• Account: email, display name, language, plan, country (approximate, from your connection). If you sign in with Google or Apple, we receive your email and name from them — never your password.
• Your audio: the takes you record, beats you upload, Pro reference tracks, and the masters we produce — this is the product itself.
• Transactions: credit wallet history and receipts. Card details go directly to Stripe (web) or Apple (iPhone app) — we never see or store them.
• Support: messages you send us in the portal.
• Invites: if you join with a friend's invite link, we record who invited you and when your first subscription payment went through. The friend who invited you sees only the first two letters of your display name and whether you have joined, subscribed or counted toward their reward — never your email, full name or anything else.
• App notifications: if you turn on push notifications in the iPhone app, a device token so we can reach your phone.
• Technical basics: the minimum logs needed to run and secure the service (errors, slow screens, failed sign-ins), kept 30 days. Advertising and analytics tags run only with your consent (sections 10 and 11).

• To deliver the service you signed up for — record, mix, master, deliver (contract, GDPR art. 6(1)(b)).
• To process payments and keep required accounting records (contract & legal obligation, art. 6(1)(c)).
• To send transactional emails and app notifications — sign-in codes, master ready, credits added or expiring, support replies (contract). Marketing emails only with your consent (art. 6(1)(a)), and you can unsubscribe anytime.
• To keep the platform safe — abuse prevention, rate limiting, one welcome gift per mailbox (legitimate interest, art. 6(1)(f)).
• To run the invite program — crediting rewards and preventing self-invites and fake accounts (contract & legitimate interest). See Terms §4.
• To measure our ads and how the site is used — only with your consent (art. 6(1)(a)).

No other third party receives your data. No external AI service receives your audio (section 6). We don't sell your data. Ever.

Your account, audio and processing live in the European Union. Some of the companies above are based in the United States and may access data from there (support, infrastructure). For every such transfer we rely on a safeguard recognised by the GDPR (chapter V):

• EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023): Stripe, Cloudflare, Google, Meta, Apple.
• Standard Contractual Clauses of the European Commission, built into each provider's data processing agreement: Railway, RevenueCat — and as a fallback for all the others.

You can ask us for a copy of the safeguard that applies to a given provider at [email protected].

• On the iPhone app, plans and credit packs are sold as in-app purchases processed by Apple. Apple handles payment, receipts and refunds under its own terms; we receive a confirmation of the purchase, never your card.
• On the web, payments are processed by Stripe. Your card details go straight to Stripe; we keep the receipt (amount, date, plan) for our accounts.
• In neither case do we see or store card numbers.

• Recordings and masters are stored so you can access them in your portal, and processed only to produce your track.
• Your recordings are never used to train artificial-intelligence models — ours or anyone else's.
• Mixing and mastering run on our own servers (the Fortes Mix Engine, hosted on Railway in the EU). No external AI API receives your audio.
• Custom reference tracks (Pro) are used for your master only and deleted right after the job.
• We never use your music for anything else without asking you first.
• Microphone (apps): the Fortes app asks for microphone access only to record your takes in the booth, while you are recording. Nothing is captured in the background, and audio only leaves your device when you send a track to be mixed and mastered.

• Finished masters: as long as your account exists.
• Raw session inputs — your uploaded beat, raw takes, the phone mixdown and any intermediate stems — are kept 30 days after each master (so support can re-run it), then deleted automatically. Pro reference tracks are deleted right after the job.
• Account and wallet: as long as your account exists.
• Billing records (receipts, invoices): 10 years, as required by Luxembourg accounting law — even after you delete your account.
• Support conversations: deleted shortly after a ticket is resolved.
• Technical logs: 30 days. Push tokens: until you turn notifications off or delete the account.
• iPhone waiting list: until the launch email is sent, or until you ask us to remove you.
• When you delete your account, personal data is removed or anonymised within 30 days, except the billing records above. To make sure each mailbox gets the welcome gift only once, we keep an irreversible hash of your email — not the email itself.

You can access, rectify, erase, restrict, object to, and take your data with you (portability), and withdraw a consent at any time. Three ways to do it:

• Download my data — Settings → Account in the portal gives you a machine-readable file (JSON) with everything we hold, plus links to your masters.
• Delete account — Settings → Account in the portal or the app. Files, wallet and account go at once; what the law makes us keep is listed in section 7.
• Write to us at [email protected] for anything else (rectification, objection, restriction, questions).

We answer within one month (extendable by two months for complex requests — we would tell you why). We may ask you to confirm you own the account before acting. You can also complain to a supervisory authority — in Luxembourg, the CNPD (cnpd.lu).

Fortes is for people aged 16 or over. Between 13 and 16 you may only use it with the permission of a parent or legal guardian. We do not knowingly collect data from children under 13 — if you think we have, write to us and we will delete it.

Your browser's local storage keeps app essentials only — your session, language, cookie choice and studio settings (like mic timing) — on your device. Two optional tags exist and both wait for your answer in the cookie banner:

• Meta pixel (advertising): its script is not even downloaded until you choose "Accept all".
• Google Analytics (usage statistics): runs in consent mode — until you accept, it sets no cookies and sends only anonymous, cookieless signals; after "Accept all" it sets its cookies.

"Essential only" keeps both off. Change your mind anytime in Cookie settings. Inside the iPhone app there is no ad tracking at all.

With your consent, we use the Meta Pixel (Meta Platforms Ireland Ltd, our sub-processor) to measure whether our ads on Facebook and Instagram bring people to the studio, and to optimise them. Purpose: ad measurement and optimisation. Legal basis: your consent (GDPR art. 6(1)(a)), asked once in the cookie banner — never pre-ticked. Data: an identifier cookie (_fbp/_fbc), the pages you visit and events such as "sign-up completed" or "checkout started"; when you pay, a hashed (unreadable) version of your email is sent server-side so the purchase is counted once. Retention: as set by Meta (see Meta's data policy). Also with your consent, Google Analytics 4 (Google Ireland Ltd) counts visits and key steps (sign-up, checkout) so we can improve the site — without advertising identifiers in the app. You can withdraw consent at any time in Cookie settings — the pixel stops immediately and its cookies are no longer set.

If this policy changes materially, we'll tell you in the portal. Questions: [email protected].