Privacy Policy
Last updated: 5 July 2026
1. INTRODUCTION
Welcome to Sangatkaar!
This Privacy Policy ("Policy") explains how Sangatkaar, owned and operated by Srinivasan Krishnamurthy ("we", "us", "our") collects, uses, stores, processes, discloses, and protects Personal Data in connection with your access to and use of Sangatkaar, including our mobile application(s), website(s) having URL: fluteschoolpro.com, and any related products, services, content, features, tools, and digital offerings (collectively, the "Platform").
We are committed to respecting and protecting your privacy and handling Personal Data responsibly and in accordance with applicable laws, including the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the General Data Protection Regulation ("GDPR"), the UK GDPR, and other applicable privacy laws to the extent they apply.
This Policy applies to all users who access or use the Platform from any location worldwide.
The purpose of this Policy is to explain:
| Topic | Description |
|---|---|
| Personal Data We Process | The categories of information that may be processed through the Platform |
| Use of Information | How and why such information is used |
| Permissions | Device permissions requested by the Platform and their purpose |
| User Content | How audio recordings, video recordings, and other content created through the Platform are handled |
| Data Sharing | Circumstances in which information may be shared with third parties |
| Privacy Rights | Rights and choices available to users under applicable law |
| Security and Retention | How information is protected and retained |
By accessing, downloading, installing, or using the Platform, you acknowledge that you have read and understood this Policy.
If you do not agree with this Policy, you should discontinue use of the Platform.
2. PERSONAL DATA WE PROCESS
We have designed the Platform to operate primarily as a local-first service. In the ordinary course of use, users are not required to create an account, register, submit personal information, or log in to access the core functionality of the Platform.
Depending on the features used, the Platform may process the following categories of information:
| Category | Description |
|---|---|
| Device Permissions Information | Information necessary to access device features such as the microphone, camera, storage, photo library, and notifications, where enabled by the user. |
| Audio and Video Content | Audio recordings, video recordings, and related content created by the user through the Platform. Such content is generally stored locally on the user's device. |
| Notification Information | Where users voluntarily opt in to receive push notifications, the Platform may process a device push notification token (including an Apple Push Notification service (APNs) device token or an equivalent identifier provided by the applicable operating system) solely for the purpose of delivering optional push notifications and maintaining notification functionality. No notification content is accessed through such token. |
| Purchase Information | Where purchases, subscriptions, premium features, or in-app transactions are offered through third-party app store providers, limited transaction-related information may be processed to verify purchases, manage access to paid features, comply with legal obligations, or support operational requirements. Payment card, banking, and other payment instrument information is processed by the applicable app store provider and not by us. |
| Support Communications | Information voluntarily provided by users when contacting us for support, feedback, inquiries, or assistance. |
| Diagnostic and Crash Information | Limited diagnostic information, crash logs, and app performance information may be processed to identify technical issues, improve stability, troubleshoot errors, and maintain the security and performance of the Platform. Such information is not used for advertising or profiling purposes. |
Information We Do Not Intentionally Collect
Except as expressly disclosed in this Policy, the Platform does not intentionally require or collect the following categories of Personal Data for its core functionality: user account credentials, name, postal address, government identification information, financial account information, contact lists, precise location information, biometric information, advertising identifiers for behavioural advertising, user profiles created through platform registration.
The Platform does not require account creation, does not provide social networking features, does not operate user-to-user messaging services, and does not use behavioural advertising technologies, profiling technologies, or analytics tools that track user behaviour for advertising or marketing purposes unless expressly disclosed in a future update to this Policy.
Where any information processed through the Platform constitutes "Personal Data", "Personal Information", or a similar concept under applicable law, such information shall be processed only for the purposes described in this Policy and in accordance with applicable legal requirements.
3. HOW WE USE PERSONAL DATA
We process Personal Data only for legitimate purposes connected with the operation, functionality, security, maintenance, and improvement of the Platform.
The categories of information processed and the purposes for which they may be used are set out below:
| Purpose | Information Used |
|---|---|
| To provide the functionality of the Platform | Device permissions and technical information necessary to enable features selected by the user |
| To create, record, save, edit, export, and manage audio or video content | Audio recordings, video recordings, and related user-generated content stored through the Platform |
| To deliver optional notifications | Device notification token and related notification information where notifications are enabled by the user |
| To process purchases, subscriptions, and premium features | Transaction-related information provided by the applicable app store provider |
| To respond to inquiries, support requests, or feedback | Information voluntarily provided by users when contacting us |
| To maintain the security, integrity, performance, and operation of the Platform | Technical and operational information necessary for troubleshooting, maintenance, and compliance purposes |
| To monitor app stability, diagnose technical issues, and improve performance | Diagnostic information, crash logs, and app performance information. |
We do not sell Personal Data, use Personal Data for behavioural advertising, profile users for marketing purposes, or track users across third-party websites, applications, or services.
Where Personal Data is processed on the basis of consent, users may withdraw such consent at any time by disabling the relevant permission, feature, or setting, subject to the functionality affected.
We shall process Personal Data only for the purposes described in this Policy or as otherwise permitted or required by applicable law. We shall not process Personal Data in a manner incompatible with the purposes described in this Policy unless otherwise permitted or required by applicable law.
4. DEVICE PERMISSIONS
The Platform may request access to certain device features and permissions in order to provide specific functionality requested by the user. Such permissions are used solely for the purposes described below.
| Permission | Purpose |
|---|---|
| Microphone | To enable audio recording and related audio-processing features initiated by the user. |
| Camera | To enable video recording and related content creation features initiated by the user. |
| Storage / Files | To save, access, manage, export, and share recordings, presets, and other content created through the Platform. |
| Photos / Media Library | To save exported images and videos to the user's device library, where applicable. |
| Notifications | To deliver optional notifications relating to Platform updates, content releases, feature announcements, and similar communications. |
The Platform accesses such permissions only to provide the functionality selected by the user and does not use such permissions for behavioural advertising, profiling, tracking, or unrelated monitoring activities.
Users may grant, deny, restrict, or revoke permissions through their device settings at any time. However, certain features of the Platform may not function properly if the relevant permissions are not granted.
The Platform does not access location information, contact lists, or other device features unless expressly disclosed in a future update to this Policy.
5. AUDIO, VIDEO AND USER CONTENT
The Platform may enable users to create, record, save, edit, export, and share audio recordings, video recordings, performances, presets, and other content generated through the Platform ("User Content").
The Platform is designed to operate primarily on a local-first basis. Accordingly, User Content created through the Platform is generally stored locally on the user's device and is not routinely transmitted to, stored on, or processed by our servers.
The manner in which User Content is handled is summarized below:
| Activity | Description |
|---|---|
| Recording | Users may create audio and video recordings using the Platform's recording features. |
| Storage | User Content is generally stored locally on the user's device. |
| Export | Users may export recordings and other content to their device or supported applications and services. |
| Sharing | Users may voluntarily share content using available device or operating-system functionality. |
| Deletion | Users may delete User Content directly from their device, subject to device limitations and operating-system controls. |
We do not routinely access, review, monitor, listen to, view, upload, transmit, or store User Content on our servers.
Any access to the microphone, camera, storage, photo library, or related device functionality occurs solely for the purpose of enabling the features requested by the user.
Where User Content is shared with third-party applications, platforms, services, or recipients, such sharing shall be governed by the privacy policies, terms, and practices of those third parties, and we shall not be responsible for the processing of such content by them.
6. IN-APP PURCHASES AND PAYMENTS
The Platform may offer premium features through one-time in-app purchases, auto-renewable subscriptions, or other paid content made available through the applicable app store.
Where purchases are made through the Apple App Store, Google Play Store, or any other authorized distribution platform, the applicable app store provider shall be responsible for processing the transaction and handling payment-related information in accordance with its own terms, conditions, and privacy policies.
We do not receive, collect, process, store, or retain complete payment card information, banking information, or other payment instrument details used to complete such transactions.
We may receive limited transaction-related information from the applicable app store provider, such as information necessary to verify purchases, subscriptions, renewals, cancellations, refunds, or access to paid features.
Users should review the privacy policies and terms of the relevant app store provider before making any purchase through the Platform.
| Payment Provider | Role |
|---|---|
| Apple App Store | Processes one-time in-app purchases, auto-renewable subscriptions, renewals, refunds, cancellations, and payment transactions through Apple's In-App Purchase (StoreKit) system. |
| Google Play Store | Processes purchases, subscriptions, renewals, and payment transactions made through Google's ecosystem, where applicable. |
The collection, use, storage, and processing of payment information by the relevant app store provider shall be governed by that provider's policies and practices, and not by this Policy.
7. DATA SHARING AND THIRD-PARTY SERVICES
We respect user privacy and do not sell, rent, lease, trade, disclose, or otherwise monetize Personal Data for advertising, marketing, profiling, or similar commercial purposes.
Given the local-first nature of the Platform, much of the information generated through the Platform remains on the user's device and is not routinely transmitted to us. However, in limited circumstances, we may share, disclose, transfer, or permit access to Personal Data where reasonably necessary for the operation of the Platform, compliance with legal obligations, protection of rights, or other legitimate purposes described in this Policy.
The categories of recipients with whom Personal Data may be shared are set out below:
| Recipient / Category | Purpose of Disclosure |
|---|---|
| App Store Providers | To facilitate purchases, subscriptions, payment verification, renewals, cancellations, refunds, and access to paid features. |
| Notification Service Providers | To facilitate the delivery of optional push notifications and related communications where enabled by the user. |
| Professional Advisors | Legal advisors, auditors, accountants, consultants, insurers, and other professional advisors where reasonably necessary for legal, regulatory, operational, or business purposes. |
| Service Providers | Technology, hosting, infrastructure, customer support, security, compliance, or other service providers engaged to support the operation of the Platform, subject to appropriate contractual safeguards. |
| Regulatory Authorities and Government Agencies | Where required by applicable law, legal process, court order, regulatory requirement, governmental request, or enforcement action. |
| Business Successors and Transferees | In connection with a merger, acquisition, restructuring, financing transaction, business transfer, sale of assets, or similar corporate transaction. |
Legal Compliance and Protection of Rights
We may disclose Personal Data where we reasonably believe such disclosure is necessary to:
Third-Party Platforms and Services
The Platform may be distributed through third-party platforms, including app stores and operating-system providers. Certain information may be processed directly by such third parties in accordance with their own privacy policies, terms, and practices.
Where users voluntarily export, share, transmit, or distribute content through third-party applications, platforms, services, social media networks, messaging services, cloud services, or other destinations, the processing of such information shall be governed by the policies and practices of those third parties, and we shall not be responsible for their privacy practices or data-handling activities.
No Sale or Behavioural Advertising
We do not:
| Activity | Position |
|---|---|
| Sell Personal Data | No |
| Rent Personal Data | No |
| Share Personal Data for Behavioural Advertising | No |
| Profile Users for Advertising Purposes | No |
| Track Users Across Third-Party Websites or Applications for Advertising Purposes | No |
Any future use of third-party analytics services, advertising services, tracking technologies, or similar tools that materially affect the processing of Personal Data shall be disclosed through an update to this Policy.
8. DATA STORAGE AND RETENTION
The Platform has been designed to operate primarily on a local-first basis. Accordingly, audio recordings, video recordings, presets, settings, and other User Content created through the Platform are generally stored locally on the user's device and not on our servers. The manner in which information is stored and retained may vary depending on the nature of the information and the functionality being used.
| Category of Information | Storage and Retention |
|---|---|
| Audio Recordings and Video Recordings | Generally stored locally on the user's device and retained until deleted by the user or removed through device settings. |
| Presets, Settings, and User Preferences | Generally stored locally on the user's device and retained until modified, reset, or deleted by the user. |
| Notification Information | Where a device push notification token (including an APNs device token or equivalent identifier) is processed for optional push notifications, such information shall be retained only for so long as reasonably necessary to provide notification functionality, maintain operational integrity, comply with legal obligations, or protect legitimate interests, or until notifications are disabled or the token is no longer valid. |
| Purchase-Related Information | Where transaction-related information is received or processed in connection with purchases, subscriptions, or premium features, such information may be retained for accounting, compliance, dispute resolution, security, operational, legal, or regulatory purposes. |
| Support Communications | Information provided through support requests, inquiries, or correspondence may be retained for as long as reasonably necessary to respond to the request, maintain records, resolve disputes, comply with legal obligations, or protect our legitimate interests. |
| Diagnostic and Crash Information | Retained only for so long as reasonably necessary to investigate technical issues, maintain platform stability, improve performance, comply with legal obligations, or protect legitimate interests. |
We retain Personal Data only for as long as reasonably necessary to fulfil the purposes described in this Policy, comply with applicable legal, regulatory, accounting, reporting, or contractual obligations, resolve disputes, enforce our rights, protect the security and integrity of the Platform, or as otherwise permitted or required by applicable law.
Where Personal Data is no longer required for the purposes for which it was collected or processed, we may delete, anonymize, aggregate, de-identify, or otherwise dispose of such information in accordance with applicable law and our internal retention practices.
Users remain responsible for managing, backing up, exporting, and deleting content stored on their devices. Deleting the Platform, resetting a device, changing devices, or modifying device settings may affect the availability of locally stored content, and we may not be able to recover such content.
Nothing in this Policy shall require us to retain information for longer than is reasonably necessary for the purposes described herein or as otherwise required by applicable law.
9. INTERNATIONAL DATA TRANSFERS
The Platform is made available to users in multiple countries. However, the Platform is designed to operate primarily on a local-first basis and, as part of its core functionality, does not ordinarily transfer Personal Data internationally. Much of the information generated through the Platform, including audio recordings, video recordings, presets, settings, and other User Content, generally remains stored on the user's device and is not routinely transmitted to us.
To the extent that Personal Data is processed through app store providers, notification service providers, legal and regulatory processes, professional advisors, service providers, or other operational requirements, such processing may occur in jurisdictions outside the user's country of residence.
Where applicable, we shall take reasonable steps to ensure that any such processing is carried out in accordance with this Policy and applicable legal requirements, including the implementation of appropriate safeguards to the extent required by law.
10. CHILDREN'S PRIVACY
The Platform may be used by individuals of different age groups, including children and young music students, for learning, practice, and educational purposes. The Platform has been designed to operate primarily on a local-first basis and does not ordinarily require users to create accounts, register, or provide Personal Data in order to access its core functionality.
We do not knowingly collect, solicit, or require Personal Data from children as part of the ordinary operation of the Platform. To the extent Personal Data relating to a child is voluntarily provided through support requests, communications, inquiries, feedback, or similar interactions, such information shall be handled in accordance with this Policy and applicable law.
Parents and guardians are encouraged to supervise children's use of the Platform and to contact us if they believe that Personal Data relating to a child has been provided to us or processed in a manner inconsistent with applicable law.
Where we become aware that Personal Data relating to a child has been collected, processed, or retained in a manner requiring additional consent, authorization, or legal safeguards under applicable law, we may take appropriate measures, including obtaining necessary permissions, restricting processing, deleting information, or taking any other action reasonably necessary to comply with applicable legal requirements.
Nothing in this Policy shall limit any rights, protections, obligations, or requirements applicable under laws relating to the privacy and protection of children.
11. YOUR PRIVACY RIGHTS
Depending on your location and the applicable law, you may have certain rights in relation to your Personal Data.
Subject to applicable legal requirements, limitations, and verification procedures, such rights may include:
| Right | Description |
|---|---|
| Right to Access | The right to request information regarding the Personal Data processed by us. |
| Right to Correction | The right to request correction, updating, or rectification of inaccurate or incomplete Personal Data. |
| Right to Erasure | The right to request deletion of Personal Data, subject to applicable legal, regulatory, contractual, operational, and security requirements. |
| Right to Withdraw Consent | Where processing is based on consent, the right to withdraw such consent at any time, subject to the functionality affected. |
| Right to Grievance Redressal | The right to raise concerns, complaints, or grievances regarding the processing of Personal Data. |
| Right to Restrict or Object | Where provided by applicable law, the right to object to or request restriction of certain processing activities. |
Given the local-first nature of the Platform, users may exercise many privacy-related controls directly through their devices, including by:
We may request information reasonably necessary to verify the identity or authority of a person submitting a privacy-related request before responding to such request.
Certain information may be retained where required to comply with applicable law, resolve disputes, enforce legal rights, maintain security, protect legitimate interests, or fulfil regulatory obligations.
Requests relating to privacy rights may be submitted using the contact details provided in this Policy, and we shall consider and respond to such requests in accordance with applicable law.
12. SECURITY
We take reasonable technical, administrative, organizational, and operational measures designed to protect Personal Data against unauthorized access, disclosure, alteration, misuse, loss, destruction, or other unauthorized processing.
The security measures implemented may vary depending on the nature of the information processed, the functionality being used, the sensitivity of the information involved, available technology, and applicable legal requirements.
As the Platform is designed to operate primarily on a local-first basis, much of the information generated through the Platform generally remains stored on the user's device rather than on our systems. Users are responsible for maintaining the security of their devices, operating systems, passwords, backups, and access controls, and for taking appropriate measures to prevent unauthorized access to content stored locally on their devices.
While we strive to implement reasonable safeguards, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security and disclaim any representation or warranty that the Platform will be immune from security breaches, cyberattacks, unauthorized access, system failures, or other security incidents.
In the event that we become aware of a security incident affecting Personal Data under our control, we may take such actions as we consider appropriate under the circumstances, including investigation, mitigation, remediation, notification, reporting, and compliance measures, to the extent required by applicable law.
Users are encouraged to maintain updated software, install security updates, use appropriate device security settings, and exercise caution when exporting, sharing, or transmitting content through third-party applications, platforms, or services.
13. CHANGES TO THIS PRIVACY POLICY
We may revise, update, amend, or modify this Privacy Policy from time to time to reflect changes in the Platform, applicable laws, regulatory requirements, industry practices, technology, business operations, security measures, or other legitimate considerations.
Any updated version of this Privacy Policy shall be effective from the date of publication unless otherwise stated.
Where required by applicable law or where we consider it appropriate in the circumstances, we may provide notice of material changes through the Platform, our website, app store listing, notifications, or other reasonable means.
Your continued access to or use of the Platform following the effective date of an updated Privacy Policy shall constitute acknowledgement of the revised Policy, subject to any rights available to you under applicable law.
We encourage users to review this Privacy Policy periodically to remain informed about our privacy practices and any updates that may affect them.
14. CONTACT US
If you have any questions, concerns, requests, complaints, or grievances regarding this Privacy Policy, the Platform, or our processing of Personal Data, you may contact us using the details:
Contact Person: Srinivasan Krishnamurthy; Email Address: [email protected]
Users may use the above contact details to:
We will endeavour to review and respond to such requests within a reasonable period and in accordance with applicable law.