Privacy Policy

Effective date: July 18, 2020

EXALTD CO., Ltd. ("Us", "We", or "Our Company") operates the https://www.drumtunepro.com/ website and the Drumtune PRO (Drum Tuner app for iOS/Android) mobile application (hereinafter referred to as the "Service").

This privacy policy explains how EXALTD CO., Ltd. (Our Company or We) uses the personal Data we collect from you when you use our website or apps.

Our primary goal in collecting personal information and usage data is to allow you to log in into your app account and to provide you with a friendly, customized, and efficient experience.

By using the Service you acknowledge and agree that you have read and accept the Privacy Policy, the EULA and our Terms and conditions.

By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our EULA and Terms and Conditions.

Definitions

Service

Service means the https://www.drumtunepro.com/ website and the Drumtune PRO and drum tuner EZ (Drum Tuner apps for iOS/Android) mobile applications operated by EXALTD CO., Ltd.

Personal identification information

Personal identification information means data about a living individual who can be identified from those data.

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on your device (computer or mobile device).

‘Drumtune PRO’ and ‘drum tuner EZ’ are apps of EXALTD CO., Ltd.

Drumtunepro.com, exaltd.com, drumtuner-ez.com, cymlok.com are websites of EXALTD CO., Ltd.

Our service is GDPR compliant (EU).

If you are from the European Economic Area (EEA), Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We know that you care about how your personal information is used!

We respect your privacy following the GDPR.

We take your privacy seriously and comply with the GDPR, no matter where you are located.

We use your data to provide and improve our mobile apps and website.

Read up on our policy below:

Topics:

What Data do we collect?
How do we collect your data?
How will we use your data?
How do we store your data?
Marketing
What are your data protection rights?
What are cookies?
How do we use cookies?
What types of cookies do we use?
How to manage your cookies
Privacy policies of other websites
Changes to our privacy policy
How to contact us
How to contact the appropriate authorities

What Data do we collect?

We collect the following data:

Personal identification information required for login and which is used to identify you as a user.

UserName, email address, anonymized FB-profile token, password for login.

We use and store this information to allow you to log in to the app, to offer you a 7-day FREE trial, to create an app account that empowers you to backup your tuning presetson our server and to download the expansion packs.

We have built-in encryption in our Services so that when we receive this data, it is SSL-encrypted. That SSL-encryption is to protect your privacy.

Your password is SSL-encrypted and is invisible to us, or to others.

This is why an existing password cannot be recovered or sent to you when lost. If you forgot your password, we cannot send it to you, because we don't know it. If you forget your password, you must create a new password. To create a new password we'll send an SSL-encrypted link to your email address that allows you to create a new password. That way your new-password is always sent and stored in an SSL-encrypted manner, ensuring its content is invisible to us, or others.

Our Company uses and stores this information in anonymized form whenever possible so that it is not associated with individual end-users and does not include personal information, other than the login information itself.

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, the screens of our Service that you visit, the time and date of your visit, the time spent on those screens, unique device identifiers and other diagnostic data.

In most cases we cannot link your Usage data with your Personal indentification information. In the cases where we could link it, we do not store it in a linked form but in an anonymized from to further protect your privacy.

Device model, operating system, and device-id. Our Company uses and stores this information in anonymized form so that it is not associated with individual end users and does not include personal information.
App performance data to get insight in code bugs and when/where/which crashes occur, on which different device models and operating systems. Our Company uses and stores this information in anonymized form so that it is not associated with individual end users and does not include personal information. Your privacy is in no way compromised by using the Services.
Tuning presets. Our Company stores this information with SSL-encryption on encrypted Amazon servers, and only after you make a backup of your presets. Your tuning presets are securely linked to your app account in anonymized form so that it does not include personal information, other than your FB-token or email address used for app login. Your privacy is in no way compromised by using the Tuning presets function, or by using the Services.
Device microphone data TUNER. The tuner is using your microphone to record drum hits. The recorded data is used by the tuner to analyse the impact hardness, fundamental tone, timbre and overtone frequencies of a drum sound. Recorded sound data via the tuner function of Drumtune PRO does not include personal information and is only kept on your device. Recorded sound data is never sent to our servers or to third parties. Your privacy is in no way compromised by using the tuner function, or by using the Services.
Device microphone data RECORDER. You could also use the recorder function of Drumtune PRO (iOS only) to record songs, rehearsals, practice etc. The recorded data via the recorder function can be saved in the app and or exported as .wav or mp3, if you decide to do so.Recorded sound data via the recorder function of Drumtune PRO does not include personal information and is only kept on your device.Recorded sound data is never sent to our servers or to third parties. Your privacy is in no way compromised by using the recorder function, or by using the Services.

How do we collect your data?

One the one hand, you directly provide Our Company with most of the Data yourself when you do the following:

Register online or place an order, log in or subscribe, for any of our products or services.
Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
Use or view our website via your browser’s cookies.
Make a backup of your tuning presets via EVEN MORE/MY PROFILE/Backup tuning presets.
Send our support an email or FB message.
Experience a crash, or when the app hangs on your device.
Send a bug/crash report with the build-in reporter tool. (Instabug)

On the other hand, we also receive some of the Data indirectly from the following third-party Service Providers that collect the Data when you use their services:

Facebook, Google, Google Ads, Google Analytics, Google Firebase, Google Crashalytics, Google Performance, Instabug crash reporting, ...

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Firebase

Firebase is analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

The payment processors we work with are:
Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
Google Play In-App Payments
Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

How will we use your data?

We collect your Data so that we can:

Process your order and manage your account.
Grant you a 7-day free trial to our app on Android devices, without enforcing you into the Play Store’s automated subscription model. (We prefer to offer you a genuinely free opportunity to test the app without any cost or further obligation so that you can decide to purchase the app, or subscribe to it, or to delete it, or to keep on using its free features, after your trial ended without any silent, automatic subscription.
Email you to provide support.
Fix bugs and improve our code to ensure our apps perform smoothly on a wide range of different devices allowing for a bug-free user experience.
Send you your backed-up tuning presets, if you wish to restore your tuning presets on your device or if you switch between iOS and Android versions of the app.

Will we share any of your data?

We will not sell, rent, transfer or otherwise disclose anonymized information, nor will we sell, rent, transfer or otherwise disclose your personally identifiable information to third parties, except as provided in this Privacy Policy or as otherwise expressly authorized or directed by you.

We receive anonymized information from the above third party Service Providers which we can use for research, data modeling, and performance analytics. Via the integration of the Services of those third party Service Providers into our Service, we may share anonymized information with third parties for any purpose, including, without limitation, for market research, data modeling, and performance analytics.

For exampe: When our app crashes on your device, the crash can be tracked by Apple, Google, Crashalytics, Instabug. Their Service is integrated in our app as a plug-in to track crashes and thus we may send your data to Apple, Google, Instabug for processing. communicate the resulting information to Us, so that we know in which line of code the app crashed, on what device type in order to fix the app to future crashes.

We may share personally identifiable information we collect from and about you with third parties in the following instances:

With our service providers, if the disclosure will enable them to process payments made by you using the Services or otherwise perform a business, professional or technical support function for us or you;
As necessary, if we believe that there has been a violation of the the applicable Terms of Service for the Services or of our rights or the rights of any third party;
As necessary, to identify, investigate, prevent or take action regarding illegal activities or suspected fraud or other abuse related to the Services; and
To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
In addition, Our Company reserves the right to disclose and transfer your information, including your personally identifiable information and anonymized information about you: (a) to a subsequent owner, co-owner or operator of the Services; or (b) in connection with a merger, consolidation, restructuring, the sale of substantially all of our equity ownership interests and/or assets or other corporate change. If EXALTD CO., Ltd. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

For example: When Our Company processes your order, it may send your data to Apple, Google, PayPal, and also use the resulting information from credit reference agencies to prevent fraudulent purchases.

How do we store your data?

Your data may be transferred to - and maintained on - computers located outside of your jurisdiction where the data protection laws may differ from those of your jurisdiction.

Our Company securely stores your data at different server-service providers that are located in the USA: Apple’s servers, One.com’s servers, GoDaddy servers, Google’s servers, and Amazon’s servers.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer and storage.

Our company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

All stored data is encrypted and secured by the service providers. In addition Our Company takes commercially reasonable steps to ensure data privacy and security, including through various hardware and software methodologies:

Our Company maintains EV SSL-certificates that offer the highest level of security and 256-bit encryption on traffic and data. To better protect our apps from tampering and fraudulent use, and to further limit your exposure to possible privacy and data risks, Our Company encrypts our apps and incorporates hooked/rooted device checks.

Our Company securely stores your email and login data and keep it protected for an indefinite time for as long as we offer our Service.

As long as we keep active accounts on the provider’s servers, and as long as their services remain available, we will store it safely in their systems with their and our security layers applied.

Should we switch service provider, or should the services or accounts of a current provider become terminated, the data will be deleted following the server-service provider’s procedures.

The security of your Data is important to us, but remember that no method of transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Users of the websites, apps, or services do so at their own risk concerning such communications.

We do not accept any responsibility or liability for actions that may result from your data or information being hacked, intercepted, or accessed by an unauthorized third-party.

In case we are aware of such a security breach, we will inform you.

Marketing

Our Company does not send you information about the products and services of third parties. Our company doesn’t share, trade, or sell any of your personal information with third parties for marketing purposes.

We may send a newsletter quarterly. If you have agreed to receive our newsletter, you may always opt-out at a later date.

Ad display during the 7-DAY FREE TRIAL period (Android only)

We use third-party Service Providers to show advertisements to you to help support your 7-day free trial.

Google AdSense & DoubleClick

Google, as a third party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

AdMob by Google

AdMob by Google is provided by Google Inc. You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google: http://www.google.com/policies/privacy/

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook byvisiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance.

You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/,

the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. If you decide to purchase cymloks via exaltd.com, or if you decide to purchase an app or in-app purchase via th Play Store or the App Store, we use third-party services for payment processing (e.g. payment processors).

The payment processors we work with are:

Apple Store purchases & In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Google Play purchases & In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

What are your data protection rights under the GDPR?

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. EXALTD CO., Ltd. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

Our Company would like to make sure you are fully aware of all of your data protection rights. In certain circumstances, you are entitled to the following data protection rights:

The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: support@drumtunepro.com

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information.

When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

Keeping you signed in
Understanding how you use our website and how it performs on your system
Showing localized pricing

What types of cookies do we use?

There are many different types of cookies; however, our website uses:

Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
Advertising – Our Company uses Google’s services like Analytics and Ads. These services use cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Google’s services sometimes share some limited aspects of this data with third parties for advertising purposes. They may also share online data collected through cookies with their advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of Third Party websites and services

Our Company’s websites or apps contain links to Third Party Sites, like websites and services.

Third Party Sites are not under our control. The privacy and security practices of websites and/or services linked to or from our websites or apps are not covered by this Privacy Policy. Our privacy policy applies only to our websites and apps, so if you click on a link to another website, you should read their privacy policy. Our Company is not responsible for the privacy or security practices or the content of such websites or services.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page.

We may update our Privacy Policy from time to time. Our company reserves the sole right to update our Privacy Policy when we deem required to do so.

We will update the "effective date" at the top of this Privacy Policy.

We will not inform you about any updates. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

By using our apps and or websites or other services, after the effective date of the most recent Privacy Policy you explicitly agree with the content of the most recent Privacy Policy in place.

How to contact us

If you have any questions about Our Company’s privacy policy or about the data we hold on you; or if you would like to exercise one of your data protection rights; or if you wish to report a complaint if you feel that Our Company has not addressed your concern in a satisfactory manner, please do not hesitate to email us at support@drumtunepro.com