PRIVACY POLICY
1. Who we are (the controller)
The controller of your personal data is Myceron s.r.o., Orešianková 9162/15, 840 08 Bratislava – mestská časť Záhorská Bystrica, Slovakia, operating the service under the name Funkum.studio.
- Company ID (IČO): 56937253
- Tax ID (DIČ): 2122509048
- VAT ID (IČ DPH): SK2122509048
- Registered in the Commercial Register of the Municipal Court Bratislava III, Section: Sro, Insert No. 187624/B
For any question about this policy or about your data, contact us at info@funkum.studio.
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR.
2. What data we collect and why
We collect only what the service needs in order to work. The table below lists each category, the purpose it serves, and the legal basis under Article 6 GDPR.
| Data | Purpose | Legal basis |
|---|---|---|
| Account data: name, email address, profile photo and account identifier received from Google when you sign in | Creating and running your account; identifying you as the owner of your content | Contract (Art. 6(1)(b)) |
| Artist profile: display name, biography, avatar and header images | Displaying your public artist page | Contract (Art. 6(1)(b)) |
| Content you upload: audio, images, video, software and configuration files, together with titles, descriptions, tags and technical metadata (size, duration, tempo, checksum) | Storing, versioning, streaming and sharing your work as you instruct | Contract (Art. 6(1)(b)) |
| Collaboration data: co-author names, roles, percentage splits, group membership, and the name and email address of people you invite | Crediting collaborators and sending the invitation you asked us to send | Contract (Art. 6(1)(b)); legitimate interests for the invitee (Art. 6(1)(f)) |
| Subscription data: plan, status, renewal date and the customer and subscription identifiers issued by our payment provider | Providing and billing the subscription; enforcing storage limits | Contract (Art. 6(1)(b)) |
| Consent records: your acceptance of these terms, your marketing choice and your cookie choice, each with the date | Demonstrating that consent was given, as GDPR requires | Legal obligation (Art. 6(1)(c)) |
| Marketing preference and email address | Sending news, offers and updates — only if you opt in | Consent (Art. 6(1)(a)) |
| Analytics data: pages viewed, approximate location derived from a truncated IP address, device and browser type | Understanding how the site is used so we can improve it | Consent (Art. 6(1)(a)) |
| Server and security logs, including IP address | Keeping the service available, diagnosing faults and preventing abuse | Legitimate interests (Art. 6(1)(f)) |
We do not collect special categories of personal data, and we do not carry out automated decision-making or profiling that produces legal or similarly significant effects (Article 22 GDPR).
3. Cookies and similar technologies
We use essential cookies and browser storage to keep you signed in, to remember your cookie choice, and to carry an invitation link through the sign-in process. These are strictly necessary and are set without consent, as permitted by the ePrivacy Directive.
Analytics cookies are only set if you choose Allow all cookies. If you choose essential cookies only, no analytics script is loaded and no analytics cookie is written. You can change or withdraw your choice at any time using the Cookie settings link in the footer; withdrawing also deletes the analytics cookies already stored.
4. Who we share data with
We do not sell your personal data. We share it only with the service providers below, who process it on our instructions as processors under Article 28 GDPR:
| Provider | Purpose | Location |
|---|---|---|
| Google Ireland / Google LLC (Firebase Authentication, Firestore, Cloud Run, Google Analytics) | Sign-in, database, application hosting, analytics | EU (europe-west1 / europe-west3); support may involve access from outside the EEA |
| Cloudflare, Inc. (R2 object storage) | Storing the files you upload | EEA and other regions |
| Stripe Payments Europe, Ltd. | Subscription payments and billing | EEA and United States |
| Purelymail | Sending transactional and, if you opted in, marketing email | United States |
We may also disclose data where we are legally required to do so, or where it is necessary to establish, exercise or defend legal claims.
Payment card details are entered directly with Stripe and never reach our servers. Stripe acts as an independent controller for parts of that processing; see their privacy policy for details.
5. International transfers
Some of the providers above process data outside the European Economic Area. Where that happens, the transfer is covered by the European Commission’s Standard Contractual Clauses, or by an adequacy decision such as the EU–US Data Privacy Framework where the provider is certified under it. You may request a copy of the relevant safeguards from us at any time.
6. How long we keep data
- Account, profile, content and collaboration data: until you delete your account, or until you delete the individual item.
- Consent records: for as long as the consent is relied upon, and for a reasonable period afterwards as evidence that it was given.
- Invitation records: until accepted, or until the release they relate to is deleted.
- Billing records held by our payment provider: for the period required by tax and accounting law, generally ten years under Slovak law.
- Server logs: a short rolling period, typically no more than 90 days.
When you delete your account we remove your profile, uploaded files, releases and collections. We retain a minimal record linking your former account to payment records where accounting law requires it. Deletion is irreversible.
7. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you, and obtain a copy (Art. 15);
- have inaccurate data corrected (Art. 16);
- have your data erased (Art. 17) — you can do this yourself from your profile;
- restrict processing in certain circumstances (Art. 18);
- receive your data in a portable, machine-readable format (Art. 20);
- object to processing based on our legitimate interests (Art. 21);
- withdraw consent at any time, without affecting processing already carried out (Art. 7(3)) — use the communication setting in your profile for marketing, and the footer link for cookies.
To exercise any of these rights, email info@funkum.studio. We respond within one month, as required by Article 12(3).
If you believe we have handled your data unlawfully, you have the right to lodge a complaint with a supervisory authority. In Slovakia this is the Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27, Slovakia. You may also complain to the authority in your own country of residence.
8. Content you publish
Content you set to shared, and your artist and group pages, are accessible to anyone holding the link, without signing in. Anything you place in them — including your display name, biography and any personal data in titles or descriptions — becomes public. Please consider that before publishing. Setting content back to private removes public access going forward but cannot recall copies already downloaded.
9. Security
Access to the database and to stored files is only ever made by our server using credentials that are never exposed to the browser; files are served through short-lived signed URLs. Traffic is encrypted in transit. No system is perfectly secure, but we take appropriate technical and organisational measures as required by Article 32 GDPR, and will notify you and the supervisory authority of a breach where the GDPR requires it.
10. Children
The service is not intended for children under 16. We do not knowingly collect data from anyone under that age; if you believe we have, contact us and we will delete it.
11. Changes to this policy
We may update this policy as the service changes. The date at the top always reflects the current version, and we will tell you about material changes before they take effect. Continued use after that point means the updated policy applies.
See also our Terms & Conditions.