Privacy Policy
This Privacy Policy describes how OAK TEK - FZCO ("we," "us," or "our") handles information in connection with the Open Chord mobile application ("the App"). We are the data controller for the information described below.
Your use of the App is also governed by our Terms and Conditions.
Age Requirement
Open Chord is intended for users aged 13 and older, and for users aged 16 and older in the European Economic Area. We do not knowingly collect personal information from children below these ages. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at the email address below and we will remove it.
Information We Collect
Open Chord does not require you to create an account. We do not collect your name, email address, or any other personal contact information. The App has no free text entry fields, so there is no written content for us to collect.
Data Stored on Your Device
All of your learning progress, preferences, and settings are stored locally on your device. This data is not transmitted to us. You can delete all of it at any time using the "Clear all data" option in the Guitarist tab, under My Profile, in the My Data section.
The App also caches its instrument sound files on your device so they need not be downloaded again. These files contain no information about you and are removed when the App's data is cleared or the App is uninstalled.
Microphone Access
The App includes an instrument tuner that requires access to your device's microphone to detect pitch in real time. All audio captured by the microphone is analysed entirely on your device using on-device signal processing. No audio is recorded, stored, cached, or transmitted to any server, third party, or external service at any time. Microphone access is used solely for the tuner and for no other purpose. You can revoke microphone permission at any time through your device settings without affecting any other feature of the App.
Usage Analytics
We use PostHog to understand how the App is used, so that we can see where learners get stuck or stop practising and improve those parts of the App. PostHog processes this data on our behalf on servers located in the United States, under a data processing agreement with us.
We collect a fixed set of events that we have defined ourselves. We do not use automatic click tracking, so we do not record every tap or interface element you touch. The events we collect describe:
- Opening the App and completing onboarding, including which guitarist type you selected
- Starting, completing, or leaving a lesson section or challenge, and how long you spent
- Completing a practice session, and its length
- Using the tuner or metronome, and for how long
- Reaching or losing a practice streak
- Switching between tabs, opening the chord library, and playing the chord of the day
- Technical errors, such as the microphone failing to start
Alongside these events, PostHog records standard technical information such as your device type, operating system version, and App version, and assigns a randomly generated identifier to your installation so that repeat visits can be counted. This identifier is not linked to your name or to any account.
PostHog necessarily receives your IP address in transit, as any internet service does. We have configured our PostHog project not to store IP addresses and not to perform geographic lookup, so we do not collect or derive your country, city, or coordinates.
We do not record your screen. Session replay is switched off in the App. We do not capture playback of your movement through the interface.
Turning Analytics Off
Analytics are optional. You can switch them off at any time using the toggle in the Guitarist tab, under My Profile, in the Analytics section. When switched off, no further events are sent from your device.
Analytics are currently collected unless you switch them off. We are adding a consent prompt for users in the European Economic Area and the United Kingdom, so that nothing is collected in those regions unless you first agree. Until that prompt is released, if you are in those regions and would prefer we collect nothing, use the toggle described above and no further events will be sent.
Crash Reporting
We use Google Firebase Crashlytics to be told when the App crashes, so that we can fix it. When a crash occurs, Crashlytics collects the technical details of the failure, including device model, operating system version, App version, and the internal state of the App at the moment it stopped working. It also assigns a randomly generated installation identifier. This information is technical and is not used to identify you.
Instrument Sounds
The instrument sounds used in the App are downloaded once from a public content delivery network, jsDelivr, and then stored on your device. As with any request to a website, this reveals your device's IP address and general technical details to that network. We send no information about you or your practice with the request, and the files are static and identical for every user.
Advertising
Open Chord does not currently display advertisements. The advertising component in the App is switched off, makes no network requests, and the App does not request or collect an advertising identifier.
Open Chord is free, with no subscriptions and no paywalls, and we intend to introduce advertising in a future version to keep it that way. When that happens, adverts will be supplied by Google AdMob, an advertising identifier will be collected, and users in the European Economic Area and the United Kingdom will be asked for consent before any personalised advertising is served. We will update this Privacy Policy, our Terms and Conditions, and our Google Play data disclosures before advertising is enabled.
Why We Use This Information, and Our Legal Basis
For users in the European Economic Area and the United Kingdom, we rely on the following legal bases under the EU and UK General Data Protection Regulation:
| What | Why | Legal basis |
|---|---|---|
| Data stored on your device | To run the App and remember your progress | Necessary to perform our agreement with you, Article 6(1)(b) |
| Usage analytics | To see where learners get stuck and improve the App | Our legitimate interest in improving the App, Article 6(1)(f), moving to consent, Article 6(1)(a), when the consent prompt is released |
| Crash reporting | To detect and fix faults that stop the App working | Our legitimate interest in a stable App, Article 6(1)(f) |
| Instrument sound downloads | To deliver the sounds the App needs to function | Necessary to perform our agreement with you, Article 6(1)(b) |
| Advertising, once enabled | To keep the App free of charge | Your consent, Article 6(1)(a) |
We do not sell or rent your information. We do not share it with third parties for their own purposes. The services listed below process data only on our instructions, as our processors.
Third-Party Services
The App uses the following third-party services, each of which has its own privacy policy:
- PostHog for usage analytics
- Google Firebase Crashlytics for crash reporting
- jsDelivr for delivery of the instrument sound files
International Transfers
We are established in the United Arab Emirates. PostHog and Google process data in the United States. Where information about users in the European Economic Area or the United Kingdom is transferred outside those areas, the transfer is made under the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum where applicable, as incorporated into our agreements with those providers. You may request a copy of the relevant safeguards by writing to us.
Data Retention
Data stored locally on your device remains there until you use "Clear all data" in the App, clear the App's data through your device settings, or uninstall the App.
- Analytics events and the installation identifier: retained for 12 months from collection, then deleted.
- Crash reports: retained by Google Firebase Crashlytics for 90 days, then deleted automatically.
- Aggregated statistics that contain no identifier and cannot be traced back to any device may be kept indefinitely.
We do not maintain our own separate copy of any of this data.
Your Rights
If you are in the European Economic Area or the United Kingdom, you have the right to request access to the personal data we hold about you, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent at any time. You also have the right to lodge a complaint with your national data protection supervisory authority. In the United Kingdom this is the Information Commissioner's Office.
If you are in the United Arab Emirates, you have equivalent rights under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and may complain to the UAE Data Office.
In practice, you can:
- Stop all analytics collection immediately using the toggle in the Guitarist tab
- Delete everything held on your device using "Clear all data"
- Request deletion of analytics data already collected by following the steps on our Delete Your Data page
Because the App has no accounts, the only way we can locate your records is the anonymous installation identifier shown in the My Data section. Without it we hold nothing that would let us identify you, and we may be unable to act on a request.
California Residents
We do not sell personal information, and we do not share personal information for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act. We have not done so in the preceding twelve months. We do not knowingly sell or share the personal information of consumers under 16 years of age.
The categories of personal information we collect are identifiers, in the form of a randomly generated installation identifier, and internet or other electronic network activity information, in the form of the usage events and technical details described above. California residents may request access to and deletion of this information using the contact details below, and will not be treated differently for exercising those rights.
If we enable personalised advertising in a future version, that may constitute sharing for cross-context behavioural advertising. We will update this section and provide an opt-out mechanism before that happens.
Data Security
All data transmitted between the App and our service providers is encrypted in transit. Learning progress stored on your device is protected by your device's own security features. We do not operate our own servers and do not hold a separate copy of your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Effective Date" at the top of this page. Where a change materially affects how we handle your information, we will make that clear within the App before the change takes effect. We encourage you to review this page periodically.
Contact Us
For any question about this Privacy Policy, or to exercise any of the rights described above, please contact us at:
OAK TEK - FZCO
Dubai Silicon Oasis, Dubai, United Arab Emirates
Trade Licence No. 90142, issued by the Dubai Integrated Economic Zones Authority
Email: oaktechnologiesfze@gmail.com
We aim to respond to any request within 30 days.