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Privacy Policy

This policy explains what personal data Naluna Studio collects when you use nalunastudio.com or place an order, and what we do with it. Naluna Studio decides how and why your data is used, which under UK data protection law makes us the "controller" of that data.

1. What we collect

• Contact details: your name, email address, and phone number if you provide one.
• Order content: the recipient's name and relationship to you, and the personal story or details you write for your song.
• Photos and videos you upload, only if you order the "Gift Video" package.
• Payment details: collected directly by Stripe, our payment processor — we never receive or store your card number.
• City and country (billing details): once you complete payment, we keep the city and country from the billing/customer details you provide to Stripe at checkout, attached to your order. We use this to administer your order and for our own aggregate reporting on where orders come from — we do not collect your street address, postcode, or GPS coordinates for this purpose, and we do not use IP address-based location lookups to determine or supplement it.
• Basic technical data: order status and timestamps, and your IP address, used only for security and to prevent abuse (e.g. rate-limiting) — never for advertising or tracking.
• Order attribution data: if present in the link you used to reach the site, campaign/referral identifiers (such as utm_source, utm_campaign, or Meta's "fbclid" click identifier) are attached to your order so we know which marketing channel it came from. This is collected for every order, regardless of your Analytics/Marketing cookie choice below — it is a first-party record about the order itself, not a tracking cookie, used only for our own internal reporting, and never sent to any advertising platform unless a future integration is built and you have separately given Marketing consent for it.
• Analytics data, only if you consent: an anonymous visitor identifier, and the steps you take while placing an order (for example, that you started or completed the order form). See "Cookies and analytics" below for the full detail, and for how to refuse or withdraw consent.
• Marketing consent, only if you consent: a separate, optional choice from Analytics — see "Cookies and analytics" below. When you give this consent, we use Meta's ("Facebook"/"Instagram") advertising tools to measure and improve our ads: a browser-based "Pixel" that may set its own cookie (_fbp), and a server-side "Conversions API" that reports a confirmed purchase directly from our servers, based on your actual payment. Nothing under this category runs, and no data is sent, unless you have given this specific consent.
• Order reminder emails: when you place an order, a clear, optional checkbox shown right where you enter your email lets you tell us you don't want reminder emails if you don't complete your order. If you don't tick it, and your order is left unfinished (for example, your song is ready but you have not checked out, or you started checkout but did not finish paying), we may send you a small number of email reminders pointing you back to your order. This is separate from the "Marketing" cookie category above (which relates only to Meta advertising) and from your Analytics choice — see "Order reminder emails" under "Cookies and analytics" below for the full detail, including how to opt out or unsubscribe.

2. Cookies and analytics

We only use analytics cookies and similar technologies (such as browser local storage) if you give explicit consent via the banner shown on your first visit. If you do not consent, none of this loads: no analytics cookie is set, no anonymous identifier is created, and nothing described in this section is collected.

Our cookie banner asks for two separate, optional choices — Analytics and Marketing — plus a third, Necessary, category that is always active because it is required for the site to function and does not need consent. Accepting one of Analytics or Marketing is never treated as accepting the other: each is asked, recorded, and can be withdrawn independently, from the same "Cookie settings" link.

When you accept Analytics, we use Google Analytics 4 ("GA4") to understand how the site is used (for example, which pages are viewed and which button led you to place an order). We also run our own first-party, in-house funnel measurement, entirely separate from Google: an anonymous identifier (a random code, not linked to your name or email) is stored in your browser and used to measure how visitors move through the ordering process — for example, that a visitor viewed the order page, started the form, or reached checkout.

Separately from Analytics consent, if the link you used to reach the site carries campaign/referral parameters (such as utm_source, utm_campaign, or Meta's "fbclid" click identifier), we attach them to your order so we know which marketing channel it came from — see "Order attribution data" above. This first-party attribution happens for every order regardless of your cookie choices; it identifies a campaign or link, not you personally, is used only for our own internal reporting, and is never sent to any advertising platform without a future integration and your separate Marketing consent.

This analytics data:

• Never includes your name, email address, phone number, the story or details you wrote for your song, or any other content you enter into the order form — our internal funnel-measurement records are structurally limited to an anonymous identifier, an event name (e.g. "form started"), a timestamp, and campaign/referral identifiers; personal content has no field to be stored in.
• Is never combined with fingerprinting techniques (deriving an identifier from your device or browser configuration), and never uses your IP address for tracking.
• Is used only to measure and improve how our site and ordering process work, and to understand which marketing channels bring genuine visitors and customers — never for advertising, and never to build a profile about you across other websites.

If you had given Analytics consent and go on to place an order, the anonymous visitor identifier and the funnel events already recorded for it (the pre-order actions described above) are linked internally to that order, so we can connect your browsing activity to the order it led to. This link does not change what was collected — the underlying anonymous events remain kept for a fixed period regardless of that link, see "How long we keep your data" below. The campaign/referral attribution attached directly to your order ("Order attribution data" above) is a separate mechanism: it exists for every order regardless of Analytics consent, and follows your order's own retention, not the funnel-event retention period.

Marketing (optional): this category is used to measure and improve our advertising, currently through tools provided by Meta ("Facebook"/"Instagram"). When you give Marketing consent, we load the Meta Pixel in your browser, which may set its own first-party cookie (_fbp) and reports standard interaction events — such as viewing the site or starting checkout — directly to Meta. Separately, after your payment is confirmed, our own server sends a "Purchase" event directly to Meta's Conversions API: this always happens server-side, based on your confirmed payment with Stripe, and only if you had given Marketing consent before checkout — it does not depend on whether the Pixel loaded or ran successfully in your browser. Before sending it, we hash your email address (a one-way transformation Meta uses to match the event to an advertising account, without us sharing your email in readable form) and, if the _fbp cookie already exists, include it to help Meta associate the event with your browsing session — we never send your name, phone number, IP address, or anything you wrote in the order form to Meta. If you decline or withdraw Marketing consent, none of this runs: the Pixel is not loaded (or, if already loaded, is instructed to stop sending data), and our server sends nothing to Meta for that visit or order.

You can withdraw your consent at any time from the small "Cookie settings" link shown on every page, where Analytics and Marketing can each be turned on or off independently. Withdrawing stops all further analytics activity immediately, including Google Analytics, and removes the anonymous identifier stored in your browser. It does not delete data already recorded before you withdrew — you can ask us to delete that separately (see "Your rights" below).

Order reminder emails (separate from Marketing/Analytics cookie consent): we send two different kinds of order-related email, and treat them differently:

• Operational email — "your song is ready": a one-time email confirming your song is ready and giving you the access link, so you don't lose it if you closed the page while it was generating. This is part of delivering the order you already placed (the same purpose as "Our email delivery provider" in the table below) — it contains STRICT access to your order: no discounts, no upsells, no promotional content. It is sent regardless of the reminder-email checkbox described below, and does not include an unsubscribe link.
• Recovery/reminder email (direct marketing): if you place an order and don't finish it, we may separately email you a small number of reminders pointing you back to it. This is not the "Marketing" cookie category described above (which relates only to Meta advertising and does not use the Meta Pixel or any advertising cookie), and it is not linked to your Analytics choice either.

For the reminder/recovery email specifically, UK law treats this as direct marketing by email, which is separately regulated by the Privacy and Electronic Communications Regulations ("PECR") on top of UK GDPR. Our legitimate interest in helping you complete an order you already started is not, by itself, a sufficient basis to email you for this purpose — PECR additionally requires that people in your position ("soft opt-in": you gave us your email while placing an order, for a similar product/service) are given a clear and simple opportunity to refuse this kind of email, free of charge, both when we first collect your email and in every message afterwards. We meet this by showing a clear, optional checkbox right next to the email field on the order form — unticked by default, never required to place your order — and by including an unsubscribe link in every reminder email. If you tick that checkbox, or unsubscribe later via the link, we stop sending reminder emails to that address, permanently, independent of your Analytics/Marketing cookie choices — this does not affect the one-time operational "song is ready" email above. This applies only to orders placed after we introduced this checkbox: if you ordered before then, you were never shown that choice, so you do not receive reminder emails from us at all, regardless of anything else — it is never applied retroactively.

3. Why we process your data

• To create and deliver your personalised song or video (necessary to perform our contract with you).
• To process your payment and prevent fraud (necessary to perform our contract, and to comply with our legal obligations).
• To respond to your support, refund, or data requests (our legitimate interest in running the service, and/or our legal obligations).
• To send you a one-time email letting you know your song is ready and giving you the access link (necessary to deliver the order you placed).
• To send you a small number of reminder emails if you leave an order unfinished, unless you opted out when we collected your email or have since unsubscribed — based on our legitimate interest in helping you complete an order you already started, together with (not instead of) the clear opportunity to refuse we give you at collection and in every reminder, as required by PECR for this kind of email. See "Order reminder emails" above for the full detail and how to opt out.

4. Who receives your data

We share personal data only with the providers we rely on to run the service, and only as much as each of them needs to do their job:

We also load a small number of trusted third-party software libraries needed for the site to work correctly (for example, a phone-number input field), which may receive basic technical request data (such as your IP address) directly from your browser when the page loads.

5. International transfers

Our application and database are hosted in the United States by our hosting provider. If you are located in the UK or the EU, this means your personal data is transferred outside your country when you use our service. Where this requires a safeguard under UK data protection law, we only work with providers who commit contractually to protecting your data to UK standards — for example through the UK International Data Transfer Addendum or the EU Standard Contractual Clauses. Contact us at contact@nalunastudio.com if you would like more information about the safeguards that apply to a specific transfer.

6. How long we keep your data

We keep different categories of your data for different lengths of time, based on why we hold them. We do not keep any personal data for longer than we can justify.

• Your order content — your purchased song, WAV and/or video files, the personal story or details you wrote for your song, and any photos or videos you uploaded for the Gift Video package: all kept for 30 days from delivery, so you can stream, download, and request a correction if needed. After 30 days, this content is automatically and irreversibly removed. This is a single, simple operational choice, not a legal requirement, and it does not affect your statutory rights (see our Terms) — if you report a genuine fault after this period, we may need to ask you to share the relevant details or files again. Your underlying order record (needed for support and accounting, see below) is kept separately and is not deleted at the same time.
• Records of the consent you gave at checkout: kept for 6 years, so we can demonstrate what you agreed to if a dispute ever arises — aligned with standard contract-claim time limits in England and Wales.
• Payment and order records needed for tax and accounting (including the billing city/country described in "What we collect" above): kept for 5 years from the 31 January following the relevant tax year, as required by HMRC record-keeping rules that apply to us as a UK sole trader.
• Anonymous funnel-analytics events (the visitor identifier and the individual events described in "Cookies and analytics" above — for example, that a visitor viewed the order page or started the form): kept for up to 180 days from when the event happened, then automatically and permanently deleted — regardless of whether that event was ever linked to an order. This is a separate, event-level retention period and does not apply to your order record: if you go on to place an order, the campaign/referral identifiers attributed to it are stored on the order itself and follow your order's own retention (the payment/accounting/consent rows above), not this 180-day period. You can ask us to delete your own analytics events sooner (see "Your rights" below), and you can stop any further collection immediately from "Cookie settings" (see "Cookies and analytics" above).
• Security and error logs (technical records used to detect abuse, prevent fraud, and diagnose faults): we do not export, duplicate, or manually extend these logs — they exist only for as long as our hosting provider's platform retains them by default (currently no more than 30 days), after which they are automatically deleted. We keep the amount of personal data that reaches these logs to a minimum — for example, a customer's email address is masked before being written to an operational log.

You can ask us to delete your personal data at any time by contacting contact@nalunastudio.com. We will remove your personal details, story, and any uploaded media that has not already been automatically removed, except where we are required to keep certain records (such as the payment and consent records above) for legal purposes, in which case we keep only what the law requires and for no longer than necessary.

7. Your rights

If you are in the UK or the EU, you have the right to access, correct, delete, or export your personal data, and to object to or restrict certain processing. To exercise any of these rights, contact us at contact@nalunastudio.com. You also have the right to complain to your local data protection authority — in the UK, the Information Commissioner's Office (ico.org.uk). For analytics specifically, you do not need to contact us at all to stop it — withdraw consent at any time from "Cookie settings" (see "Cookies and analytics" above).

8. Children

Our service is intended for adults placing orders on behalf of themselves or others. We do not knowingly collect personal data directly from children.

9. Contact

For any question about this Privacy Policy or your data, contact contact@nalunastudio.com.