Privacy Policy

Effective date: 11 November 2025

Controller: MOBIWAYS LTD, Nikou Pattichi, 105, Office 1‑2, Agios Georgios Chavouzas, 3070 Limassol, Cyprus ("Tunecy", "we", "us", "our").
Contact (privacy): support@mobiways.com

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use the Tunecy mobile application(s), website(s), and related services that generate or process audio and music using artificial intelligence (together, the “Service”). By using the Service, you agree to this Policy and our Terms & Conditions.

1) Scope & Roles

For most processing described here, MOBIWAYS LTD is the data controller under the GDPR/UK GDPR and the business under U.S. state privacy laws.

We are established in Cyprus (EU). We may use processors/sub‑processors outside your country to provide the Service.

Purchases are processed exclusively via Apple In‑App Purchases; Apple is the merchant of record. We receive limited purchase metadata and do not receive or store payment card data.

2) What We Collect

A. Account & Profile

• Identifiers: name/alias, email, Apple App Store identifiers, device identifiers (e.g., IDFV), country/locale, settings, subscription status, Apple receipt tokens.
• Optional profile details you add (e.g., avatar, links).

B. Content & Creative Inputs

• Inputs you provide to generate or process content (text prompts, reference audio, lyrics, uploaded files) and associated metadata.
• Safety/abuse signals derived from Inputs/Outputs.

C. Usage & Device Data

• Telemetry, diagnostics, events, timestamps, performance metrics.
• Crash logs, device type/OS/version, language, time zone, IP‑derived region, coarse location.
• In‑app navigation and latency.

D. Communications

Emails/messages you send us and related metadata.

E. Cookies & Web Data

Essential cookies, local storage, and similar technologies for login/session, security, preferences, and analytics.

We do not intentionally collect sensitive categories. Do not upload personal data of others without lawful basis.

3) Why We Use Data (Purposes & Legal Bases)

• Core operation: provide and secure the Service; maintain accounts; prevent fraud/abuse.
• Creative functionality & AI: process inputs, store projects, provide features, safety, model improvement.
• Billing: validate Apple receipts, manage subscriptions.
• Communications: support responses, service notices, optional marketing.
• Analytics & quality: metrics, crash analytics, anti‑spam/abuse.
• Compliance: legal requests, enforcement.

4) How We Share Data

We do not sell personal data or share it for cross‑context behavioral advertising.

We share data with:

• Service providers / processors.
• Apple (for purchase validation).
• Affiliates.
• Legal/Safety recipients.
• Business transactions.

5) Retention

• Account data: for account lifetime + up to 24 months.
• Inputs/Projects: stored while account active; deletable in‑app.
• Telemetry: 90–180 days (aggregated longer).
• Support communications: ~24 months.
• Transaction metadata: 6–10 years (legal duties).

6) Your Choices & Rights

A. Model improvement & training

You may opt out via in‑app settings or by contacting support@mobiways.com.

B. Marketing communications

You may unsubscribe at any time.

C. Device permissions

Analytics/crash reporting may be disabled in OS settings.

D. GDPR/UK/Swiss rights

Access, rectification, erasure, restriction, objection, portability, and complaint rights.

E. U.S. State rights

Access, correction, deletion, portability, disclosure information, and appeals.

7) Children’s Privacy

Service intended for 13+. We do not knowingly collect data from children under 13.

8) International Transfers

We may transfer your data internationally using appropriate safeguards (e.g., SCCs).

9) Security

We implement technical and organizational measures to protect personal data.

10) Cookies & Similar Technologies

We use essential cookies and storage for authentication, security, and analytics.

11) Automated Decision‑Making

We do not engage in automated decisions with legal or similarly significant effects.

12) Third‑Party Services & Links

Third‑party services are governed by their own policies.

13) Changes to this Policy

We may update this Policy and will notify you of material changes.

14) Regional Notices

A. EEA/UK/CH Legal Bases Summary

Contract, Legitimate Interests, Consent, Legal Obligations.

B. California “Notice at Collection”

Categories, purposes, retention, and rights as described above. No selling/sharing.

15) How to Contact Us

MOBIWAYS LTD
Nikou Pattichi, 105, Office 1‑2
Agios Georgios Chavouzas, 3070 Limassol, Cyprus
Email: support@mobiways.com
Subject line: “Privacy Request – Tunecy”