Privacy Policy

Effective Date: July 01, 2025

Last Updated: 26.11.2025

This Privacy Policy explains how Grai Inc. (“GRAI”, “we”, “us”, or “our”) collects, uses, shares and protects your personal data when you use our music and audio application, website, and related services (“Service”).

We comply with applicable data protection laws, including:

• EU General Data Protection Regulation (GDPR)

• United Kingdom GDPR & Data Protection Act 2018

• California Consumer Privacy Act (CCPA)

• Canada’s PIPEDA, CASL, Quebec Law 25, Alberta PIPA, British Columbia PIPA

Grai Inc., a Delaware corporation, is the data controller for personal data processed during your use of the Service.

1. Information We Collect

We may collect the following categories of personal data:

Personal Identifiers

• name, email, username

• account information

Device Information

• IP address

• device type, model, OS version

• unique identifiers (where permitted)

Usage Data

• music/audio interactions

• app features used

• session duration, interaction logs

Analytics and Crash Data

• Collected via third-party SDKs (e.g., Firebase, Amplitude, Google Cloud).

• Location Data (optional)

• Only if you enable location-based features.

• Children’s Data

The Service is not intended for individuals under 16. We do not knowingly collect data from users under 16. If we learn such data was collected, we will delete it promptly.

2. Legal Bases for Processing

EU / EEA (GDPR)

Contract performance

Legitimate interests

Consent (for optional features)

Legal obligations

UK (UK GDPR)

Includes the above and recognized legitimate interests such as fraud prevention and safety.

Canada (PIPEDA, Law 25, provincial laws)

Meaningful consent

Accountability

Purpose limitation and transparency

California (CCPA)

We do not “sell” or “share” personal data as defined under CCPA.

3. How We Use Personal Data

We process your personal data to:

• Provide, operate, and personalize the Service;

• Deliver music and audio features;

• Improve app functionality and fix bugs;

• Perform analytics and app performance monitoring;

• Send service and marketing communications (where permitted);

• Detect fraud and ensure security;

• Comply with legal obligations;

• Provide subscription access and manage paid features.

4. Data Sharing & International Transfers

We do not sell personal data.

We may share data with:

• Service Providers

• Firebase (analytics, crash reporting)

• Amplitude (analytics)

• Google Cloud (storage & processing)

These providers operate under contractual safeguards and cannot use your data for their own advertising.

Legal & Compliance

We may share information where required by law or to protect rights and safety.

International Transfers

EU/EEA: Standard Contractual Clauses

UK: ICO-approved transfer mechanisms

Canada/Quebec: contractual safeguards and transfer disclosures

5. Your Rights

EU / UK GDPR Rights: Access, rectification, erasure, Restriction and objection, Data portability, Withdraw consent, Right to file complaints with regulators, Rightto review automated decisions (UK), California (CCPA) Rights, Know, access, delete, Opt-out of sale/sharing (we do not sell/share), No discrimination for exercising rights.

Canada (PIPEDA, Quebec Law 25): Access and correction, Data portability (Quebec), Transparency around profiling, Withdrawal of consent.

To exercise your rights, email: [email protected]

We may verify your identity before processing requests.

6. Cookies, SDKs & Tracking Technologies

We use cookies and SDKs to support:

• analytics

• crash reporting

• basic app functionality

Marketing & Advertising Cookies / SDKs (Optional) - We use them only with your consent where required (UK, EU, Canada).

You may disable non-essential cookies in your device or browser settings.

7. App Tracking Transparency (Apple Devices)

If the app engages in “tracking” as defined by Apple, we will request your permission through App Tracking Transparency (ATT) before accessing data used for tracking.

You may allow or deny tracking. If denied, we will not collect data used for cross-app tracking.

You can change your preference at: Settings → Privacy → Tracking

If the app does not perform tracking, no ATT prompt will appear.

8. Subscription, Payments and Billing Data

Subscriptions and one-time purchases are processed by:

• Apple App Store

• Google Play Store

We do not receive or store your credit card number or Apple/Google billing details.

We only receive limited information necessary to activate or validate your purchase (e.g., transaction ID, subscription status).

For platform-specific billing information:

• Apple: https://support.apple.com/billing

• Google: https://support.google.com/googleplay

9. Third-Party SDKs and Service Providers

We use the following:

• Firebase - analytics, crash reporting;

• Amplitude - product analytics;

• Google Cloud - hosting and data storage.

These providers process data on our behalf and in line with data protection agreements.

We do not permit them to use your data for their own advertising.

10. Data Retention

We retain personal data only as long as necessary to:

• provide the Service;

• comply with legal obligations;

• resolve disputes;

• enforce agreements.

When no longer needed, data is deleted or anonymized.

11. Security

We use technical and organizational measures to protect your data, including:

• encryption in transit

• access controls

• secure hosting environments

No system is fully secure, but we work to ensure industry-standard protections.

12. Children’s Privacy

The Service is not intended for children under 16. We do not knowingly collect data from users under 16. If such data is discovered, it will be deleted.

This aligns with our Terms of Service.

13. Changes to This Policy

We may update this Privacy Policy periodically. If changes are significant, we will notify you in the app or via email. Your continued use of the Service after changes take effect constitutes acceptance.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Grai Inc.

Email: [email protected]