Privacy Policy for Legato

Effective Date: November 6, 2026
Last Updated: November 6, 2026

Introduction

ProximityLabs (“we,” “us,” or “our”) develops the Legato mobile application for iOS and Android (the “App”) and operates the website at proximitylabs.dev (the “Website”). This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have.

ProximityLabs is the trading name of a sole trader based in the United Kingdom, who is the data controller for the personal information described in this policy. We process personal information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR) where it applies, the California Consumer Privacy Act (CCPA), and other applicable privacy laws.

Information We Collect

Information Stored Locally on Your Device

The App stores the following data on your device in its local database:

• Practice Data: Practice sessions, durations, goals, timings, tempos, and progress
• Your Library: Activities, pieces, routines, composers, instruments, tags, milestones, and holiday periods
• Audio Recordings: Practice recordings in M4A format
• Sheet Music: PDF files and scanned pages you import, and any annotations you add
• Notes: Practice notes and notes attached to items
• Course and Drill Progress: Progress in rhythm and polyrhythm courses, drills, and ear-training exercises
• Statistics: Daily snapshots, streaks, and other practice statistics
• Preferences: Instrument, goals, language, theme, notification and report preferences

Home screen widgets display a summary of this data and read it from storage on your device. If you export a practice report, the file is created on your device and shared only where you choose to send it.

Note: If you enable Data Sync (see below), a copy of this data is also stored on our servers. The data always remains on your device; sync creates an additional copy.

Account Information (Optional)

Creating an account is optional, and the App works without one. An account lets you use your subscription on multiple devices and, for LegatoPlus subscribers, enable Data Sync. If you create an account, we collect:

• Email address
• Name (if provided by Google or Apple sign-in) and any display name you set
• Account creation date and sign-in method
• Your Firebase anonymous identifier, linked to your account

Device Information (Account Holders Only)

When you are signed in, we record information about each device to power the linked-devices feature:

• Device identifier, device name, and platform (iOS or Android)
• App version and operating system version
• Last seen time

Subscription Information

• Subscription status (for example active, expired, or cancelled), platform, and product
• Purchase tokens or transaction IDs
• Purchase and expiry dates and auto-renewal status
• Your account ID, if you have linked your subscription to an account
• Subscription events sent to us by the Apple App Store and Google Play, with timestamps and processing logs

Referral Programme

If you take part in the referral programme, we store:

• Your referral code and the accounts that redeemed it
• Referral status and the dates referral rewards were granted
• The days an invited user practised during the qualifying period (dates only, with the time our server received them), used to confirm eligibility and prevent abuse

If you invite someone, the App shows you the display name of each person who joined using your code and the status of their referral.

Support and Feedback

• Your message, its category, and the email address you provide
• The App screen you sent it from
• Your app version, operating system version, and device model

Synced Practice Data (Optional)

If you have an active LegatoPlus subscription, are signed in, and turn on the “Data Sync” toggle in Settings, we store a copy of the following on our servers so that you can use it on other devices:

• Practice sessions, including items, notes, tempos, and timings
• Activities, pieces, routines, composers, instruments, milestones, holiday periods, and their tags
• PDF sheet music files, their annotations, and tags
• Audio recording files and their details
• Daily practice snapshots
• Course progress and routine templates
• Settings, such as goals, theme, and notification preferences

Data Sync is off by default. Once enabled, sync runs when the App opens or resumes, shortly after local data changes, when your connection is restored, and when you tap “Sync Now”. Records of deleted items are kept for 30 days so that deletions reach your other devices.

Analytics and Diagnostics in the App

The App uses the following services to understand how it is used and to find and fix problems:

Firebase Analytics (Google):

• Screens viewed and actions taken in the App
• Session length and frequency
• Device model, operating system, app version, and approximate location (country or region)
• On Android, Firebase may collect your device's advertising ID. You can reset or delete it in your device settings.

PostHog:

• Screens viewed and actions taken in the App, and when the App is installed, updated, opened, or closed
• Device model, operating system, app version, and approximate location derived from your IP address
• If you are signed in, your account ID and email address, so that activity on your devices can be linked

Sentry (error and performance monitoring):

• Error and crash reports, including technical details of what went wrong and the recent steps leading up to it
• Performance measurements for a sample of App sessions
• Technical information about audio problems, such as microphone signal levels (no audio is sent)
• Device model, operating system, app version, and IP address
• Your Firebase anonymous identifier or, if you are signed in, your account ID and email address

Firebase Authentication: When you first open the App, Firebase creates an anonymous identifier for your installation. It contains no personal details and lets us associate your subscription with your device.

freeRASP (Talsec): Checks whether the App is running on a rooted, jailbroken, or tampered device. Talsec receives security signals about the device and App, such as the detected threat type, device model, and operating system version.

Firebase Cloud Messaging is included in the App but is not currently used to send messages. We will update this policy before using it.

Information Collected on the Website

• Analytics (with your consent): If you accept analytics cookies in the cookie banner, we use Google Analytics and PostHog to see which pages are visited, how visitors reach the Website, and what device and browser they use. Neither runs until you accept. If you decline, no analytics cookies are set.
• Consent choice: We store your cookie choice in your browser so that we don't ask again.
• Server logs: Our hosting provider records standard request information, such as IP address, browser type, and pages requested, to deliver and secure the Website.

Website analytics data is sent to PostHog through our own domain (gnb.proximitylabs.dev) and is processed by PostHog in the same way as data sent to it directly.

How Accounts Work

Account Creation

You can create an account using:

• Email and password — requires email verification via a confirmation link sent to your inbox.
• Google Sign-In — available on iOS and Android.
• Apple Sign-In — available on iOS.

When you sign in with Google or Apple, we receive an identity token, which our authentication provider exchanges for a session. We store your email address and, where the provider supplies it, your name.

Cross-Device Subscription Sharing

When you link your subscription to an account, your Firebase anonymous identifier is associated with your account, and the subscription record is updated with your account ID. You can then use your subscription on any device where you are signed in. A subscription can be linked to one account only.

Data Sync Controls

• Data Sync toggle: Available to signed-in LegatoPlus subscribers; must be turned on by you
• Sync Now: Start a sync at any time
• Device management: View and manage linked devices

Turning off Data Sync stops future syncing but does not delete data already on our servers. To remove it, request account deletion (see below).

Emails

We send account emails (such as verification and password reset), subscription notifications, and replies to support requests. These are delivered by our email providers, Resend and Supabase.

Account Deletion

You may request deletion of your account at any time by emailing support@proximitylabs.dev from the address on your account. We will delete your account details, display name, linked device records, referral records, all synced practice data, and all uploaded PDF and audio files. Subscription event history and support tickets are kept for the periods described under Data Retention. Data stored only on your device is not affected; you can remove it by deleting the App.

How We Use Your Information

• Provide the App: Practice tracking, practice tools, statistics, widgets, and reports
• Subscriptions: Verify purchases, keep subscription status current, and enable cross-device sharing
• Accounts and Sync: Authenticate you, manage linked devices, and sync your data if you opt in
• Referral Programme: Track referrals, confirm eligibility, grant rewards, and prevent abuse
• Support: Respond to support requests and feedback
• Analytics: Understand how the App and Website are used so we can improve them
• Reliability: Detect, diagnose, and fix crashes, errors, and performance problems
• Security: Protect the App against tampering and our services against fraud and misuse
• Legal Compliance: Meet legal obligations and enforce our Terms of Service

Legal Bases for Processing

Under UK GDPR and EU GDPR, we rely on the following legal bases:

• Contract: To provide the App, your account, subscriptions, Data Sync, the referral programme, and support
• Legitimate Interests: For analytics and diagnostics in the App, to improve the App and keep it reliable; for security, fraud prevention, and integrity checks; and for operating and securing the Website. We have balanced these interests against your rights, keep the data we use to a minimum, and do not use it for advertising.
• Consent: For analytics cookies on the Website. You can withdraw consent at any time by clearing your browser's site data for proximitylabs.dev, which shows the cookie banner again.
• Legal Obligation: Where we must keep or disclose information by law

You have the right to object to processing based on legitimate interests, including analytics and diagnostics in the App. To object, contact support@proximitylabs.dev.

Device Permissions

Legato may request the following permissions. You can change them at any time in your device settings, though some features may stop working.

Microphone (iOS and Android)

Used for the tuner, singing and intonation exercises, and recording your practice. Pitch detection happens on your device; audio is stored only when you make a recording.

Camera (iOS and Android)

Used to scan sheet music pages. Images are processed on your device.

Photo Library (iOS)

Used to import sheet music images from your photo library.

Storage (Android 12 and below)

Used to import PDF sheet music and manage recordings.

Notifications (iOS and Android)

Used for practice reminders and the practice timer. Notifications are scheduled on your device.

Exact Alarms and Start on Boot (Android)

Used to deliver practice reminders at the times you choose, including after your device restarts.

Foreground Service (Android)

Keeps the practice timer running while the screen is off or you are using other apps.

Internet Access (iOS and Android)

Used for subscriptions, accounts, Data Sync, the referral programme, support, analytics, error reporting, and checking for App updates. All data is sent over encrypted connections.

Billing (Android)

Used to process in-app purchases through Google Play Billing.

Data Sharing and Disclosure

We do not sell or rent your personal information, and we do not share it for advertising. We share it only with the service providers below, who process it on our behalf, and in the circumstances listed after them.

Service Providers

• Supabase — database, authentication, and file storage for accounts, devices, subscriptions, referrals, support tickets, and synced data
• Google (Firebase) — anonymous authentication and App analytics
• Google Analytics — Website analytics (with consent)
• PostHog — App and Website analytics
• Sentry — error and performance monitoring
• Resend — email delivery
• Amazon Web Services — Website hosting
• Talsec (freeRASP) — App security and integrity checks
• Apple and Google — sign-in, in-app purchases, and purchase verification. The App also checks the App Store or Google Play for newer versions of the App.

Other Disclosures

• Legal Requirements: If required by law, court order, or a governmental authority
• Protection of Rights: To protect our rights, privacy, safety, or property, or those of others
• Business Transfers: If the App or Website is sold or transferred
• With Your Consent: When you agree to sharing for a specific purpose

International Data Transfers

• Supabase: Our database and file storage are hosted in London, United Kingdom
• PostHog and Sentry: Data is processed in the United States
• Google, Resend, Amazon Web Services, and Talsec: May process data in the United States and other countries

Where personal information is transferred outside the UK or European Economic Area, we rely on safeguards such as adequacy regulations, the UK International Data Transfer Addendum, or the EU Standard Contractual Clauses.

Data Security

• Encryption: All data sent to our servers uses TLS encryption
• Access Controls: Database tables and stored files are protected by row-level security, so you can access only your own data
• File Isolation: Synced files are stored in folders separated by account
• Limited Access: Only we can access server-side data, and administrative keys are kept out of the App
• App Integrity: Runtime checks help protect the App from tampering

No method of electronic storage or transmission is completely secure, but we work to protect your information.

Data Retention

Local Device Data

Kept until you delete it, clear the App's data, or uninstall the App.

Server-Stored Data

• Accounts, devices, profiles, and referral records: Kept while your account exists; deleted when your account is deleted
• Synced data and files: Kept while your account exists; deleted when your account is deleted
• Subscriptions: Kept for the life of your subscription plus 90 days
• Subscription events: 90 days
• Support tickets: 2 years

Analytics and Diagnostics

• Firebase Analytics and Google Analytics: Up to 14 months
• Sentry: Up to 90 days
• PostHog: Kept for as long as it is useful for improving the App and Website. We delete data linked to you on request.

Your Privacy Rights

UK and EU Rights

• Access: Request a copy of your personal information
• Rectification: Correct inaccurate information
• Erasure: Request deletion of your information
• Restriction: Limit how we use your information
• Portability: Receive your information in a portable format
• Objection: Object to processing based on legitimate interests, including analytics
• Withdraw Consent: Where we rely on consent, withdraw it at any time

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

California Rights

• Know: What personal information we collect, use, and share
• Delete: Request deletion of your personal information
• Correct: Request correction of inaccurate information
• Opt-Out: Of the sale or sharing of personal information. We do not sell or share personal information for advertising.
• Non-Discrimination: Equal service whether or not you exercise these rights

How to Exercise Your Rights

Contact us at support@proximitylabs.dev. We will respond within one month. We may need to confirm your identity first, for example by asking you to email us from the address on your account.

Complaints

If you are unhappy with how we handle your information, please contact us first. You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk, or, if you live in the EU, to your local data protection authority.

Children's Privacy

Legato is designed for musicians of all ages. For users under 13:

• We do not knowingly collect personal information from children under 13 without parental consent
• The App works without an account, and the Firebase identifier it uses contains no personal details
• Creating an account, which requires an email address, is optional
• Parents and guardians may review and request deletion of their child's information

If we learn that we have collected personal information from a child under 13 without parental consent, we will delete it. Parents who believe we hold information about their child should contact support@proximitylabs.dev.

Subscriptions (LegatoPlus)

• Purchases are handled by the Apple App Store or Google Play. Payment details are processed by Apple or Google, not by us.
• We receive subscription status and basic transaction information, which we verify with Apple or Google to prevent fraud.
• Apple and Google notify us when your subscription renews, changes, or ends, and we update its status.
• Referral rewards grant LegatoPlus for a limited time and are recorded with your subscription information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the new version here and update the “Last Updated” date, and we will notify you in the App of significant changes.

Contact Information

For questions about this policy or to exercise your rights, contact:

ProximityLabs
16b Insignia Point
London
E20 1JG
United Kingdom
Email: support@proximitylabs.dev