Privacy Policy / Datenschutzerklärung

§1 Controller (Verantwortlicher)

The controller within the meaning of Art. 4(7) GDPR for the processing of personal data on the CHOZEN platform is:

Thomas Ehresmann
Einzelunternehmen, Geschäftsbezeichnung CHOZEN
Reichenberger Str. 25, 36039 Fulda, Deutschland
E-Mail: privacy@chozen.io

See Impressum for full contact details.

§2 Categories of personal data we collect

2.1 Account data

• Full name (from Google, or from Apple if you share it when you use Sign in with Apple)
• Email address (your Google account email, your Apple ID email, or the private relay address Apple creates if you choose "Hide My Email")
• Profile picture (imported from Google or uploaded by you)
• Username / display name; subscription tier and status; account creation date
• Your consent record: the version of the Terms you accepted, when you accepted them, and when you confirmed that you are at least 16 years old

2.2 Authentication data

• Google OAuth tokens (access / refresh)
• Sign in with Apple: your Apple user identifier, whether your email is a private relay address, and the refresh token Apple issues to us. The token is encrypted at rest. We revoke it with Apple when you delete your account.
• An optional password for email sign-in, if one is set on your account. We store only a salted hash, never the password itself.
• Session identifiers; login timestamps and IP address at login

2.3 Payment data

• Stripe Connect account ID, PayPal merchant identifier
• Transaction history (purchases, sales, payouts), invoice data, billing address (when provided)
• Full credit card numbers are never stored by CHOZEN — they are handled exclusively by Stripe / PayPal.

2.4 Content data

• Audio files (beats, instrumentals, stems, loops, samples, oneshot kits, templates)
• Metadata (title, BPM, key, genre, mood tags, description)
• Cover artwork and visual assets; license configurations and pricing

2.5 Interaction data

• Comments, direct messages, forum posts; votes, likes, saves, reposts
• Follow / unfollow relationships
• Users you have blocked, and when (see §2.16)

2.6 Behavioural data

• Play history (tracks played, timestamps, duration of play)
• Search queries, Discover-feature swipes, page views, scroll depth
• Download history

2.7 Competitive data (FL Ranked)

• Matchmaking Rating (MMR) and rating history
• Match history (opponents, results, scores); division / rank progression
• Tournament participation and results; season statistics

2.8 Technical data

• IP address; device type, OS and version; browser type and version
• Mobile app version and build number; desktop app version
• App telemetry (crash reports, performance metrics)
• Screen resolution, viewport size, timezone and language preferences

2.9 Third-party integration data

• Google account information received via OAuth; Apple account information received via Sign in with Apple (see §2.1 and §2.2)
• Embed-player interaction data from third-party sites

2.10 Collaborator data

• Collaborator names, roles, revenue-share percentages
• Collaborator contact email for split notifications

2.11 Producer-collected emails

• Email addresses of buyers / fans collected through the producer email-collection feature
• Opt-in timestamps and consent records; segment assignments
• For these emails the Producer is the Controller and CHOZEN is the Processor — see §12.

2.12 Screen capture data (CHOZEN Ranked Overlay desktop app)

The CHOZEN Ranked Overlay (desktop app for Windows / macOS) can capture video frames of your selected window or screen and the corresponding system audio for the duration of a ranked beat battle. This is used to generate the post-match Reel that is shown back to you (and, where you choose to publish it, to other users).

• Legal basis: Art. 6(1)(a) GDPR — your explicit, revocable consent. The capture only starts after you grant the OS-level recording permission AND toggle the feature on in overlay settings.
• Opt-in / opt-out: Capture is opt-in. You can disable it at any time in the overlay settings — ranked play continues to work without it; only the post-match Reel will not be produced.
• Data category: video frames + system audio of the screen region you select. We do not capture your camera, microphone, or any window you have not selected.
• Recipients: The capture is streamed to our rendering service (Render.com, US) which assembles the Reel, then to Cloudflare R2 for storage. No further sharing.
• International transfer: Render.com is US-based. A Data Processing Agreement with Render.com is currently being arranged. Transfer relies on the EU-US Data Privacy Framework (where the processor is certified) or Standard Contractual Clauses (Art. 46(2)(c) GDPR).
• Retention: Intermediate frames are deleted within 24 hours of render completion. The final Reel is retained as long as the associated match remains in your account, then deleted within 30 days of match deletion.
• Publication. Reels are never shown publicly without your explicit consent. Sharing to other users (lobby feed, public reel feed, shareable link) requires a separate explicit action and a separate consent under Art. 6(1)(a).
• Right of instant removal ("Take down my footage"). Any person who appears in, or is the source of, a published Reel can request immediate removal at any time using the Remove my footage button on the Reel page. Effect:
  1. The Reel is taken offline immediately (within seconds, before any human review).
  2. You provide a short reason for the removal.
  3. The case is queued for review in the admin / support dashboard.
  4. After review the Reel either remains offline permanently or is restored — you are notified of the outcome.
  This right applies in addition to the general right of erasure under Art. 17 GDPR and the consent-withdrawal right under Art. 7(3) GDPR; it is faster and does not require contacting support.
• Sensitive content: Because the capture mirrors a selected portion of your screen, you should not include sensitive personal data (banking apps, private messages, etc.) in the captured region.

2.13 YouTube Data API (CHOZEN Uploader desktop app)

The CHOZEN Uploader desktop application (Windows / macOS) uses YouTube API Services to let you upload your own videos to your own YouTube channel. When you connect your Google / YouTube account you authorize CHOZEN to:

• upload videos to your channel on your behalf (youtube.upload); and
• read your channel's public profile — name, handle and avatar — so the app can show you which channel you are connected to and confirm the correct upload target (youtube.readonly).

• Data received and stored. Google returns an OAuth access token and refresh token. We store these tokens, their expiry and the granted scope on our servers (Cloudflare D1), linked to your CHOZEN account, solely to perform uploads you initiate. We never receive your Google password. The only YouTube data we display back to you is your channel name, handle and avatar.
• Use. We use YouTube API data only to provide the upload feature that is prominent in the app's interface. We do not use it for advertising, we never sell it, and no human at CHOZEN reads it.
• Google Limited Use. CHOZEN's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
• Preset Research (public YouTube data). Separately from the upload feature, the uploader's Preset Research step looks up publicly availablevideos for a search term you enter, so it can suggest tags and title templates. This runs on our server with a CHOZEN API key — not with your account or your authorisation — and returns public video metadata only (title, description, tags, channel name, and view counts when you filter by them). Results are cached for a maximum of 24 hours and swept hourly; nothing from this step is linked to your CHOZEN account except a per-day counter used to enforce a fair-use limit. No YouTube video, audio, caption or thumbnail file is ever downloaded or stored.
• Revoking access and deleting your data. You can disconnect YouTube at any time using the log-out icon on the connected-channel badge in the uploader (next to “Uploading to:”), or from Settings → YouTube on this website. Disconnecting revokes our access with Google straight away and deletes every piece of YouTube data we hold for you — your access and refresh tokens, the granted scope, and your research usage counter — immediately, and in any case within 7 days. Deleting your CHOZEN account does the same. You can also revoke access directly at myaccount.google.com/permissions; we re-verify our stored authorisations at least every 30 days and delete the data of anyone whose authorisation can no longer be refreshed.
  Deleting the data stored by CHOZEN does not, in any way, affect data stored by YouTube — including videos you have already uploaded. To delete data on YouTube, use the YouTube app or website.
• YouTube Terms. Use of the upload feature is also subject to the YouTube Terms of Service.
• Google Privacy Policy. Information that Google collects, and how Google handles it, is described in the Google Privacy Policy.

2.14 TikTok Content Posting API (CHOZEN Uploader desktop app)

The CHOZEN Uploader can post your own videos to your own TikTok account. Connecting TikTok is optional; nothing is sent to TikTok unless you switch TikTok on for a reel and press publish. When you connect, you authorize CHOZEN to:

• post videos to your account on your behalf (video.publish); and
• read your basic profile — nickname, username and avatar — so the app can show you which account will receive the post (user.info.basic).

• Data received and stored. TikTok returns an access token, a refresh token and your open_id. We store those, their expiry dates, the granted scopes, and your nickname, username and avatar URL on our servers (Cloudflare D1), linked to your CHOZEN account. The tokens are encrypted at rest (AES-256-GCM with a key held only as a server secret), so a database copy alone cannot be used to post anywhere. We never receive your TikTok password.
• Use. Only to show you the connected account, to read the posting options your account allows (who may see the post, whether comments, Duet and Stitch are available), and to upload the video you chose. Nothing is used for advertising, nothing is sold, and no human at CHOZEN reads it.
• What we send. The video file, its cover frame, your caption, and the posting options you set on the TikTok section of the publish screen. We never set those options for you: TikTok requires that you choose the audience yourself, so the dropdown starts empty and publishing is blocked until you pick.
• Revoking access and deleting your data. Disconnect TikTok in the Reels area of the uploader. Disconnecting revokes our access with TikTok straight away (we call TikTok's revoke endpoint) and deletes every piece of TikTok data we hold for you — tokens, scopes, profile fields — in the same step. Deleting your CHOZEN account does the same. You can also revoke access in the TikTok app under Settings and privacy → Security and permissions → Manage app permissions.
  Deleting the data stored by CHOZEN does not affect anything stored by TikTok, including posts already published. To delete those, use the TikTok app.
• TikTok terms. Posting through this feature is also subject to TikTok's Terms of Service, Branded Content Policy and Music Usage Confirmation. How TikTok handles your data is described in the TikTok Privacy Policy.

2.15 Instagram API with Instagram Login (CHOZEN Uploader desktop app)

The CHOZEN Uploader can publish your own videos as Reels on your own Instagram professional account (Business or Creator — Instagram does not allow API publishing from personal accounts). Connecting Instagram is optional; nothing is sent unless you switch Instagram on for a reel and press publish. When you connect, you authorize CHOZEN to:

• publish content to your account on your behalf (instagram_business_content_publish); and
• read your basic profile — username, name, account type and avatar — so the app can show you which account will receive the Reel and check that it may publish at all (instagram_business_basic).

• Data received and stored. Instagram returns a long-lived access token (valid 60 days) and your Instagram user ID. We store those, the expiry, the granted permissions, and your username, name, account type and avatar URL on our servers (Cloudflare D1), linked to your CHOZEN account. The token is encrypted at rest (AES-256-GCM with a key held only as a server secret). We never receive your Instagram password. We refresh the token automatically while the connection is in use, so that you do not have to reconnect every two months.
• Use. Only to show you the connected account and to publish the Reel you chose, with the caption, cover frame, collaborators and audio name you set. Nothing is used for advertising, nothing is sold, and no human at CHOZEN reads it.
• How the video reaches Instagram. Instagram's publishing API does not accept an upload from us; it fetches the video itself from a link. Your reel is therefore stored on CHOZEN and made reachable at an unguessable address for Instagram to download while it publishes. It is the same file that is used for your CHOZEN feed post.
• Revoking access and deleting your data. Disconnect Instagram in the Reels area of the uploader. Disconnecting deletes every piece of Instagram data we hold for you — the token, the permissions and the profile fields — immediately. Deleting your CHOZEN account does the same. Instagram offers apps no revoke endpoint, so to withdraw the permission on Instagram's side as well, open Instagram → Settings → Website permissions → Apps and websites and remove CHOZEN there. If you would rather have us delete it for you, write to privacy@chozen.io and we will confirm within 30 days.
  Deleting the data stored by CHOZEN does not affect anything stored by Instagram, including Reels already published. To delete those, use the Instagram app.
• Meta terms. Publishing through this feature is also subject to the Instagram Terms of Use. How Meta handles your data is described in the Meta Privacy Policy.

2.16 Blocking other users

You can block another user in the iOS app and on the website. A block works both ways: neither of you can send the other direct messages, and the platform stops showing you to each other where it can.

• Data stored. We store who blocked whom and when. Your list of blocked users is visible only to you, in your settings.
• Report to moderation. Every block also creates a report to our moderation team, so that we notice harassment and other abuse early. The report names both accounts and the time of the block. We do not send the blocked user a notification, and we never tell them that a report exists. They may notice the block because they can no longer message you or comment on your content.
• Legal basis. Art. 6(1)(b) GDPR for the block itself (it is a platform feature you use); Art. 6(1)(f) GDPR for the report (our legitimate interest, and our duty under the Digital Services Act, in keeping the platform safe).
• Retention. A block is deleted when you unblock the user or when either account is deleted.

2.17 CHOZEN iOS app

• No tracking, no ads. The iOS app does not track you across other companies' apps or websites. It contains no advertising SDKs and no third-party analytics or crash-reporting SDKs, and it does not read the advertising identifier.
• App Store country. The app reads the country of your App Store account (the “storefront”) on your device. It uses this only to decide whether purchases are shown in the app. The country is not sent to us.
• Data stored on your device. Settings, a cache of audio you played, and a debug log stay on your device. The debug log leaves your device only if you export it yourself.
• Crash reports. We receive crash reports only through Apple, and only if you chose to share analytics with app developers in your iOS settings.
• Everything else the app sends to us is the same account, content and interaction data described in §§2.1–2.8.

§3 Legal bases for processing (Art. 6 GDPR)

3.1 Performance of contract (Art. 6(1)(b))

Account creation and management, providing platform features, processing transactions and payouts, subscription management, facilitating license agreements between Producers and Buyers, competitive features (FL Ranked matchmaking), community features (DMs, forums, comments), gamification (XP, rank progression). This includes sign-in with Google or Apple, and the record of which Terms version you accepted and that you confirmed you are at least 16.

3.2 Legitimate interest (Art. 6(1)(f))

Platform security and fraud prevention, content recommendation, analytics for platform improvement, enforcement of our Terms of Service, technical infrastructure maintenance.

3.3 Consent (Art. 6(1)(a))

Non-essential cookies and tracking (see Cookie Policy), marketing communications and newsletters, screen capture by the Ranked Overlay (§2.12), publication of Reels to other users, producer email-collection (consent of the email subscriber).

3.4 Legal obligation (Art. 6(1)(c))

Tax documentation and invoice retention (§ 147 AO, § 257 HGB), responses to lawful authority requests, copyright infringement notifications, DAC7 seller reporting.

§4 Purposes of processing

• Operating the CHOZEN marketplace and creative community
• Authenticating you and securing your account
• Facilitating beat licensing between Producers and Buyers
• Processing payments and managing payouts
• Personalizing content recommendations and discovery features
• Operating FL Ranked competitive features
• Managing gamification (XP, ranks, achievements)
• Facilitating community interactions (forums, comments, DMs)
• Sending transactional communications (order confirmations, payout notifications)
• Platform improvement, analytics, fraud detection
• Complying with legal and regulatory obligations; resolving disputes

§5 Data retention

5.1 Deleting your account

You can delete your account yourself at any time. On the website, go to your account settings. In the iOS app, go to Settings → Delete account. You do not need to contact us, but you can also ask us to do it at privacy@chozen.io.

Deleted immediately:

• Your profile, name, username, email address and profile picture.
• Your uploads (except files that buyers licensed and loops used in battles, see below), comments, direct messages, likes, follows, download history and your block list.
• Your sessions. You are signed out on every device.

Running subscriptions are cancelled in the same step.

Third-party connections: We revoke our access with Google, YouTube and TikTok and delete every token we hold for them. We also delete your Instagram token (Instagram offers apps no way to revoke; see §2.15).

Kept, and why:

• Orders, purchases, payouts and invoices. German tax and commercial law requires us to keep these records for up to 10 years (§ 147 AO, § 257 HGB). We keep them in anonymized form. They are linked to a placeholder for the deleted account, not to your name or email address. When the retention period ends, we delete them.
• Files that buyers licensed. If you sold content, it is removed from the marketplace and your profile. The files stay available to the buyers who already licensed them, so they keep their licenses (see Terms §17).
• Battle history. Ranked and Reel battles belong to every player in them. Your battle entries (recordings, votes and results) and loops that were played in a battle stay part of that shared history, so the other players keep their results. They are no longer shown with your name or profile picture, only under the anonymous placeholder name. Loops kept this way are removed from the marketplace and from matchmaking.
• Backups. Deleted data can remain in our database backups for up to 30 days before it is overwritten.

When deletion has to wait: If you still have money waiting to be paid out, a payout in progress, or open revenue splits with collaborators, we cannot delete the account yet. The settings page tells you what needs to be settled first.

Suspended accounts: If your account is suspended, you cannot sign in to delete it yourself. Write to privacy@chozen.io from the email address of the account, and we delete it for you.

After the deletion we send a confirmation to your email address. Your Stripe account (if you sell on CHOZEN) is a contract between you and Stripe. Stripe keeps its own records under its own legal duties.

§6 Recipients and processors

Data Processing Agreements (Art. 28 GDPR) are in place or being executed with all processors. We do not sell your personal data.

§7 International data transfers

Several processors are US-based. Transfers rely on:

• EU-US Data Privacy Framework (DPF): primary basis for transfers to DPF-certified recipients (Cloudflare, Stripe, Google).
• Standard Contractual Clauses (SCCs): fallback for non-DPF-certified recipients, with a Transfer Impact Assessment.
• Art. 49 derogations: only in exceptional cases, with explicit consent or contractual necessity.

§8 Cookies and similar technologies

We use first- and third-party cookies and localStorage to ensure functionality, remember preferences, and (in future) analyze usage. Details, categories, and your consent options are documented in our Cookie Policy. Consent for non-essential storage is collected via our consent banner in compliance with TTDSG § 25 and GDPR Art. 6(1)(a).

§9 Your rights under GDPR

• Access (Art. 15): confirmation of processing and a copy of your data
• Rectification (Art. 16): correct inaccurate or incomplete data
• Erasure (Art. 17): "right to be forgotten" — subject to legal retention obligations. You can delete your account yourself; see §5.1.
• Restriction (Art. 18) and Portability (Art. 20)
• Object (Art. 21): in particular against profiling for personalized recommendations
• Withdraw consent (Art. 7(3)): at any time, without affecting prior lawful processing

To exercise these rights, contact privacy@chozen.io. We respond within one month of receipt (extendable by two months for complex requests, with notice).

Right to lodge a complaint (Art. 77): you may complain to a supervisory authority, in particular in the Member State of your habitual residence. The competent authority for the controller is Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (HBDI), Gustav-Stresemann-Ring 1, 65189 Wiesbaden, datenschutz.hessen.de.

§10 Automated decision-making and profiling

10.1 Algorithmic recommendations. The Platform profiles your behavioural data to personalize feeds and the Discover feature. This is not "solely automated decision-making producing legal effects" under Art. 22(1) GDPR because the recommendations are suggestions only, do not restrict access to content, and you retain full manual control. Legal basis: Art. 6(1)(f) legitimate interest, or consent where separately obtained.

10.2 Ranked matchmaking. FL Ranked uses an Elo-style MMR system to match opponents and determine division placement. This is necessary for the performance of the competitive feature (Art. 22(2)(a)). You can contest match outcomes via the dispute mechanism.

10.3 Object to profiling. You may object to profiling under Art. 21 at any time. A non-profiling (chronological) feed alternative is available in your account settings.

§11 Protection of minors

The Platform is intended for users 16 and older (Art. 8(1) GDPR; § 7 TTDSG). We do not knowingly collect data from anyone under 16. If you become aware that a minor has provided us data, contact privacy@chozen.io and we will delete it promptly.

§12 Producer email-collection feature

When a Producer activates email-collection on a content page, they act as independent data controller for the addresses they receive. CHOZEN acts as their processor under Art. 28 GDPR. Before the feature can be enabled, the Producer must accept a Data Processing Agreement (Auftragsverarbeitungsvertrag); the acceptance is recorded (timestamp, account ID, IP, DPA version) and gates the feature — CHOZEN does not collect addresses on behalf of a Producer who has not accepted it. Subscribers may exercise their data-subject rights directly with the Producer or use the unsubscribe link in each email. CHOZEN provides the technical infrastructure (Mailchimp integration where activated) but does not determine the purposes of marketing processing.

§13 Data Protection Impact Assessments (DPIAs)

Pursuant to Art. 35 GDPR, DPIAs are in preparation for the following processing activities where the risk profile warrants formal assessment:

• Discover-feed profiling (large-scale algorithmic recommendation)
• Ranked matchmaking (systematic MMR-based evaluation of individuals)
• Behavioural tracking for content discovery
• Ranked Overlay screen-capture pipeline

Mitigating measures already implemented include data minimization, opt-out controls for profiling, short retention windows (intermediate frames ≤ 24 h; behavioural data anonymized after 24 months), and the consent gate for the screen-capture pipeline. Final DPIA documents will be available to the competent supervisory authority upon request.

§14 Data breach procedure

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we notify the competent supervisory authority within 72 hours (Art. 33) and, where the risk is high, the affected data subjects without undue delay (Art. 34). All breaches are documented internally regardless of notification obligations.

§15 Changes to this Privacy Policy

Material changes are communicated via email and a prominent notice on the platform at least 30 days before they take effect. The "Last updated" date at the top of this page indicates the most recent revision.

§16 Contact and DPO

Privacy enquiries and data-subject requests: privacy@chozen.io.

Data Protection Officer (DPO): Under § 38 BDSG, a designated DPO is not yet mandatory for CHOZEN as a sole proprietorship with fewer than 20 persons engaged in automated processing. We will reassess as the platform scales.