MiWave Privacy Policy
MiWave is operated by Marc Holenstein and Anthony Cieslik, trading as Luma 2. This policy explains what personal data we process, why, how long we keep it, and the choices and rights you have. It applies to the MiWave iOS app and the MiWave website.
Luma 2 is a trading name and not a registered company. The controllers responsible for this processing are therefore Marc Holenstein and Anthony Cieslik personally, jointly, in Switzerland, reachable at c/o Frey Services, Eggstrasse 14f, 8134 Adliswil. Privacy enquiries and data-subject requests: luma2dev@gmail.com. We answer within 30 days.
In short: we do not sell your personal data, we do not use it for advertising, we do not track you across other companies’ apps or websites, and we never send your songbook to an AI provider until you have said yes to a screen that names each provider and the country it is in.
Last updated: 8 October 2026.
1. Data we process
Account data
When you create an account we process your email address, the name you provide, a cryptographically hashed password (we never see or store the plain password), and session metadata used to keep you signed in and to secure your account. If you sign in with Apple or Google, we receive your name and email address from that provider instead of a password — with Sign in with Apple you can choose to hide your real address, and we only ever see the relay address Apple gives us.
Your songbook content
MiWave is a songwriting studio. We process the ideas, prompts, lyrics, and production directions you write (“songbook content”), the production documents derived from them, and the audio files generated for you. Songbook content is stored in our database and private object storage; audio is served only through short-lived, signed links to your authenticated account.
Songbook content is sent to our AI providers only after you explicitly agree in the app (“Before MiWave uses AI”). The app names each provider and its purpose at that moment. You can decline, and declining stops that production. Our text-composition provider (OpenAI or Anthropic) processes your prompt and lyrics to shape structure, writing, and production direction. ElevenLabs processes the production package, including lyrics, to generate music and vocals, as described in section 3.
Your agreement is recorded against a version of this notice and enforced on our servers, not only in the app: if you have not agreed to the current version, we refuse the request rather than sending anything to a provider. You can withdraw your agreement at any time in the app, which stops further sharing immediately, including for productions still queued. Withdrawing does not undo sharing that already happened.
Purchases
Payment is processed by Apple. We never receive card or payment details. Via RevenueCat we receive subscription lifecycle information (product, expiry, renewal state) linked to your account so MiWave Pro features and quotas work correctly.
Transactional email
We send email address verification, password reset, and account deletion messages through our email provider, Resend. These messages contain no songbook content.
Push notifications
If you enable notifications, Apple’s push service requires us to process a device token to deliver production status updates you requested. You can turn notifications off at any time.
Diagnostics and product analytics
We use PostHog (EU region), Sentry, and Langfuse (EU region) to understand crashes and how the product is used. A strict allowlist controls which event fields may leave the device or server: technical status, events, latency and cost buckets, and similar operational fields. Never included in an event: lyrics, prompts, song documents, audio URLs, your email address, or authentication tokens. Automated tests attempt to leak such values and fail the build if any export contains them.
We do not record session replays or screenshots of the app. Versions of the app released before October 2026 could record a sampled, masked replay for people who had allowed product analytics; that recording is switched off for every version.
Sessions and legal records
Each sign-in session stores the IP address and user agent (device and app version) it was created from, so a session you no longer recognise can be identified and revoked. When you accept these terms or a consent notice, we record which document you accepted and when, along with the IP address, user agent, app version, and country code at that moment — the evidence that the acceptance happened.
Abuse and security records
We keep bounded security, rate-limit, and abuse signals (for example request counts) to protect the service and other users. Before you create an account, activity is recorded under a device-scoped anonymous identifier that is not linked to a name or email address. A deletion request stores only a pseudonymized record that the deletion happened.
2. Legal bases
- Performance of a contract: operating your account, producing your songs, and providing MiWave Pro features you subscribed to.
- Consent: sharing songbook content with AI providers, sending push notifications, and product analytics where required. You can withdraw consent at any time; withdrawal does not affect processing already completed.
- Legitimate interests: keeping the service secure, preventing fraud and abuse, and diagnosing errors.
- Legal obligation: retaining minimal billing records in pseudonymized form where law requires it.
3. Providers and transfers
We work with: Apple (United States — App Store, payments, push), RevenueCat (United States — subscription infrastructure), OpenAI and Anthropic (United States — text composition; one of the two composes each song), ElevenLabs (United States — music generation), Resend (United States — email), PostHog (EU region), Sentry (United States), Langfuse (EU region), and Railway (hosting, database, and file storage, on servers in the EU; Railway itself is a United States company).
Where your lyrics go. Music generation is performed by ElevenLabs, which receives the production package — including the lyrics you wrote — generates the recording, and returns it directly to our servers. The request is not routed onward to another company. Your lyrics are therefore processed in the United States by our text-composition provider (OpenAI or Anthropic) and by ElevenLabs, and stored by us in the EU.
Versions of the MiWave app released before October 2026 describe music generation on the consent screen as going through AtlasCloud and APIMart, with part of the processing in China. That is no longer the case: since October 2026 no songbook content is sent to AtlasCloud, APIMart, or any recipient in China. An app update brings the consent screen in line with this policy.
Please do not put sensitive personal information into a song, and decline the AI step if you would rather this processing did not happen.
Switzerland recognises the EU and EEA as providing adequate protection, so transfers to providers in the EU region need no further safeguard. For the other providers listed above we rely on the data processing terms those providers incorporate into their own service terms, which include the standard contractual clauses, together with technical measures — the field allowlist that keeps songbook content out of diagnostics, the download allowlist described above, and encryption in transit throughout.
We name every recipient of your songbook rather than describing them as a category. If that list changes, the consent notice changes with it and you are asked again.
4. Retention and deletion
As a rule we keep personal data only while your account exists, and delete it with the account. Where a shorter or fixed period applies, it is this:
- Email verification and password reset links expire one hour after they are sent.
- Sign-in sessions expire automatically and can be revoked by you at any time under You → Account, which lists every active session with the device and the IP address it was created from.
- Read notifications leave your inbox after seven days.
- Deleted accounts are recoverable for seven days and then permanently removed, as described below.
- Diagnostics and product analytics are held by our processors under their own retention schedules; we do not use them to build a profile of you, and they never contain your songbook.
- Minimal billing records are kept in pseudonymized form for as long as accounting and tax law requires, and for no other purpose.
You can start deletion from inside the app, under You → Account.
Deletion runs after a recovery period of seven days, which exists so an accidental deletion can be undone. You can cancel at any point during those seven days; after that the deletion is permanent and cannot be reversed. The app shows you the exact date before you confirm.
When it runs, we delete your account, sessions, songbook content, generated audio and cover art, push tokens, and device records, and pseudonymize the minimal billing records we must keep. If you signed in with Apple, we also revoke the Apple sign-in tokens issued for MiWave. We retain one minimal, pseudonymous record that the deletion happened — it contains no direct identifiers and exists so we can demonstrate that your request was honoured. Deletion is confirmed to you by email.
Content you never send to production is never shared with AI providers.
5. Your rights
You can request access to your personal data, correction of it, deletion, restriction of processing, or a portable copy; you can object to processing based on legitimate interests; and you can withdraw any consent you have given. Withdrawing consent does not make the processing that already happened unlawful.
Several of these are built into the app rather than being a request you have to make and wait for: account deletion, withdrawal of AI data sharing, withdrawal of product analytics, and revoking an individual sign-in session are all under You → Account and You → Help & privacy.
For anything else, write to luma2dev@gmail.com. We answer within 30 days and free of charge. If we cannot identify you from the request we may ask for information that lets us match it to an account — we ask for the minimum needed, and never for identity documents.
If you are not satisfied, you can lodge a complaint with a data protection authority. In Switzerland that is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.
6. How we protect your data
- All traffic between the app and our servers is encrypted in transit, and requests from the app are cryptographically signed.
- Passwords are stored only as a salted cryptographic hash. We cannot read your password, and neither can anyone who obtains the database.
- Sign in with Apple refresh tokens are stored under authenticated encryption rather than in the clear, because a refresh token is a credential in its own right.
- Generated audio and cover art live in private storage and are served only through short-lived signed links issued to your authenticated account. They are not public URLs and are not guessable.
- Our music provider returns finished audio directly rather than as a link, and wherever a provider does answer with a link, it is downloaded only from an explicit allowlist of provider hosts, so a compromised or malicious provider response cannot make our servers fetch somewhere else.
- Automated tests attempt to leak lyrics, prompts, emails and tokens into analytics and diagnostics on every build, and fail the build if any of them gets through.
No system is perfect. If a breach occurs that is likely to result in a high risk to your rights, we will inform you and the competent authority as the law requires, and tell you what happened and what to do about it.
7. Automated decisions, profiling, and advertising
MiWave makes no automated decision that produces a legal effect for you or similarly significantly affects you. The AI in MiWave writes songs; it does not decide anything about you. We do not profile you, we do not sell or rent personal data, we do not use it for advertising, and we do not track you across other companies’ apps or websites — the app declares exactly this in its App Store privacy information.
8. The website
The MiWave website uses only the cookies and local storage needed to keep you signed in and to make the pages work. There are no advertising cookies, and no third-party analytics or tracking scripts on the public pages. A song shared through a share link is served to whoever holds the link, for as long as you leave that link active; you can revoke a share link in the app.
9. Children
MiWave is not directed at children. You must be at least 16 years old to use the service. Songs are written by an AI system from whatever you ask it for, and MiWave does not filter the words it produces, which is why the App Store rating for this app is 16+.
10. Changes and contact
We may update this policy as the product evolves; the date above shows the current version. If a change is material — a new category of data, a new purpose, or a new recipient of your songbook — we tell you in the app or by email before it takes effect, and where the change concerns AI processing you are asked to agree again rather than being opted in by a new date on a page. Questions about privacy: luma2dev@gmail.com.