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 uses no cookies and no analytics.
• 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 currently uses no cookies, no analytics and no advertising tools.

3.4 Beta sign-up and “Email me the link”

If you join the beta or ask us to email you the download link, we process your email address and, only if you enter them, your name, the size of your library and the DJ software you use. 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. While our email sending is not yet set up, unconfirmed sign-ups are kept for up to 60 days so they are not lost before the confirmation email can go out. We keep confirmed sign-ups until the beta ends or you unsubscribe, whichever comes first.

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 Founder 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.

In the free plan, 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, we also receive technical details such as the database version, the number of tracks and pending changes and recent log lines of the app. Diagnostics never include license keys, access tokens or the paths of your music files.

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 Update check

The app checks our server for a newer version. This request contains 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 beta sign-ups and download link requests (section 3.4). Payments: Paddle (section 5). Sign-up emails: Brevo, operated by Sendinblue SAS, Paris, France (section 3.4). 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.