Behind the Hands, LLC (“BtH””, “we”, “us”, “our”) and its websites and mobile applications (the “BtH Properties”) promote the development of piano skills throughout the world, providing sheet music available for practice and other services (collectively the “Services”).
BtH respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use BtH Properties.
Access to this Privacy Policy is provided at the time of account registration, and users are encouraged to review it before using the Services. If for any reason you are not comfortable with this privacy policy, you may delete your account and any data that we may have collected about you will be promptly deleted.
We collect the following personal information for the purposes and retention periods shown below.
Category
Identifiers
Payment Info
User experience
Communications
Examples
Apple USerID, e-mail address, device-specific local password, user preferences and personalization settings, network related information such as IP address, device IDs
Card details (not collected by BtH; collected by Apple and processed by payment providers)
Application usage, interaction events, feature usage data and related event parameters, subscription status information
Crash reports and diagnostic information
Support tickets
Purpose (why we use it)
Account creation, login, security, fraud prevention
Purchases (e.g., BtH subscriptions)
Personalization of the user experience such as language selection, note-naming language, theme settings, interface customization settings, application state and other application preferencesAnalytics and product improvement to understand how users interact with the application, measure feature adoption and improve the user experience.
Application stability, diagnostics, and troubleshooting to identify, investigate, and resolve application errors, crashes, and performance issues
Product maintenance
Retention
Life of account; deleted upon account closure
Not stored by BtH (collected by Apple)
Typically retained until user deleted account; aggregate or de-identified data may be retained for longer periods
Generally retained for up to 100 days; perhaps longer if needed for security / debugging purposes
Typically, 2 years (longer if under review)
Where we process personal information, our legal bases under the GDPR/UK GDPR include:
· Legal Obligations (Art. 6(1)(c)) – to comply with accounting, tax, anti-fraud, and regulatory requirements.
· Contract (Art. 6(1)(b)) – to provide our Services, including account management, piano practice, and support.
· Legitimate Interests (Art. 6(1)(f)) – to secure our Services, prevent fraud, conduct analytics, and preserve historical records.
The BtH website contains video content. BtH may retain information about which videos you watch and store that information with third-party service providers. BtH does not provide information about your video watching to any third party other than for the purpose of allowing BtH to provide and enhance its services. By accepting this privacy policy, you are providing your express and informed consent to BtH’s retaining records regarding your choice of videos to watch.
· You (account registration, support).
· Your device (cookies, SDKs, telemetry, crash logs).
· Payment processors (confirmation and tokens; we do not store card numbers).
· Analytics partners (limited identifiers; see §8).
· Provide, personalize, and operate the Services.
· Authenticate and secure accounts; prevent fraud.
· Enforce Terms of Service.
· Communicate about updates, features, promotions (with your preferences).
· Perform analytics, improve performance, and fix bugs.
· Comply with legal obligations and cooperate with lawful requests.
We disclose personal information to:
· Service providers (hosting, payments, customer support, analytics and others) under contracts that limit their use to our instructions.
· Analytics partners (limited identifiers).
· Law enforcement/regulators, when legally required, or to protect the users and BtH.
· Corporate affiliates/successors in case of merger, acquisition, or reorganization.
We do not sell personal information, either for money or in the context of ad/analytics disclosures for targeted advertising.
Purpose limitation: This data sharing is limited to optimizing the player/member user experience and improving reactivation/retention. It is not used for profiling credit, insurance, employment, or any other purpose with significant legal or similarly significant effects on individuals.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR): BtH has a legitimate interest in maintaining an active and engaged user base, and this sharing is conducted in a privacy-preserving manner that minimizes the data exchanged and does not involve third-party advertising.
We do not use cookies and similar technologies for advertising purposes.
Depending on your location, you may have rights to access, delete and correct the personal information that we collect and retain about you, and appeal any denial of your request relating to your exercise of those rights.
· Submit requests via privacy@behindthehands.com, including your BtH Username and email address associated with your Apple ID in the email body.
· We will verify your identity before acting on a request. You may use an authorized agent as allowed by law.
· We do not discriminate against you for exercising your rights.
If you are located in the EEA, UK, or Switzerland, you have additional rights under applicable law, including:
· Right of access to your personal information.
· Right to rectification of inaccurate or incomplete information.
· Right to erasure (“right to be forgotten”).
· Right to restrict processing in certain circumstances.
· Right to data portability (to receive your data in a machine-readable format).
· Right to object to certain processing, including for marketing.
· Right not to be subject to automated decision-making producing legal or similarly significant effects.
· Right to lodge a complaint with a supervisory authority.
To exercise the rights, contact us at the address specified in Section 17 below. If you are located in the European Economic Area, you have the right to lodge a complaint with the data protection supervisory authority in your Member State of residence, place of work, or where you believe a violation of applicable data protection law has occurred.
We generally retain data until a user deletes his/her account, at which time it is promptly deleted. Notwithstanding the foregoing, we reserve the right to retain data for the following retention periods:
· Payment/invoice data: 7 years (accounting/tax)
· Security logs: ~100 days (longer if needed for security purposes)
We may de-identify or aggregate data for analytics and service improvement and retain such de-identified or aggregated data indefinitely.
We may retain Payment and invoicing data for seven (7) years to comply with applicable accounting, tax, and financial record-keeping obligations under U.S. federal and state law (Article 6(1)(c) GDPR). During such retention periods, such data is restricted to compliance purposes and access is limited to authorized personnel only.
We process data in the United States and may transfer it to other countries. For EEA/UK/Swiss users, we rely on Standard Contractual Clauses and other safeguards for transfers.
To operate our Services, we use trusted vendors, including:
· Cloud hosting (e.g., AWS, U.S./EU)
· Payment processors (e.g., Apple Pay)
· Analytics partners (Google Analytics, etc.)
All vendors above are bound by contract, and where applicable, EU Standard Contractual Clauses govern international data transfers.
We use administrative, technical, and organizational measures, including encryption in transit and at rest, access controls, monitoring, and regular testing. No system is perfect. Please use strong passwords and notify us of any suspected unauthorized access.
Our Services are intended for users aged 18 or older. We do not knowingly collect personal information from children under 13 (or under 16 where required by applicable law).
If you believe a child under 13 (or under 16 where required by applicable law) has provided personal information to BtH, contact privacy@bridgebase.com.
We may update this Policy from time to time. If we make material changes, we will notify you via email or an in-product notice. The “Effective” date shows the latest version.
For any questions or concerns about Privacy Policy or any of our Services, contact us at privacy@behindthehands.com or at
Chief Privacy Officer
Behind the Hands LLC
15 Appaloosa Lane
South Hamilton, MA 01982
USA
