Privacy Policy

Last updated: August 21, 2026

1. Information We Collect

Data You Provide Directly

• Account Information: Telegram identifiers for the bot, or Google account ID, name, and email for the Android/web app
• Payment Information: Billing details when you purchase credits (processed securely by our payment providers)
• Content Data: Videos, audio files, and text you submit for translation
• Communications: Messages you send through our support channels

Data Collected Automatically

• Usage Analytics: How you interact with our service (features used, processing time, error logs)
• Technical Data: Device/app version, installation identifier, IP address, locale, time zone, consent state, and service performance metrics
• Telegram Integration: Message metadata required for bot functionality (message IDs, chat IDs)

Data from Third Parties

• Payment Processors: Transaction confirmations from Google Play, Telegram Payments, and other checkout providers shown at purchase time
• Advertising: AdMob may process consent, advertising identifiers, coarse location/device data, and ad interaction data as described by Google and your consent choices
• AI Service Providers: Transcription runs locally; translated text and processing logs may be handled by OpenRouter translation models
• Video Platforms: Metadata from YouTube, TikTok when processing shared URLs

2. How We Use Your Information

Core Service Operations

• Video Translation: Processing your content through our AI pipeline
• Account Management: Managing your credits, subscription, and service access
• Quality Assurance: Improving transcription and translation accuracy
• Customer Support: Responding to inquiries and resolving technical issues

Business Operations

• Analytics & Insights: Understanding service usage to improve features
• Security & Fraud Prevention: Protecting against abuse and unauthorized access
• Legal Compliance: Meeting regulatory requirements and responding to legal requests
• Marketing Communications: Service updates and feature announcements (with your consent)

Data Processing Legal Basis (GDPR)

• Contract Performance: Processing necessary to provide our translation service
• Legitimate Interest: Analytics, security, and service improvements
• Legal Obligation: Compliance with tax, financial, and data protection laws
• Consent: Marketing communications and optional analytics

3. Data Sharing and Disclosure

Service Providers (Data Processors)

• Local Faster-Whisper: Speech-to-text is processed on our own workers
• OpenRouter: AI translation model access
• BunnyCDN: Temporary file storage and content delivery
• Supabase: Database hosting and management
• Google: Google Sign-In, Google Play Billing, consent management, and AdMob rewarded ads

Third-Party Integrations

• Payment Processors: Stripe, PayPal, Telegram Payments for transaction processing
• Analytics Providers: Aggregated usage statistics (no personal identification)
• Email Services: Transactional emails and support communications

Legal Disclosures

We may disclose your information when required by law, court order, or government request, or to: - Protect our rights, property, or safety - Prevent fraud or security threats - Comply with legal obligations - Enforce our Terms of Service

We never sell your personal data to third parties.

4. Data Security and Retention

Security Measures

• Encryption: All data transmitted using TLS/SSL encryption
• Access Controls: Role-based access with multi-factor authentication
• Regular Audits: Security assessments and penetration testing
• Infrastructure: SOC 2 compliant hosting providers
• Monitoring: 24/7 security monitoring and incident response

Data Retention Periods

• Account Data: Retained while your account is active, plus 30 days after deletion
• Uploaded Source Media: Scheduled for automatic deletion within 24 hours by default; temporary copies held by processors or backups may take longer to cycle out
• Translation Outputs: Retained for the period shown in the product, then deleted or anonymized; users may request earlier deletion
• Transaction Records: Retained for 7 years for tax and legal compliance
• Usage Logs: Aggregated analytics retained for 2 years, detailed logs for 90 days
• Support Communications: Retained for 3 years for quality assurance

International Transfers

Your data may be processed in countries outside your residence, including the United States and European Union. We ensure adequate protection through: - Standard Contractual Clauses for EU data transfers - Privacy Shield framework compliance where applicable - Adequacy Decisions by relevant data protection authorities

5. Your Privacy Rights

Universal Rights

• Access: Request a copy of your personal data
• Correction: Update inaccurate or incomplete information
• Deletion: Request removal of your data (subject to legal obligations)
• Portability: Receive your data in a portable format
• Withdrawal: Opt out of marketing communications at any time

GDPR Rights (EU Residents)

• Right to Object: Object to processing based on legitimate interest
• Right to Restrict: Limit how we process your data in certain circumstances
• Right to Lodge Complaints: File complaints with your local data protection authority
• Automated Decision Making: We do not make automated decisions that significantly affect you

CCPA Rights (California Residents)

• Right to Know: Detailed information about data collection and sharing
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the sale of personal information (we don't sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices

Exercising Your Rights

To exercise any of these rights, contact us at: - Email: [email protected] - Account deletion: subly.xyz/account-deletion/ or Me → Privacy and data in the Android app - Telegram Support: @sublyadmin with your request - Response Time: We'll respond within 30 days (or as required by applicable law)

6. Cookies and Tracking

Essential Cookies

• Session Management: Maintaining your login state and preferences
• Security: CSRF protection and fraud prevention
• Functionality: Language preferences and accessibility settings

Analytics Cookies (Optional)

• Usage Analytics: Understanding how users interact with our service
• Performance Monitoring: Identifying and fixing technical issues
• Feature Optimization: A/B testing for interface improvements

Third-Party Services

Our website may include embedded content from: - Social Media: Twitter, LinkedIn sharing buttons - Payment Providers: Stripe, PayPal checkout forms - Support Tools: Help desk and chat widgets

You can control cookie preferences through your browser settings. Disabling essential cookies may affect service functionality.

7. Children's Privacy

Subly is not intended for users under 13 years old. We do not knowingly collect personal information from children under 13. If we discover that we have collected information from a child under 13, we will: - Delete the information immediately - Terminate the account - Notify the parent or guardian if contact information is available

If you believe we have collected information from a child under 13, please contact us immediately at [email protected].

8. Privacy Policy Updates

We may update this privacy policy to reflect: - Changes in our data practices - New features or services - Legal or regulatory requirements - Industry best practices

Notification Process

• Material Changes: 30-day advance notice via email and in-app notification
• Minor Updates: Posted on our website with updated "Last Modified" date
• Continued Use: Constitutes acceptance of updated terms

Version History

We maintain a record of significant privacy policy changes available upon request.

9. Contact Information

Privacy Officer

Email: [email protected]
Response Time: Within 5 business days for privacy inquiries

Data Protection Officer (EU)

For GDPR-related inquiries:
Email: [email protected]
Address: Available upon request for formal complaints

General Support

Telegram Support: @sublyadmin
Email: [email protected]
Bot Service: @subly1bot

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This privacy policy demonstrates our commitment to transparency and data protection. Your trust is essential to our mission of breaking down language barriers through AI-powered video translation.