Refine

Privacy policy

Last updated: 1 November 2026

Draft: still to be reviewed by a lawyer before Refine is sold.

Who we are

Refine (refine-music.com and the app at refine-music.com/app) is run by [company name, registration number and address: to fill in once the business is registered (likely a Dutch company)]. We decide how your data is used: the "controller" under the EU's GDPR and Brazil's LGPD. For anything about your data, use Support & Help inside the app; that is also our channel for data requests under the LGPD (the "encarregado").

What we collect and why

We don't sell your data, there are no ads and we don't use your data to profile you.

Who else handles it

These companies process data for us, each only for the job named:

Only if you use them: Spotify, when you connect your Spotify account to play songs (your Spotify sign-in stays in your browser), and YouTube, when you play a lesson video (we use YouTube's privacy-enhanced mode). Their own privacy policies apply to what you do there.

Data outside your country

Some of these companies are in the United States or store data outside Brazil and the EU. Where they do, the transfer is covered by the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework or its standard contractual clauses, and for Brazil by the mechanisms in articles 33 to 36 of the LGPD. [To confirm with the lawyer and each provider's data processing agreement.]

How long we keep it

Your rights

In the app, Settings → Data & Backup lets you download a copy of everything your account holds (a JSON file) and delete your account with all its data. You can also ask to see your data, correct it, get a copy to take elsewhere, or have it deleted; you can object to how we use it and withdraw consent you gave. Send us a request from Support & Help inside the app and we'll answer within 15 days. You can also complain to a data protection authority: the Autoriteit Persoonsgegevens in the Netherlands, your own country's authority in the EU, or the ANPD in Brazil.

Cookies and browser storage

The website sets no cookies and uses no analytics or tracking. It remembers the language you pick in your browser's storage, and nothing else.

The app keeps your sign-in and a copy of your practice in your browser's storage so it opens quickly and doesn't lose a session when the connection drops. That's strictly needed to run the app, so it doesn't ask first. Stripe's checkout pages set their own cookies to prevent fraud, and a YouTube lesson video may store data in your browser once you play it.

Children and teenagers

If you're under 18, a parent or guardian has to agree to Refine's terms and this policy for you. [Minimum age and how consent is checked: to decide with the lawyer (ECA and ECA Digital in Brazil, 16 in the Netherlands under the GDPR).]

Changes

If we change this policy in a way that matters, we'll tell you in the app or by email before it applies. The date at the top shows the latest version.

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