Privacy policy

1Who we are

ClearyKeys is a trade name of Cleary Piano Lessons, the sole proprietorship (eenmanszaak) of Lorcan Cleary in Amsterdam, registered with the Netherlands Chamber of Commerce (KvK) under number 90984757. In this policy, “we” and “us” mean Cleary Piano Lessons, trading as ClearyKeys.

For the personal data described below, we are the controller under the General Data Protection Regulation (GDPR). You can reach us at clearykeys@gmail.com.

Cleary Keys Studio, our app for piano teachers, has its own privacy policy at clearykeys.com/studio/privacy.

2What the app keeps on your phone

To plan your practice, ClearyKeys stores the following on your phone, in Chrome’s storage for app.clearykeys.com, the address the app opens from:

• the name you ask it to call you, and the level you chose
• your pieces, their status and the passages you mark
• your practice days, plan, lessons, scale routine and goals
• the sessions you practise, their length and tempos, and your practice diary
• your answers and scores in the drills and courses
• recordings you make, photos and PDFs of your scores with the marks you add to them, and your settings
• the last ten error messages from the app, kept so you can add them to a problem report

Without an account, we never receive any of this and can’t see it. It stays on your device until you change or delete it. If you make an account, part of it is also kept there: see A ClearyKeys account.

You can edit or delete anything in the app. Settings → Your data → Delete everything deletes your practice, recordings and scores from the phone and starts the app again from the beginning. A code for Premium stays on the phone, so that Premium from it carries on. Uninstalling may not delete your data, because it is kept in Chrome’s storage for app.clearykeys.com. To remove it, use Delete everything before you uninstall, or delete the site data for app.clearykeys.com in Chrome’s settings. Save a backup saves a file to your phone’s Downloads folder. It carries your plan, pieces, progress and settings; audio notes and scanned scores stay on the phone. If you keep it in a cloud service such as Google Drive, that service’s own terms apply to the file. The file is plain text, so anyone who has it can read it.

3Microphone, camera and notifications

ClearyKeys uses the microphone only when you press record. Your phone asks your permission the first time. You can refuse, or switch it off later: press and hold the ClearyKeys icon, open App info or Site settings, then Microphone. Everything else in the app works without it.

Recordings are saved on your phone only. You can download any of them to your phone’s Downloads folder.

ClearyKeys uses the camera only when you take a photo of a score. The photo is straightened and kept on your phone with the marks you add, and it is not sent anywhere. Your phone asks your permission the first time, and you can switch the camera off in the same way as the microphone.

If you switch on practice reminders, or the reminder after a lesson, your phone asks whether ClearyKeys may show notifications. The reminders are made on your phone from your own plan, and nothing is sent to us.

4No advertising, no tracking

ClearyKeys contains no advertising, no analytics and no tracking tools. Without an account, it doesn’t send information about your practice anywhere. With an account, it saves your progress to that account and nowhere else. The other thing it sends on its own is the daily check of a code for Premium, if you have typed one (see Codes for Premium). Once it has opened for the first time, it works offline. The app opens from app.clearykeys.com, which Cloudflare hosts, and checks there for updates when it starts. Cloudflare processes your IP address to deliver the files, as it does for this website. Your practice leaves your phone only when you save, share or email something yourself. Links in the app, such as those to study scores on IMSLP, open in your browser, where that site’s own privacy policy applies.

When you share a picture of a finished stage, send your week to your teacher or save a PDF, the app hands the file to your phone’s share menu or to your Downloads folder, and you choose where it goes from there.

A ClearyKeys account (optional)

You don’t need an account to use ClearyKeys. If you make one in Settings → Your account, or with Sign in to my account on the first screen, your progress is saved to it so you can open it on another phone or after changing phones.

You sign in with an email address and a password, or with your Google account. If you use Google, we receive your email address, your name and the link to your profile picture from Google, and nothing else from your Google account. The app doesn’t show or use the name or picture. We use your email address only to sign you in and to send a password reset when you ask for one. We don’t send newsletters to it and don’t share it.

What the account holds:

• your email address, a user number, the dates the account was made and last signed in to, and, if you use Google, your name and profile picture link
• your answer to the age question (16 or over, or under 16), and for someone under 16, that a parent or carer agreed and the date they did
• a copy of your progress: your name in the app, level, pieces and the passages you mark, practice days and sessions, plan, scale routine, goals, diary, drill and course results, and settings

It doesn’t hold your recordings, the photos or PDFs of your scores, or your Premium plan. Those stay on the phone. The copy is updated a few seconds after you practise or change something, whenever the phone is online.

The account and the copy are kept by Google Firebase, a Google Cloud service, in its European region (eur3, in Belgium and the Netherlands). Google processes them for us under its data processing terms, and only you and Lorcan Cleary can reach them. We don’t look at anyone’s progress unless you ask us to, for example to help with a problem.

Deleting your account. In the app, open Settings → Your account → Delete my account and its saved progress. This deletes the account and the copy at once. The progress on that phone stays, and you can delete it with Delete everything. If you can’t open the app, email clearykeys@gmail.com from the address you signed up with, and we’ll delete the account and its copy within 30 days and confirm by email. Signing out keeps the account; it only stops the phone saving to it.

Legal basis: carrying out our agreement with you when you make an account (article 6(1)(b) GDPR). How long: until you delete the account, or you ask us to.

5Your Google account and Premium

Premium isn’t linked to a ClearyKeys account, and nothing you practise is linked to your Google account unless you choose to sign in with Google. Premium isn’t on sale yet. Once it is, this is how buying it works.

Premium is bought through Google Play, and Google takes the payment. We never see your name, your card or your payment details.

When you buy or restore Premium, the app sends the purchase code Google gives it to our checking service, a small program we run on Cloudflare. The service asks Google whether the purchase is valid, confirms it to Google as Google requires, and tells the app whether Premium is on. From Google it receives the order number, the product, the dates of the subscription and whether it renews. It keeps no copy of them.

Google Play Console also shows us each order with its order number, country, price and dates. We keep these records for our accounts, as Dutch tax law requires.

Legal basis: carrying out our contract with you (article 6(1)(b) GDPR), and our legal duty to keep accounts (article 6(1)(c) GDPR).

Codes for Premium

We give some people a code for Premium, for example as a prize in a giveaway. If you type a code in Settings → Your plan → I have a code, the app sends the code and a random number to a small Google Apps Script that belongs to us. The app makes the number up for your phone the first time you use a code. It isn’t linked to your name, your Google account or anything you practise, and it lets a code work on one phone only.

The script looks the code up in a Google Sheet in our own Google account. It notes the phone’s random number, the date the code was first used and the date it was last checked, and tells the app whether the code gives Premium and, for a code that lasts a set number of months, when it ends. While a code is saved on your phone, the app checks it about once a day when you’re online, so that a code we switch off stops giving Premium. Google receives each check with your IP address, as with any connection, and handles it under Google’s privacy policy. Nothing about your practice is sent.

We keep the random number and the dates with the code while it is in use, and delete them within 12 months after the code was last checked. You can ask us to delete them sooner by writing to clearykeys@gmail.com. Removing the code in the app stops the checks.

Legal basis: carrying out our agreement with you when you use a code (article 6(1)(b) GDPR).

6Downloading from Google Play

When you use the Play Store, Google collects data under its own privacy policy. Google Play gives us statistics such as the number of installs by country and device model. If you’ve allowed your phone to share usage and diagnostics with Google, it also gives us anonymous crash reports. We can’t identify you from them, and we use them only to find and fix problems.

Legal basis: our legitimate interest in keeping the app working (article 6(1)(f) GDPR).

7When you email us

If you write to us, we receive your email address, your name if you give it, and whatever you write. We use it to reply and to help with your question. Our email is provided by Google (Gmail).

Report a problem and Suggest an idea, in Settings, write an email for you to send from your own mail app, and you see it before it goes. If you tick Add the app version and device details, the email also carries the app version, your plan, level and look, your screen size and language, your browser’s description of your phone, and the last five error messages from the app. It carries none of your notes, pieces or recordings. If the app can’t start, its error screen offers an email with the error message and the same description of your phone.

Legal basis: our legitimate interest in answering you (article 6(1)(f) GDPR). How long: we delete correspondence two years after the matter is closed, unless we need it for a legal claim.

8This website

clearykeys.com sets no cookies and uses no analytics or tracking. The fonts and images are served from our own site, so visiting it doesn’t send your data to font or image services. The demos on the home page run in your browser, and what you play in them isn’t stored or sent anywhere.

This site, and app.clearykeys.com where the app’s files come from, are hosted by Cloudflare. To deliver pages and files and protect them against attacks, Cloudflare processes technical data such as your IP address, browser type and the time of your visit, and keeps it for a short time under Cloudflare’s privacy policy.

Legal basis: our legitimate interest in running a secure website (article 6(1)(f) GDPR).

The email list

If you leave your email address in the box on the home page, we use it for one thing: to email you once when ClearyKeys is available on Google Play in your country. Your browser sends the address to a small Google Apps Script that belongs to us, and the script saves it in a Google Sheet in our own Google account. Google receives the address with your IP address, as with any connection, and handles them under Google’s privacy policy. Nothing else about you is collected with it, and it is never shared or used for advertising.

Once that email has gone out, we delete your address. If that is more than 12 months away, we delete it anyway. You can ask us to remove your address at any time by writing to clearykeys@gmail.com, and the email will say so too.

Legal basis: your consent (article 6(1)(a) GDPR). You can withdraw it at any time, and withdrawing it doesn’t affect anything we did with your consent before.

9Our social media pages

ClearyKeys has pages on Instagram, TikTok and Facebook. When you visit or follow them, the platform processes your data under its own policy: Instagram, TikTok and Facebook.

Meta gives page owners anonymous statistics about visits. For those statistics, Meta and we are joint controllers under Meta’s Page Insights Controller Addendum, and Meta has taken on the main responsibility for them. We see only these statistics, plus any comments and messages you send us.

Legal basis: our legitimate interest in presenting ClearyKeys and talking to the people who use it (article 6(1)(f) GDPR).

10Children

ClearyKeys is designed for teenagers and adults. Without an account, the app sends no personal data to us, so we collect none from anyone who uses it, whatever their age. Accounts aren’t offered in child mode.

In the Netherlands, someone under 16 needs a parent or carer to agree before their personal data is kept in an account (article 8 GDPR, and article 5 of the Dutch GDPR Implementation Act). So when you create an account, the app first asks whether you’re 16 or over. If you’re under 16, a parent or carer ticks a box to say they agree, and the account can’t be made until they do. The app keeps the answer and its date on the phone and in the account, so the agreement can be shown later. A parent or carer can withdraw it at any time: delete the account in the app, or write to clearykeys@gmail.com and we’ll delete it, and we’ll show them or delete a child’s account data when they ask.

A code check sends only the code and a random number for the phone. When a child practises with ClearyKeys, a parent can turn on child mode in Settings → About you: the app then asks for no rating and shows no social media by itself, and a grown-up presses and holds before links out of the app, restoring a backup or typing a code.

If you’re a parent and think your child has emailed us personal information, contact us and we’ll delete it.

11What we hold, and for how long

12Who else is involved

• Google, for Google Play; Gmail, for email; Google Apps Script and Google Sheets, which check codes for Premium and keep the email list; and Google Firebase, which keeps accounts and their progress in Europe
• Cloudflare, for hosting this website and the app’s files at app.clearykeys.com, and for running our Premium checking service
• Meta and TikTok, for our social media pages

We don’t sell personal data, and we don’t share it for advertising.

Some of these companies process data outside the European Economic Area, mainly in the United States. Where that happens, the data is protected by the EU–US Data Privacy Framework or by standard contractual clauses approved by the European Commission.

13Your rights under the GDPR

You have the right to access the personal data we hold about you, to have it corrected or deleted, to restrict or object to how we use it, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time.

Most of your data never leaves your phone, so you can use these rights yourself: edit or delete anything in the app, save a backup to take your data elsewhere, or use Delete everything to delete it. If you have an account, you can delete it in the app (see Deleting your account), and save a backup to take a copy of your progress with you. For the data we do hold, such as emails, the launch list and the dates kept with a code, write to clearykeys@gmail.com and we’ll reply within one month.

If you’re unhappy with how we handle your data, you can complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens, or to the authority in the country where you live. We’d be glad to hear from you first.

14Security

Your practice data is kept in Chrome’s storage on your phone and protected by the phone’s own security, including its screen lock and Android’s separation between apps. Accounts are kept in Google Firebase, where security rules let each signed-in person read and change only their own progress, and the connection is encrypted. The data we hold is kept in accounts protected by strong passwords and two-step verification, and only Lorcan Cleary has access to it.

15Changes to this policy

If we change this policy, we’ll update the date at the top. If a change affects how your data is handled, for example if we add a way to sign in or to sync between devices, we’ll update this policy and tell you in the app before the change takes effect.

16Contact