1. Introduction

Datax Limited ("we," "us," or "our") is committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of your information when you use our website, our online subtitling and transcription application, Subtitlewhisper, and any related services (collectively, the "Service").

This policy applies to all users of our Service, including those on free or paid subscription plans. By accessing or using our Service, you signify that you have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

2. The Data We Collect

Personal data means any information that can be used to identify an individual. We collect several types of information for various purposes to provide and improve our Service to you.

We have grouped the data we collect as follows:

• Identity and Contact Data: This includes your email address and name when you create an account or log in. You may choose to sign up or log in using a third-party service (e.g., Google, Microsoft), in which case we will collect the necessary authentication information from that service, specifically your name and email address, to create and manage your account.
• User-Generated Content: This is any data you actively provide when using our Service. This includes video and audio files you upload, content from third-party links (e.g., YouTube), and recordings of meetings made by our service bots that you authorize. This also includes the transcripts, subtitles, translations, summaries, and any other output generated by the Service from your content.
• Calendar and Meeting Data: If you connect your calendar (e.g., Google Calendar, Microsoft Outlook) to our Service, we will access calendar event information to schedule our meeting recording bot. This may include meeting titles, start/end times, and participant lists.
• Transaction Data: This includes details about the subscription plans you have purchased from us and the payments made. Please note, we do not collect or store full payment card details. This information is provided directly to our third-party payment processor.
• Technical Data: This includes data collected automatically when you use our Service, such as your Internet Protocol (IP) address, browser type and version, device type, operating system, time zone setting, and other diagnostic data.
• Usage Data: This includes information about how you interact with our Service, such as the features you use, the pages you visit, the time and date of your visit, the time spent on those pages, and other actions you take within the application.
• Communications Data: This includes your preferences for receiving marketing and other communications from us, as well as any correspondence you have with our support team.

3. How We Collect Your Data

We use different methods to collect data from and about you:

• Direct Interactions: You provide us with data when you sign up for an account, upload content, subscribe to a plan, connect your calendar, or contact us for support.
• Automated Technologies: As you use our Service, we automatically collect Technical and Usage Data using cookies and similar technologies (e.g., analytics scripts, error logs) to help our Service function correctly and to understand user behavior.
• Third-Party Sources: We receive data from third parties when you use them to interact with our Service. This includes:
  • Authentication Providers (e.g., Google, Microsoft): When you use them to sign in.
  • Calendar Providers (e.g., Google, Microsoft): When you connect your calendar.
  • Payment Processors (Stripe): We receive transaction confirmation and subscription status from them.
  • Customer Support Platforms (Intercom): When you communicate with us through our support channels.

4. How We Use Your Personal Data

We only use your personal data when the law allows us to. We use your data for the following purposes:

• To Provide and Maintain Our Service: We process your Identity Data and User-Generated Content to deliver our core features, such as transcription, subtitling, translation, and generating meeting summaries.
• To Manage Your Account: We use your Identity and Contact Data to register you as a user, manage your subscription, and communicate with you about service-related matters, such as updates and security notifications. When you sign in with a third-party service like Google, we use your name and email solely for authentication and account management.
• To Schedule Meeting Recordings: If you connect your Google Calendar, we use event data (title, time, attendees) exclusively to schedule our meeting bot as you direct.
• To Process Payments: We use Transaction Data to manage your subscription, process payments (via our payment processor), and handle billing inquiries.
• For Service Improvement and Development: We may use User-Generated Content, Usage Data, and Technical Data to analyze trends, troubleshoot issues, and improve the functionality, accuracy, and performance of our Service.
• To Communicate With You: We use your Contact Data to respond to your support requests via our customer service platform and to send you marketing communications, special offers, and news about our Service, unless you have opted out of receiving such information.
• For Security and Legal Compliance: We use data to monitor for and prevent fraudulent or illegal activity, to enforce our terms, and to comply with legal obligations.

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements. We will not use Google user data for any prohibited purposes such as selling it, using it for targeted advertising, or for determining credit-worthiness.

5. Disclosure of Your Personal Data

We do not sell your personal data. We may share your information with third-party service providers who help us operate our business, but only for the purposes outlined in this policy. These situations include:

• Core AI and Cloud Infrastructure Providers: We share User-Generated Content with our AI and cloud hosting partners to perform transcription, translation, and other AI-powered functions.
• Payment Processing Services: We share transaction information with Stripe to process your subscription payments securely.
• Customer Support Platforms: We use Intercom to manage our customer communications and support tickets.
• Authentication Service Providers: We use third-party services to securely manage user logins and authentication.
• Meeting and Calendar Integration Services: When you authorize it, we share information with services that enable our meeting bot to join and record meetings and integrate with your calendar.
• Analytics and Service Monitoring Providers: We share Usage and Technical Data with providers who help us analyze service performance, identify bugs, and improve user experience.
• Email Delivery Service Providers: We use third-party services to send transactional and marketing emails.
• Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your data is transferred and becomes subject to a different privacy policy.
• Legal Requirements: We may disclose your data if required to do so by law or in response to valid requests by public authorities.
• Affiliates: We may share your information with our affiliates, which include our parent company, subsidiaries, or other companies under common control with us. We require our affiliates to honor this Privacy Policy.

All third-party providers are bound by strict confidentiality obligations and are only permitted to process your data for the specific purposes we have instructed them for. Specifically, we do not transfer or disclose Google user data to third parties for purposes other than providing or improving our application's functionality.

6. International Data Transfers

Our Service is global, and your information, including personal data, may be transferred to—and maintained on—computers located outside of your state, province, or country where data protection laws may differ. Our service providers operate in various locations globally.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We will ensure that any transfer of your personal data is subject to appropriate safeguards as required by applicable data protection laws, such as the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong.

7. Data Security

We implement reasonable and appropriate security measures designed to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include using encryption to protect your information both in transit and at rest. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security.

8. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. This includes retaining your User-Generated Content while your account is active to allow you to access your projects. We will also retain and use data to the extent necessary to comply with our legal obligations (for example, for tax and accounting purposes), resolve disputes, and enforce our agreements.

You may request the deletion of your account and personal data at any time. Upon deletion, your data will be removed from our active systems in accordance with our internal policies.

9. Your Legal Rights

Under Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and depending on your location, you may have the following rights in relation to your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Correction: You have the right to request that we correct any information you believe is inaccurate or incomplete.
• Right to Erasure (Deletion): You have the right to request that we delete your personal data, under certain conditions.
• Right to Object to Processing: You have the right to object to our processing of your personal data for direct marketing purposes.

To exercise any of these rights, please contact us at hello@subtitlewhisper.com. We may need to request specific information from you to help us confirm your identity before processing your request.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Email: hello@subtitlewhisper.com