⚠️ DRAFT. Must be reviewed by a data-protection lawyer before launch.
Controller
Соболев Дмитрий Павлович, sole proprietor registered in the Russian Federation (OGRNIP 326508100266477, INN 501502113878). Contact: privacy@vibepiano.ru. Full postal details at the end of this document.
Data we process
Email, name, sign-in identifier, IP address, anonymous device id, learning progress, practice history (which notes were asked, what was answered and how quickly), published performance recordings. No payment data is collected during the closed beta.
Purposes & legal bases
Providing the service, performing the subscription contract, consent records. GDPR bases: contract and consent.
Strictly necessary cookies and anonymous telemetry
Before a choice is made, we set only a strictly necessary HttpOnly cookie containing a random consent-correlation id. It links the choice to the consent ledger, is unavailable to JavaScript, is not used for analytics, advertising or profiling, and expires after at most 180 days. No analytics identifier is set before explicit opt-in, and no individual visitor journal is kept. Only daily aggregate counters are maintained: date · metric · dimension → count, where the dimension is drawn from a fixed whitelist. Unique visitors are estimated by hashing the connection's IP and User-Agent in server memory under a random key that is regenerated daily, never stored, and destroyed when the day ends; the digest is not retained but folded into a probabilistic structure from which no individual visitor can be recovered. Counters and probabilistic structures are retained for up to 400 days.
Storage & transfers
Data is collected and stored on infrastructure located in the Russian Federation. The international edition geo-fences the RF out; see the deployment's jurisdiction configuration.
Your rights
Access, rectification, erasure, withdrawal of consent, portability. Response within 30 days. Contact: privacy@vibepiano.ru.
Controller details
Соболев Дмитрий Павлович — OGRNIP 326508100266477, INN 501502113878
Address: 143180, Московская обл., г. Звенигород, Шиховский проезд, д. 1
Requests: privacy@vibepiano.ru