Privacy policy

This Privacy Policy explains how Branco Labs Ltd (“Branco Labs”, “we”, “us”, or “our”) handles information in connection with the mobile application Forma: Music Lab (the “App”).

Branco Labs Ltd is a company registered in England & Wales under company number 17387448, with its registered office at 82A James Carter Road, Mildenhall, IP28 7DE, United Kingdom. For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Branco Labs Ltd is the data controller for any personal data processed in relation to the App.

1. Summary

The only data flow outside your device is between your device and Apple, so that Apple can process App Store purchases and deliver optional audio content. We never see that data.

2. Information we collect

2.1 Information you provide directly

None. The App does not ask you to create an account, sign in, provide an email address, or submit any personal information.

2.2 Information collected automatically

None. The App does not include analytics, telemetry, advertising identifiers, tracking pixels, crash reporters, or any third-party SDK that transmits information about you or your device to Branco Labs or to any third party.

2.3 Information stored on your device

The App stores the following information locally on your device using Apple’s standard UserDefaults storage. This information never leaves your device and is not accessible to us:

• Your current subscription or credit status (as reported by Apple).
• App preferences (for example, favourite loops and saved mix titles).
• Audio files you export or save within the App’s sandbox.

You can erase all of this at any time by deleting the App from your device.

3. Apple’s services

The App uses two standard services provided by Apple. Your interactions with these services are governed by Apple’s own privacy policy, not by this policy. We do not receive personal data from Apple through these services.

3.1 In-app purchases and subscriptions (StoreKit)

Purchases and subscriptions in Forma: Music Lab are processed by Apple through StoreKit. When you buy a subscription or credit pack, Apple handles payment, receipts, renewal, cancellation, and refunds. We receive only anonymous transaction metadata (for example, the product identifier and whether a subscription is active) so the App can unlock the correct features. We do not receive your name, email address, billing address, or payment details.

3.2 On-demand resources

Some audio content in the App is downloaded on demand from Apple’s content delivery network the first time you use it. This download happens directly between your device and Apple’s servers. We do not host or log these downloads.

4. Device permissions

Forma: Music Lab does not request access to the microphone, camera, photo library, contacts, location, Bluetooth, or Apple’s App Tracking Transparency framework. If a future version of the App requires a new permission, we will update this policy and iOS will prompt you before that permission is granted.

5. Sharing your creations

When you export a mix, the App renders an audio file to a temporary folder on your device and opens the iOS share sheet. You choose whether to save the file to Files, Photos, iCloud Drive, AirDrop, a messaging app, or any other destination. Once you share a file with a third party (for example, uploading it to a social network), that third party’s privacy policy will apply. We have no involvement in, or visibility over, what you do with your exports.

6. Children

Forma: Music Lab is a general-audience music-creation tool and is not directed at children under 13. We do not knowingly collect personal data from anyone, including children. If you believe a child has provided personal data to us in error, please contact us and we will confirm that no such data exists on our systems.

7. Your rights under UK GDPR and EU GDPR

If you are located in the United Kingdom, the European Economic Area, or another jurisdiction with equivalent data-protection laws, you have the following rights in respect of personal data we hold about you:

• The right to be informed;
• The right of access;
• The right to rectification;
• The right to erasure (“right to be forgotten”);
• The right to restrict processing;
• The right to data portability;
• The right to object;
• Rights relating to automated decision-making and profiling.

Because we do not collect or store personal data about you, in most cases we will have no data to provide, correct, or delete. You can nevertheless exercise these rights, or ask questions about them, by contacting us using the details in Section 11.

You also have the right to lodge a complaint with a supervisory authority. In the United Kingdom this is the Information Commissioner’s Office.

8. Legal bases for processing

To the limited extent that we process any personal data (for example, if you send us an email at the contact address below), our lawful basis under Article 6 of the UK GDPR is:

• Legitimate interests (Article 6(1)(f)) — to respond to your enquiry, provide customer support, and keep records of correspondence; and
• Legal obligation (Article 6(1)(c)) — where we are required to retain or disclose information to comply with applicable law.

9. Data retention and security

We do not maintain a database of user personal data. Correspondence you send us by email is retained only for as long as reasonably necessary to answer your query and to keep a record of the request, after which it is deleted. We apply appropriate organisational and technical measures to protect that correspondence.

10. International transfers

Because we do not collect or store user personal data on our own systems, no international transfer of your personal data by Branco Labs takes place. Apple may process purchase and delivery data in jurisdictions outside your own, subject to Apple’s own safeguards described in Apple’s privacy policy.

11. Changes to this policy

We may update this Privacy Policy from time to time — for example, to reflect changes to the App or to applicable law. The “Effective date” and “Last updated” fields at the top of the policy will always show when the current version came into effect. Material changes will be communicated in the App or on our website before they take effect.

12. Contact us

If you have questions about this Privacy Policy, or if you wish to exercise any of your rights, please contact us at:

Branco Labs Ltd 82A James Carter Road Mildenhall IP28 7DE United Kingdom

Email: support@brancolabsltd.com

We aim to respond to all reasonable enquiries within 30 days.