ZenChords Privacy Policy

Last Updated: April 2026

Version: 1.2

1. Introduction

ZenChords (“we”, “us”, or “our”) is committed to protecting your privacy. This policy explains how we collect, use, and safeguard your personal data when you use our website (zenchords.com) and the ZenChords mobile applications.

2. Data Controller

The Data Controller for your information is: Hatfold Limited

Company Registration Number: [16695752]

Registered Office: [Hatfold Limited Limited, 3 Grantlands, Uffculme, Devon. EX15 3ED]

Email: help(at)zenchords.com

3. The Information We Collect

We only collect the minimum amount of data necessary to provide our services:

• Account Information: Your email address and name (to create your account and sync purchases).

• Transaction Data: When you purchase audio packs, payments are processed by our secure third-party providers: Stripe, Apple Pay, and Google Pay. We do not store your credit card numbers or biometric data on our servers.

• Usage & Technical Data: We collect IP addresses and device identifiers via Google Firebase to ensure app stability, security, and to fulfill digital rights management.

4. Lawful Basis for Processing

Under UK GDPR, we process your data based on:

• Contractual Necessity: To deliver the digital products you have purchased.

• Legitimate Interests: To maintain the security of our platform and improve our musical tools.

• Consent: For any marketing communications you explicitly opt into.

5. How We Share Your Data

We do not sell, rent, or trade your personal data. We share information only with the following essential “Sub-processors” to operate ZenChords:

• Google Firebase: For secure account authentication and database hosting.

• Stripe / Apple Pay / Google Pay: To facilitate secure, encrypted payment processing.

• Regulatory Authorities: Only where required by UK law.

6. International Data Transfers

Our service providers (like Google) may store data on servers located outside the UK (e.g., in the US). We ensure these transfers are protected by Standard Contractual Clauses (SCCs) or equivalent UK-approved safeguards to ensure your data remains protected to UK standards.

7. Data Retention & Your “Right to Erasure”

We retain your data only for as long as your account remains active.

• Account Deletion: You can exercise your “Right to be Forgotten” at any time by using the “Delete Account” button within the App Settings (Help Page). This will permanently erase your personal data and purchase records from our active databases.

• Backups: Residual data may remain in secure, encrypted backups for a limited period (typically 30 days) before being overwritten.

8. Cookies & Tracking

We use essential cookies to manage your login session and secure your checkout. You can disable cookies in your browser settings, but please note that the Web Store and account syncing will cease to function without them.

9. Your Rights

You have the right to:

• Access: Request a copy of the data we hold about you.

• Rectify: Update inaccurate or incomplete information.

• Object: Withdraw consent for marketing at any time.

• Complain: If you are unhappy with how we handle your data, you have a formal right to complain.

10. Complaints Procedure (UK GDPR 2026)

If you wish to make a complaint regarding your data:

1. Email help(at)zenchords.com.

2. We will acknowledge your complaint within 30 days.

3. We will investigate and provide a full response without undue delay.

4. You also have the right to contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.