1. Controller

The controller for the purposes of the GDPR is An Phan, Lassallestr. 95, 80995 München, Germany. For any privacy question, write to support@onkoel.com.

2. What we collect

• Account data — your name, email address and a hash of your password.
• Organization data — your subdomain, plan, and the members and guests you invite.
• Your library — the audio files you upload and the metadata in them.
• Usage data — what you play and when, so the app can show recently played and favorites.
• Technical data — IP address, browser and device, and server logs.
• Correspondence — the emails you send us.

We never receive your card details. Payments are handled by Paddle as merchant of record; we only see the subscription status they report back to us.

3. Why we process it, and on what basis

• To provide the service you signed up for — performance of a contract (Art. 6(1)(b)).
• To bill you and meet tax obligations — contract and legal obligation (Art. 6(1)(b), (c)).
• To keep the service secure and block spam sign-ups — legitimate interest (Art. 6(1)(f)).
• To answer support requests — contract and legitimate interest.

To answer a support request, our staff may sign in to your account and see it as you do. That access lasts at most an hour and is logged, and it can’t change your password, two-factor, passkeys, members or billing, or delete your account.

4. Who we share it with

We use a small number of processors, each bound by a data processing agreement:

• Paddle — subscriptions, invoicing and VAT.
• Cloudflare — object storage for your audio files and our database backups, and Turnstile to check that sign-ups are human. Turnstile runs invisibly: it looks at signals from your browser to tell a person from a script, without asking you to solve anything. What it collects is set out in Cloudflare's Turnstile Privacy Addendum.
• netcup, in Germany — the servers the application runs on.
• Amazon Web Services, in its Frankfurt region — transactional email such as invitations and password resets.
• StopForumSpam — we check the email address and IP of a sign-up against their public database.
• PostHog, in its EU region — in the app, which pages you open, errors, and account events such as starting a trial or subscribing, tied to your account ID. Text on the page, including your song titles, is masked, and nothing is stored in your browser.
• Cloudflare Web Analytics — on this website, visits counted without cookies and without identifying you.

If you sign up or log in with Google, Google confirms who you are and sends us your name, email address, Google account ID and profile picture. Google handles that sign-in under its own privacy policy.

We do not sell your data and we do not use advertising trackers.

Separately from this, you can publish parts of your library yourself. If you use a sharing feature such as an embed or a public link, the audio behind it becomes reachable by anyone who has the link, without an account and outside the access controls described here. You control that: removing the share stops it.

5. Where it is stored

Audio files and application data are stored in the EU. Where a processor transfers data outside the EU, that transfer relies on Standard Contractual Clauses or an adequacy decision.

6. How long we keep it

Your account data and library are kept while your account is active. After you cancel, your library stays downloadable for 30 days and is then deleted permanently. Invoices are kept for as long as tax law requires. Server logs are kept for at most 14 days.

7. Your rights

You can ask for a copy of your data, correct it, delete it, restrict or object to its processing, and receive it in a portable format. Where we rely on consent, you can withdraw it at any time. You also have the right to complain to a supervisory authority; ours is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach.

8. Cookies

The app keeps you logged in by storing a login token in your browser's local storage. Cloudflare Turnstile may set a short-lived cookie while it verifies a sign-up, as described in its Privacy Addendum. There are no analytics or advertising cookies, so there is no consent banner to click away.