The short version: Etudia doesn't have accounts, doesn't run analytics or ad tracking, and doesn't send your sheet music anywhere. Nearly everything below exists to spell out exactly what "almost no data" means in practice.
Etudia is designed to work entirely on your device. There is no account, sign-in, or server that Etudia talks to. The sheet music you upload, your practice settings, and your premium-unlock status are all stored locally on your device (and, incidentally, in whatever backup of your whole device you already make through Apple). Fuyu Labs LLC never receives a copy of any of it.
This policy still covers everything a privacy policy is expected to cover — including the handful of things that genuinely are outside our control, like the diagnostic data Apple itself collects as the platform operator — so that it's accurate and complete, not just short.
Directly from you, or automatically through the app: nothing that identifies you. Specifically, Etudia stores the following locally on your device, and never transmits it to Fuyu Labs or any third party:
We do not ask for your name, email address, date of birth, or any other identifying information anywhere in the app. There is no account to create.
If a future version of Etudia ever adds optional analytics or cloud sync, it will be off by default, clearly disclosed, and require your explicit opt-in — this policy will be updated first, per §13.
You are responsible for having the right to import and use any sheet music you bring into Etudia — whether that's because it's in the public domain, you wrote it yourself, or you have permission from the rights holder. Etudia does not inspect imported files for copyright status and cannot make that determination for you.
UserDefaults and the app's own Documents folder) — not in iCloud sync, not in CloudKit, and not on any Fuyu Labs server. Etudia does not currently offer cross-device sync.Etudia's premium unlock (monthly, annual, or lifetime) is billed and processed entirely by Apple through the App Store's In-App Purchase system. Fuyu Labs never sees or stores your payment card details, billing address, or Apple ID — that entire transaction happens between you and Apple, governed by Apple's Media Services Terms. Etudia only ever stores a local yes/no flag reflecting whether the purchase succeeded.
Etudia's music engraving is rendered by Verovio, an open-source music notation engine, licensed under the GNU Lesser General Public License v3.0 (LGPL-3.0). Verovio runs entirely on-device and makes no network requests; it does not independently collect or transmit any data. Its full license text and source are available at github.com/rism-digital/verovio. A full list of open-source components and their licenses is also available on request at the contact below.
Because Etudia does not transmit personal data to Fuyu Labs, most of what happens on your device isn't "processing" by us as a controller under the GDPR at all — it's your own device storing your own data locally, under your own control. To the extent any processing by Fuyu Labs occurs (for example, if you email us for support), it is on the basis of:
Etudia runs inside Apple's App Sandbox, with no network entitlement used for any data-transmission purpose. Because nothing is transmitted off your device, there is no "in transit" exposure for your imported content or settings — the relevant security boundary is your device's own passcode/biometric lock and any backup encryption you've configured through Apple. If a security issue affecting Etudia is ever identified, we will disclose it and any necessary remediation steps within 72 hours of confirming it, consistent with GDPR breach-notification norms, even though Etudia's architecture makes a data breach of user content on our end structurally unlikely (we have nothing to breach).
Etudia is intended for a general audience, including students learning piano who may be under 13, typically with a parent or teacher nearby. Because Etudia does not collect, store, or transmit any personal information from any user — child or adult — no age gate or parental-consent flow is required under COPPA, and none is presented in the app today. If a future version adds a feature that would collect personal information, we will add appropriate age verification and parental-consent handling before that feature ships, and will update this policy first.
Because there's no account and no server-side personal data, most of these rights are already satisfied by the design of the app itself — but for completeness:
EU/EEA/UK residents have rights under the GDPR (access, rectification, erasure, portability, restriction, objection); California residents have analogous rights under the CPRA; Canadian and Australian residents have analogous rights under PIPEDA and the Privacy Act 1988, respectively. Contact us at the address below for any request — since we typically hold no personal data to act on, most requests will simply be confirmed as already satisfied.
Because Etudia does not transmit personal data off your device to Fuyu Labs, no international transfer of your personal data occurs through your use of the app. If that ever changes (for example, if we introduce an optional cloud-sync feature), we will implement appropriate safeguards — such as Standard Contractual Clauses or an adequacy decision — before that feature processes personal data across borders, and will disclose this here first.
If we materially change what Etudia collects or how it's handled, we'll update the "last updated" date above and, for material changes, provide notice in-app before the change takes effect. Continued use of Etudia after a change takes effect constitutes acceptance of the revised policy.
Fuyu Labs LLC
Privacy inquiries and data requests: synclively@gmail.com
We aim to respond within 30 days for straightforward requests, and up to 90 days for anything requiring more involved review.
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