This Privacy Policy explains how Ryusuke Seto Music Lab ("the Operator," "we," or "us"), a business operated from Japan, handles information when you use Tonic Clef ("the Service"). By using the Service, you agree to this Privacy Policy and our Terms of Service. If you do not agree, do not use the Service.

Controller: Ryusuke Seto Music Lab, Japan.

The Service is offered to individual users worldwide from Japan. We are not established in the EU, UK, or US for data-protection registration purposes unless separately stated.

Contact: https://tonicclef.ryusukeseto.com/feedback (Google sign-in required; product and support inquiries). Privacy disputes are resolved under Japanese law and the exclusive jurisdiction in our Terms of Service.

Technical data: pages viewed, IP-derived approximate location, device and browser type, OS, referral URLs, timestamps, and similar logs.

Preferences: display language (cookie "tonic-clef-lang", up to about one year).

Account data (if you sign in): account IDs, profile fields you provide (e.g., display name, instrument preferences, optional Coach memo), learning history (exercises, settings, scores, progress), Footprints activity logs (e.g., Bootcamp results and stamps you save), Coach Dialogue chat messages if you use Pro Coach chat, and feedback you submit.

Payment data: Stripe, Inc. processes payments. We receive subscription status, billing period, and limited metadata (e.g., card brand, last four digits). We do not store full card numbers.

We do not intentionally collect sensitive categories (health, biometric IDs, government IDs, etc.). Do not submit such data through the Service.

We process information to: provide and operate the Service; perform our contract with you; pursue legitimate interests (security, cookieless analytics, improvement, fraud prevention); and, where required, obtain your consent. We currently use only essential cookies (language preference and authentication) and no non-essential or advertising cookies.

Learning history is used only for signed-in features, personalization, AI-assisted tools you use, and in-Service progress—not for third-party advertising.

We use a privacy-friendly, cookieless analytics tool that we self-host on our own infrastructure. It sets no cookies, does not track you across other websites, and does not collect identifying personal data such as your name or email.

It records only aggregated, non-identifying usage (e.g., pages viewed, referral URLs, approximate country/region derived from IP, device and browser type). IP addresses are used transiently to derive this information and are not stored in a way intended to identify you. Because analytics is cookieless and non-identifying, no analytics consent banner is required.

We use cookies only for essential functions: your language preference and authentication (for Google or Apple sign-in). Our analytics is cookieless and sets no cookies.

Blocking cookies may disable features such as language memory or staying signed in. We do not use cookies for advertising.

Coach and related features may send prompts, context, and learning history to third-party LLM providers to generate responses.

If you use Coach Dialogue (Pro), we send your messages, relevant recent chat history, on-screen context, and any Coach memo you have saved in Settings to the LLM provider. Do not include sensitive personal information in Coach messages or your memo.

To personalize future sessions, Coach may also remember durable learning goals it infers from your conversations. This goal memory is stored with your chat history; it is disabled when you turn off chat history saving and is removed when you delete your chat history.

Such data is used only to operate AI features you use. We do not sell learning history to AI vendors for their independent advertising products.

When Coach features use third-party APIs, your prompts and responses are not used to train their models, except for limited operational logging such as abuse detection.

AI output may be wrong or unsafe. See our Terms of Service. Providers may retain API data per their terms; we select providers we believe appropriate but do not control their infrastructure.

Footprints stores your practice and Bootcamp activity linked to your account so you can review your own history in the Service.

As a general rule, your data is viewable only by you. We do not publish Footprints data to other users, public leaderboards, or third parties for advertising.

However, for legitimate purposes such as system maintenance, troubleshooting, or investigating defects, limited administrators may access your data only to the extent necessary. Such access is not used for marketing or unrelated purposes.

We do not sell personal information. We share data with processors that help run the Service, including: hosting and database infrastructure we operate or contract, Stripe (payments), Google (Sign-In), Apple (Sign-In), third-party AI inference providers used for Coach features, and email or support tools if used. Analytics is self-hosted by us and is not shared with a third-party analytics provider.

We may disclose information when required by law or to protect rights, safety, or property.

Data may be processed in Japan and in countries where our processors operate (including the United States). By using the Service, you consent to transfer and processing in those locations to the extent permitted by law.

We do not represent EU Standard Contractual Clauses or UK IDTA coverage unless separately published. Privacy disputes: Japanese law and Terms of Service jurisdiction in Japan.

Account and learning data: retained while your account is active and for a reasonable period after deletion for backups, security, and legal compliance, then deleted or anonymized where feasible.

Coach Dialogue chat log: on our servers, up to 500 messages per account and up to 90 days; older or excess messages are deleted when limits apply.

Billing records: retained as required for tax and accounting.

Analytics: aggregated, non-identifying data kept on our own servers per our operational needs.

Language cookies: until expiry or you clear site data.

We use reasonable safeguards. No system is perfectly secure. We are not liable for unauthorized access beyond our reasonable control.

If we become aware of a breach affecting personal data, we will take reasonable steps we deem appropriate, which may include investigation and notification where required by applicable law. We do not guarantee notification in every jurisdiction or circumstance.

AI features may analyze your learning data to personalize content. This is not a legally binding automated decision with significant effects; it is educational software. You use AI output at your own risk per our Terms.

The Service is not directed at children under 13. We do not knowingly collect personal information from children under 13. If you believe we have, contact us and we will take reasonable steps to delete it.

Paid subscriptions require eligibility under our Terms (generally age 18+ or age of majority).

You may request access, correction, or deletion via Feedback (https://tonicclef.ryusukeseto.com/feedback; Google sign-in required). We respond in reasonable discretion and may verify identity. We may be unable to honor requests that conflict with Japanese law, our Terms, or legitimate retention needs.

California (CCPA/CPRA): we do not sell or share personal information for cross-context behavioral advertising as defined under CPRA. Privacy disputes: Japan jurisdiction per Terms, except where non-waivable law requires otherwise.

EU/EEA/UK: we do not appoint an EU/UK representative unless published. Mandatory local rights apply only to the minimum extent required. Other privacy claims: Japanese law and Utsunomiya District Court per Terms.

Japan (APPI): you may request disclosure, correction, suspension of use, or deletion as applicable under Japanese law via Feedback (https://tonicclef.ryusukeseto.com/feedback; Google sign-in required).

We may update this policy at any time. The "Last updated" date shows the current version. Continued use after changes means acceptance.

Privacy questions: https://tonicclef.ryusukeseto.com/feedback (Google sign-in required; product and support inquiries).