Privacy Policy

This policy explains what personal data we collect, why, who we share it with, how long we keep it, and your rights over it. It covers the Website, the Subtitl plugin, the Subtitl Manager app and the private beta. The most important point: the plugin transcribes on your own computer, so your footage and audio are never sent to us unless you choose to attach them to a bug report.

1. Who is responsible for your data

1.1 Subtitl is run by Utkarsh Singh, an individual carrying on business as a sole proprietor from Muzaffarnagar, Uttar Pradesh, India. Under the Digital Personal Data Protection Act, 2023, he is the "Data Fiduciary" for the personal data described here.

1.2 For anything in this policy, contact support@subtitl.ai. Section 13 names our grievance officer.

1.3 This policy does not cover other products we may offer under the Subtitl name, such as a separate mobile or web app. Those have their own privacy notice, shown in the app.

2. The short version

• Your media stays on your computer. The plugin transcribes locally. It does not upload your audio, video, projects, transcripts or captions, and it has no usage tracking.
• The plugin talks to us for a few narrow reasons: to activate and check your licence, to check for updates and download them and language packs, and to send a bug report or feedback when you choose to.
• Your account holds the minimum: your name, email, licence, the Devices it is activated on, and your purchases.
• The Website uses analytics to understand how pages are used (section 6).
• We never sell your data and never use it for advertising.

3. What we collect, and why

3.1 Account data. Your name and email address. If you sign in with Google, Google gives us your name and email (never your Google password). If you use an email and password, our authentication provider stores the password in hashed form, and we cannot read it. Why: to create and secure your account and to deliver your Licence.

3.2 Purchase and billing data. Your plan, number of Devices, the amount and currency charged, the country used to set that currency, the date, the payment gateway's reference, your invoices and, for Monthly plans, the subscription and mandate status. Card, UPI and bank details are entered directly with our payment gateway, and we never see or store them. Why: to sell you a Licence, bill you correctly, issue invoices, handle refunds and disputes, prevent fraud, and keep the records the law requires.

3.3 Licence and Device records. Your licence key and status, and one record per Device activated on your Licence. Each Device record holds:

• an identifier derived from the computer's hardware (not your name or files);
• a device name derived automatically from the computer (for example "MacBook Air · macOS");
• its processor type (for example Apple Silicon);
• when it was activated; and
• when the Software on it last checked in.

Why: to enforce your Device limit, show you which Devices use your Licence, and let you sign one out. You can see all of this on your account page, and signing a Device out deletes its record.

3.4 Bug reports and feedback from the plugin. When you choose to send one, we receive your message, any screenshot you attach, and a short fixed list of technical details: plugin and engine versions, Host Application and version, operating system, processor type and Licence status. If you are not signed in, we also receive the email address you type. We do not receive your licence key, file paths or your projects. A screenshot can show your work, so only attach what you are happy for us to see. Replies to your report are stored with it so you can see them in the plugin. We never use bug reports or screenshots to train AI or machine-learning models. Why: to fix problems and reply to you.

3.5 Beta requests. When you request a beta invite, we collect your email address and, if you give them, your name, the editor you use and what you would use Subtitl for. If we approve you, we create your account and a Beta Licence and email you an invitation. Why: to run the invite-only beta and decide who to invite.

3.6 Onboarding survey. After you sign up we may ask, optionally, about your role, the editors you use, how you heard about us, and your Instagram or YouTube handle. You can skip it. Handles are for our own understanding of who uses Subtitl. We never publish them. Why: to understand our users and improve the product.

3.7 Support emails. If you email us, we keep the conversation. Why: to help you and refer back to it.

3.8 Technical data. Like any online service, our servers and providers receive your IP address and basic request information when you visit the Website, sign in, check a licence or download a file. Some of our own features limit how often requests can be made. For those we store only a scrambled, salted value derived from your IP address, which changes daily and cannot be turned back into the address. Why: to deliver the service, keep it secure, and prevent abuse.

3.9 Records of your agreement to our terms. When you create or sign in to an account, or request a beta invite, we record which versions of our Terms and this policy you accepted, where (for example, the website sign-in or the Subtitl Manager app), when, and your browser or app version. Why: to be able to show what you agreed to if there is ever a question or dispute.

3.10 Website analytics. See section 6.

4. The legal basis

We process your personal data:

• because you give it to us voluntarily for a specific purpose, such as buying a Licence, requesting a beta invite or sending a bug report;
• with your consent where we ask for it; and
• where the law requires it, for example to keep transaction records.

Where we rely on consent, you can withdraw it at any time (section 10). Withdrawing does not affect anything done before.

5. Emails we send

5.1 We send emails you need: purchase receipts and invoices, your beta invitation and Licence details, password and sign-in emails, replies to your messages, and important notices about your Licence, these terms, or this policy.

5.2 If we ever send product news or offers, each such email will have an unsubscribe link. Unsubscribing does not stop the emails in 5.1.

6. Website analytics

6.1 The Website uses Microsoft Clarity, provided by Microsoft Corporation. It records how visitors use the pages, which can include mouse movement, clicks, scrolling, session recordings and heatmaps, along with technical information such as browser and device type, approximate region and referring page. Microsoft handles this data under the Microsoft Privacy Statement.

6.2 The Website also uses Cloudflare Web Analytics, provided by Cloudflare, Inc. It counts page views and reports totals such as pages visited, referring site, country, browser, device type and load speed. It does not record sessions or follow you between visits, and it sets no cookies.

6.3 Clarity is not loaded at all for visitors in the European Economic Area, the United Kingdom or Switzerland, or when your browser sends a Do Not Track or Global Privacy Control signal.

6.4 We use analytics only to understand and improve the Website. Analytics runs on the Website only, never in the plugin or the Subtitl Manager app. We run no advertising networks, retargeting pixels or ad cookies. You can block analytics with your browser's privacy settings or a content-blocking extension. The Website still works.

7. Who we share it with

7.1 We share personal data only with service providers that process it for us, under their own security and privacy commitments, and only as much as each one needs:

• Supabase: database and sign-in (accounts, licences, Devices, purchases, bug reports, beta requests, survey answers). Hosted in Singapore.
• Razorpay: payment processing. It receives what it needs to take your payment, and we receive back the confirmation and reference.
• Cloudflare: Website hosting, our API gateway, downloads of the Software and language packs, and Web Analytics.
• Resend: delivery of the emails in section 5.
• Google: only if you choose "Sign in with Google".
• Microsoft: Clarity analytics on the Website.

7.2 We may disclose personal data where the law requires it, to comply with a valid order from a court or authority, or to establish, exercise or defend legal claims.

7.3 If the Subtitl business is transferred to a new owner, your data may transfer with it. The new owner must protect it under this policy.

7.4 We do not sell, rent or trade your personal data.

8. Transfers outside India

Some of our providers store or process data outside India, for example in Singapore, the United States or the European Union. We transfer data only as the Digital Personal Data Protection Act, 2023 allows, and we rely on our providers' contractual and security safeguards.

9. How long we keep it

• Account, licence and Device records: for as long as your account exists, because a Lifetime Licence must stay verifiable for as long as you hold it.
• Purchase and invoice records: for as long as tax and accounting laws require (generally up to 8 years), even after your account is deleted. We keep only what those laws need.
• Bug reports and feedback: while your account exists, or until you ask us to delete them.
• Beta requests: for up to 12 months after we decide on them (approved requests stay linked to your account while it exists), or until you ask us to delete them.
• Support emails: for up to 3 years after the conversation ends.
• Records of your agreement to our terms: while your account exists and for up to 3 years after it is deleted, because they may be needed to resolve a dispute.
• Rate-limit values: a few hours.
• Analytics: under Microsoft's and Cloudflare's own retention periods.

When you ask us to delete your account, we delete your account data within 30 days, apart from the records the law requires us to keep. Copies in routine backups are overwritten in the normal backup cycle.

10. Your rights

10.1 Under the Digital Personal Data Protection Act, 2023 you have the right to:

• get a summary of the personal data we hold about you and how we use it;
• have it corrected, completed or updated (you can also edit your name on your account page);
• have it erased, subject to section 9;
• withdraw any consent you have given;
• nominate someone to exercise these rights for you if you die or become unable to; and
• have your grievances addressed (section 13).

10.2 To use any of these rights, email support@subtitl.ai from the address on your account. We may need to confirm it is you. We will respond within 2 business days and complete the request as soon as we reasonably can, normally within 30 days.

10.3 Deleting your account ends your Licence permanently, because the Licence is tied to the account (see the Terms, section 3.4). Please be sure before you ask.

11. Children

Subtitl is for people aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us data, tell us and we will delete it.

12. Security

12.1 Data travels between your browser, the Software and our servers over encrypted connections (HTTPS). Passwords are stored hashed. Access to our systems is restricted to the people who need it. Licence sessions are cryptographically signed so they cannot be forged.

12.2 No system is perfectly secure. If a breach affects your personal data, we will act promptly, and we will notify you and the Data Protection Board of India as the law requires.

12.3 Because your media never leaves your computer, a breach of our systems cannot expose your footage, unless you sent it to us in a bug report screenshot.

13. Complaints and grievance officer

13.1 If you have a concern about how we handle your data, contact our grievance officer:

Utkarsh Singh, Proprietor and Grievance Officer
Subtitl, Muzaffarnagar, Uttar Pradesh, India
Email: support@subtitl.ai (please put "Privacy" in the subject line)

13.2 We will acknowledge your complaint within 48 hours and aim to resolve it within one month. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

14. Cookies and browser storage

14.1 We use your browser's storage to keep you signed in and to remember small choices, such as whether you have seen the onboarding survey. These are needed for the Website to work.

14.2 Microsoft Clarity sets its own cookies or storage to recognise a returning session (section 6). Cloudflare Web Analytics sets none. We use no advertising cookies.

15. Changes to this policy

We may update this policy. The date at the top shows when it last changed, and earlier versions stay published: Privacy Policy of 1 August 2026. If a change materially affects how we use your personal data, we will tell you by email or on the Website before it takes effect, and where the law requires it we will ask for your consent again.

16. Contact

Utkarsh Singh (sole proprietor), trading as Subtitl
Muzaffarnagar, Uttar Pradesh, India
Email: support@subtitl.ai. We aim to respond within 2 business days.

Full contact details are on our Contact page.