Privacy policy

1. Controller

The controller responsible for data processing under the GDPR is:

We are not required to appoint a data protection officer. For all privacy questions, write to the address above.

2. In short

• We do not upload your music, your library or your file paths.
• This website sets no cookies of its own and uses no analytics. Only the checkout page loads Paddle.
• The app only sends anonymous usage statistics if you agree. Nothing is preselected.
• Payments are handled by Paddle as merchant of record. We never see your card details.
• We do not sell or rent your data.

3. This website

3.1 Hosting

This website runs on our own server at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The server is located in Germany. When you open a page, your browser sends technical data such as your IP address, the requested page, the referrer and your browser type. The web server uses this data only to deliver the page. It keeps no access logs for this website, so this data is not stored. Legal basis is Art. 6 (1) (f) GDPR (legitimate interest in a secure, working website).

3.2 Fonts

Fonts are served from our own server. Your browser does not connect to Google or any other font provider.

3.3 No cookies, no analytics

This website sets no cookies of its own and uses no analytics or advertising tools.

The checkout page (/checkout) is the only exception. When you buy Cuetto, it loads Paddle’s checkout (Paddle.js) from Paddle’s servers. Paddle then processes your IP address, browser data and what you enter in the checkout, and may use cookies or similar technologies that are needed to complete the payment and prevent fraud. This happens under Paddle’s own responsibility (see section 5). Legal basis is Art. 6 (1) (b) GDPR and § 25 (2) TDDDG (strictly necessary for the purchase you requested).

3.4 “Email me the link”

If you ask us to email you the download link, we process your email address to send it. If you arrived through a link with a campaign label (for example from a post), we also store that label. We use double opt-in: you first receive an email with a confirmation link, and only after you confirm do we send you anything else.

Your sign-up is stored on our own server at Hetzner in Germany (see section 7). Emails are sent via Brevo, operated by Sendinblue SAS, 106 boulevard Haussmann, 75008 Paris, France, which processes your email address on our behalf under a data processing agreement (Art. 28 GDPR). To prevent misuse, we limit the number of sign-ups per network address and per email address. For this we use only hashed values, never the IP address or email address itself. They are kept in the server’s memory only, for a rolling window of one hour (24 hours for the email address), and are never written to disk.

Legal basis is your consent, Art. 6 (1) (a) GDPR. You can withdraw it at any time with the unsubscribe link in every email, which deletes your entry, or by writing to hello@cuetto.com.

Unconfirmed sign-ups are deleted 14 days after we sent the confirmation email. We keep confirmed sign-ups until you unsubscribe.

If we invite you to test Cuetto, we create a license for your email address and email you your license key (legal basis: Art. 6 (1) (b) GDPR). The license and your address are then kept like any other license (section 6.1). Details you gave us in an earlier beta application are never shared; you can have them deleted at any time with the unsubscribe link or by writing to us.

4. Contacting us

If you email us, we process your email address and the content of your message to answer you. Legal basis is Art. 6 (1) (b) GDPR if your message relates to a contract, otherwise Art. 6 (1) (f) GDPR. We delete the correspondence when it is no longer needed, unless statutory retention periods apply.

5. Purchases via Paddle

Cuetto Pro and Lifetime are sold by our online reseller Paddle.com Market Limited, United Kingdom (“Paddle”). Paddle is the merchant of record: it processes your order, payment, invoice, VAT and refunds as an independent controller. Please see Paddle’s privacy policy.

To issue and manage your license, we receive from Paddle your email address, country, the product you bought, and the status of your order or subscription, along with Paddle’s customer and subscription IDs. Legal basis is Art. 6 (1) (b) GDPR. We keep this data for as long as your license exists and as required by commercial and tax retention periods.

6. The Cuetto app

Cuetto runs on your Mac. Your library, your tags, your audio files and the tag suggestions Cuetto learns from your own tagging are processed locally and never sent to us. Backups of your library are stored on your Mac only. The iPhone and iPad companion talks directly to your Mac on your local network.

The following sections describe the few cases in which the app talks to a server.

6.1 License server and free plan

To check your license and the monthly limits of the free plan, the app contacts our license server. It sends a device ID, which is a one-way hash derived from your Mac’s hardware ID (we cannot read the hardware ID from it). When you activate a license, it also sends your license key and the name of your Mac so you can recognise it in the device list.

If you start the free plan, you enter your email address in the app. We send you one email with a confirmation link and your license key, and store the address with your free license so we can send you your key again if you lose it (“Lost your key?”). For Pro and Lifetime we get your address from Paddle and use it the same way. If you start a Pro free trial, we also use it to remind you 2 days before the trial ends, so you can cancel in time (a transactional email, legal basis Art. 6 (1) (b) GDPR). We only send you tips and news if you ask for them (next paragraph).

Tips and news (only with your consent). When you start the free plan, you can tick “Send me tagging tips and Cuetto news”. The box is never ticked for you. Your consent only counts once you click the confirmation link in the email (double opt-in). We store when you agreed, where (the app) and the wording, so we can prove it. We then occasionally send you tips on using Cuetto, new features and offers such as the Pro trial. Legal basis is your consent, Art. 6 (1) (a) GDPR. You can withdraw it at any time with the unsubscribe link in every such email or by writing to us; your license is not affected. After you withdraw, we keep only the date of your consent and of the withdrawal as proof.

If you use the “Lost your key?” form on this website, we process the email address you enter and send your license key to it, but only if a license exists for that address. To prevent misuse, we limit requests per network address and per email address; these counters are kept in the server’s memory only and are never written to disk.

In the free plan, the app counts on your Mac which tracks you tagged this month; this list stays on your Mac. In addition, the server counts how many tracks you wrote to your library this month. For this the app sends a hash per track, calculated together with your device ID. We cannot tell which tracks these are. We never receive titles, artists or file names.

Legal basis is Art. 6 (1) (b) GDPR (providing the plan you chose). We keep monthly usage counters for the current and the previous five months, then delete them. License and activation data are kept as long as the license exists.

6.2 Remote Access relay

If you turn on Remote Access (Pro), your Mac opens an encrypted connection to our relay server, and your iPhone or iPad reaches your Mac through it over HTTPS. To set this up, we store your Mac’s public key, a random relay ID and the related access data. Requests from your phone (for example tag changes, track details and audio previews while you listen) pass through the relay and their content is not stored.

Our server keeps an access log for the relay, the license server and the other app services. IP addresses, request headers and access tokens are removed before anything is written. The log records the time, the requested path (which can include the internal ID of a track you preview, never its title or file name), the status and the size of each request. It is rotated at 20 MiB, and at most five older files are kept. From this log we keep daily usage counters per relay ID (requests, data volume, previews, changes) for 90 days to detect misuse and plan capacity.

Legal basis is Art. 6 (1) (b) GDPR. When you turn Remote Access off or your subscription ends, your access is parked so you can turn it on again later. Parked access data is deleted after 365 days; you can ask us to delete it earlier at any time.

6.3 Anonymous usage statistics (only with your consent)

When you first set up Cuetto, we ask whether you want to share anonymous usage statistics. Both options are equal and nothing is preselected. Without your yes, nothing is collected or sent.

If you agree, the Mac app sends at most one package per day with counters (for example how many tracks were tagged, whether the setup assistant was finished), the app and macOS version and your plan. The package carries a random installation ID that is not linked to your device ID or license. We store this ID only in hashed form. We never receive titles, artists, file paths or other content from your library.

Per-installation data is deleted after 90 days at the latest; after that we keep only aggregated totals that cannot be traced back to anyone. Legal basis is your consent, Art. 6 (1) (a) GDPR and § 25 (1) TDDDG. You can withdraw consent at any time in the app’s settings, with effect for the future.

6.4 Feedback and bug reports

If you send feedback from the app, we receive your message, the type (bug, idea, other), app and system version, your plan and, only if you enter it, your email address. If you choose to attach diagnostics (preselected only for bug reports, with a preview of exactly what is sent), we also receive technical details: app and bridge versions, how long the app has been running and what kind of folder it runs from; macOS version, Mac model, chip, memory, language, region and time zone offset; free space, file system and type (internal or external) of the drive your library is on; rekordbox version, whether it is running, database version and library counts; license plan, status and expiry; Remote Access state with a hashed access ID, tunnel status and last check; paired and connected devices (device type, app version, connection type, which device is tagging); counts of pending changes; session counters such as swipes; recent apply, sync and error events, also from earlier sessions; the result of the last apply with counts of applied and skipped changes and their reasons; whether rekordbox changed the library since the app read it (from file dates only, without opening the database); a list of likely causes when changes don’t show up in rekordbox; crash reports of the app from the last 14 days (crash type and the app’s own function names only); and recent log lines of the app. The app keeps a local list of at most 400 such events, which stays on your device unless you attach diagnostics. Diagnostics never include track titles, artists, playlist or tag names, file names or paths, license keys, tokens, PINs, your email address or device names.

We use this data to fix problems and improve Cuetto, and your email address only to reply to you. We track reports in a private issue tracker without your email address. Legal basis is Art. 6 (1) (f) GDPR (our interest in a working product) and, for your email address, Art. 6 (1) (a) GDPR. We keep feedback until the issue is resolved, at most 24 months, or earlier on request.

6.5 Online lookups for artwork and metadata

When you use the online lookup, the app sends search terms such as artist, title and album of the selected tracks directly from your Mac to public music databases: Deezer, Apple (iTunes Search), MusicBrainz and Discogs. These services see your IP address and the search terms and process them under their own privacy policies. This only happens when you start a lookup. Legal basis is Art. 6 (1) (b) GDPR.

6.6 Cuetto for iPhone and iPad

The companion app talks directly to Cuetto on your own Mac: on your local network, or through the Remote Access relay described in section 6.2. For this it asks for Local Network access, and for the camera only to scan the pairing code shown on your Mac. Pairing data (your Mac’s address and an access token) is stored on your device only. The app contains no tracking, no advertising and no analytics SDKs, and it sends no usage statistics.

The demo mode (“Explore the Demo”) works entirely offline with sample data. If you use Send Feedback in the app, we receive your message, optionally your email address, technical details (app and iOS version, device model, connection type) and a random installation ID that is not derived from your device. If you attach diagnostics, we also receive connection and sync status, the Cuetto version on your Mac and recent events and log lines of the app, with the same exclusions as on the Mac. This is handled as described in section 6.4.

6.7 Update check

The app checks our server for a newer version when it starts and once a day, and, with an active license, downloads updates from our server. These requests contain the app version. It appears in our server’s access log without your IP address, as described in section 6.2.

7. Recipients and transfers

Our website, license, relay and feedback servers are operated by us and hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, as our processor under Art. 28 GDPR. The same servers store download link requests (section 3.4). Payments: Paddle (section 5). Emails (sign-up confirmations, license keys, trial reminders, lost key requests, tips and news if you agreed): Brevo, operated by Sendinblue SAS, Paris, France, as our processor under Art. 28 GDPR (sections 3.4 and 6.1). We do not share your data with anyone else unless we are legally required to.

Paddle is based in the United Kingdom, for which the European Commission has issued an adequacy decision. Online lookups (section 6.5) may involve providers outside the EU, which you contact directly from your Mac.

8. Your rights

Under the GDPR you have the right to:

• access the data we hold about you (Art. 15)
• have it corrected (Art. 16) or deleted (Art. 17)
• restrict processing (Art. 18)
• receive your data in a portable format (Art. 20)
• object to processing based on legitimate interest (Art. 21)
• withdraw consent at any time, with effect for the future (Art. 7 (3))

To use these rights, write to hello@cuetto.com. You also have the right to lodge a complaint with a data protection supervisory authority, for example the one responsible for our place of business: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestraße 2-4, 40213 Düsseldorf, Germany.

We do not use automated decision-making or profiling.

9. Changes

We update this policy when our services or the law change. The current version is always available on this page.