Privacy Policy for FluentDrummer

Last updated: 21 October 2026

1. Who we are

FluentDrummer ("we", "us", "our") provides online drum practice tools, free and
by subscription, at https://fluentdrummer.com.

We are the data controller for the personal data described in this policy.

Controller: Anthony Capel, trading as FluentDrummer
Address: 16 Goetre Fawr, Radyr, Cardiff, CF15 8EU, United Kingdom
Email: support@fluentdrummer.com
ICO registration number: ZB608104

This policy is written for the UK GDPR and the Data Protection Act 2018. If you
are in the EEA, equivalent rights apply to you under the EU GDPR.

2. The personal data we collect

2.1 If you take the free assessment
- Your email address, if you choose to give it on the results screen
- Your assessment result: an overall score, six sub-scores (groove, time, fills,
  reading, coordination, technique), the skill area identified as your main
  bottleneck, and the date you completed it

You can take the assessment without giving us your email address, and if you do
we will not know who you are. We store a result against you only if you submit
your email address on the results page.

Anonymous statistics: whenever anyone finishes the assessment we record one
anonymous entry. It contains only the options chosen on the two multiple-choice
questions, the skill area the assessment pointed to, the level band it produced,
and the month. It contains no email address, no name, no account or device
identifier, no cookie, no IP address, and no date or time more precise than the
month. It is not linked to your email address if you give one afterwards, and
there is no key that would let us or anyone else connect it back to you. We use
it only to count how many people choose each answer, so we know what to build
and what to teach.

Because that entry cannot be traced to any individual, it is not personal data,
and the rest of this policy does not apply to it.

2.2 If you take the Practice Score quiz
- Your email address
- Your answers, your score out of 50 and the band it falls in
- The wording you were shown when you signed up, and the date and time you did

We record the wording and timestamp because the law requires us to be able to
show that consent was actually given.

2.3 If you create an account
- Your email address
- Your name and profile image, if your sign-in provider (Google) supplies them
- Account identifiers used by our authentication system
- If you tick the optional box asking for practice emails when you sign in: the
  wording you were shown and the date and time you ticked it
- Your answers to the questions we ask when you first sign in: whether you have
  played before, what you play on (electronic kit, acoustic kit or none), your
  goal, your age band (18–24, 25–34 and so on; never your date of birth), and,
  if you choose to write anything, what you are finding hardest. You can skip
  these questions, in which case we store only that you skipped

2.4 If you use the practice tools while signed in
- Practice items, schedules, due dates, review history, ratings, intervals and
  repetition data
- Progress in the Learn to Speak Drum curriculum and its groove and fill
  cards, such as levels, passes, attempts, scores, tempos, placement results
  and where you are on a route
- Settings you choose
- Which areas of the site you opened on each day, so we can see which tools are
  used

This data is linked to your account so your progress persists between sessions.
It is not anonymous.

Some settings, such as your MIDI kit mapping and cached progress, are also kept
in your browser's local storage on your own device.

2.5 If you subscribe to FluentDrummer Pro
- Your name, email address and billing details, collected and processed by Stripe
- Your plan, subscription and payment status, and the Stripe customer and
  session identifiers
- We never see or store your full card number. Card details are entered on
  Stripe's own checkout and billing pages, not ours.

2.6 Technical data
- IP address, browser and device information, and pages requested, in ordinary
  server logs
- Aggregated, cookieless usage statistics from Vercel Analytics
- Cookies strictly necessary to keep you signed in and to keep the site secure

3. Why we use it, and our legal basis

Delivering an assessment or quiz result you asked for
  Basis: performance of a contract, or steps taken at your request before
  entering one.

Running your account and saving your practice progress
  Basis: performance of a contract.

Using your first-sign-in answers (experience, kit, goal, age band, what you
find hardest) to start you in the right place, set up the tools for your
kit, and improve the lessons
  Basis: our legitimate interests in giving you a useful starting point and
  making the teaching better. The questions are optional and can be skipped,
  and we never use your answers for advertising or share them.

Taking payment and providing your subscription
  Basis: performance of a contract.

Keeping tax and accounting records
  Basis: legal obligation.

Sending practice tips and news about FluentDrummer
  Basis: your consent, which you give by submitting a form that says plainly
  it signs you up to the list, or by ticking the optional box when you sign
  in. You can withdraw it at any time (see section 7).

Security, fraud prevention, fixing faults and improving the product
  Basis: our legitimate interests in running a reliable, secure service. We have
  considered your rights and use the least intrusive data that achieves this.

Responding to you when you get in touch
  Basis: our legitimate interests in answering enquiries and providing support.

We do not use your data for automated decision-making that produces legal or
similarly significant effects. Your assessment result is a practice
recommendation, not a decision about you.

4. Marketing email

We only send marketing email to people who have asked for it.

On the assessment results page and the Practice Score quiz, the mailing list is
what you are signing up for, and your emailed result is what you get for
joining. Each page says so directly above the button, and submitting the form is
how you agree.

When you sign in, there is an optional box asking for practice emails. It is
unticked, and you can sign in, use the free tools and subscribe to Pro without
ticking it.

There is no pre-ticked box anywhere, and we never add an address that was not
entered deliberately. Subscribing to Pro does not add you to the list.

How often we email: weekly, and sometimes daily.

Every marketing email contains a one-click unsubscribe link, and we support your
mail provider's own unsubscribe button. Unsubscribing takes effect immediately.

Emails that are not marketing — a receipt, a password-free sign-in link, or a reply to something you asked — are sent because they are
necessary to provide what you requested, and they continue regardless of your
marketing preference.

5. Who we share it with

We do not sell your personal data, and we do not share it for anyone else's
marketing.

We use these providers to run the service. Each processes data on our
instructions, under a contract, or as an independent controller where noted:

- Vercel Inc. — website hosting and cookieless analytics (USA)
- MongoDB, Inc. — database hosting (Atlas)
- Stripe, Inc. — payments, subscriptions and the billing portal. Stripe is an independent controller
  for its own fraud prevention and regulatory purposes (USA)
- Resend (Plus Five Five, Inc.) — email delivery and mailing list (USA)
- Google LLC — Google sign-in, if you choose it (USA)

We may also share data with our professional advisers, or with authorities where
the law requires it, and with a buyer or successor if the business is sold, in
which case this policy continues to apply until you are told otherwise.

6. International transfers

Some of the providers above are based in the United States, so your data may be
transferred outside the UK. Where that happens we rely on the UK's adequacy
regulations for the EU/EEA, the UK extension to the EU-US Data Privacy Framework
where the provider is certified, or the International Data Transfer Agreement or
Addendum to the EU Standard Contractual Clauses.

You can ask us for details of the safeguards used for any specific transfer.

7. Your rights

You have the right to:
- Access a copy of your personal data
- Have inaccurate data corrected
- Have your data erased
- Restrict how we use your data
- Object to processing based on our legitimate interests
- Receive your data in a portable format
- Withdraw consent at any time, where we rely on it

Withdrawing consent does not affect anything we did lawfully before you withdrew
it, and it does not remove data we must keep for tax or legal reasons.

These rights apply to personal data. They do not apply to the anonymous
assessment statistics described in section 2.1, because there is no identifier
in them that would let us find "your" entry — that is the point of collecting
them that way.

To exercise any of these, email support@fluentdrummer.com. We will respond
within one month. There is no charge. We may ask you to confirm your identity
before we act, so that we do not disclose your data to someone else.

To stop marketing email you do not need to contact us at all — use the
unsubscribe link in any marketing email.

If you are unhappy with how we have handled your data, please tell us first so
we can put it right. You also have the right to complain to the Information
Commissioner's Office at any time:

  Information Commissioner's Office
  Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
  0303 123 1113
  https://ico.org.uk/make-a-complaint/

8. How long we keep it

- Marketing contacts: until you unsubscribe. We then keep a minimal suppression
  record so you are not added back by mistake, and a record of your original
  consent, for 6 years.
- Assessment and Practice Score results: 24 months from your last interaction,
  then deleted.
- Account and practice data, including your first-sign-in answers: for as long
  as your account is open, and 12 months after you close it.
- Payment and transaction records: 6 years after the end of the relevant tax
  year, because HMRC requires it.
- Support correspondence: 24 months.
- Server logs: up to 30 days, other than where retained for a security
  investigation.
- Anonymous assessment statistics: kept indefinitely. There is nothing in them
  to identify, correct or delete.

9. Cookies

We use cookies that are strictly necessary for the site to work: keeping you
signed in, protecting against cross-site request forgery, and, if you tick the
practice-emails box before signing in with Google, carrying that choice through
the sign-in. These do not require consent.

Vercel Analytics gives us aggregated page statistics without using cookies and
without tracking you across other websites.

We do not use advertising cookies, ad-network pixels or cross-site tracking. If
that changes we will ask for your consent first, through a cookie banner, before
any non-essential cookie is set.

Stripe may set its own cookies on its own pages when you are sent there to pay
or to manage your subscription. Their own privacy policies apply on those pages.

10. Security

We use HTTPS throughout, store data with reputable hosting providers, restrict
administrative access, and keep card payments entirely on Stripe's systems so
card numbers never reach ours.

No service can promise perfect security. If a breach affects your rights and
freedoms we will tell the ICO within 72 hours where required, and tell you
without undue delay where the risk to you is high.

11. Age

This service is for adults only. We ask for your age band when you first sign
in, and there is no option under 18. You must be 18 or over to create an
account, subscribe, or give us your email address. We do not knowingly
collect data from under-18s. If you believe a child has given us their data,
email support@fluentdrummer.com and we will delete it.

12. Changes

If we change this policy we will update the date at the top and, where the
change is significant, tell you by email or with a notice on the site.

13. Contact

Anthony Capel, trading as FluentDrummer
16 Goetre Fawr, Radyr, Cardiff, CF15 8EU, United Kingdom
support@fluentdrummer.com