External Transmission Disclosure

External Transmission Disclosure

Telecommunications Business Act, Article 27-12

Last updated: May 2026

Telecommunications Business Operator

Luminary ROLI Ltd.

326/327 Stean Street, London E8 4ED, United Kingdom

Scope of this Disclosure

This disclosure applies to the website roli.com, the ROLI mobile and desktop applications, and related online services operated by Luminary ROLI Ltd. (collectively, the “Services”). It sets out the information that is transmitted from your device to third parties when you use the Services, in accordance with Article 27-12 of the Telecommunications Business Act (as amended June 2023). The list of third parties below is current as at the date stated at the foot of this disclosure and may be updated from time to time.

Information Transmitted to Third Parties

Service

Operator 

Information Transmitted

Purpose

Google Analytics

Google LLC

Cookies (client ID, session ID); Pages visited, time on page; Device type, browser, OS; Approximate location (IP-based); Referral source

Website traffic analysis, usage measurement, and service improvement

Privacy Policy

https://policies.google.com/privacy

Opt-out

https://tools.google.com/dlpage/gaoptout

Google Tag Manager

Google LLC

Cookies (tag management); Pages visited; Device and browser information

Tag management and coordination of analytics and marketing scripts

Privacy Policy

https://policies.google.com/privacy

Opt-out

N/A

Facebook Pixel (Meta Pixel)

Meta Platforms, Inc.

Cookies (user identifier, browser ID); Pages visited, actions taken on site; Device type, browser, OS; IP address; Referral source

Advertising measurement, conversion tracking, and audience targeting

Privacy Policy

https://www.facebook.com/privacy/policy/

Opt-out

https://www.facebook.com/adpreferences

TikTok Pixel

ByteDance Ltd. / TikTok Inc.

Cookies (click ID, user identifier); Pages visited, actions taken on site; Device type, browser, OS; IP address

Advertising measurement, conversion tracking, and audience targeting

Privacy Policy

https://www.tiktok.com/legal/privacy-policy

Opt-out

https://www.tiktok.com/legal/privacy-policy (opt-out settings)

OpenAI (AI Music Coach: GPT, TTS API, Realtime API)

OpenAI, L.L.C.

User-submitted prompts (text); voice recordings, where the AI Music Coach voice feature is used; generated responses; associated session and request metadata. Where the AI Music Coach feature has been enabled by a parent or legal guardian for a Child user, the foregoing may include content submitted by the Child.

Generation of responses by the AI Music Coach feature, and (to the extent permitted by OpenAI’s terms) monitoring of service quality and investigation of safety or security issues.

Privacy Policy

https://openai.com/policies/privacy-policy

Opt-out

Transmission to OpenAI is intrinsic to the AI Music Coach feature; opt-out is by not enabling or not using AI Music Coach. 

How to Control External Transmission

You can manage external transmissions via the per-service opt-out links set out in the table above. Browser-level cookie controls remain available, but may not be effective against all of the transmissions described above, because certain transmissions are processed on a server-to-server basis and cannot be disabled at the user's device. For any query regarding the transmissions described in this disclosure, please contact us using the details in the Contact section below.

Contact

For enquiries regarding this disclosure, please contact:

Luminary ROLI Ltd.

Support page: https://roli.com/eu/static/support