Privacy Policy

1. Who We Are

The Thol application ("Thol", "our Service") is provided by Black Goblin Audio Limited. We are the data controller for your personal data. If you have any questions about this policy or your data, please contact us at privacy@thol.app.

2. The Data We Collect

• Account Data: Your name and email address.
• User Content: Video files you upload for analysis. We collect and store this data in your private account space to provide you with access to it after the initial analysis.
• Generated Files: The MIDI files and associated data created by the Service, which are stored in your account.
• Usage Data: With your consent, we use analytics cookies (Microsoft Clarity) to collect data about your interactions with our app. This may include session recordings, heatmaps, and clicks to help us improve the service.
• Communications: Any emails or feedback you send to us.

3. Our Lawful Basis for Processing (UK GDPR)

We only process your personal data when we have a valid legal reason to do so. Our lawful bases are:

• Performance of a Contract: We process your Account Data, User Content, and Generated Files to provide the Thol service you have signed up for.
• Consent: We rely on your explicit consent to process Usage Data via non-essential analytics cookies (Microsoft Clarity). You have full control over this consent and can change your mind at any time.
• Legitimate Interests: We process your Communications to provide support and improve our services.

4. How We Use Your Data

• To create and manage your account.
• To provide, secure, and operate the Thol service.
• To analyse and improve the user experience of our app, but only with your explicit consent.
• To communicate with you about service updates or support requests.

5. Third-Party Data Processors

We use the following third-party processors to deliver our service:

• Supabase (EU): Database, authentication, and file storage.
• Google Cloud Platform (EU/UK/US): Temporary AI processing of video files.
• Microsoft Clarity (US): Product analytics (subject to your consent).
• Bubble.io (US): Application hosting.

6. International Data Transfers

Some of our processors (Microsoft, Bubble, and Google Cloud Platform) are based in or may process data in the US. When your data is transferred outside the UK/EEA, we ensure it is protected by appropriate legal safeguards, such as the UK's adequacy regulations for the EU-U.S. Data Privacy Framework or the UK's International Data Transfer Agreement.

7. Data Retention & Deletion

We are committed to the principle of storage limitation. Our retention policies are as follows:

• Active Accounts: We retain your Account Data and Generated Files for as long as your account remains active.
• User Content (Video Files): Your original video files are stored after analysis and are linked to your account. They are permanently deleted when you delete your account, when your account is deleted due to inactivity, or upon your specific request for erasure as covered under your rights.
• Inactive Accounts: To ensure we do not hold data longer than necessary, we will consider your account inactive if you do not log in for a continuous period of 24 months. We will notify you by email before taking any action. If you do not reactivate your account, we will permanently delete it along with all associated data, including Account Data, Generated Files, and any stored User Content (video files).
• Manual Deletion: You can permanently delete your account and all associated data at any time from your 'Account' page. This action is irreversible and will delete all data, including your video files.

8. AI and Automated Processing

Thol uses automated AI systems to generate spotting data from your video. This process does not involve making any legal or similarly significant decisions about you. You retain full control and responsibility over the use of the Generated Files.

9. Your Data Protection Rights

Under UK GDPR, you have the right to: access, rectify, erase, restrict processing of, and port your personal data. To make a request, please contact us at privacy@thol.app. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

10. Cookies and Tracking Technologies

We use cookies and similar technologies to help our application function and, with your permission, to understand how you use it. For detailed information on the specific cookies we use, their purpose, and how you can manage your consent preferences, please see our comprehensive Cookie Policy.