Sublystic Privacy Policy

2. Definitions and Interpretation

2.1 Key Definitions

• Personal Information: Any information that relates to an identified or identifiable individual.
• Processing: Any operation performed on personal data, such as collection, storage, use, or disclosure.
• User Content: Video files, audio content, and subtitle files you submit to the Service.
• Controller: The entity that determines the purposes and means of processing personal data. For purposes of this Policy, B. Bharath kumar is the data controller.
• Processor: An entity that processes personal data on behalf of the controller.
• Third Party: Any individual or entity other than you or me.
• Sensitive Personal Information: Includes information revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sexual orientation, as well as financial information and government-issued identification numbers.

2.2 Interpretation

• References to "you" or "your" mean the individual user or, where applicable, the entity on whose behalf such individual is accessing the Service
• Words in the singular include the plural and vice versa
• "Including" means "including without limitation"
• Headings are for convenience only and do not affect interpretation
• References to laws or regulations include amendments and successor provisions

3. Information We Collect

3.1 Categories of Information Collected

I collect various types of information in connection with your use of the Service, which can be categorized as follows:

3.1.1 Account and Registration Information

When you create an account or register for the Service, I collect:

• Full Name: Your first and last name or username
• Email Address: Primary email address for account authentication, communication, and password recovery
• Password: Encrypted and hashed authentication credentials (passwords are not stored in plain text)
• Account Creation Date and Time: Timestamp of account registration
• Account Type: Subscription tier (Free, Pro Lite, or Pro)
• Account Status: Active, suspended, or terminated status
• Authentication Tokens: Session identifiers and authentication tokens for maintaining logged-in sessions
• Social Media Profile Information: If you choose to sign up or log in using third-party authentication services (Google, Apple, Facebook), I may receive your name, email address, profile picture, and other information made available by those services

3.1.2 Payment and Billing Information

For users who purchase subscriptions or booster packs, I collect:

• Payment Method Details: Credit card type, last four digits, expiration date, billing postal code (full payment card details are processed and stored by the payment processor, Paddle, and are not directly accessible)
• Billing Address: Street address, city, state/province, country, and postal code
• Transaction History: Date, time, amount, and description of purchases
• Payment Processor Identifiers: Unique customer IDs assigned by Paddle
• Tax Information: VAT numbers, tax identification numbers, or other tax-related information as required by applicable law
• Invoice and Receipt Information: Billing records and payment confirmations
• Refund and Dispute Records: Information related to refund requests, chargebacks, or payment disputes

3.1.3 Usage Data and Analytics Information

I automatically collect information about how you interact with the Service:

• Feature Usage Statistics: Which features you use, frequency of use, and duration of use
• Video Processing Data: Number of videos processed, total minutes consumed, processing success/failure rates, file sizes, and video durations
• Subtitle Generation Metrics: Number of subtitles created, edited, translated, or exported; formats used; languages selected
• Session Information: Login frequency, session duration, time spent on different screens or features
• Navigation Patterns: Click paths, screen transitions, button interactions, and user flow through the App
• Search Queries: Terms you enter when searching within the App
• Error Logs and Crash Reports: Technical error messages, application crashes, bugs, and diagnostic information
• Performance Metrics: App loading times, response times, and performance benchmarks
• Referral Data: Information about how you were referred to the Service, including referral codes and referring users

3.1.4 Device and Technical Information

I collect technical information about the devices you use to access the Service:

• Device Type and Model: Manufacturer, model name, and hardware specifications
• Operating System: OS type, version, and build number (e.g., iOS 17.2, Android 14)
• Device Identifiers: Unique device identifiers such as IDFA (Identifier for Advertisers) on iOS, Android Advertising ID, or other device-specific identifiers
• App Version: Version number and build number of the Sublystic app installed on your device
• Mobile Network Information: Mobile carrier name and network type (Wi-Fi, cellular, 4G, 5G)
• IP Address: Internet Protocol address of your device (may be automatically collected by hosting infrastructure and third-party services; not actively used for profiling purposes)
• Browser Information: If accessing via web, browser type, version, and settings
• Screen Resolution and Display Settings: Device screen size, resolution, and orientation
• Language and Locale Settings: Preferred language, time zone, and regional settings
• Device Sensors Data: With your permission, accelerometer, gyroscope, or other sensor data if used for app functionality

3.1.5 Content and User-Generated Data

When you use the Service to create, edit, or manage subtitles:

• Video Metadata: Video titles, URLs (for YouTube or other online videos), file names, durations, formats, and upload timestamps
• Subtitle Content: Text content of subtitles you create, extract, or edit through the Service
• Subtitle Files: SRT, VTT, SSA, ASS, and other subtitle format files you generate or upload
• Editing History: Records of changes, revisions, and versions of subtitle projects
• Project Information: Project names, descriptions, creation dates, and organizational data
• Translation Data: Source and target languages for translation requests
• OCR Extraction Data: Text extracted from video frames using optical character recognition
• AI Processing Requests: Inputs and outputs from AI-powered subtitle cleaning and enhancement features
• Note: Your actual video files are not stored. For local videos, only file references or paths are stored. For online videos (YouTube), only the URL is stored, not the video content itself.

3.1.6 Communication and Support Data

When you contact me or interact with customer support:

• Support Tickets: Content of your support requests, questions, and complaints
• Email Communications: Correspondence sent to or received from support or other email addresses
• Chat Transcripts: If you use in-app chat or live support, transcripts of conversations are retained
• Feedback and Survey Responses: Information provided through feedback forms, user surveys, or product reviews
• Customer Satisfaction Ratings: Ratings or reviews you provide about your experience
• Attachments: Screenshots, log files, or other materials you provide to assist with support requests

3.1.7 Marketing and Communication Preferences

• Email Subscription Status: Whether you have opted in or out of marketing emails
• Communication Preferences: Frequency and type of communications you wish to receive
• Push Notification Settings: Whether you have enabled or disabled push notifications
• Marketing Engagement Data: Email open rates, click-through rates, and interaction with promotional content

3.1.8 Referral Program Information

If you participate in the referral program:

• Referral Codes: Unique codes assigned to you for sharing
• Referred Users: Information about users who sign up using your referral link or code
• Referral Rewards: Processing minutes earned through successful referrals
• Referral Source Tracking: How your referral link was shared or accessed

3.1.9 Social Media and Third-Party Platform Data

If you connect your social media accounts or share content from the Service:

• Social Media Profile Information: Username, profile picture, and public profile data
• Sharing Activity: Content you share from the Service to social media platforms
• Social Media Interactions: Likes, comments, or engagement with social media presence

3.1.10 Location Information (If Applicable)

While precise geolocation data is not currently collected, approximate location information may be collected:

• Country and Region: Derived from IP address or device settings for localization purposes
• Time Zone: To display timestamps and schedule communications appropriately
• Language and Regional Preferences: Based on device settings
• If features that require precise location data are introduced in the future, explicit consent will be sought before collecting such information.

3.2 Sensitive Personal Information

I do not intentionally collect or process Sensitive Personal Information as defined in Section 2.1. If you voluntarily provide such information (for example, in support communications), it will be handled with heightened security measures and in accordance with applicable data protection laws.

3.3 Information Not Collected

To be transparent about data practices, the following is explicitly not collected:

• Biometric Data: Fingerprints, facial recognition data, or other biometric identifiers (except as required by device-level authentication you control)
• Health Information: Medical records, health conditions, or health-related data
• Financial Account Credentials: Banking passwords, financial account login credentials, or full credit card numbers (these are processed exclusively by the payment processor)
• Government-Issued ID Numbers: Social security numbers, passport numbers, or national identification numbers (except as specifically required for tax compliance in certain jurisdictions)
• Background Information: Criminal records, credit reports, or background check data

3.4 Voluntary Information Disclosure

You are not legally required to provide personal information. However, certain information is necessary to create an account, access features, or process payments. If you choose not to provide required information, you may not be able to use all features of the Service.

4. How We Collect Your Information

4.1 Direct Collection Methods

Information is collected directly from you through various methods:

4.1.1 Account Registration and Profile Creation

• When you sign up for a Sublystic account through the mobile app or website
• When you complete your user profile or update account information
• When you voluntarily provide additional information to enhance your profile

4.1.2 Payment and Purchase Transactions

• When you subscribe to Pro Lite or Pro plans
• When you purchase booster packs
• When you update payment methods or billing information
• Through the payment processor, Paddle, which shares transaction data

4.1.3 Service Usage and Interactions

• When you upload or link to videos for subtitle extraction
• When you create, edit, translate, or export subtitles
• When you use AI-powered features such as subtitle cleaning or translation
• When you save projects or sync data to cloud storage
• When you participate in the referral program

4.1.4 Communications and Support

• When you contact customer support via email, chat, or in-app messaging
• When you respond to surveys, questionnaires, or feedback requests
• When you communicate through social media or other channels
• When you subscribe to newsletters or promotional communications

4.1.5 Third-Party Authentication

• When you use "Sign in with Google," "Sign in with Apple," or other third-party authentication services
• These services share certain profile information based on your permissions

4.2 Automatic Collection Methods

Certain information is automatically collected through technical means:

4.2.1 Analytics and Tracking Technologies

• Firebase Analytics: Collects usage patterns, feature interactions, and app performance data
• Event Tracking: Records specific user actions and interactions within the App
• Session Recording: Captures aggregated session data (not individual screen recordings)

4.2.2 Log Files and Server Data

• Servers and hosting infrastructure automatically log technical information such as timestamps, error messages, and system events
• Cloud storage providers (Firebase) maintain logs of data access and storage operations

4.2.3 Mobile Device Information

• The mobile app automatically collects device type, OS version, and app version for compatibility and performance purposes
• Device identifiers are collected for analytics and personalization (subject to device OS permissions)

4.2.4 Cookies and Similar Technologies

• Cookies and similar technologies are used on the website (if applicable) to maintain sessions, remember preferences, and collect analytics data
• See Section 12 for detailed information about cookies

4.3 Third-Party Collection Methods

Information about you is received from third-party sources:

4.3.1 Payment Processor (Paddle)

• Paddle shares transaction information, payment status, subscription details, and billing information
• Paddle may share customer service records related to payment disputes or issues

4.3.2 Social Media and Authentication Providers

If you use third-party sign-in services, profile information is received from Google, Apple, Facebook, or other providers based on your authorization

4.3.3 AI Service Providers (Gemini AI)

When you use AI features, your subtitle content is sent to Gemini AI for processing. Gemini AI may retain data according to its own policies; reviewing Google's privacy policies is recommended

4.3.4 Analytics and Advertising Partners

Firebase and other analytics partners collect usage data and may share aggregated or de-identified insights

4.3.5 Referral Sources

If you were referred by another user, information about the referral source and relationship is collected

4.4 Information from Public Sources

Information collected may be supplemented with publicly available information from:

• Public social media profiles (if you link your account)
• Public business registries or directories (for business accounts)
• Publicly accessible data breach databases (to enhance security)

4.5 Inferences and Derived Information

Inferred or derived information may be created based on the data collected:

• User preferences and interests based on usage patterns
• Subscription upgrade or churn predictions
• Feature recommendations based on behavior
• Categorization of user types or personas for service improvement

5. How We Use Your Information

5.1 Primary Purposes

Your personal information is used for the following core purposes:

5.1.1 Service Provision and Functionality

• Account Management: Creating, maintaining, and managing your user account; authenticating your identity; securing your account
• Core Features Delivery: Providing video subtitle extraction using OCR technology; enabling AI-powered subtitle cleaning and grammar correction; facilitating subtitle editing, formatting, and synchronization; supporting subtitle translation into multiple languages
• Content Processing: Processing your videos and generating subtitles through AI and OCR systems; storing and managing your subtitle projects; enabling cloud storage and synchronization for paid users
• Format Conversion and Export: Converting subtitles to various formats (SRT, VTT, SSA, ASS); enabling download and export of subtitle files
• Video Player Integration: Providing in-app video preview and subtitle synchronization features
• Usage Tracking: Monitoring your monthly minutes consumption; applying subscription tier limitations; managing booster pack minutes

5.1.2 Payment Processing and Billing

• Transaction Processing: Facilitating payment for subscriptions and booster packs through the payment processor, Paddle
• Subscription Management: Managing recurring billing cycles; processing subscription renewals, upgrades, or downgrades; handling cancellations
• Invoice Generation: Creating and sending payment receipts and invoices
• Refund Processing: Evaluating and processing refund requests in accordance with policies
• Fraud Prevention: Detecting and preventing fraudulent transactions, chargebacks, or payment abuse

5.1.3 Communication and Customer Support

• Service Communications: Sending transactional emails related to your account, subscriptions, payments, and service usage
• Customer Support: Responding to your support requests, questions, and complaints; troubleshooting technical issues; providing assistance with features
• Important Notices: Communicating service changes, policy updates, security alerts, and other critical information
• Feedback Collection: Requesting and collecting your feedback to improve the Service

5.1.4 Service Improvement and Development

• Analytics and Performance Monitoring: Analyzing usage patterns to understand how users interact with the Service; identifying popular features and areas for improvement
• Product Development: Developing new features, functionalities, and services based on user needs and behavior
• Quality Assurance: Testing new features; identifying and fixing bugs; improving AI model accuracy; enhancing user experience
• A/B Testing: Conducting experiments to test different features, designs, or workflows to optimize user experience
• Research and Innovation: Conducting research on subtitle generation, AI processing, and related technologies

5.2 Secondary Purposes

Your information is also used for these additional purposes:

5.2.1 Marketing and Promotional Activities

• Marketing Communications: With your consent, sending promotional emails about new features, special offers, updates, and news (you may opt out at any time)
• In-App Promotions: Displaying information about subscription upgrades, new features, or promotional offers within the App
• Personalized Recommendations: Suggesting features, subscription tiers, or upgrades based on your usage patterns
• Referral Program Management: Managing the referral program; tracking referrals and rewards; crediting referral minutes

5.2.2 Security and Fraud Prevention

• Account Security: Detecting and preventing unauthorized account access; identifying suspicious activity; preventing account takeovers
• System Security: Protecting systems and infrastructure from cyber attacks, malware, and security threats
• Fraud Detection: Identifying fraudulent activities such as payment fraud, referral abuse, or violation of terms
• Compliance Monitoring: Ensuring users comply with Terms and Conditions and Acceptable Use Policy
• Abuse Prevention: Detecting and preventing spam, bot activity, or other abusive behavior

5.2.3 Legal Compliance and Protection

• Legal Obligations: Complying with applicable laws, regulations, court orders, subpoenas, or legal processes
• Rights Protection: Protecting intellectual property rights, legal rights, and interests
• Dispute Resolution: Responding to legal claims, disputes, or investigations; enforcing Terms and Conditions
• Record Keeping: Maintaining business records as required by law or legitimate business purposes
• Tax and Financial Reporting: Fulfilling tax obligations and financial reporting requirements

5.2.4 Business Operations and Analytics

• Business Intelligence: Analyzing aggregate trends and metrics to understand market conditions and competitive landscape
• Financial Planning: Forecasting revenue, subscription retention, and growth metrics
• Strategic Planning: Making informed business decisions about product direction and resource allocation
• Reporting: Providing aggregated and anonymized data for business purposes
• Benchmarking: Comparing performance metrics against industry standards

5.2.5 Advertising (Free Tier Users Only)

• Ad Delivery: Displaying third-party advertisements to Free tier users within the App
• Ad Personalization: Working with advertising partners to deliver relevant advertisements based on your interests and usage patterns (subject to applicable privacy laws and your consent where required)
• Ad Performance Measurement: Measuring the effectiveness of advertisements displayed in the App

5.3 AI and Machine Learning Purposes

• AI Model Training: Using anonymized and aggregated subtitle data to improve AI models' accuracy and performance (identifiable personal information is not used for training without explicit consent)
• Algorithm Optimization: Refining OCR accuracy, grammar correction algorithms, and translation quality
• Predictive Features: Developing features that anticipate user needs or automate workflows

5.4 Aggregated and De-identified Data

Your personal information may be aggregated and de-identified so that it no longer identifies you individually. Such aggregated or de-identified data may be used for any purpose, including:

• Industry research and reports
• Public statistics about subtitle creation and video content
• Marketing materials and case studies
• Sharing with partners or the public

Once data is properly anonymized, it is no longer considered personal information and is not subject to this Privacy Policy.

5.5 Purposes Requiring Consent

For certain purposes, explicit consent will be sought before processing your information:

• Sending marketing communications (where required by law)
• Collecting precise geolocation data (if this feature is introduced)
• Using sensitive personal information
• Sharing information with third parties for their own marketing purposes
• Significantly different uses not disclosed in this Policy

You may withdraw your consent at any time by contacting me or adjusting your settings within the App.

5.6 Purposes Your Information Is Not Used For

To be transparent, your information is explicitly not:

• Sold to third parties for monetary compensation
• Used for commercial purposes unrelated to providing the Service (your subtitle content)
• Shared with third parties (your video files are not stored)
• Used to discriminate against you based on protected characteristics
• Used to make solely automated decisions that significantly affect you without human review (where prohibited by law)

6. Legal Basis for Processing (GDPR/Applicable Laws)

For users in the European Economic Area (EEA), United Kingdom, Switzerland, and other jurisdictions with similar data protection laws, your personal information is processed based on the following legal grounds:

6.1 Contractual Necessity

Your information is processed to fulfill contractual obligations to you under the Terms and Conditions, including:

• Providing access to the Service and its features
• Processing payments and managing subscriptions
• Delivering customer support
• Maintaining your account

If you do not provide the necessary information, the Service may be unable to be provided to you.

6.2 Legitimate Interests

Your information is processed based on legitimate business interests, including:

• Improving and optimizing the Service
• Ensuring security and preventing fraud
• Conducting analytics and research
• Marketing products and services
• Operating the business efficiently

Legitimate interests are balanced against your rights and freedoms, and your information is not processed where your interests override these legitimate interests.

6.3 Consent

Where required by law or where another legal basis is not relied upon, your information is processed based on your explicit consent, including:

• Sending marketing communications
• Using cookies and tracking technologies (where consent is required)
• Collecting certain types of sensitive or optional information

You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6.4 Legal Obligations

Your information is processed to comply with legal obligations, including:

• Responding to law enforcement requests or court orders
• Fulfilling tax and financial reporting requirements
• Complying with data protection laws and regulations
• Maintaining records as required by law

6.5 Vital Interests

In rare circumstances, your information may be processed to protect your vital interests or those of another person, such as in emergency situations where processing is necessary to prevent serious harm.

6.6 Public Interest

Information may be processed where necessary for tasks carried out in the public interest, though this legal basis is rarely applicable to the Service.

7. Data Storage, Retention, and Deletion

7.1 Data Storage Locations

Your personal information and data may be stored in the following locations:

7.1.1 Cloud Infrastructure

• Firebase (Google Cloud Platform): User account data, authentication information, analytics data, and cloud-stored subtitle projects are stored on Google's Firebase infrastructure, which may involve data centers in multiple countries
• Payment Processor Servers: Payment and billing information is stored by Paddle on their secure servers
• AI Processing Servers: When using AI features, your subtitle content is temporarily processed on servers operated by Google (Gemini AI)

7.1.2 Local Device Storage

• Free Tier Users: Subtitle projects and generated files are stored locally on your device and are not uploaded to cloud servers
• All Users: App settings, cached data, and temporary files are stored on your device

7.1.3 Backup Systems

Encrypted backups of critical data are maintained on secure backup infrastructure to prevent data loss and ensure business continuity.

7.2 Data Retention Periods

Your personal information is retained for different periods depending on the type of data and the purpose for which it was collected:

7.2.1 Account Information

• Active Accounts: Retained for the duration of your account's active status
• Closed Accounts: Basic account information (email, username, transaction history) is retained for 3 years after account closure for legal compliance, fraud prevention, and dispute resolution purposes
• Permanently Deleted: After the retention period, account information is permanently deleted unless longer retention is required by law

7.2.2 Subtitle Content and Projects

• Free Tier Users: Subtitle data stored locally on your device remains until you delete the app or clear app data; this data is not retained on servers beyond temporary processing caches (cleared within 24-48 hours)
• Pro Lite Users: Cloud-stored subtitle projects (up to 3 projects) are retained indefinitely while your subscription is active; upon subscription cancellation or downgrade, cloud projects are retained for 30 days before deletion
• Pro Users: Cloud-stored subtitle projects are retained indefinitely while your subscription is active; upon subscription cancellation, projects are retained for 90 days before deletion
• User-Requested Deletion: You may request deletion of specific projects or all subtitle content at any time through the App or by contacting support

7.2.3 Payment and Transaction Data

• Transaction Records: Retained for 7 years to comply with tax laws, financial regulations, and accounting requirements
• Payment Method Information: Retained until you remove it from your account or until it expires; historical transaction information remains for the 7-year period
• Refund and Dispute Records: Retained for 7 years or until disputes are fully resolved, whichever is longer

7.2.4 Usage Data and Analytics

• Detailed Usage Logs: Retained for 90 days for troubleshooting and performance optimization
• Aggregated Analytics: Aggregated and anonymized usage statistics may be retained indefinitely as they no longer constitute personal information
• Error Logs and Crash Reports: Retained for 180 days for debugging and service improvement

7.2.5 Communications and Support Records

• Support Tickets: Retained for 3 years after ticket closure for quality assurance and legal compliance
• Email Communications: Retained according to email retention policies, typically 3 years
• Chat Transcripts: Retained for 2 years

7.2.6 Marketing Communications

• Subscriber Lists: Retained until you unsubscribe or your account is deleted
• Engagement Data: Retained for 2 years to analyze marketing effectiveness

7.2.7 Legal and Compliance Records

Information required for ongoing legal proceedings, disputes, or investigations is retained until the matter is fully resolved and any applicable appeal periods have expired.

7.3 Data Deletion and Anonymization

7.3.1 Automatic Deletion

• Data is automatically deleted at the end of applicable retention periods through automated processes
• Temporary processing caches and session data are automatically cleared regularly

7.3.2 User-Initiated Deletion

You may request deletion of your data through:

• Account Deletion: Navigate to account settings and select "Delete Account" to initiate full account deletion
• Project Deletion: Delete individual subtitle projects within the App
• Selective Deletion Requests: Contact customer support to request deletion of specific data categories

7.3.3 Deletion Process and Timeline

• Upon receiving a deletion request, it will be processed within 30 days
• Some data may be retained in backup systems for up to 90 days before being permanently purged
• Certain information may be retained longer where required by law or legitimate business interests (e.g., transaction records for tax purposes)

7.3.4 Data Anonymization

Where permitted by law and practical, your personal information may be anonymized rather than deleted, allowing insights to be retained for analytics and research while protecting your privacy.

7.4 Data Loss Disclaimer

While robust backup and data protection measures are implemented, absolute protection against data loss cannot be guaranteed due to:

• Hardware failures or natural disasters
• Cyber attacks or security breaches
• Software bugs or technical errors
• User error (e.g., accidental deletion)
• Force majeure events

You are strongly recommended to maintain your own backups of important subtitle files and projects. For Free tier users who store data locally, you are solely responsible for backing up your data. There is no liability for any data loss, and recovery may not always be possible.

8. Data Sharing and Third-Party Services

8.1 Overview of Data Sharing

Your personal information is shared with third parties only as necessary to provide the Service, comply with legal obligations, or as described in this Privacy Policy. Your personal information is not sold for monetary compensation.

8.2 Third-Party Service Providers

Information is shared with the following categories of service providers who process data on behalf of the Service:

8.2.1 Payment Processing

• Paddle (Paddle.com Market Limited)
• Information Shared: Name, email address, billing address, payment method details, transaction amounts, subscription information
• Purpose: Processing payments, managing subscriptions, handling refunds, preventing payment fraud
• Data Processing Agreement: Paddle acts as the payment processor and merchant of record
• Privacy Policy: Available at paddle.com/legal/privacy
• Location: Paddle may process payments globally depending on your location

8.2.2 Cloud Infrastructure and Storage

• Firebase / Google Cloud Platform
• Information Shared: Account information, authentication data, usage analytics, cloud-stored subtitle projects (for Pro users)
• Purpose: Hosting application infrastructure, providing authentication services, storing user data, collecting analytics
• Data Processing Agreement: A data processing agreement exists with Google
• Privacy Policy: Available at firebase.google.com/support/privacy
• Location: Data may be stored in Google data centers globally

8.2.3 AI and Machine Learning Services

• Gemini AI (Google)
• Information Shared: Subtitle text content for processing, cleaning, translation, and enhancement
• Purpose: Providing AI-powered subtitle cleaning, grammar correction, formatting, and translation features
• Data Retention: Gemini AI may temporarily retain data for processing purposes according to Google's policies
• Privacy Policy: Available at ai.google/responsibility/privacy
• Important Note: When you use AI features, your subtitle content is sent to Google's servers for processing. Reviewing Google's AI principles and privacy policies is recommended.

8.2.4 Analytics and Performance Monitoring

• Firebase Analytics
• Information Shared: Usage patterns, feature interactions, device information, app performance data, error logs
• Purpose: Understanding user behavior, improving the Service, identifying technical issues, optimizing user experience
• Privacy Policy: Available at firebase.google.com/support/privacy

8.2.5 Email and Communication Services

As a solo developer, I use standard Gmail for communications. No third-party email service provider is used for marketing.

8.2.7 Advertising Networks (Free Tier Users Only)

• Google AdMob
• Information Shared: Device identifiers, usage data, ad interaction data, general demographic information
• Purpose: Displaying targeted advertisements to Free tier users, measuring ad performance
• User Control: You can limit ad tracking through your device settings or upgrade to a paid plan for an ad-free experience
• Privacy Policy: policies.google.com/technologies/ads

8.3 Business Transfers and Corporate Transactions

In the event of a sale of the business, merger, reorganization, or similar transaction, your personal information may be transferred to the acquiring or successor entity as part of the transaction.

In such circumstances:

• You will be notified via email and/or prominent notice within the App before your information is transferred
• The successor entity will be bound by this Privacy Policy or will provide you with notice of any changes to privacy practices
• You will have the opportunity to delete your account before the transfer if you do not wish your information to be transferred
• Your information will continue to be protected in accordance with this Privacy Policy or any subsequently updated policy

8.4 Legal and Regulatory Authorities

Your personal information may be disclosed to law enforcement, government authorities, regulatory bodies, courts, or other third parties when required or permitted by law:

8.4.1 Legal Compliance

• In response to valid legal processes such as subpoenas, court orders, search warrants, or other lawful requests from public authorities
• To comply with applicable laws, regulations, or legal obligations
• To respond to requests from government agencies or regulatory authorities

8.4.2 Rights Protection

• To enforce Terms and Conditions and other agreements
• To protect intellectual property rights, property, or safety
• To protect the rights, property, or safety of users or the public
• To prevent or investigate potential fraud, security breaches, or illegal activities

8.4.3 National Security and Law Enforcement

• To comply with national security requirements or law enforcement requests where legally required
• When believed in good faith that disclosure is necessary to prevent imminent harm

Reasonable efforts will be made to notify you of such requests unless prohibited by law or court order, or when providing notice could create a risk of harm.

8.5 Professional Advisors

Your information may be shared with professional advisors such as:

• Lawyers: For legal advice, dispute resolution, and contract review
• Accountants and Auditors: For financial reporting, tax compliance, and auditing purposes
• Business Consultants: For strategic planning and business operations (under strict confidentiality obligations)
• Insurance Providers: In connection with insurance claims or coverage matters

These advisors are bound by professional obligations of confidentiality and data protection.

8.6 Aggregated and De-identified Data

Aggregated, anonymized, or de-identified data that does not identify you personally may be shared with:

• Business partners and collaborators
• Research institutions
• Industry analysts and market research firms
• The public through reports, presentations, or marketing materials
• Investors and stakeholders

Such data is not considered personal information and is not subject to the restrictions in this Privacy Policy.

8.7 With Your Consent

Your information may be shared with third parties when you explicitly consent to such sharing, including:

• When you authorize integration with third-party apps or services
• When you choose to share content on social media platforms
• When you participate in co-branded promotions or partnerships
• When you grant explicit permission for specific data sharing

You can withdraw your consent at any time by contacting me or adjusting your settings.

8.8 Public Information

Information you choose to make public, such as:

• Public profile information (if you opt to make your profile public)
• Content you share on social media platforms
• Reviews or testimonials you provide (with your permission)
• Community forum posts (if such features are introduced)

will be accessible to others and is not considered confidential.

8.9 Third-Party Data Processing Safeguards

The following measures are taken to ensure third parties protect your information:

• Due Diligence: Third-party service providers' security practices and privacy policies are carefully evaluated before engaging them
• Contractual Obligations: Written agreements are entered into with service providers that require them to protect your information and use it only for specified purposes
• Data Processing Agreements: Where required by law (such as GDPR), data processing agreements are executed that include standard contractual clauses
• Regular Audits: Third-party compliance with contractual obligations and security standards is periodically reviewed
• Minimal Data Sharing: Only the minimum information necessary for the third party to perform its services is shared
• Confidentiality Requirements: Service providers are bound by confidentiality obligations

8.10 No Sale of Personal Information

Important: Your personal information is not sold to third parties for monetary or other valuable consideration. Under the California Consumer Privacy Act (CCPA) and similar laws, "sale" has a broad definition that may include sharing for advertising purposes. While information is shared with advertising partners for Free tier users as described, California residents have the right to opt out of such sharing. See Section 16 for details on California privacy rights.

8.11 International Data Sharing

Because service providers that operate globally are used, your information may be shared with entities in countries other than your country of residence. See Section 9 for information about international data transfers.

8.12 Changes to Third-Party Services

Third-party service providers may be changed, added, or removed at any time as business needs evolve. Material changes to data sharing practices will be reflected in updates to this Privacy Policy.

9. International Data Transfers

9.1 Cross-Border Data Transfers

Sublystic operates globally and uses service providers located in various countries. As a result, your personal information may be transferred to, stored in, and processed in countries other than your country of residence, including but not limited to:

• India: Where the service is operated from
• United States: Where many service providers (Google, Firebase, Gemini AI) operate data centers
• European Union: Where some data processing and storage may occur
• Other Countries: Where cloud infrastructure and service providers maintain facilities

These countries may have data protection laws that differ from those in your jurisdiction.

9.2 Legal Basis for International Transfers

When personal information is transferred from the European Economic Area (EEA), United Kingdom, or Switzerland to countries that do not provide an adequate level of data protection as determined by the European Commission or other regulatory authorities, the following legal mechanisms are relied upon:

9.2.1 Standard Contractual Clauses (SCCs)

• European Commission-approved Standard Contractual Clauses are used with service providers to ensure appropriate safeguards for data transferred outside the EEA
• These contractual clauses obligate recipients to protect your personal information in accordance with European data protection standards

9.2.2 Adequacy Decisions

Where available, adequacy decisions made by the European Commission recognizing certain countries as providing adequate data protection are relied upon

9.2.3 Certification Frameworks

Some service providers participate in certification frameworks such as the EU-U.S. Data Privacy Framework (successor to Privacy Shield) or other recognized mechanisms

9.2.4 Consent

In certain circumstances, explicit consent may be obtained for specific international transfers

9.3 Safeguards for International Transfers

To protect your information during international transfers, the following are implemented:

• Encryption: Data is encrypted in transit using industry-standard protocols (TLS/SSL)
• Access Controls: Strict access controls limit who can access transferred data
• Data Processing Agreements: Contracts with international service providers include data protection obligations
• Security Assessments: The security practices of international service providers are assessed
• Monitoring and Compliance: Compliance with transfer mechanisms and contractual obligations is monitored

9.4 Data Localization Options

While data is generally processed across multiple jurisdictions for efficiency and reliability:

• Free Tier Users: Your subtitle data is stored locally on your device and is not transferred internationally unless you use AI features
• Paid Users: Cloud-stored projects may be stored in data centers closest to your location where available, though data remaining in a specific country cannot be guaranteed

9.5 Your Rights Regarding International Transfers

If you are located in the EEA, UK, or Switzerland, you have the right to:

• Request information about the safeguards in place for international transfers
• Object to international transfers in certain circumstances
• Request a copy of the Standard Contractual Clauses or other transfer mechanisms used

To exercise these rights, please contact me using the information in Section 20.

9.6 Changes to International Data Flows

As the business and infrastructure evolve, the countries where your data is processed may change. Appropriate safeguards will remain in place for any new international transfers and this Privacy Policy will be updated accordingly.

10. Your Privacy Rights and Choices

10.1 General Privacy Rights

Depending on your jurisdiction, you may have various rights regarding your personal information. This section outlines rights that may be available to you:

10.1.1 Right to Access

You have the right to request access to the personal information held about you, including:

• Confirmation of whether your personal information is processed
• Categories of personal information collected
• Purposes of processing
• Categories of third parties with whom information is shared
• Retention periods or criteria for determining retention periods
• A copy of your personal information in a commonly used format

How to Exercise: Log into your account to view and download your account information and subtitle projects, or contact me at sublystic.helpdesk@gmail.com to request a comprehensive data report.

10.1.2 Right to Rectification/Correction

You have the right to request correction of inaccurate or incomplete personal information.

How to Exercise: Update your account information directly in the App settings, or contact me to request corrections to information you cannot change yourself.

10.1.3 Right to Deletion/Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal information in certain circumstances, including:

• The information is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• Your information has been unlawfully processed
• Deletion is required to comply with a legal obligation

Exceptions: Deletion requests may be refused when retention is necessary for:

• Compliance with legal obligations
• Establishment, exercise, or defense of legal claims
• Fulfilling contractual obligations
• Freedom of expression and information rights

How to Exercise: Navigate to account settings and select "Delete Account," or contact me at sublystic.helpdesk@gmail.com with your deletion request.

Important Note: Deletion is permanent and irreversible. All subtitle projects, account information, and purchase history will be permanently deleted (except as required by law).

10.1.4 Right to Restriction of Processing

You have the right to request restriction of processing of your personal information in certain circumstances:

• You contest the accuracy of the information (restriction during verification)
• Processing is unlawful but you prefer restriction over deletion
• The information is no longer needed but you need it for legal claims
• You have objected to processing (pending verification of legitimate grounds)

How to Exercise: Contact me at sublystic.helpdesk@gmail.com with your restriction request and explanation.

10.1.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller where:

• Processing is based on consent or contract
• Processing is carried out by automated means

How to Exercise: Contact me at sublystic.helpdesk@gmail.com to request data portability. Your data will be provided in JSON, CSV, or other appropriate formats.

10.1.6 Right to Object

You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes.

• Direct Marketing: You can object at any time to processing for direct marketing purposes by clicking "unsubscribe" in marketing emails, adjusting communication preferences in account settings, or contacting me at sublystic.helpdesk@gmail.com
• Legitimate Interests: You can object to processing based on legitimate interests by explaining your particular situation. Processing will cease unless compelling legitimate grounds that override your interests can be demonstrated.

How to Exercise: Contact me at sublystic.helpdesk@gmail.com with your objection and the specific processing you wish to object to.

10.1.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.

How to Exercise: Adjust consent preferences in account settings, unsubscribe from marketing communications, disable cookies through browser settings, or contact me at sublystic.helpdesk@gmail.com.

10.1.8 Right Not to be Subject to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.

Current Practice: Solely automated decisions that significantly affect you are not currently made. If this changes, this Policy will be updated and appropriate safeguards will be provided.

10.1.9 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority (data protection authority) in your jurisdiction if you believe your privacy rights have been violated.

Relevant Authorities:

• European Economic Area: Your local data protection authority (find contact information at edpb.europa.eu)
• United Kingdom: Information Commissioner's Office (ICO) at ico.org.uk
• India: Contact your state or national data protection authority
• Other Jurisdictions: Contact the data protection or privacy authority in your jurisdiction

You are encouraged to contact me first so I can attempt to resolve your concerns directly.

10.2 How to Exercise Your Rights

To exercise any of the rights described above:

• Email: Send a detailed request to sublystic.helpdesk@gmail.com
• Include Information: Your full name and email address associated with your account, specific right(s) you wish to exercise, detailed description of your request, and any supporting documentation.
• Verify Your Identity: Additional information may be requested to verify your identity before processing your request.
• Response Timeline: Responses will be provided within 30 days for most requests (may be extended by 60 days for complex requests), 45 days for California residents under CCPA, or within timeframes required by applicable law in your jurisdiction.

10.3 No Discrimination

You will not be discriminated against for exercising any of your privacy rights. However, different pricing tiers with different features may be offered, and certain features naturally require account information to function.

10.4 Authorized Agents

In certain jurisdictions, you may designate an authorized agent to make privacy requests on your behalf. The agent must provide proof of authorization.

10.5 Communication Preferences and Opt-Outs

10.5.1 Marketing Communications

You can opt-out of email marketing by clicking "unsubscribe" in any marketing email or adjusting preferences in account settings. You will continue to receive transactional emails.

10.5.2 Push Notifications

Manage push notification preferences in your device settings or within the App.

10.5.3 Advertising and Tracking

Use your device's privacy settings to limit ad tracking. Upgrading to a paid plan removes all advertisements.

10.6 Account Closure

To close your account, navigate to Settings > Account > Delete Account or contact support. This will lead to the deletion of your data after applicable retention periods.

11. Children's Privacy and Age Restrictions

11.1 Minimum Age Requirements

Sublystic is not intended for use by children under the age of 13 (or the applicable age of digital consent in your jurisdiction). By using the Service, you represent that you meet this age requirement.

11.2 Parental Consent for Minors

If you are between 13 and 18, you may only use the Service with the supervision and consent of a parent or guardian who agrees to these terms on your behalf.

11.3 No Intentional Collection from Children

I do not knowingly collect personal information from children without verifiable parental consent. If I learn that I have collected such information, I will delete it promptly.

11.4 Parental Rights and Controls

Parents can contact me at sublystic.helpdesk@gmail.com to review, request deletion of, or refuse further collection of their child's information.

12. Cookies, Tracking Technologies, and Analytics

12.1 Overview of Technologies Used

I use cookies, mobile identifiers, and other tracking technologies for essential functions, analytics, and advertising (on the free tier).

12.2 Third-Party Tracking and Analytics

I use Firebase Analytics to understand app usage and performance. For free-tier users, I partner with Google AdMob to display ads. These partners may collect data according to their own privacy policies.

12.3 Your Choices and Controls

You can manage cookies through your browser settings and limit ad tracking via your mobile device's privacy settings. Upgrading to a paid plan provides an ad-free experience.

13. Data Security and Protection Measures

13.1 Security Commitment

I implement comprehensive technical, organizational, and administrative measures to protect your data, including encryption, access controls, and regular security reviews. However, no system is 100% secure.

13.2 Your Security Responsibilities

You are responsible for using strong passwords, keeping your credentials confidential, and monitoring your account for suspicious activity.

13.3 Security Incident Response

In the event of a data breach, I will investigate, mitigate, and notify affected users and authorities as required by law.

14. Automated Decision-Making and Profiling

I use automated systems for AI features (like subtitle generation), security monitoring, and usage analytics. I do not use solely automated decision-making that has a legal or similarly significant effect on you without human review.

15. Data Breach Notification

In the event of a data breach involving your personal information, I will notify you and the relevant data protection authorities without undue delay, as required by applicable law. The notification will include information about the nature of the breach and steps you can take to protect yourself.

16. California Privacy Rights (CCPA/CPRA)

California residents have specific rights regarding their personal information, including the right to know, delete, correct, and opt-out of the "sharing" of their data for advertising. To exercise these rights, please contact me at sublystic.helpdesk@gmail.com.

17. European Privacy Rights (GDPR)

Users in the EEA, UK, and Switzerland have rights under GDPR, including access, rectification, erasure, and data portability. The data controller is B.Bharath kumar. You can lodge complaints with your local data protection authority.

18. Other Jurisdictional Privacy Rights

I comply with applicable data protection laws in India and other regions. If you reside in a jurisdiction with specific privacy rights, please contact me to exercise them.

19. Changes to This Privacy Policy

I may update this policy from time to time. Material changes will be communicated via email or in-app notification. Continued use of the Service after changes means you accept the new policy.

20. Contact Information

For any privacy-related questions or requests, please contact me:

• Owner: B.Bharath kumar (operating as Sublystic)
• Email: sublystic.helpdesk@gmail.com
• Address: 4/1b, Appavu Nagar, Dharmapuri, 636701, India

I will respond to email inquiries within a maximum of 7 days.

21. Dispute Resolution and Complaints

Please contact me first to resolve any privacy concerns. If you are unsatisfied, you have the right to lodge a complaint with your local data protection authority.

22. Additional Disclosures

This Privacy Policy, along with the Terms and Conditions, constitutes the complete agreement regarding your privacy. By using Sublystic, you acknowledge you have read, understood, and agree to these terms.