MetroTune™ Privacy Policy

1. Introduction

Archet Studio LLC ("Archet Studio," "we," "our," or "us") develops and operates MetroTune™, a mobile application that provides metronome and chromatic tuning capabilities for musicians.

This Privacy Policy explains how we collect, use, and disclose information when you use the MetroTune™ application or visit our website at https://archetstudio.com, and describes your privacy rights and choices.

2. Scope

This policy applies to the MetroTune™ mobile application developed and published by Archet Studio LLC, including versions distributed through the Apple App Store and Google Play Store, as well as the Archet Studio LLC website (archetstudio.com) as it relates to MetroTune™. This policy applies globally to all users regardless of location, with jurisdiction-specific rights described in Section 10.

3. Current Data Collection

This policy describes the data practices of MetroTune™ during normal operation and distribution through public app stores. The only data we directly collect is through direct email contact. This includes messages sent to any of our email addresses: inquiry@archetstudio.com (general inquiries), support@archetstudio.com (app support), and privacy@archetstudio.com (privacy requests). If you contact us for support, we receive the information you voluntarily provide, such as your email address and any technical details (device type, OS version) you include. We use this information only to resolve your technical issues and improve our products. We do not sell this information or use it for marketing purposes. Email correspondence is retained for 12 months after the inquiry is resolved, after which it is permanently deleted.

Data we do not collect:

• Your name or any in-app account credentials
• Email addresses entered within the app
• Contacts, call logs, or SMS data
• Photos, camera, or video content
• Precise or coarse geolocation
• Payment information or financial data
• Biometric identifiers or health data
• Browsing history or cross-app behavior

4. Application Data Practices

MetroTune™ adheres to the Privacy Manifest and Data Minimization principles outlined in this document. The following describes the data practices built into the application:

4.1 Microphone Audio (Transient)

MetroTune™ accesses the device microphone for real-time audio analysis, including pitch detection (tuner) and optional hands-free control via double-clap detection (metronome). All audio is processed entirely in-memory on the user's device using pure signal processing. It is never recorded, stored, or transmitted. No speech recognition is performed. We do not derive or infer your identity, biometrics, or any personal characteristics from audio data.

4.2 User Preferences (Local Only)

MetroTune™ stores user preferences (such as color theme and premium unlock status) locally on the device using AsyncStorage. This data never leaves the device and is not transmitted to any server.

4.3 Third-Party SDK Data

MetroTune™ integrates the Google Mobile Ads SDK (AdMob) to serve advertisements. Ad personalization is determined dynamically at startup based on user consent and platform tracking permissions (see Section 7 for the full logic). The AdMob SDK may collect:

• Advertising identifiers — AAID (Android Advertising ID), available by default unless the user opts out via device settings. On iOS, no advertising identifier (IDFA) is collected; all ads are non-personalized.
• IP address
• App interaction data (ad views, taps, rewarded ad completions)
• SDK diagnostic telemetry — standard operational diagnostics collected by the AdMob SDK; no separate crash reporting SDK is integrated

This data is collected and processed by Google in accordance with the Google Privacy Policy. We do not have direct access to the personal data Google collects through its SDK.

4.4 Rewarded Ad Value Exchange

MetroTune™ offers a 24-hour premium content unlock in exchange for watching a rewarded video advertisement. When a user completes a rewarded ad, we process the ad completion event to grant temporary access to premium features (e.g., additional sound packs).

• The ad completion timestamp is stored locally on the device via AsyncStorage
• Access expires automatically after 24 hours
• No payment information, account credentials, or personal data is collected during this exchange
• The AdMob SDK records the rewarded ad conversion event for ad network reporting

4.5 Geolocation Data

MetroTune™ does not collect Precise Geolocation Data. In the event that any future feature requires temporary location access, it will be accompanied by a clear, obvious on-screen indicator as required by applicable law.

5. Data Storage & Security

Archet Studio LLC does not operate its own backend servers or cloud storage. User preferences and app state are stored locally on the device. Ad data is transmitted to Google's servers by the AdMob SDK.

• Local storage: Preferences are stored via AsyncStorage (SQLite on Android, NSUserDefaults on iOS). This data is non-sensitive — containing only UI preferences such as color theme and a premium unlock timestamp, with no personal identifiers — and is therefore not encrypted at rest.
• Network security: All network connections (AdMob) are enforced over HTTPS/TLS.
• Data retention: Local data persists until the user uninstalls the application, at which point all local data is permanently deleted. Data collected by the AdMob SDK is retained according to Google's data retention policies. We do not control Google's retention schedule. To review and manage data Google holds about you, visit Google's Data & Privacy controls.
• Data breach notification: In the event of a data breach affecting personal information, we will notify affected individuals and relevant authorities in accordance with applicable law, including within 72 hours for GDPR-covered incidents and as required under California Civil Code § 1798.82.

6. Third-Party Services

MetroTune™ integrates or will be distributed through the following third-party services. Third-party partners (in particular, Google/AdMob) collect data directly from your device as described below — this collection occurs independently of Archet Studio LLC and is subject to the partner's own privacy policy.

No other third-party tracking, analytics, crash reporting, or social SDKs are integrated. Archet Studio LLC does not independently collect, sell, or share user data with third parties. The AdMob SDK collects data as described in Section 4.3 as part of its standard operation.

7. Advertising & Tracking

MetroTune™ displays advertisements through Google AdMob. Ad personalization is determined dynamically at startup based on the following logic:

The AAID (Android) may be used by the AdMob SDK to serve personalized advertisements and to track ad conversions that unlock premium content (see Section 4.4). On iOS, all ads are non-personalized.

iOS Ad Serving

On iOS, MetroTune™ serves non-personalized advertisements only. No advertising identifier (IDFA) is collected, and the App Tracking Transparency (ATT) framework is not implemented. MetroTune™ does not track users across apps or websites owned by other companies.

EU/EEA/UK Consent (Google UMP)

For users located in the European Economic Area, the United Kingdom, or Switzerland, MetroTune™ implements the Google User Messaging Platform (UMP) consent framework on Android. At first launch (or when consent status has lapsed), a Google-hosted consent form is presented. This form explains the categories of data collected, the purposes of processing, and the third-party partners (including Google/AdMob) that may access data. Personalized ads are served to EU/EEA/UK Android users only if explicit consent is given. If consent is declined, ads are served without advertising identifiers (non-personalized). On iOS, all ads are non-personalized regardless of region.

Ad Supply Chain Transparency

Our ad supply chain is authorized via an app-ads.txt file hosted at archetstudio.com/app-ads.txt, identifying Archet Studio LLC as a DIRECT publisher (ID: pub-8090048526672531). Google's TAG (Trustworthy Accountability Group) certification authority ID f08c47fec0942fa0 is included to provide users and advertisers with a verified, transparent ad supply chain.

To limit ad personalization:

• iOS: No action needed — MetroTune always serves non-personalized ads on iOS.
• Android: Settings > Google > Ads > Opt out of Ads Personalization (prevents the AdMob SDK from using the AAID).
• EU/EEA/UK: The Google UMP consent form is shown at first launch. To change your consent choice, contact us at privacy@archetstudio.com to request a consent reset.

8. Privacy Manifest & Required Reason APIs

MetroTune™ is developed in accordance with Apple's Privacy Manifest policy. The application does not implement the App Tracking Transparency (ATT) framework and does not collect the IDFA.

• NSPrivacyTracking: Disabled. MetroTune™ does not request IDFA access or implement ATT. All ads on iOS are non-personalized.
• NSPrivacyTrackingDomains: Applicable. Google/AdMob tracking domains are declared in the Privacy Manifest in accordance with Apple's requirements.
• Required Reason APIs: MetroTune™ uses UserDefaults (via AsyncStorage) strictly for storing user preferences such as color theme and premium unlock timestamps. File Timestamp APIs, if accessed, are used solely for cache management of bundled assets. These APIs are never used for device fingerprinting or cross-app identification.

All current and future releases adhere to these Privacy Manifest and Data Minimization principles.

9. Device Permissions

MetroTune™ may request the following device permissions:

iOS

• Microphone: Required for real-time audio analysis features such as pitch detection (tuner) and optional hands-free control via double-clap detection (metronome).
• Microphone (Background): Used for real-time audio analysis while the app is in the foreground. Background audio is not enabled; playback and microphone listening stop when the app is backgrounded or the screen is off.

Android

• Record Audio: Required for real-time audio analysis features such as pitch detection (tuner) and optional double-clap detection (metronome).
• Modify Audio Settings: Required for audio routing during simultaneous playback and recording.
• Foreground Service: Keeps the microphone-based audio analysis active while the app is in the foreground. On Android 14+, the sub-type FOREGROUND_SERVICE_MICROPHONE is declared for real-time pitch detection and double-clap listening. The app does not use a media-playback foreground service; metronome audio stops when the app is backgrounded.
• Internet: Required by the AdMob SDK for ad delivery.

10. Your Rights

The only data Archet Studio LLC directly holds is information you voluntarily provide via email correspondence to privacy@archetstudio.com.

All locally stored preferences are automatically deleted when the user uninstalls the application. For data collected by the AdMob SDK, users may refer to Google's privacy tools to manage their data.

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of personal information we hold about you. To submit a data deletion request, email privacy@archetstudio.com with the subject line "Data Deletion Request."
• Right to Correct: Under CPRA § 1798.106, you may request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale/Sharing: We do not "sell" personal information. However, our use of the Google AdMob SDK on Android may be considered "sharing" for cross-contextual behavioral advertising purposes under the CPRA. You may opt out by adjusting your device settings (see Section 7).
• Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined under the CPRA (e.g., Social Security numbers, financial account details, precise geolocation, racial or ethnic origin, biometric data for identification).
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your California privacy rights.

Authorized Agent

You may designate an authorized agent to submit a request on your behalf. To do so, provide a signed, written authorization to the agent and contact us at privacy@archetstudio.com so we can verify your identity and the agent's authority.

Financial Incentive Disclosure

MetroTune™ offers a rewarded ad value exchange in which users may watch a personalized video advertisement to receive a 24-hour premium content unlock (see Section 4.4). This exchange requires the processing of advertising identifiers by the AdMob SDK. Participation is entirely voluntary, and you may use the application without participating. The value of the premium content unlock is reasonably related to the value of the data involved in serving the personalized advertisement.

To exercise any of these rights, contact us at privacy@archetstudio.com. We may need to verify your identity before processing your request; we will ask you to confirm the email address from which your inquiry was sent. We will respond within 45 days as required by California law.

European Economic Area (EEA) / GDPR Rights

If you are located in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) provides you with additional rights regarding your personal data.

Data Controller

Archet Studio LLC is the data controller for personal data it directly collects, specifically email correspondence and website contact interactions. For data collected through the Google AdMob SDK, Google LLC acts as an independent data controller and processes that data in accordance with the Google Privacy Policy.

Legal Basis for Processing

We process personal data under the following legal bases:

• Consent (Art. 6(1)(a)): Relied upon for EEA/UK users. MetroTune™ implements Google UMP, which presents a consent form to EEA/UK users at first launch. Personalized advertising is served to EEA/UK users only with explicit consent (Android only; iOS always serves non-personalized ads). You may withdraw consent at any time (see "Right to Withdraw Consent" below).
• Legitimate Interest (Art. 6(1)(f)): Non-personalized advertisement delivery (where consent is not given or not applicable) and email correspondence to respond to inquiries.

Your GDPR Rights

Under the GDPR, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate or incomplete personal data
• Erasure — request deletion of your personal data ("right to be forgotten")
• Restriction — request restriction of processing of your personal data
• Data Portability — receive your personal data in a structured, commonly used, machine-readable format
• Object — object to processing of your personal data based on legitimate interest
• Withdraw Consent — withdraw previously granted consent at any time (see below)
• Lodge a Complaint — file a complaint with your local data protection supervisory authority

To exercise any of these rights, contact us at privacy@archetstudio.com. We will respond within 30 days as required by the GDPR.

International Data Transfers

Data collected by the AdMob SDK may be transferred to Google servers located in the United States and other countries outside the EEA. These transfers are governed by the EU-US Data Privacy Framework and/or Standard Contractual Clauses (SCCs) as implemented by Google. For more information, see Google's data transfer frameworks.

EU Representative

Archet Studio LLC is a small business whose processing of EEA personal data is occasional, does not include large-scale processing, and does not involve special categories of data or data relating to criminal convictions. Accordingly, we rely on the exemption under GDPR Article 27(2) and have not appointed an EU representative. You may contact us directly at privacy@archetstudio.com for any data protection inquiries.

Automated Decision-Making

Archet Studio LLC does not engage in automated decision-making or profiling that produces legal or similarly significant effects. The AdMob SDK may use automated processes to select and serve personalized advertisements; for details, refer to the Google Privacy Policy.

Right to Withdraw Consent / Limit Ad Personalization

You may withdraw or limit ad personalization consent at any time:

• iOS: No action needed — MetroTune always serves non-personalized ads on iOS.
• Android: Settings > Google > Ads > Opt out of Ads Personalization.
• EU/EEA/UK — UMP consent: To reset your consent choice, contact us at privacy@archetstudio.com to request a consent reset. We will respond within 30 days.

South Korea (PIPA)

If you are located in the Republic of Korea, the Personal Information Protection Act (개인정보 보호법, "PIPA") provides you with additional rights and protections regarding your personal information. For the complete Korean-language privacy policy with full PIPA compliance, please refer to our 한국어 개인정보 처리방침.

To exercise any of your rights under PIPA, contact the Privacy Officer at privacy@archetstudio.com. We will respond without delay and within 10 days as required by PIPA. You may also file a complaint with the Personal Information Protection Commission (PIPC) at pipc.go.kr.

11. Children's Privacy

MetroTune™ is a general-audience utility application and is not directed at children under 13. Archet Studio LLC does not knowingly collect personal information from children. If we become aware that personal data from a child under 13 has been inadvertently collected, we will take steps to delete it promptly.

If you are a parent or guardian and believe your child has provided personal information to us, please contact us at privacy@archetstudio.com.

12. Changes to This Policy

Current version: v2.0

We may update this Privacy Policy from time to time, including when features, legal requirements, or data practices change. Any changes will be posted on this page with a revised effective date. For material changes, we will provide prominent notice within MetroTune™ before changes take effect. We encourage you to review this page periodically.

13. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us: