Privacy policy
This policy explains what personal data Vinkl processes in theYourpace Music app and on this website, why we do it, how long we keep it and what rights you have.
1. Who processes your data
The controller is Vinkl, Vlasaardstraat 8, 8210 Veldegem, Belgium — VAT BE1002988413. You can reach us at info@vinkl.be. Full company details are on the contact page.
Vinkl publishes Yourpace, the learning platform the Yourpace Music app (be.vinkl.musicexercises) runs on, and operates this website.
2. What this policy covers
This policy covers two different things, with different data and different lawful bases:
- The Yourpace Music app — sections 3 to 5.
- This website, vinkl.be — section 6.
3. The Yourpace Music app
Practising without an account
You can use Yourpace Music without signing in. Your progress then stays in your own browser or device storage and is never sent to our servers. Clear that storage and the progress is gone.
What we process if you do create an account
- Account data
- Your name, your email address and a unique Google identifier, which we receive from Google when you use “Sign in with Google”. We never receive your Google password.
Basis: performance of the contract (Art. 6(1)(b) GDPR) — without an account we cannot keep your progress.
- Practice data
- Your level per topic, which exercises you completed, your answers, whether they were correct and how quickly you answered, your scores, your practice counter and your streak.
Basis: performance of the contract (Art. 6(1)(b) GDPR) — this is the service; without this data Yourpace cannot adjust the difficulty.
- Technical data
- Server logs containing your IP address, the time, the page requested and a description of your browser or device. These are generated automatically on every use.
Basis: legitimate interest (Art. 6(1)(f) GDPR) — securing the service, preventing abuse and being able to investigate faults.
- Data collected by SDKs
- The app uses third-party software that collects data itself. This is not limited to what we store on our own servers:
- Google Sign-In handles your sign-in and in doing so sees your Google account and technical data about your device.
- Google analytics software records usage events in the app — which screens you open, which exercises you start — together with an app-instance identifier and general device data.
Basis: performance of the contract for signing in; consent for analytics (Art. 6(1)(a) GDPR).
We do not sell your data, we do not rent it out, and we do not use it to target advertising at you. We make no automated decisions with legal effect about you. The difficulty Yourpace picks is not an assessment of you as a person.
4. Children
Yourpace Music is intended for a mixed audience: adults and children, including children under 13.
In Belgium, the age at which a child can validly consent on their own to information society services is set at 13 (Article 8 GDPR, as implemented by the Act of 30 July 2018). If you are under 13, you may only create and use an accountwith the permission of your parent or guardian, and it is that parent or guardian who gives the consent.
Parents and guardians can at any time request access to their child's data, have it corrected or deleted, and withdraw their consent. Emailinfo@vinkl.be or use theaccount deletion page. We may ask for reasonable proof that you are the parent or guardian — precisely in order to protect the child.
We show no advertising in the app, we do not profile users for commercial purposes, and we never ask children for more data than practising requires. If we discover we are processing data from a child under 13 without a parent's consent, we delete it.
5. Who we share data with (app)
We pass your data only to parties needed to make the service work:
- Microsoft (Azure) — hosting for the app and the database. The servers are in the European Union (West Europe).
- Google Ireland Limited — “Sign in with Google” and the analytics software in the app.
These parties act as processors or, where it concerns their own service, as independent controllers. Beyond this, we disclose data only where the law obliges us to.
Transfers outside the EEA
Our own storage stays in the European Union. Google may process data outside the EEA, including in the United States. Those transfers rely on the European Commission's standard contractual clauses and, where applicable, on the EU–US Data Privacy Framework.
6. This website (vinkl.be)
The website is a static site: you can read all of it without an account and without identifying yourself.
Cookies and statistics
We use Google Analytics to see which pages get read. This happensonly if you expressly agree to it beforehand.
- Before you choose, no statistics cookie is placed and no request is sent to Google at all. Google Consent Mode v2 defaults to denied for every category.
- Declining is exactly as easy as accepting: both buttons sit side by side, equally visible and equally reachable by keyboard.
- If you decline, nothing whatsoever is sent to Google. We store your choice itself in your browser's local storage — so even declining sets no cookie.
- You can revisit your choice at any time by clearing this site's storage in your browser.
If you do agree, Google Analytics processes a visitor identifier, your (truncated) IP address, which pages you view and for how long, and general data about your browser, device and country. Basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time.
This site runs on Azure Static Web Apps. Microsoft processes technical server logs in order to deliver and secure the site.
7. How long we keep data
- Account and practice data
- For as long as your account exists. If you request deletion, we erase it within 30 days.
- Backups
- Up to 90 days after deletion, until the normal rotation overwrites them.
- Server logs
- Up to 12 months.
- Website statistics
- Up to 14 months, the retention period we have configured in Google Analytics.
- Emails to info@vinkl.be
- For as long as needed to deal with your question, and at most 12 months after.
8. Security
All traffic to the app and to this site runs over an encrypted connection (HTTPS). Data in the database is stored encrypted, and only those who need it to operate the service can reach it. We hold no passwords: signing in goes entirely through Google.
9. Your rights
Under the GDPR you have the following rights. Exercising them is free.
- Access — obtain a copy of the data we hold about you.
- Rectification — have inaccurate data corrected.
- Erasure — have your data deleted. Seeaccount deletion.
- Restriction — have the processing temporarily halted.
- Portability — receive your data in a machine-readable format.
- Objection — object to processing based on legitimate interest.
- Withdraw consent — where we rely on consent, you can withdraw it at any time, without making what happened before unlawful.
Email info@vinkl.be to exercise a right. We reply within one month. To avoid handing data to the wrong person, we may ask you to prove your identity.
10. Lodging a complaint
If you are unhappy with how we handle your data, tell us first. You also always have the right to lodge a complaint with the Belgian supervisory authority:
Gegevensbeschermingsautoriteit (Data Protection Authority)Drukpersstraat 351000 Brusselscontact@apd-gba.bewww.gegevensbeschermingsautoriteit.be11. Changes
If what we process or why changes, we update this policy and change the date at the top. For a significant change we will say so in the app. This policy always stays at the same URL.