Tokklr Privacy Policy

Version 2.0

This policy explains what Tokklr does with your personal data, why, and what you can decide about it. Tokklr is the app; The Complete Guitar Method is the course you learn from inside it. This policy covers both, and it sits alongside our Terms of Use and Licence Agreement.

1. Who we are

Tokklr is published and operated by Kusters IT BV, with its registered seat in Antwerp, Belgium ("we", "us", "our"). We are the controller of the personal data described here.

Enterprise number: BE 0777.616.237.

Registered address: De Moystraat 4, 2018 Antwerpen, Belgium.

For any privacy question or request: privacy@tokklr.com.

2. The short version

You can use Tokklr without giving us an email address. An account works anonymously until you choose to attach one.
We never receive your microphone audio. Listening features run entirely on your device.
No advertising, no analytics, no crash-reporting, no tracking SDKs. There are none in either app.
We ask for your year of birth when you start, and you cannot skip that question. We ask for the year alone, never the full date. We do not ask for location, health or any other special-category data.
Your data is stored in the European Union.
We do not sell your data, and we do not use it to train models.

3. What we collect, and why

Your account

Your email address (optional, and only if you choose to sign in), your display name and username if you set them, and a password if you use one. Passwords are stored only as a cryptographic hash, never in readable form, and are never sent back to any app or browser.

Why: to create and secure your account, to sign you in, and to send you account messages such as a sign-in link or an address-verification message. Basis: performance of our agreement with you, plus our legitimate interest in keeping accounts secure.

What you tell us when you start

The instrument you chose and your own description of your experience (for example "never played"). Why: to put you at a sensible starting point. Basis: performance of our agreement with you.

Your year of birth, asked on the same screens. This one is required: you cannot move past the question. We ask for the year alone, never the day or the month. Why: to work out which age group you are in, so that what we say about the people we serve is true rather than assumed — section 7 explains what that grouping does and does not change. Basis: our legal obligations towards younger learners, and our legitimate interest in looking after them.

How you use the course

Which lessons and exercises you opened and when, what you marked as done, your practice streak and the dates you practised, per-lesson play counts and a timestamped record of plays, the ratings you give songs, the areas the app tracks as worth revisiting, and the written reflections you choose to type into a lesson.

Your reflections are free text. Please do not type anything there you would not want stored.

Why: to show your progress, to let you continue where you stopped, to choose what to suggest next, and, in aggregate, to account fairly to the people whose music appears in the course. Basis: performance of our agreement with you.

Your settings

Your app settings sync to your account so they follow you between devices. This includes your language, theme, notation and playback preferences, and your notification choices. Basis: performance of our agreement with you.

Your devices

For each signed-in device: the device name it reports (for example "iPhone 17"), when it was last seen, and how it signed in. Session tokens are stored only as a hash. If you turn notifications on, we also store the push token your device provides. Why: so you can see and revoke your own sessions, and so notifications you asked for can reach you. Basis: performance of our agreement, and your consent for notifications.

Checking that the app is genuine

The app can prove to us that it is a real copy of Tokklr running on real hardware, using a check built into the device's operating system. Where it does, we keep the identifier that check produces, the public key that belongs to it, and the receipt the operating system issued, together with a count of how many times that installation has started up.

None of this is connected to your account. There is no place in those records to put a person, and we never join them to one. They tell us that a genuine installation exists; they do not tell us who is using it, and they carry nothing you typed or recorded. If you delete your account, these records are unaffected, because there is nothing in them that points to you.

Why: so that accounts can only be created by the real app, and not by a script pretending to be it. Basis: our legitimate interest in protecting the service from automated abuse.

Purchases

Which subscription or content you hold, when it runs to, and the transaction records the app stores return to us. We never see your card details. Basis: performance of our agreement, and our legal obligation to keep business records.

Messages and people

If you use the social features: your friend connections, and messages between you and a teacher. Messages are stored as written so they can be shown to both of you. Basis: performance of our agreement with you.

Operational records

Our servers write a technical log line for each request (method, path, response status, timing, a request identifier, the calling network address and the browser or app version string). Administrative actions on our side are recorded in an audit trail. Why: to run the service, investigate problems and detect abuse. Basis: our legitimate interest in a secure, working service.

4. Your microphone, and why we never receive your playing

Audio understanding is the heart of Tokklr, and it is built so that your playing stays yours.

Analysis runs on your device. Your audio is not uploaded, not stored on our servers, and not sent to anyone else. There is no server endpoint that accepts your recordings.
The microphone is off until you turn it on, for the feature you turned it on for, and you can withdraw that at any time in Settings.
Your consent choice never leaves your device either. It is kept in local device storage and is not synced to us.
The app stops listening when it goes to the background, on both platforms.
Tokklr does not use your camera. Neither app requests camera access.

Basis: your consent.

5. What other people can see

Other learners who are your friends, in your family plan, or in a message thread with you see only your display name and username. They never receive your email address or anything else from your account.
Your teacher, if you join a class, can see your identity and contact details as the account holder of a class you joined. Your detailed progress is shared only if you switch it on; it is off until you do.
Classmates see your name and streak in a class leaderboard, if your teacher has switched that leaderboard on. Ask your teacher to turn it off if you would rather not appear.

6. If your account was created for you

A teacher can create an account for a student and supply the name and email address for it. If that happened to you, we hold that data because your teacher gave it to us. You have exactly the same rights over it as anyone else, listed in section 12, and you can exercise them with us directly without going through your teacher.

7. Children

Tokklr is a general-audience app, and its audience is mixed: children learn from it too. When you start, we ask for your year of birth, and the answer is required. We ask for the year alone — never the day or the month — because the year is enough for what we do with it, and a full birth date is more than we need.

From that year we work out one of three age groups: under 13, 13 to 17, and 18 or over. Today that grouping changes nothing about how the app behaves. It exists so we can say truthfully which age groups we serve instead of claiming not to know. There is also nothing for it to switch off: there is no advertising, no advertising identifier, and the only person outside your own circle who can message you is a teacher your account invited or accepted. If any of that changes, the age group is where the change will apply, and we will say so here.

Where an adult (a parent, guardian or teacher) sets up or supervises an account for a child, that adult is responsible for deciding that this is appropriate and for accepting this policy on the child's behalf. If you believe a child's data is held here without the right authority, write to privacy@tokklr.com and we will remove it.

8. Who else processes data for us

We keep this list short on purpose.

Microsoft Azure hosts the service and stores its data, in the European Union.
Azure Communication Services sends our account emails.
Apple and Google deliver push notifications you asked for, and process purchases made through their stores. Their handling of a purchase is governed by their own terms and privacy policies.

We use no advertising, analytics, crash-reporting or attribution services. There is no such component in either app.

Some pages on our website load a stylesheet from a public content delivery network, which means that network sees the request. We are removing that dependency.

9. Where your data is

In the European Union (Microsoft Azure, West Europe). We do not routinely transfer personal data outside the EU. Push notifications and app-store purchases necessarily involve Apple and Google, who operate globally under their own safeguards. If anything else changes, we will update this policy before it does.

10. Cookies

Our website uses a small number of strictly functional cookies. There are no advertising or tracking cookies, and nothing is shared with third parties.

a session cookie, once you sign in, so the site knows it is you;
a security cookie that protects forms against cross-site request forgery;
a language cookie and a theme cookie, remembering your choices.

The app itself does not use cookies.

11. How long we keep things

While your account exists, we keep the data above so the service works.
Technical and audit records are kept for security and accountability. When an account is erased, the account reference in those records is removed so they no longer identify you.
Business records of purchases are kept for as long as tax and accounting law requires.
Backups. Our database keeps point-in-time backups for up to 35 days. Data you delete disappears from the live service immediately, and ages out of the backups within that window. We do not restore a backup to bring deleted data back.
Your microphone audio has no retention period, because we never receive it.

12. Deleting, and your other rights

There are two different things you can ask for, and they are not the same.

Delete this account. The account and every session stop working straight away. It stays recoverable for 30 days in case you change your mind, and is then permanently erased. If you have cancelled a subscription that still has paid time left, the recovery window runs to the later of the two dates.
Erase all my data. Immediate and permanent, with no recovery window.

Both are in the app under Settings. A few situations have to be settled first, and the app will tell you which applies: an active subscription has to be cancelled first, and a teacher who owns classes or has authored course content hands those over before erasing. We do not refuse silently.

You can also:

get a copy of your data, in the app, as a complete machine-readable export;
correct anything inaccurate, in the app or by writing to us;
withdraw consent for the microphone or notifications at any time, in Settings, without affecting what happened before you withdrew it;
object to or restrict some processing;
complain to a supervisory authority. In Belgium that is the Gegevensbeschermingsautoriteit / Autorité de protection des données. You may also go to the authority in your own EU country.

To exercise any of these, use the in-app controls where they exist, or write to privacy@tokklr.com.

13. Security

Data is hosted in the EU, connections are encrypted, passwords are stored only as hashes, session tokens are stored only as hashes, and access to production data is restricted and recorded. Two-factor authentication and passkeys are available on accounts that support them.

No service is perfectly secure. Keeping audio analysis on your device is a deliberate part of how we reduce what there is to lose.

14. If the business changes

We intend to move Tokklr into a dedicated company in future. If Tokklr, or the part of the business that runs it, is transferred, your data moves with it and this policy continues to apply until the receiving company publishes its own. We will tell you in the app before that happens.

15. Changes to this policy

We publish updated versions from time to time.

We will never show you an older version than the one you already have. Updates only move forward.
When a change materially affects you, we will tell you in the app.

16. Contact

privacy@tokklr.com for anything in this policy. Read it together with our Terms of Use and Licence Agreement.

Class leaderboard sharing. If your teacher enables sharing for a class, class members can export an image of the class leaderboard (positions, display names, and streaks) outside the app. Display names of members under 13 are never included in that export.