Privacy Policy
How we collect, use and protect your personal data
1. Who We Are
This Privacy Policy applies to the website freekeylessons.com, operated by:
Mirco Lieber, MMag.
ML Elite Online Music School
Estrada Regional da Relva 240, 9500-655 Ponta Delgada, Portugal
Email: hello@freekeylessons.com
We are committed to protecting your personal data and processing it in accordance with the EU General Data Protection Regulation (GDPR) and applicable Portuguese law.
Note Regarding Minors
Our website and lead forms are directed at adults (18+) or parents and legal guardians acting on behalf of minors. While we offer a Junior Program for ages 6 to 14, we do not knowingly collect personal data directly from children under the age of 16, bookings and account details for Junior Program lessons must be submitted by a parent or legal guardian. If you believe a child has submitted personal data without parental consent, please contact us at hello@freekeylessons.com and we will delete the data promptly.
2. Data We Collect and Why
Email Address (Opt-in)
When you sign up for our Free Starter Kit or any lead magnet on this website, we collect your email address. We use this to:
- Deliver the free materials you requested (PDFs, guides)
- Send follow-up practice tips and music education content
- Inform you about courses and offers from ML Elite Online Music School
Legal basis: Your explicit consent (GDPR Art. 6(1)(a)). You may withdraw consent at any time.
Double Opt-In: After submitting your email address, you will receive a confirmation email. Your email address is only added to our list after you click the confirmation link in that email. This ensures that only you can register your email address.
Contact Form / Direct Email
If you contact us directly, we process your name and email address to respond to your inquiry. Legal basis: Legitimate interest (GDPR Art. 6(1)(f)).
Server Logs
Our hosting provider (Netlify, Inc.) automatically logs technical data (IP address, browser type, pages visited, timestamps) for security and performance purposes. These logs are retained for a maximum of 30 days. Legal basis: Legitimate interest (GDPR Art. 6(1)(f)).
3. Email Marketing
We use Brevo (formerly Sendinblue, operated by Sendinblue SAS, 55 rue d'Amsterdam, 75008 Paris, France) to manage our email subscriber list and send transactional and marketing emails.
Brevo acts as a data processor on our behalf. Your email address is stored on Brevo's servers within the EU. Brevo is GDPR compliant. For details, see Brevo's Privacy Policy.
You can unsubscribe from any of our emails at any time by clicking the unsubscribe link in any email we send.
4. Hosting
This website is hosted by Netlify, Inc. (44 Montgomery Street, Suite 300, San Francisco, CA 94104, USA). Netlify processes technical data (IP addresses, server logs) as part of hosting the website. Netlify is certified under the EU-US Data Privacy Framework.
For details, see Netlify's Privacy Policy.
5. Cookies & Analytics
Netlify may set functional session cookies necessary for the website to operate correctly; these do not track you across other websites.
We use Google Analytics 4 (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to understand how visitors use this website (pages viewed, time on site, traffic source). Google Analytics only runs after you actively consent via the cookie banner shown on your first visit, we use Google's Consent Mode v2, and analytics cookies stay blocked by default until you click "Accept." You can withdraw consent at any time by clearing your browser's cookies for this site or via the settings in the cookie banner. For details, see Google's Privacy Policy.
We also use the Meta (Facebook) Pixel (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland) to measure the performance of our ads and understand how visitors who arrive from Facebook or Instagram use this website. Like Google Analytics, the Meta Pixel is consent-gated: it stays blocked by default and only begins measuring after you click "Accept" in the cookie banner. You can withdraw consent at any time via the settings in the cookie banner. For details, see Meta's Privacy Policy.
6. Data Sharing
We do not sell, rent, or trade your personal data. We share data only with service providers who process it on our behalf (Brevo for email, Netlify for hosting), under data processing agreements, and only to the extent necessary to provide the service.
We do not transfer your data to third countries outside the EU/EEA except where adequate safeguards are in place (e.g. the EU-US Data Privacy Framework).
7. Retention
We retain your email address in our subscriber list for as long as you remain subscribed. Upon unsubscription, your email is deleted from our active list within 30 days. We also delete subscriber records that have shown no activity (no email opens or clicks) for 24 consecutive months. Server logs are deleted within 30 days.
MusicTeacherPros, Booking Widget
Our website uses a booking widget provided by MusicTeacherPros (link.musicteacherpros.com) to enable scheduling of free trial lessons, 1-on-1 coaching sessions, and Junior Program sessions. When you use the booking form, personal data (name, email address, and optionally phone number) is transmitted to and processed by MusicTeacherPros.
Legal basis: Contract performance / pre-contractual measures (GDPR Art. 6(1)(b)).
For Junior Program bookings (ages 6 to 14), we require that the booking is made by a parent or legal guardian. By completing the booking form on behalf of a minor, you confirm that you are the parent or guardian and consent to the processing of the child's data for the purpose of lesson scheduling.
MusicTeacherPros acts as a data processor on our behalf. For more information, please refer to the MusicTeacherPros Privacy Policy and the Data Processing Agreement (DPA).
Zoom, Online Lessons
All live lessons are conducted via Zoom (Zoom Video Communications, Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA). When you participate in a lesson, Zoom processes personal data including your name, email address, IP address, and audio/video data during the session.
Legal basis: Contract performance (GDPR Art. 6(1)(b)).
Zoom is certified under the EU-U.S. Data Privacy Framework. For more information, please refer to Zoom's privacy policy at zoom.us/privacy.
Course Checkout & Payments
When you purchase a course (Piano Level 1, Piano Level 2, or the Complete Bundle), you are directed to our course platform, ClientClub (mircolieber.app.clientclub.net), to complete checkout. ClientClub processes your name, email address, billing address, and payment details, and works with its own integrated payment processor to complete the transaction.
Legal basis: Contract performance (GDPR Art. 6(1)(b)).
We do not see or store your full payment card details, these are handled directly by ClientClub and its payment processor. For details on how your data is processed at checkout, please refer to the privacy policy presented on the ClientClub checkout page.
YouTube, Video Embeds
Some pages on this website embed videos hosted on YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), using YouTube's privacy-enhanced mode (youtube-nocookie.com). In this mode, YouTube does not store information about visitors on your device unless you actually play the video. If you click play, YouTube may then set cookies and collect technical data (such as your IP address and device information) to enable playback and, if you are signed into a Google account, to personalize your experience.
Legal basis: Legitimate interest in presenting our video content (GDPR Art. 6(1)(f)) for the no-cookie embed itself; your consent (GDPR Art. 6(1)(a)) for any cookies YouTube sets once you choose to play a video.
For details, see Google's Privacy Policy and YouTube's Terms of Service.
8. Your Rights (GDPR)
Under the GDPR, you have the following rights regarding your personal data:
- Access, request a copy of the data we hold about you
- Rectification, ask us to correct inaccurate data
- Erasure, request deletion of your data ("right to be forgotten")
- Restriction, ask us to limit how we process your data
- Portability, receive your data in a structured, machine-readable format
- Objection, object to processing based on legitimate interest
- Withdrawal of consent, withdraw consent for email marketing at any time (unsubscribe link in every email)
To exercise any of these rights, contact us at: hello@freekeylessons.com
You also have the right to lodge a complaint with the competent Portuguese data protection authority:
CNPD, Comissão Nacional de Proteção de Dados · Av. D. Carlos I, 134, 1200-651 Lisbon · www.cnpd.pt
9. Contact
For any privacy-related questions or requests:
Email: hello@freekeylessons.com
Website: www.freekeylessons.com