Privacy Policy
Version 2026-10-16 · Effective October 16, 2026
1. Who We Are & Our Role
Álvaro Berlanga Fernández, operating Conduct Studio as a sole trader established in Madrid, Spain, is the controller for account, billing, usage, security, and support data. Where a customer uploads personal data about collaborators or people appearing in content, the customer is normally the controller and we process that data on its instructions under the Data Processing Addendum.
Privacy questions and data-subject requests should be directed to privacy@conductstudio.com. We aim to acknowledge requests within 72 hours and respond within the period required by applicable law, including lawful extensions. We periodically assess whether appointment of a Data Protection Officer is required and publish only conclusions supported by the current assessment.
2. What Data We Collect
2.1 Account Data
Name, email address, profile photo, organisation name, role within organisation, job title (optional), account creation date, and last-active timestamp.
2.2 Content Data
Audio and picture files uploaded to the Service; project metadata including cue names, timecodes, reel/episode structure, delivery notes, and version history; chat messages, @mentions, and cue thread comments; review feedback; and delivery and approval history. This content may itself contain personal data of third parties, for which you are the controller (see Section 1). We do not use customer content to train artificial-intelligence or machine-learning models.
2.3 Payment Data
Billing name and address, country, subscription plan, payment-method type (last 4 digits only), transaction history, and invoice records. Full card details are processed exclusively by Stripe — we never receive or store raw card numbers or CVVs.
2.4 Usage & Technical Data
Device type, operating-system and app version, features accessed, session duration, and error or diagnostic reports. Our hosting, security, and (where you consent) analytics providers process your IP address transiently to deliver, secure, and monitor the Service. We do not store your IP address in our own application database; limited abuse-prevention records may contain a non-reversible (hashed) representation of an IP address or similar identifier, which cannot be read back to the original value. If the Conduct desktop app crashes, it sends a native crash report to Sentry. A crash report can contain parts of the app's memory at the moment of the crash, which may include whatever the app was handling then. We use crash reports only to find and fix crashes. To keep automated abuse away from our sign-in, sign-up and password-reset forms, those forms run Cloudflare Turnstile, an invisible bot check that processes technical signals from your browser or the desktop app (such as IP address and browser characteristics) under Cloudflare's Turnstile Privacy Addendum (cloudflare.com/turnstile-privacy-policy); it does not use advertising cookies.
2.5 Communications
Support tickets and responses, and any feedback or survey submissions you choose to send us.
2.6 Local Workspaces and Dropbox
When you select a local workspace, external drive, or Dropbox File Provider folder in the desktop app, master files normally remain in the location you selected and are accessed through macOS file permissions. In Dropbox mode, Conduct is not acting as a Dropbox OAuth client: Dropbox sync is provided by the local Dropbox File Provider. Conduct may upload a compressed preview and project metadata to its cloud so authorised collaborators and reviewers can use web features. The selected provider remains responsible for its own local and cloud synchronization.
3. Legal Basis for Processing (GDPR Article 13)
Every processing activity we carry out has a named legal basis under GDPR. Where we rely on legitimate interests (Article 6.1(f)), you have the right to object — see Section 6. Where we rely on consent (for example, for non-essential analytics or marketing email), you may withdraw it at any time. See the table below for the full breakdown.
| Processing Activity | Legal Basis | GDPR Article |
|---|---|---|
| Account creation and management | Contract performance | 6.1(b) |
| Delivering the Service (storage, sync, audio processing, streaming) | Contract performance | 6.1(b) |
| Payment processing via Stripe | Contract performance | 6.1(b) |
| Transactional emails (receipts, delivery notifications, account alerts) | Contract performance | 6.1(b) |
| Product update emails and newsletters | Consent | 6.1(a) |
| Product analytics (where you consent) | Consent | 6.1(a) |
| Security monitoring, fraud prevention, abuse detection | Legitimate interests | 6.1(f) |
| Service improvement and error monitoring | Legitimate interests | 6.1(f) |
| Retaining payment records for tax compliance | Legal obligation | 6.1(c) |
| Responding to legal requests (DMCA, court orders) | Legal obligation | 6.1(c) |
4. Third-Party Processors (Sub-processors)
We share data with service providers solely to deliver the Service. The current list identifies each provider's role and published data-protection terms, and explains how to subscribe to change notifications: conductstudio.com/legal/subprocessors. Before paid checkout is enabled, the operator register requires confirmation of the terms and transfer mechanism that apply to each production account.
We do not sell your personal data to any third party. We do not use third-party advertising networks, ad tracking, or cross-context behavioural advertising on any part of the Service.
| Processor | Purpose | Location | DPA |
|---|---|---|---|
| Supabase Inc. | Authentication, database, file storage, and realtime | EU project region; provider support operations may be global | supabase.com/legal/dpa |
| Vercel Inc. | Application hosting, web portal, serverless functions, and cron | EU execution preference; provider operations may be global | vercel.com/legal/dpa |
| Stripe, Inc. / Stripe Payments Europe | Payment processing, billing, fraud prevention, and tax calculation | EU and global payment network | stripe.com/legal/dpa |
| Brevo SAS | Transactional email delivery | EU (France) | brevo.com/legal/dpa |
| PostHog Inc. | Product analytics (account ID, organisation ID, feature-usage events) — only with consent | EU (eu.posthog.com) | posthog.com/dpa |
| Functional Software, Inc. (Sentry) | Error monitoring, desktop-app crash reports, and performance tracing with application-side redaction | Provider infrastructure and support may be global | sentry.io/legal/dpa |
| Cloudflare, Inc. | Encrypted off-site backups in R2, and Turnstile bot protection on the sign-in, sign-up and password-reset forms (see the Turnstile Privacy Addendum: cloudflare.com/turnstile-privacy-policy) | Provider infrastructure and support may be global | cloudflare.com/cloudflare-customer-dpa |
5. International Data Transfers
Our primary application database and selected service regions are configured in the European Union. Some providers may process limited data elsewhere. For each relevant transfer we use the mechanism recorded in our current vendor register, such as an adequacy decision or the European Commission's Standard Contractual Clauses with supplementary measures and, where applicable, the UK Addendum or IDTA. We claim Data Privacy Framework coverage only where the recipient's current certification has been verified. You may request information about the applicable mechanism through privacy@conductstudio.com.
6. Your Rights
6.1 GDPR & UK GDPR Rights (EU, EEA & UK users)
Right of access (Art. 15) — request a copy of all personal data we hold about you. Right to rectification (Art. 16) — correct inaccurate or incomplete data. Right to erasure (Art. 17) — request deletion of your data ("right to be forgotten"). Right to data portability (Art. 20) — receive your data in a structured, machine-readable format. Right to restriction (Art. 18) — pause processing while a dispute is resolved. Right to object (Art. 21) — object to processing based on legitimate interests, including direct marketing. Right to withdraw consent (Art. 7.3) — where processing is based on consent, withdraw it at any time without affecting prior processing.
6.2 California Rights (CCPA/CPRA)
If you are a California resident, you have the right to know what personal information we collect and how it is used; to access and delete it; to correct inaccurate information; to opt out of the sale or sharing of personal information; and to limit the use of sensitive personal information. We do not sell or share your personal information and we do not use it for cross-context behavioural advertising. We honour the Global Privacy Control (GPC) browser signal as a valid opt-out. You will not be discriminated against for exercising these rights.
6.3 Other U.S. State Rights
If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or another U.S. state with a comprehensive privacy law, you generally have the right to confirm whether we process your personal data and to access it; to correct it; to delete it; to obtain a portable copy; and to opt out of the sale of personal data, targeted advertising, and certain profiling (we do not engage in these activities). Where required, we recognise universal opt-out mechanisms such as the Global Privacy Control. If we decline a request, you may appeal by replying to our decision or emailing us; we will respond to appeals within the period your state's law requires.
6.4 Canadian Rights and Québec Availability
If you are in a supported Canadian province, you may request access to and correction of your personal information and may withdraw consent subject to lawful and contractual limits. Conduct is not offered to residents of Québec at this launch. Québec availability requires French legal documents and the applicable privacy assessments; checkout blocks Québec addresses.
6.5 How to Exercise Your Rights
Open Settings → Privacy in the Conduct app for self-serve consent toggles, processing-restriction toggle, rectification form, objection to legitimate-interests processing, and request submission. Self-serve actions are recorded immediately to an immutable audit trail and placed in the staff queue. You may also email privacy@conductstudio.com; both routes use the same rights-request workflow.
We aim to acknowledge requests within 72 hours and respond within the period required by applicable law, including one month under the GDPR and the applicable period under U.S. state law. We may need to verify your identity before processing your request, particularly when the change affects identity-bearing fields (email, billing identity). We will not discriminate against you for exercising your rights.
When you exercise the right to data portability, your archive ships as JSON Lines (one record per line) accompanied by JSON Schema draft-2020-12 definitions for each category — the GDPR Article 20 "structured, commonly used, machine-readable" format. A SHA-256 of each file is included for tamper-evidence.
EU residents may lodge a complaint with the AEPD — Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001 Madrid (www.aepd.es) — or their local supervisory authority. UK residents may contact the ICO (ico.org.uk).
7. Data Retention
We retain data only as long as necessary for the purpose for which it was collected or as required by law. Retention of payment records for tax compliance is a legal obligation under Spanish tax law that overrides the right to erasure for that specific data category. Routine operational backups target deletion within 60 days. Conduct also currently maintains encrypted, access-restricted disaster-recovery snapshots under daily, weekly, and monthly retention tiers, with some locked snapshots retained for longer periods. Deleted accounts are not restored to active use from those snapshots; if a disaster recovery restores older data, deletion and restriction records must be re-applied before service resumes. The operator is separating legally retained transaction evidence from customer-content backups so that the longer disaster-recovery retention can be reduced. See the table below.
| Data Category | Retention Period | Reason |
|---|---|---|
| Account and project data | Duration of active subscription | Contract necessity |
| Audio files and content after account deletion | 14 days in the reversible deletion period | Restore or export before deletion |
| Content after a paid-plan lapse | 30 days in read-only mode | Restore, reduce usage, or export |
| Routine operational backup copies | Target: up to 60 days after primary deletion | Technical backup cycles; see the disaster-recovery qualification below |
| Identifiable product analytics | Up to 6 months | Consented product improvement |
| Aggregated analytics | May be retained longer once non-identifying | Long-term service statistics |
| Security and audit logs | 24 months unless a legal hold applies | Security, fraud prevention, and incident investigation |
| Inactive Free accounts | At 24 months, enter the 14-day deletion-recovery lifecycle after prior warning | Data minimisation; activity cancels deletion |
| Contract, acceptance, invoice, and refund evidence | 6 years after the relationship or transaction | Commercial, tax, and legal-claims obligations |
| Support communications | 3 years | Legitimate interests (dispute resolution) |
| Legal hold data | Duration of legal proceedings | Legal obligation |
9. Security
We use transport encryption, encrypted provider storage, role-based and row-level access controls, opaque storage keys, expiring media URLs, least-privilege staff access, security logging, and documented encrypted-backup procedures. No service can guarantee absolute security.
We investigate suspected personal-data breaches, record confirmed incidents in our confidential breach register, notify competent authorities within the periods required by applicable law, and notify affected people when legally required.
A small number of authorised staff may use time-limited, logged impersonation only when necessary for support or incident response. We do not use that access for marketing or profiling. You may request the access log for your account through privacy@conductstudio.com.
10. Automated Decision-Making
We do not carry out solely automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of GDPR Article 22. Automated rate-limiting and abuse-prevention controls are used only to protect the Service and do not make significant decisions about you without human involvement.
11. Children's Privacy
The Service is intended for business and professional use and is not directed at children. We do not knowingly collect personal data from children. We apply, at a minimum, the age of digital consent in the user's jurisdiction (for example, 14 in Spain under LOPDGDD Art. 7, 16 in some EU member states, and under-13 under the U.S. COPPA standard). If we become aware that we have collected personal data from a child below the applicable age without the required consent, we will delete it promptly.
12. Changes to This Policy
We will notify you of material changes by email and in-app notification at least 30 days before they take effect. The effective date is displayed at the top of this document.
13. Contact
Privacy enquiries: privacy@conductstudio.com Service target: acknowledgement within 72 hours; substantive response within the period required by law
Álvaro Berlanga Fernández Madrid, Spain