SoundFingers is operated by Mathieu Rahm, micro-entrepreneur registered in France. We are committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) and French Law No. 78-17 of January 6, 1978 (Loi Informatique et Libertés, as amended).
1. Data Controller
Mathieu Rahm1 rue du cercle - 67960 ENTZHEIM - France
France
Email: privacy@soundfingers.com
Website: https://soundfingers.com
As a micro-entrepreneur, Mathieu Rahm acts as the sole data controller. No Data Protection Officer (DPO) is legally required at this scale; all data-related inquiries are handled directly by the controller.
2. Data We Collect
2.1 Account & Order Data
- Full name
- Email address
- Billing country
- Purchase history (products, amounts, dates, order IDs)
- License activation records, including the machine identifier — a hardware/software fingerprint generated locally by the plugin using the JUCE framework. It does not contain your name, location, or any directly identifying information, but is considered personal data under GDPR as it can be linked to your account.
2.2 Payment Data
Payments are processed by Stripe or PayPal. We do not store or access full card numbers or bank details. We retain only: payment method type, transaction reference, amount, currency, and status (confirmed/refunded).
2.3 Technical & Security Data
- IP address (collected at login, checkout, download, and activation events)
- Browser type and version (via standard HTTP headers)
- Timestamps of account activity (login, download, license activation/deactivation)
2.4 Communications
Email messages you send to us (support, inquiries, refund requests) are retained to manage your request and maintain correspondence history.
2.5 Product Reviews
If you choose to review a plugin you own, we store the review content (rating, optional title, and text) together with a public author name derived from your account name (e.g. “Jean-Baptiste M.”). Reviews are moderated before publication and, once approved, are displayed publicly on the corresponding product page. We retain the original text you submitted as an internal audit record even if the displayed text is later corrected for spelling or grammar. Reviews are optional and never required to use a purchased plugin.
2.6 Data We Do Not Collect
We do not collect demographic data, behavioral tracking data, third-party ad identifiers, or any data not listed above. We do not use third-party advertising cookies.
3. Legal Basis for Processing
| Processing Activity | Legal Basis |
|---|---|
| Account creation and management | Contract performance — Art. 6(1)(b) GDPR |
| Order processing and payment verification | Contract performance — Art. 6(1)(b) GDPR |
| Delivering download links and license credentials | Contract performance — Art. 6(1)(b) GDPR |
| Customer support | Contract performance — Art. 6(1)(b) GDPR |
| Recording machine identifiers during license activation (to enforce the 3-activation limit and detect abuse) | Contract performance — Art. 6(1)(b) GDPR |
| Fraud prevention, abuse detection, security monitoring | Legitimate interest — Art. 6(1)(f) GDPR |
| Retaining invoicing records | Legal obligation — Art. 6(1)(c) GDPR (French accounting law, 10-year retention) |
| Sending transactional emails (order confirmation, delivery) | Contract performance — Art. 6(1)(b) GDPR |
| Publishing verified-buyer product reviews you submit | Consent — Art. 6(1)(a) GDPR (you actively choose to submit and publish a review; you may request its removal at any time) |
| Sending marketing or newsletter emails | Consent — Art. 6(1)(a) GDPR (only if you have explicitly opted in) |
4. How We Use Your Data
- Fulfillment: To process your purchase, generate download links, and deliver license credentials.
- Account management: To allow you to log in, view your orders, and manage activations.
- Communication: To send transactional emails (order confirmation, license delivery, password reset) and respond to support inquiries.
- Security: To detect and prevent unauthorized access, fraudulent transactions, or abuse of the download and activation systems.
- Legal compliance: To fulfill obligations under French accounting and commercial law.
We do not use your data for automated profiling or automated decision-making that produces legal effects.
5. Third-Party Data Processors
We use the following service providers who may process personal data on our behalf. Each is bound by a Data Processing Agreement (DPA) and appropriate GDPR safeguards.
| Processor | Role | Data Shared | Privacy Policy |
|---|---|---|---|
| Stripe | Payment processing | Name, email, billing country, transaction data | stripe.com/privacy |
| PayPal | Payment processing | Name, email, transaction data | paypal.com/privacy |
| Backblaze B2 | File storage & delivery | IP address (via download requests) | backblaze.com/privacy |
| Acumbamail | Transactional email delivery | Name, email address | acumbamail.com/privacy |
| Hetzner Online | Web hosting & database | All data processed by the application | hetzner.com/privacy |
| Cloudflare | DNS, CDN, DDoS protection | IP address | cloudflare.com/privacy |
We do not sell, rent, or trade your personal data to any third party for their own commercial purposes.
6. Cookies
We use the minimum number of cookies necessary to operate the Site:
| Cookie | Purpose | Type | Duration |
|---|---|---|---|
| Session cookie | Maintains your authenticated login state | Strictly necessary | Session (deleted on browser close) |
| Cart cookie | Preserves your shopping cart contents | Strictly necessary | 7 days |
We do not use analytics cookies, advertising cookies, or any third-party tracking cookies. No cookie consent banner is required for strictly necessary cookies under the ePrivacy Directive. See our Cookie Policy for more detail.
If we introduce optional cookies (e.g. analytics) in the future, this policy will be updated and your prior consent will be requested.
7. Data Retention
| Data Category | Retention Period |
|---|---|
| Account and profile data | Until account deletion, then deleted within 30 days, except where legal obligation requires longer retention |
| Order records and invoices (completed) | 10 years from the transaction date (French accounting law obligation: L. 123-22 Code de Commerce) |
| Abandoned orders (pending / failed) | 30 days from creation, then permanently deleted |
| Guest checkout accounts never used (no completed order or download) | 30 days from creation, then permanently deleted |
| License activation logs (active licenses) | Duration of license + 1 year after termination |
| Revoked activation records | Machine identifier anonymised 1 year after revocation; audit record retained indefinitely |
| Download logs | 3 years from the date of download |
| Security and access logs (IP, timestamps) | 12 months |
| Support correspondence | 3 years from last contact |
| Product reviews | Until you delete your account or request removal; on account deletion the review is detached from your identity (author name anonymised) but the content may remain published as an anonymous verified-buyer review |
| Marketing consent records | Until consent is withdrawn, + 3 years |
Upon account deletion, we anonymize or delete all data not subject to a legal retention obligation. Published reviews are unlinked from your identity and their public author name is replaced with a neutral label. Retention periods are enforced periodically via an internal purge process.
8. International Data Transfers
Some processors operate outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place:
- Stripe (USA): Standard Contractual Clauses (SCCs) adopted by the European Commission.
- Backblaze (USA): Standard Contractual Clauses.
You may request details of the specific transfer mechanisms in place by contacting privacy@soundfingers.com.
9. Your Rights Under the GDPR
You have the following rights with respect to your personal data:
- Right of access (Art. 15): Obtain confirmation of whether we process your data and receive a copy.
- Right of rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right of erasure (Art. 17): Request deletion of your data where it is no longer necessary, or where you withdraw consent, subject to legal retention obligations.
- Right to restriction of processing (Art. 18): Request that we limit processing in certain circumstances.
- Right to data portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format (JSON or CSV).
- Right to object (Art. 21): Object to processing based on legitimate interest, including at any time for direct marketing purposes.
- Right to withdraw consent (Art. 7(3)): Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, send your request to privacy@soundfingers.com with sufficient information to identify your account. We will respond within 30 days. We may ask you to verify your identity before acting on the request. You can also download a copy of your data and delete your account directly from your account settings.
10. Right to Lodge a Complaint
If you believe your data has been processed unlawfully or your rights have not been respected, you have the right to lodge a complaint with the supervisory authority in your country of residence. In France:
CNIL — Commission Nationale de l'Informatique et des Libertés3 Place de Fontenoy, TSA 80715, 75334 Paris CEDEX 07
cnil.fr | Tel: +33 (0)1 53 73 22 22
11. Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- HTTPS/TLS encryption for all data in transit
- Secure password hashing (bcrypt)
- Time-limited, signed download URLs (no permanent public file access)
- Role-based access controls on the admin interface
- Regular security reviews
No system is entirely immune to breaches. In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.
12. Changes to This Policy
We may update this Privacy Policy as the Site evolves. Changes will be posted on this page with an updated date. For material changes, we will notify registered users by email at least 30 days before the change takes effect.
13. Contact
Mathieu RahmEmail: privacy@soundfingers.com
Website: https://soundfingers.com