Privacy policy

Data controller

de Aloe Greco Informatica di dott. Olga de Aloe - Sviluppo Software e Consulenze in Materia di Informatica, VAT no. IT07156900636, Via Michelangelo da Caravaggio, 143/E - 80126 Napoli, Italia.  Tel. 08118097143.

To exercise your rights, write to amministrazione@dealoegrecoinformatica.biz.

Categories of data subjects

• registered users;
• buyers and guests who use the service without registering;
• recipients of songs and gifts, whose data are provided by the person making the gift;
• contact people at reseller shops;
• visitors to the website.

Categories of data processed

Identifying and contact data, authentication data, billing and order data, content uploaded or entered to generate the songs (title, story, dedication, keywords, images), recipients' contact details, access and delivery logs, technical security data and data on the use of the public player.

Purposes and legal basis

• creating and managing the account — performance of the contract;
• generating, storing, checking and sending songs — performance of the contract;
• managing purchases, packs, gift codes, payments and usage limits — performance of the contract;
• abuse prevention, security and administrative auditing — legitimate interest in the integrity of the service and the protection of recipients;
• legal, accounting and tax obligations and defence of rights — legal obligation and legitimate interest;
• service communications (suspensions, operational notices) — performance of the contract;
• anonymous, aggregate visit statistics — legitimate interest;
• promotional emails (reminders about songs not yet purchased, discounts and news), only to those who ticked the box — consent, which can be withdrawn at any time;
• optional consents (non-essential statistics/communications; personal voice, where active) — consent.

Whether providing data is mandatory

The data needed to create the account, generate the song and complete the purchase are necessary to provide the service: without them the service cannot be provided. The recipient's contact details are necessary only to deliver a gift. Data tied to consent (optional statistics/communications, personal voice) are optional: refusing has no consequence other than the unavailability of that specific feature.

Recipients and categories of recipients

Data may be processed by technology providers and processors involved in: application hosting and data storage; payments; email or Telegram delivery; the automated writing of the lyrics; AI music generation; security and abuse protection. Payment providers process data according to the roles and purposes set out in their respective agreements and privacy notices; depending on the service used, they may act as data processors and/or as independent controllers. Card and bank details never pass through our systems.

Data sent to generation providers

To generate the Content we send the technical provider only the information needed for production, such as the text to be processed, musical directions, style, mood and other generation parameters. We do not send the provider, where not needed for generation, your account identifiers, payment data, your contact details, credentials or the technical identifiers we use internally. The content sent for generation is therefore separated, as far as technically possible, from the information we use to identify account, order and payment.

This does not mean such data is “anonymous”: the text you write may contain information referring to you, the recipient or other people. We therefore treat it as minimised content separated from identifiers, not as anonymous data.

Transfers outside the European Economic Area

The service's hosting is located in the European Union. Some external providers may instead involve processing of data outside the EEA. Where this occurs, the transfer is based on the safeguards provided by law (such as standard contractual clauses or an adequacy decision), where available.

For the music generation provider (MusicGPT), the exact location and the transfer basis are currently being verified: this section will be updated once the verification is complete.

Automated processing

Before a song is created, the request may undergo an automatic content check. This does not produce legal effects or similarly significant effects: a rejected request is returned with the reason and can be corrected and resubmitted. No automated decision-making within the meaning of art. 22 GDPR is carried out.

Visit statistics (anonymous and aggregate)

To measure the service's trend in anonymous form, we keep aggregate counts of visits, per day, brand and geographic area (the Italian region, or the country from abroad). This measurement takes place without cookies and without storing the IP address: the IP is used for an instant to derive only the area and then discarded, and only numbers remain, never data referable to an individual. Legal basis: legitimate interest (art. 6.1.f GDPR). As these are aggregate data with no storage on the device, no consent is required. Details are in the cookie policy.

In the same way we count where visits come from: the kind of source (a search engine, a social network, another site, one of our emails), taken from the page the browser says it comes from or from the markers in our own links. On a song you start and on a purchase we note only that source (for example «Google»), to know which channels work; never the page you visited or your browsing.

Information about other people

When personalising the Content you may provide information about the gift recipient or other people. Use only information that is relevant and necessary to create the Content, and avoid entering confidential, excessive or particularly sensitive information.

In particular, please do not enter special categories of personal data — health information, data on sexual life, religious or political beliefs, judicial data or other highly sensitive information — unless this is strictly necessary and lawful. Enter only what the song needs.

If you are the recipient of a song or a gift

Some data about you may have been provided by the person who created the gift, not by you. Where the data comes from: the user who made the gift. Categories: your name, a contact detail (email, Telegram username or postal address) and the message/dedication the sender wrote for you. Purpose: to deliver the song or gift to you and to let the sender know it was opened. Legal basis: performance of the contract with the sender and the sender's legitimate interest.

You have the right to access your data, to have it rectified or erased, to restrict or object to its processing. To have your data removed or corrected, or to receive the information required by art. 14 GDPR, write to amministrazione@dealoegrecoinformatica.biz. You can ask this even if you never created an account.

Data received from third parties

Beyond the recipient data described above, we receive from payment providers the opaque references and outcomes of transactions, and — for gifts purchased through a reseller shop — the order data strictly needed to issue and manage the gift code.

Promotional emails

If you tick “I’d like to receive emails with reminders about my songs, discounts and news” (when creating a song, signing up or from your account), we may write to the address you gave us to remind you of a song you have not purchased yet, to offer discounts and to tell you about news. The box is never mandatory and never pre-ticked: the service works the same without it. We keep when you ticked it, where and with which wording, so that we can prove it. You can withdraw it at any time: from the link at the bottom of every email, without signing in, or from the consents page of your account. From then on we no longer write to you for these purposes; emails about your purchases and gifts keep arriving. If you receive these emails without ever having consented, use that link or write to us.

Retention

We do not use a single retention period. As a criterion: account data are kept while the account exists, plus the configured tolerance period; songs and their content follow the song; drafts have short windows; access links are short-lived; visit statistics are aggregate and contain no personal data; accounting and tax documents are kept for the term set by law. When a song is deleted, the content is removed from ordinary use, while minimal audit data and technical references necessary to protect the system may remain.

Channels

Web. The website uses only technical cookies and anonymous, aggregate server-side statistics, as described in the cookie policy.

Telegram. If a gift is delivered on Telegram, the message and the recipient's Telegram username are processed to deliver it; delivery relies on the Telegram service.

Android / iOS apps. The apps use the same service and the same purposes described here; in-app purchases are handled by the Apple and Google stores, which act as independent controllers for their operations. Privacy, terms and the account-deletion request are reachable from the app and from the web.

Reseller shops (Shopify), where active. When a gift is sold through a reseller's shop, we receive only the data strictly needed to issue and manage the gift code. The dedicated notices are published under the business section.

Your rights and complaint

The data subject may exercise, in the cases provided by law, the rights of access, rectification, erasure, restriction, objection and portability. Requests can be sent to amministrazione@dealoegrecoinformatica.biz. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

Final notes

This notice is kept up to date whenever new providers, new purposes, new trackers, new profiling methods or new data-transfer flows are introduced.