Privacy Policy

To write your song we ask you for something more personal than most online purchases: a story about somebody you care about. That story may touch on illness, grief, a wedding, a child, a relationship. It deserves a privacy policy that names the companies involved and the periods we hold data, rather than one that gestures vaguely at industry standards.

This policy covers the Songoria website and the service behind it. It is written to satisfy the EU General Data Protection Regulation, and we apply the same standard to customers everywhere.

The data controller is Katarzyna Górecka, Nowogrodzka 31, 00-511 Warszawa, Poland, tax identification number (NIP): 7412060624. Because we are a sole trader rather than a large corporation, we are not required to appoint a data protection officer and have not appointed one.

For any privacy question, request or complaint, write to [email protected]. That reaches a person who can act on it, and we reply within 30 days at the latest.

Your story. The names, relationships, memories, qualities and messages you type into the questionnaire, plus the occasion, genre, language and voice you choose. This is the raw material of the song and there is no way to provide the service without it.

Your email address, and the recipient’s first name if you give it. We need the email to send your order confirmation and the link to your song. The name appears in the lyrics.

Payment information. Stripe processes the payment and collects your billing address, which we need to establish your country for tax purposes. We receive confirmation of payment, the amount and the billing country. We never see or store your card number.

Your IP address and the country derived from it, stored against your order. EU tax rules require two non-contradictory pieces of evidence of a customer’s location, and this is one of them. Note the difference from the next item: here the address is stored in full, attached to your order, because tax law requires evidence we can actually produce during an audit.

Website analytics. We count visits to understand which pages work. For this purpose we do not store your IP address at all - it is combined with your browser identifier into a hash that changes daily, which lets us count returning visits within one day without being able to identify you or track you across days.

Video, if you take part in the reaction-video offer. This is a file you actively choose to upload.

Correspondence. Emails you send us and our replies, kept so that whoever picks up your case can see what was already discussed.

The questionnaire is free text, so people sometimes tell us about a health condition, a bereavement, a religious ceremony or a relationship. Under the GDPR some of that counts as a special category of personal data, which carries stronger protection.

We do not ask for such details and we do not need them. If you include them, you are choosing to share them so we can write the song, and that explicit choice is the legal basis on which we process them (Article 9(2)(a)). You may withdraw it at any time by asking us to delete your story.

Our honest advice: share what makes the song true, and no more. A song can carry the weight of a loss without naming a diagnosis.

To create and deliver your song, and to handle revisions and refunds: performance of our contract with you (Article 6(1)(b)).

To keep accounting records and meet tax obligations: compliance with a legal obligation (Article 6(1)(c)).

To prevent fraud, protect the service from abuse and act on unlawful content we are made aware of: our legitimate interests in operating a lawful and secure business (Article 6(1)(f)).

For analytics, advertising measurement and marketing emails: your consent (Article 6(1)(a)), which you can withdraw at any time without affecting anything done beforehand.

For special category data inside your story: your explicit consent (Article 9(2)(a)), as described above.

We work with a small number of specialist providers. Each acts on our instructions under a data processing agreement, receives only what it needs, and may not use your data for its own purposes.

Anthropic (United States) - writes your lyrics from the story you send. Your story text is processed there, and under our commercial terms it is not used to train models.

Suno (United States) - generates the music and the singing voice from your approved lyrics. It receives the lyrics and your style choices, not your email address.

Stripe (United States and Ireland) - takes the payment and collects the billing address. Stripe also acts as an independent controller for its own fraud prevention, under its own privacy policy.

Cloudflare (United States) - stores uploaded files and finished audio in a private bucket, and screens our forms against automated abuse. Nothing is publicly listed, and playback links are signed and expire.

Alongside these we use ordinary business services: hosting for the database that holds order records, an email delivery service, and an accountant who receives invoice data because Polish law requires it. We can name any of them on request.

We do not sell your personal data, we have never done so, and the business does not depend on it. We share your story and your song with nobody beyond the providers above, and we publish neither without your separate explicit consent.

We advertise on social platforms, so this section describes what that involves - including tools that may be active now or that we may switch on later. None of them run before you consent through the cookie banner, and declining costs you no functionality.

Meta Pixel (Facebook and Instagram advertising). Where enabled, it reports which pages you visited and whether you purchased, so we can measure which advertisements work and show advertisements to people with similar interests. Meta receives your IP address, browser details and a hashed identifier, and acts as joint controller with us for that collection.

TikTok Pixel. Where enabled, it performs the same function for advertising campaigns on TikTok, and TikTok receives comparable data.

Google services, which may include Google Ads conversion tracking, Google Analytics and Google Tag Manager, used to measure campaigns and understand site usage.

These tools tell advertising platforms that a purchase happened and what it was worth. We never send them the content of your story, the lyrics, or the finished song. Where a platform requires a customer identifier for conversion matching, it is sent hashed rather than in the clear.

You can refuse all of this at the cookie banner, change your mind later through the cookie settings link in our footer, and additionally control advertising personalisation in your Meta, TikTok and Google account settings.

We may also send marketing emails if you opt in. Every one carries a one-click unsubscribe, and we honour it immediately.

Necessary cookies keep the site working: they remember what is in your order as you move through the questionnaire, keep you signed in to your listening page, and support the anti-abuse check. These are set without consent because the service cannot function without them, which the ePrivacy rules permit.

Analytics and advertising cookies, including those described in section 7, are set only after you agree. Our banner lets you accept all, reject all, or choose; rejecting is exactly as easy as accepting, and no option is pre-ticked.

You can also clear or block cookies in your browser, though blocking the necessary ones will break the ordering process.

Several providers in section 6 are based in the United States, so your data is transferred there. We rely on the European Commission’s Standard Contractual Clauses, supplemented where the provider is certified under the EU-US Data Privacy Framework.

We tell you this plainly because it matters: United States law gives its authorities powers of access that EU law does not, and no contractual clause fully removes that. If this concerns you, the practical protection is to limit what you write in the questionnaire - a song does not need a diagnosis or an address to be moving.

Your story and the lyrics: for the life of the order plus 12 months, so that revisions and the guarantee remain possible and so we can help if you lose your link. You may ask us to erase your story earlier, once the song is delivered.

Your song audio: at least 12 months after delivery, usually longer. We email you before removing anything.

Invoices and accounting records, including the amount, date, billing country and the IP-derived country: five full calendar years from the end of the year of sale, as Polish tax law requires. This is a legal obligation we cannot override, so these records survive a deletion request - but they contain transaction data, not your story.

Analytics records: 14 months, in a form that no longer identifies you.

Marketing consent and correspondence: until you withdraw consent or object, and then a minimal record that you did so, to avoid contacting you again by mistake.

Reaction videos: for as long as we use them in advertising, and we stop using them in new campaigns when you withdraw consent.

You may ask for a copy of the data we hold about you; ask us to correct anything wrong; ask us to erase your data; ask us to restrict or stop a particular use; object to processing based on legitimate interests; and receive your data in a portable, machine-readable form.

You may withdraw any consent at any time, including consent to marketing, to cookies, and to the special category data in section 4. Withdrawal does not undo what was lawfully done beforehand.

To use any of these, email [email protected]. We do not charge, we do not require a form, and we respond within 30 days - usually within a few days. We may ask you to confirm your identity, which for most requests simply means writing from the address you used to order.

If you think we have handled your data badly, please tell us first so we can fix it. You also have the right to complain to a supervisory authority: in Poland this is the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw), and if you live elsewhere in the EU you may complain to your own national authority instead.

Your song is produced by automated systems, but no automated system makes a decision producing legal or similarly significant effects about you.

The only automated check we run is an anti-abuse filter, which may block traffic that behaves like a bot. It looks at how a request behaves, not at what your story says. If you want a person to look at your order, write to [email protected].

Data is encrypted in transit. Audio files and photographs sit in a private store that is never publicly listed, reachable only through links that are signed and expire after a few hours. Access to customer records is limited to those who need it to run the service.

No system is perfectly secure. If a breach occurs that is likely to put your rights at risk, we will notify the supervisory authority within 72 hours and tell you directly where the law requires it.

The service is not intended for anyone under 18, and we do not knowingly collect data from children.

Songs are often written about children, which is fine - that is a parent or relative telling a story. If you believe a child has ordered from us, or that a child’s data has reached us in a way you did not agree to, write to [email protected] and we will delete it.

When we change this policy the date at the top changes with it. If a change materially affects how we use data we already hold, we will tell you by email rather than expecting you to check.

Where we publish a translation of this policy and the two versions disagree, the English text prevails - except where mandatory law in your country requires otherwise.