Privacy Policy

Last updated: 30 September 2026

This Privacy Policy explains how personal data is processed in connection with the website braillemusiceditor.com, the purchase of licenses and the use of the Braille Music Editor software (BME / BM2025), in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Italian law (Legislative Decree 196/2003, as amended).

1. Data Controller

Associazione Giuseppe Paccini
Via Bonino da Campione 17, 37138 Verona (VR), Italy
VAT number: IT04638810236
Tax code: 93283480239
Tel.: +39 045 8104221
Email: info@braillemusiceditor.com
Certified email (PEC): giuseppepaccini@pec.it

2. The software

Braille Music Editor does not require registration and does not collect or store personal data about the use of the software. Scores and files created with it remain on the user’s device. To activate a license, the buyer’s email address is required, as the activation code is sent to that address (see section 3b).

3. What data we process, and why

a) Purchases and invoicing. An invoice is issued for every purchase. We therefore process first and last name or company name, email address, billing address, tax code and/or VAT number, order details and payment status. We do not store full payment card details or banking credentials, which are processed directly by the payment service providers. We may receive transaction information such as the payment method used, the payment status and the transaction identifier.
Purpose: to complete the sale, issue invoices and meet accounting and tax obligations.
Legal basis: performance of a contract (Art. 6(1)(b) GDPR) and compliance with legal obligations (Art. 6(1)(c) GDPR).

b) License management. The buyer’s email address is required for activation, as the activation code is sent to that address. We record the activation code issued, the license type (single, dual, upgrade), the date of issue, and the buyer’s name and email address. For resellers, we record the company and its contact person.
Purpose: to deliver the activation code, verify license validity, and handle reactivations and upgrades.
Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

c) Support and correspondence. When you write to us, we process your email address and the content of your message.
Purpose: to answer requests and provide technical support.
Legal basis: performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR) and our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR).

d) Website browsing and cookies. Our hosting provider automatically records technical data such as IP address, browser type and access time, for the security and proper operation of the website (legitimate interest, Art. 6(1)(f) GDPR). Technical cookies are always active. Other cookies (statistics, marketing) are used only with your consent (Art. 6(1)(a) GDPR), which you can give, refuse or withdraw at any time via the “Manage consent” banner. For details on individual cookies, see our Cookie Policy. https://braillemusiceditor.com/cookie-policy-ue/

With your consent, we use Google Analytics 4, a service provided by Google Ireland Limited, to analyse the use of the website. Google Analytics collects, in pseudonymised form through an identifier stored in a cookie, information such as pages visited, visit duration, device and browser type, and approximate geographic location derived from the IP address, which is not stored. We only view aggregated statistical reports. Google Analytics is not activated unless you consent to the “Statistics” category.

Provision of data. Providing the data required for purchase, invoicing and license activation is necessary to conclude the contract and meet legal obligations: without it, we cannot complete the purchase or provide the license. Providing data for support requests is optional, but without the necessary information we may be unable to respond.

We do not carry out automated decision-making or profiling within the meaning of Article 22 GDPR, and we do not use personal data for marketing purposes without consent.

4. Minors

The software may be used by minors in educational settings, but it is not designed to collect personal data about its users. Purchases and license management are carried out by adults, such as parents, guardians, teachers, schools or resellers.

5. Recipients of data

Personal data may be disclosed, to the extent necessary for the purposes described in this policy, to the following categories of recipients:

  • Payment providers: Stripe and PayPal, which process the data needed to handle payments according to their respective roles and their own privacy policies. Depending on the activity carried out, these providers may act as processors and/or as independent controllers.
  • Sales platform: SureCart, which manages checkout and orders on the website, mainly as a processor; for certain activities carried out for its own purposes it may act as an independent controller, as described in its privacy policy.
  • Website hosting: Opalstack LLC, with servers located in Germany (European Union), as a processor.
  • Website statistics: Google Ireland Limited (Google Analytics), as a processor, only with prior consent.
  • Accountant / tax advisor, for accounting obligations.
  • Public authorities, where required by law.

Personal data is never sold or transferred to third parties for marketing purposes.

6. Transfers of data outside the European Economic Area

Some of the providers we use may process personal data, or allow access to it, from countries outside the European Economic Area, in particular the United States. Where this happens, the transfer is carried out in accordance with Articles 44 et seq. GDPR, on the basis of an adequacy decision of the European Commission, including, where applicable, the EU–US Data Privacy Framework, or by means of Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs) or other safeguards provided for by the GDPR.

Further information on the safeguards applicable to international transfers can be requested from the Data Controller by writing to info@braillemusiceditor.com.

7. Retention

  • Invoices and accounting records: 10 years, as required by Italian law (Art. 2220 Civil Code).
  • Data required to manage licenses and activation codes: for the duration of the license and thereafter for the period necessary to document the license purchased, allow reactivations and manage the related contractual rights, in accordance with applicable limitation periods.
  • Support correspondence: 24 months from the last contact, unless linked to a license or invoice.
  • Technical and security server logs: for the period necessary to ensure security, prevent abuse and diagnose technical problems, according to the retention times applied by the hosting provider.
  • Google Analytics data: 2 months, according to the retention setting configured in the service.
  • Cookies: as indicated in the cookie banner.

8. Your rights

Where provided for by the GDPR, you have the right to access your personal data, obtain its rectification or erasure, request restriction of processing, object to processing and receive your data in a portable format. Where processing is based on consent, you also have the right to withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal. Data required for legal obligations (such as invoices) cannot be erased before the applicable retention period expires.

To exercise these rights, write to info@braillemusiceditor.com. We will respond within one month.

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the supervisory authority of your country of residence.

9. Changes

This policy may be updated. The date at the top indicates the latest version.