Privacy policy

1. Data controller

[Raison sociale], a [forme juridique] with its registered office at [adresse du siège social], is the controller of the processing described here.

For any question about your data or to exercise your rights: [email protected].

2. What stays on your phone

What you listen to is nobody's business but yours. The following data is stored only on your phone and is never linked to your account on our servers:
• your favourites;
• your listening history and listening time;
• your monthly recap (Rewind);
• where you are in a programme;
• the Companion's memory, meaning the choices you make in the guide;
• the photo you may choose to personalise the look of the app.

We cannot view, analyse or pass on this data. It is erased when you delete your account; the Companion's memory is also erased each time you sign out.

There is one exception, limited to security: to prevent the catalogue from being scraped, our server records which sessions your account has unlocked and erases that list after thirty days. It is only used to enforce a cap; it is neither analysed nor used to recommend anything to you.

3. The data we process

Account: your email address, first name and sign-up date. Your password is handled by our authentication provider: we never see it.

Subscription: your plan, where your access comes from (trial, subscription, partner offer, employer), its end date, the start date of your trial, and the purchase events sent to us by the App Store or Google Play (purchase, renewal, cancellation, refund), which serve as proof in case of dispute. We never receive your bank details.

Device: a random identifier created by the app, which is not a hardware identifier of your phone, its make and model, the history of your device changes, and public keys used to encrypt downloaded sessions so that they can only be played on your device.

Security: the sessions unlocked by your account (see section 2), any instances of exceeding the unlock cap, and the fact that a device has already had the free trial or a partner offer.

Support: when you write to us from the app, the subject and text of your message, your email address, first name, language and plan, so that we can reply. We do not ask you for any health information; if you mention any, it is only used to reply to you.

ODASTRA Business: if your employer pays for your access, the company name, the seat assigned to you and the domain of your email address. Your employer may know that a seat has been activated; it receives nothing about what you listen to, when, or for how long.

On the website: if you pre-register, your email address and language, after a double opt-in confirmation by email; email open and click tracking is turned off. If you apply to the ODASTRA Partners programme: your name, email address, country, links to your accounts, audience, topic, motivation and your confirmation that you are an adult.

We do not collect your location, your contacts, your microphone or your advertising identifier. The app contains no audience-measurement or advertising tools.

4. Why, and on what legal basis

Providing the Service (account, access to sessions, subscription, one-active-device rule, support): performance of the contract between us.

Protecting the catalogue and the Service against fraud and scraping (unlock cap, one trial and one partner offer per device, protecting the website against bots): our legitimate interest in protecting our content and keeping the trial fair.

Keeping proof of purchase: our legal obligations and our legitimate interest in being able to prove a payment in case of dispute.

ODASTRA Business access: performance of the contract concluded with your employer and our legitimate interest in checking that the seat is yours.

Pre-registration: your consent, which you can withdraw at any time using the unsubscribe link in every email.

ODASTRA Partners application: steps taken at your request before entering into a contract.

5. Retention periods

Account: until it is deleted.
Unlocked sessions: 30 days.
Security log and device changes: 6 months.
Messages to support: 2 years.
Trial or partner offer already used by a device: 2 years.
Proof of purchase: 5 years.
Pre-registrations: until the app launches, then no more than 3 years without any exchange with you.
ODASTRA Partners applications: for the whole partnership if accepted, 6 months after our decision otherwise.

For the app, these periods are enforced automatically every night.

6. Deleting your account

You can delete your account at any time from the app, in the profile options. This erases your profile, your devices, your messages to support and your security log, as well as the data kept on your phone.

Two items are kept, because they meet a legal obligation or protect against fraud: proof of purchase, for 5 years, and the record that a device has already had the trial or a partner offer, for 2 years. They can no longer be traced back to you.

Deleting your account does not cancel a subscription taken out on the App Store or Google Play: cancel it first.

7. Who has access: our providers

Your data is never sold, rented or shared for advertising purposes. Within our team, only the people who need it to run the Service have access to it. We may also be required to disclose it to an authority that requests it lawfully.

Providers process some data on our behalf, on our instructions and under contract:
• account authentication: United States;
• database and Service logic: European Union;
• website hosting, audio session storage and bot protection: United States, on a global network;
• sending emails (pre-registration, support): France and United States;
• business email: Switzerland;
• technical subscription management: United States.

Transfers outside the European Union rely on adequacy decisions of the European Commission: the EU-US Data Privacy Framework, to which our US providers have signed up, and the adequacy decision covering Switzerland.

The detailed list of our processors is available on request from [email protected].

The App Store and Google Play process your purchases as separate controllers, under their own privacy policies.

8. Your rights

You can access your data, have it corrected or erased, restrict its use, object to processing based on our legitimate interest, receive the data you gave us in a reusable format, withdraw your consent at any time, and set instructions for what happens to your data after your death.

Write to us at [email protected], preferably from your account's email address. We reply within one month, which may be extended by two months for a complex request, in which case we let you know. We only ask for proof of identity if there is reasonable doubt.

We do not hold the data kept on your phone: only you can view and erase it.

You can also lodge a complaint with the French data protection authority, the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr, or with the authority of your country of residence.

9. Security

Exchanges between the app, the website and our servers are encrypted. Every sensitive operation goes through our server, never directly from the phone to the database. Downloaded sessions are encrypted on your device and can only be played there, for as long as your access is open. Your password is never stored by us.

In the event of a data breach that puts you at risk, we notify the CNIL and, where the law requires it, the people concerned.

10. Minors

ODASTRA is intended for adults, and for minors from the age of 15 with a parent's consent, under the conditions set out in the terms of use. In France, a minor can consent alone to the processing of their data from the age of 15. The Service is not intended for anyone younger: if we learn that an account belongs to them, we delete it.

The ODASTRA Partners programme is reserved for adults.

11. Cookies and trackers

The odastra.app website sets no audience-measurement, advertising or personalisation cookies, and uses no local storage in your browser. It contains no advertising pixel and no social media button that would track you. Its fonts are hosted on the website itself: displaying them does not send your IP address to anyone else. That is why no banner asks for your consent.

This is a deliberate choice. Our pages talk about addiction, anxiety and sleep: an advertising pixel would tell an ad network that you had read them, which is information about your health.

The only mechanisms used serve security: they protect the website and its forms against bots and attacks, and to do so may read technical characteristics of your browser or set a short-lived technical cookie. Being strictly necessary, they are exempt from consent.

Cookieless audience measurement, provided by our host, may be used: it counts visits in aggregate, without storing or reading anything on your device and without following you from one website to another.

The app contains no audience-measurement or advertising tools.

12. Changes to this policy

We update this policy when our processing changes; the date shown at the top is that of the latest version. Any significant change is announced in the app before it takes effect.