Privacy notice

Data controller: [to be completed — name, address, e-mail]. Hosting provider and data processor: Aruba S.p.A. (Italy), cloud server of the service [to be confirmed when the service is activated]. E-mail sending: [mailbox provider to be completed]. Minimum age to use HTC: [to be completed].

• Session cookie (htc_session, technical, HttpOnly): keeps your anonymous or registered session and your request count. No consent needed for strictly necessary cookies; there are no advertising or analytics cookies.
• Requests and results: the text of your request, its options and the projects HTC composed, so you can recover them after an interruption and so requests can be counted. Visible only to you.
• Account (if you register): your e-mail address — used to send one-time sign-in codes, and the newsletter only if you subscribe; your Library copy and its revisions, to synchronise your devices; the version of the beta terms you registered under.
• Profile (optional, only what you fill in): first and last name, city, country — private, seen only by you and the HTC team; your relation to music; a public nickname, shown only next to songs you choose to share.
• Your choices: a record of the newsletter and of your interest in the Founding Contributors programme — what you chose, when, from where and which text you were shown — so your choices can be honoured and proven. Revoking keeps the history and stops the effect.
• Feedback: what you write, its kind and the context shown before you send it (page, browser family, playback position, HTC version…); a project revision only if you choose to attach it.
• Catalogue (only if you submit a song): a frozen copy of the song, your nickname if you choose it, your prompt only if you include it, the review outcome.
• Technical events: timings, errors and the HTC version, without the text of your request, to keep the service working. IP addresses are used only in memory to limit abuse and are not stored.
• Page counts: the server counts how many times each public page and the app are opened per day — a total per page, with no cookie, address or identifier.
• Usage counts: daily totals of a fixed list of in-app actions without any identifier — off by default, switched on only by you.

Legal bases [to be confirmed in the legal review]: providing the service you ask for (account, requests, Library, catalogue submission); legitimate interest in security and in keeping the service working (technical events, abuse limits, page counts); your consent for the newsletter, the usage counts and the Founding Contributors interest, each revocable at any time.

Optional and separate from everything else: you subscribe from your account preferences (never pre-ticked), every message carries a one-click unsubscribe link, and you can also unsubscribe from your account. It is sent only to people whose current choice is “subscribed”. Sign-in codes are not newsletters and are never used for it. No newsletter has been sent yet; the sending provider is [to be completed].

The app keeps your projects and settings in your browser (IndexedDB, localStorage). The home page remembers which demo Set it showed last, to show a different one next time; the app remembers which What’s new entry you have seen. Nothing of this is used for tracking.

Proposed retention (to be confirmed): anonymous sessions expire after 180 days of inactivity and their data is deleted; recoverable results are offered for 14 days; registered accounts keep their data — profile and record of choices included — until they are deleted; one-time codes are deleted after a day and sending records after 30 days; feedback is kept for the beta and up to 12 months after it; technical events for 90 days. Backups are encrypted and kept for 14 days [to be confirmed]. When an account is deleted we keep only a one-way fingerprint (hash) of its identifiers, so that restoring a backup can never bring it back.

You can ask for access, correction, deletion, restriction, portability and object, withdraw any consent, and complain to the Italian supervisory authority (Garante per la protezione dei dati personali). In the app’s account window you can edit or clear your profile and your preferences at any time; Delete account… (or Delete my data… without an account) erases what the server keeps for you; you can also write to the controller.