How the GDPR applies to Replica Studio, and how to exercise your rights.
The controller is CIBELE, Inc., a Delaware corporation, 425 E 13th Street, New York, NY 10009, United States — contact@cibeleinc.com. CIBELE has not designated a Data Protection Officer: the processing described here does not meet the conditions of Article 37 of the GDPR.
Replica Studio has no account and no server of its own. Your recordings, your progress and your plan of sessions are written to the device and never sent to us. We therefore hold no file about you, and in the ordinary use of the app we receive no personal data at all.
Two exceptions are set out below: the subscription, and the embedded YouTube player.
Your voice recordings and practice data — processed on the device only, to let you hear yourself back and follow your progress. Legal basis: performance of the contract (Article 6(1)(b)). Because a recording of your voice is processed solely on your own device and never transmitted, no transfer to us takes place.
Subscription status — an anonymous installation identifier and the purchase information returned by Apple are processed by RevenueCat, our processor, so the app knows whether to unlock. Legal basis: performance of the contract (Article 6(1)(b)).
Playing a film scene — your IP address and technical data reach Google as the operator of the YouTube player. For this, Google acts under its own responsibility. Legal basis for embedding the player: our legitimate interest in showing the scenes the studio is built on (Article 6(1)(f)), the clips being the heart of the service.
Writing to us — your email address and the content of your message, kept only as long as needed to answer and to keep a record of the exchange. Legal basis: legitimate interest in answering you (Article 6(1)(f)).
Data on the device lasts until you delete it or delete the app. Subscription records are kept by Apple and RevenueCat for the periods their own policies set. Emails are kept for up to three years after the last exchange.
CIBELE is established in the United States, as are Apple and RevenueCat for the parts of their services concerned. Transfers are covered by the European Commission's standard contractual clauses or by another transfer mechanism recognised under Chapter V of the GDPR, as the case may be.
Under Articles 15 to 22 of the GDPR you have the rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent where processing rests on it.
In practice: most of these rights you exercise directly, without us. The data is on your device — you can read it, change it, export your recordings and erase everything by deleting the app. For anything else, write to contact@cibeleinc.com; we answer within one month, and we may need to verify your identity where a request concerns data we actually hold.
The app scores and compares your pronunciation to help you practise. These results have no legal effect and no similarly significant effect on you within the meaning of Article 22; they are a teaching aid, not an assessment that decides anything about you.
If you consider that your rights have not been respected, you may lodge a complaint with your national supervisory authority — in France, the CNIL.
Replica Studio is not aimed at children. We do not knowingly process the data of a child in breach of the applicable law.