
Gituru processes statistics about visits to its website. This is done with a Web Analytics System. The following data is stored in the Web Analytics System using cookies:
- IP address
- Technical characteristics such as the browser you are using (e.g. Chrome, Safari, Internet Explorer, or Firefox) and your computer screen resolution
- The source from which you came to Gituru (e.g. Google, Facebook, or directly)
- When and how long you visit and use the Gituru app
- Which features you are using in the Gituru app.
- Which pages you visit in the Gituru app.
Name:, Duration: [invullen]
Social Cookies make the use of Gitutu more accessible, and the experience more fun and more personal. Cookies are necessary for the various integrations of social platforms; but you can also use Gituru without these links. We will now deal with the various social cookies.
Name: datr Sender: .facebook Duration: 2 years Name: c_user Sender: .facebook Duration: 3 months Name: xs Sender: .facebook Duration: 3 months Name: fr Sender: .facebook Duration: 3 months Name: sb Sender: .facebook Duration: 2 years Name: pl Sender: .facebook Duration: 3 months Name: cmp649170965 Sender: .trackcmp.com Duration: 1 maand
[invullen indien meer of andere cookies van toepassing zijn]
Name:, Duration: [invullen]
You can easily delete cookies from your devices. The following is a list with the most used browsers and a link to the way you can delete your cookies in your browser:
Groningen, 15. December, 2020