Effective as of 10 February 2026
Thank you for using our mobile application Vocaflow - Singing Coach ("Vocaflow"), visiting our website at https://vocaflow.topmusetech.com and/or communicating with us via email or text or our social media accounts, if any (collectively, the "Services").
For the purposes of data protection and privacy laws, Tiya Pte Ltd and TopMuse Pte Ltd ("we" or "us") are joint controllers in the processing of your personal information. We are committed to protecting your privacy through our data practices described in this Privacy Policy.
This Privacy Policy describes:
For the purposes of this Privacy Policy, the terms "personal information" and "personal data" are used synonymously. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Services (unless otherwise stated below or at the time of collection).
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.
BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY. We reserve the right to change and may periodically update this Privacy Policy by posting the updated version on our website. Where required, we endeavour to notify you of material changes to this Privacy Policy by posting a notice on Vocaflow. Your continued use of our Services following the posting of changes to the Privacy Policy or any notification to you shall mean you accept those changes.
To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
The designated joint controller representative is TopMuse Pte Ltd, which is entitled to act on behalf of Tiya Pte Ltd and is responsible for processing and responding to data requests made by you or any government authority.
If you have questions about how we collect, use, process or protect your personal information, or if you have any requests in respect of your personal information, we encourage you to contact us through the feedback function within the Vocaflow app so we can respond more quickly. Alternatively, you may contact:
Name of the joint controller representative: TopMuse Pte Ltd
Address: 6 Shenton Way, #37-03, OUE Downtown, Singapore 068811
Attn: Data Protection Officer
We will respond to your requests in accordance with applicable laws and may take additional steps to verify your identity before fulfilling your request. These steps may include verifying your account details. You may also designate an authorized agent to act on your behalf but we reserve the right to verify the agent's identity and authority, and may deny any requests in appropriate circumstances.
We endeavour to respond to all requests in a timely manner. For more complex requests, we may charge a fee for processing your request. We will inform you of such fees before proceeding with your request. If you have any unresolved concerns about your privacy rights or personal data protection that we could not address adequately, you may contact your local privacy and personal data protection authority for further assistance.
| Category | Description |
|---|---|
| User Data |
You do not need to provide any personal identifiers (such as name or phone number) to start using Vocaflow. When you use Vocaflow, we will collect information such as your country, device information and subscription status in order to enable you to use the features. We collect some of this data from your device. For more information about how we collect and use this data, see 'Your general (non-precise) location' in the Usage Data category. When you send us feedback or request, we may collect your name and email address etc as well as the contents of those feedback or requests. |
| User Content |
All text, audio, or voice media that you input, upload, transmit, or use with Vocaflow ("Submitted Content") will be securely transmitted to our servers and stored for the purpose of providing the service. We may forward your Submitted Content to our Authorised Partners through encrypted APIs so they can perform the necessary processing. The results generated from your Submitted Content ("Output") will be returned to us, stored securely on our servers, and also delivered to your device for local storage. We may process your Submitted Content and Output for purposes of enabling you to use the mobile application, monitoring for and preventing abusive or harmful use of our Services or for training and analytics purposes. We apply strict access controls, encryption, and data protection measures throughout this process to safeguard your information. |
| Voice Attribute Data |
We collect and process your Voice Attribute Data to help you better understand your vocal capabilities and fully utilise the features of Vocaflow. They may include:
And other voice-related characteristics that support personalised singing analysis and feature performance. Some of these Voice Attribute Data that you provide to us may be considered sensitive data or classified under special category of data. When you voluntarily take steps to submit such data to us via the mobile app, you may be asked to provide your explicit consent before you can use the features of Vocaflow. By you choosing and taking steps to use our Services and providing information to us, you also consent to the (continued) collection, use and processing of your Voice Attribute Data and, unless otherwise stated in this Privacy Policy, we use this consent as one of the legal grounds for the processing of such data. You can withdraw your consent at any time, by not using the Vocaflow app (and its features) or sending us a request to delete your data or simply contact us for assistance. You may refer to paragraph 6(C) below for more information. |
| Category | Description |
|---|---|
| Survey and User Research Data | When you respond to a survey or take part in user research, we collect and use the personal data you provide. |
When you use our Services, we may automatically collect information about you and how you use our Services. We only use pseudonymized or anonymised data that have gone through a privacy-enhancement process to protect and improve the functionalities of the Services.
| Category | Description |
|---|---|
| Usage Data |
These are personal information collected and processed when you're accessing or using the Services. They include: Information about how you use Vocaflow. They include information about your activities using the Services (including date and time), such as:
Your technical usage data. They include:
Your general (non-precise) location. They include country, region, state or timezone. We may learn about this from technical data (e.g. network type, language setting of your device). We need this for:
|
| Categories of Third Parties | Description | Data Categories |
|---|---|---|
| Payment and transaction fulfillment providers | When you pay subscription fees (where applicable) to access the features on Vocaflow, the Apple App store (where you downloaded Vocaflow) is responsible for handling any and all payments of In-App purchases. They will collect your payment information such as credit card details and other identification information such as name, billing address, email address. After you provide the requisite information and complete the transaction, a purchasing account will be created and maintained by Apple. Apple will use your personal information to process any purchases, to confirm your orders via email, to make future purchases more convenient for you and to handle, where applicable, refunds. We do not collect or process any personal information save that Apple will provide us with high-level records of non-sensitive transaction information and subscription data (such as order number, time of order, user ID, subscription type etc) so that we can activate the paid features for your use or improve the performance of our Vocaflow app. | Pseudonymised Payment Transaction Information |
| Technical Service Partners | We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g. country or region, city, state). This makes it possible for Vocaflow to provide the Vocaflow Service, content, and features. We also work with security service providers who help us protect user accounts. | User Data Usage Data |
| Marketing partners | When you download Vocaflow through our marketing partners, they provide information about their channel. | Usage Data |
| Law Enforcement Agencies | We may receive information from law enforcement about potential violations of our Terms of Use. | User Data User Content |
DO NOT SELL. We do not sell your personal information. We also do not transfer, disclose or share your personal information with third parties, except where the information is necessarily transferred, disclosed and shared with our authorised third-party partners who must use and process your information solely to provide you with the Services on our behalf.
We use your personal information for the following purposes only when it is necessary to do so for valid reasons (such as with your consent, to comply the law, to provide you with the Services, to protect your rights and interest or to fulfil our legitimate business interests) and in accordance with applicable laws:
| Purpose | Legal basis | Personal Information |
|---|---|---|
| To allow you to use the Services and generally manage your account. | They are necessary to provide you the Services. | Account Information: Pseudonymised Device ID & Storage Capacity |
| To deliver and facilitate the delivery of the Services and to allow you to use the Vocaflow features | They are necessary to provide you the Services. You have provided your consent when you take steps to provide us with certain information or continue to use the features. |
User Content |
| To provide you with certain singing analysis features of the Vocaflow service. We will clearly ask for your consent. | Consent | Consent Data |
| To enable personalised vocal analysis that supports you in improving singing capabilities. | They are necessary to provide you the Services. You have provided your consent when you take steps to provide us with certain information or continue to use the features. |
Voice Attribute Data: Voice type, Vocal range, Provided age, Preferred music genre |
| To allow you to subscribe to the paid Services. | They are necessary to provide the paid Services. You provide consent when you take steps to upgrade to the paid Services or take steps to provide us with certain information to use the premium features. |
Pseudonymised Payment Transaction Information: Transaction ID |
| To better understand how Vocaflow users use and interact with the Services. To identify and work on areas for improvement. To optimize the user experience. |
We have legitimate interests to develop and improve our products and features for our users. | Activity Information: Activity logs, timestamps, country, pseudonymised recordings |
| We may synthesize user content to train & improve our AI services. Synthetic Data being artificially generated and not linked to personally identifiable information (PII), does not contain any identifiable or sensitive personal information. |
We have legitimate interests to develop and improve our products and features for our users. | Training AI Models |
| To detect and prevent fraudulent activities, software and tools within the Services and/or employed by end users. To identify a banned account or a device. |
It is in our legitimate interests to ensure the security of the environment of our Services and safety of our users. | Fraud Detection Information - Basic device information (eg: brand, model, device system version settings) - Device identification information (eg: IMEI, ICCID, IDFV, OAID, bluetooth, MAC) - Device network information (Eg: WIFI, IP address, network connection status) - Installed application information (Eg: SDK host application package name and version number, application list) |
| To comply with our legal obligations, respond to legal requests, respond to requests from law enforcement authorities (such as police, prisons, courts) as well as exercise, establish or defend our legal rights. | Compliance with legal obligations | User Data Usage Data User Content Device Address Book Survey and User Research Data |
| To take appropriate action in respect of intellectual property infringement claims or reports of inappropriate content or activity. | Legitimate interest to protect our legal rights | User Data Usage Data User Content |
| To diagnose, troubleshoot and fix issues with the service. To discover error frequency and trends to ensure a high level of functionality for the Services. |
They are necessary to provide you the Services. | Crash Reporting Information: Crash/Error information collected from your usage with the Vocaflow app |
| To provide you with customer and technical support when you have enquiries, provide feedback, when you need troubleshooting, to fix bugs and to assist with any issues you might experience using the Services. | With your consent to resolve your questions. | Customer Support Information Email, details of the request |
| When Vocaflow users respond to a survey or take part in user research, we collect and use the personal information as described in the survey or user research. | You provide consent for processing personal information. | Survey and User Research |
| To conduct business planning, reporting, and forecasting. For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in. | Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully. |
Aggregated usage data |
| To evaluate and develop new features or technologies. | Legitimate interest to improve our products, improve user experience and develop new products for our users. | Synthetic User Content |
We may share your information with other entities in the following situations:
A) Our Related Entities: We might share your personal information within our corporate group to assist us in technical processing operations (such as data hosting, analytics or maintenance), finance, legal, HR or accounting assistance, enhancing security against spam, abuse, fraud, infringement or other wrongdoings, and improve the Services; for corporate audit, analysis, strategic planning, corporate transactions (for example merger and acquisition, sale of company assets, financing etc); or compliance with applicable law. Each entity within the group may only use your personal information in accordance with this Privacy Policy.
B) Our Authorised Partners: We work with third party vendors to provide the Vocaflow app ("Authorised Partners" or "Vendors"). We seek to update our list of Authorised Partners below as soon as practicable. These Authorised Partners process your information only at and according to our instructions. They perform tasks such as hosting, user support, analytics and fraud detection and prevention. For more information, please read the privacy policies of our Vendors.
| Vendor | Purpose |
|---|---|
| Firebase | Crash analytics |
| iShumei | Fraud detection and prevention, Risk control |
| Appflyer | Mobile attribution and marketing analytics |
| SensorsAnalyticsSDK | Data statistics and behavioral analysis |
| ACRCloud | Song identification |
| LALAL.AI | Vocal separation service to prepare audio for analysis. |
| Google Gemini | Singing analysis, Coaching to enhance vocal ability |
C) Government Agencies: In order to verify payments of In-App purchases and combat fraud and illegal activity, we may process and disclose information to other organizations or provide information to government agencies in response to any lawful request. If required by any government authority or courts for any purposes such as the enforcement of any laws or to prevent their contravention, we may release your personal information as is legally required or permitted.
By default, your personal data is stored in the United States.
In order to provide you with the full range of Services efficiently, we are working with authorised third party partners as well as related entities within our corporate group around the world. Accordingly, your personal information may be accessed by our authorised personnel around the world and/or your personal information may be lawfully transferred at our instructions for limited access, use or processing by our authorised personnel around the world.
Because the data protection and privacy laws in other countries may be different from those of your home country, we will take steps to ensure that adequate safeguards are in place to protect your personal information as explained in this Privacy Policy. Adequate safeguards that we may use include relying on approved standard contractual clauses and implementing other lawful safeguards.
We are entitled to do the above in order to perform our contractual obligations to you. By using our Services and providing information to us, you also consent to the storage, transfer and processing of the information to jurisdictions outside your home country and, unless otherwise stated in this Privacy Policy, we use this consent as one of the legal grounds for that data transfer.
We will ask for your permission to access the microphone where necessary so that you can use the app's features. We may also request some other permissions when additional functions require them. You may opt-out at any time by changing the settings on your mobile device.
Upon your written request and successful verification of your identity, we will provide you with a copy of your personal information in an electronic format.
You may, at any time, withdraw your consent for us to collect, use, disclose or transfer your personal information to third parties. You also have the right to rectify or delete your personal information, or limit the processing of your personal information. Upon receipt of your written request, we require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences regarding the same. In general, we shall seek to process your request within thirty (30) calendar days of receiving it. Depending on the nature and scope of your request, you may not be able to access some or all features on Vocaflow, and we may have to terminate the End-User License Agreement we have with you. We will notify you before completing the processing of your request. Should you decide to cancel your request, please inform us immediately.
Please note that:
Under applicable laws, you may have the right to obtain a transferable version of your personal information to transfer to another provider.
To exercise your personal information rights, please contact us according to Section 1 Contact Us above. You will not be subject to discriminatory treatment for exercising your rights.
You may cancel your paid subscription plan any time. If you decide to cancel your paid subscription, you will enjoy the paid features as per the full billing cycle. If you decide to delete your Vocaflow account before the paid subscription expires, you may lose your subscription status, your personal information or other related information associated with the account. You will be informed and required to acknowledge the consequences of deleting your account. However, we may retain some information to the extent necessary to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.
You may delete your Vocaflow account at any time by logging to your account settings on the app. If you decide to delete your Vocaflow account, we will deactivate your account and delete your information from our active databases. You may lose your personal information or other related information associated with the account. You will be informed and required to acknowledge the consequences of deleting your account. However, we may retain some information to the extent necessary to serve our legitimate business interests such as to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of User and/or comply with applicable legal requirements.
In order to help ensure a secure environment for the Services and safe experience for our users, we are continuously developing and implementing reasonable administrative, technical and physical security measures to protect your personal information from unauthorized use or access and against loss, misuse or alteration.
While we try our best, we cannot warrant the security of any information transmitted to us through or in connection with the Services, that we store on our or our authorised partners' systems.
Any improper collection or misuse of personal information is a violation of this Privacy Policy and our Terms of Use and should be reported to vocaflow.support@topmusetech.com.
These privacy-enhancing techniques involve modifying or removing certain identifying information from your personal data and information to make it more difficult to link the data or information to you. We only use information that has gone through this privacy-enhancement process if we are using them to improve functionalities of the Services.
Generally, we will store your personal information only for the time period necessary:
Once we determine that the retention of your personal information is no longer necessary for the intended purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain your personal information, or anonymise the personal information so that it can no longer be used to identify any particular individual.
Logs are pseudonymized and retained for a year, after which we may delete or anonymize it.
We take our responsibilities to the Vocaflow community very seriously. We also believe in protecting children's privacy online. Vocaflow app is not meant for use by persons under the age of 18 years old. If you are under the age of 18, please do not use our Vocaflow app in any manner. If you are a minor, you may only access and use Vocaflow app with the consent and under supervision of your parent or legal guardian. Please note that you must be of legal age according to the laws of your home country to make any In-App purchases on Vocaflow.
We do not knowingly collect personal information and data from anyone under the age of 18 and the Vocaflow app is not directed at children under the age of 18. Any person who provides their personal information to us through our Services explicitly represents that they are 18 years of age or older. If we become aware that someone under 18 years of age provided us with their personal information, we will close the account of that person and promptly delete their information or remove their information to the extent required by law, save when we are under a legal obligation to keep certain information.
If you are a parent or legal guardian of a minor, and wish to review any personal data that may have been collected by us from your child or ward for security reasons, or request that their Vocaflow account or personal information be modified or deleted for security or accuracy reasons, you may contact us at vocaflow.support@topmusetech.com. We will respond to your requests after verifying the identities of the relevant users and their parents or legal guardians, and obtaining consent (if required under the laws) from the relevant users.
You are responsible for any and all account activity conducted by a minor on your Vocaflow account.
We use third-party services such as Google Firebase and AppsFlyer to help us understand how Vocaflow is used and to improve performance and user experience. These services may collect and analyze certain device and usage data, including mobile identifiers, app usage statistics, and crash reports.
These technologies may function similarly to cookies and may involve the collection of personally referable information under applicable laws. This data may be shared with or accessed by the respective service providers to perform analytics, attribution, or to optimize Vocaflow's performance.
We will ask for your prior consent before enabling such tracking technologies, except where they are strictly necessary for the operation or security of Vocaflow. You may withdraw your consent any time by adjusting your device settings.
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.
Pursuant to the General Data Protection Regulation (GDPR) and the UK Data Protection Act, we now explain the valid legal bases we rely on in order to process your personal information.
We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
This section applies to you if you reside in Malaysia. In this section, the term "processing" shall have the same meaning as prescribed in the Malaysian Personal Data Protection Act 2010 ("MY PDPA").
Personal Information of Minors – In respect of personal information relating to a minor (i.e. individuals under the age of 18), you confirm that you are the parent or legal guardian or person who has the parental responsibility for the said minor to consent on his/her behalf to the processing of his/her personal information in accordance with this Privacy Policy.
Obligatory Personal Information – It is obligatory that you supply us your details for fields marked as compulsory (where applicable) when you register an account or use our Services (collectively, "Compulsory Personal Information"). If you fail to supply us with any of the Compulsory Personal Information, we may refuse to, or may be unable to, process your personal information for any of the purposes specified in this Privacy Policy.
Language – In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail over the Bahasa Malaysia version.
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