Subtile's logo

Privacy Policy

1. General

Your privacy is really important to us. We will ensure that your personal data is processed safely and lawfully, and always in accordance with applicable privacy legislation, and in particular with the General Data Protection Regulation ("GDPR").


This privacy statement outlines how the enterprise with number 1012.168.274 collects and uses personal information from customers and other individuals (collectively "you") who access or use our websites, including www.subtile.ai, and our digital platform which allows you to auto-generate captions for videos (the "Application") (together, the "Services"). By using our Services, you understand that we will collect and use your personal data as described in this Privacy Statement.


This Privacy Statement does not apply to any third-party websites and apps that you may use, including the ones in which our Services are embedded. You should review the terms and policies for such third-party websites and apps before using them. If you have any questions about this Privacy Statement, you can contact us at the following e-mail address: [email protected].

2. What are personal data?

In this Privacy Policy, Personal Data refers to information that make it possible to identify you. An identifiable person is someone who can be identified, either directly or indirectly, in particular by referring to an identification number or to one or more factors that are linked to physical, physiological, mental, economic, cultural or social identity. A typical example of personal information is your name and email address.

3. What personal data do we collect?

We collect three broad categories of information about you (your "personal data") when you interact with us.

We collect personal data that you provide us to give you more information about our Services or to provide you with our Services

When you register on our website or you contact us via email or our contact form to obtain a demo, more information about our Services or (free trial or paid) access to our Services, you provide us with your personal data such as:


When you request a free plan:
  • email address
  • language
  • username
  • password

When you request a paid plan:
  • first name and surname
  • address
  • email address
  • credit card information or other payment information
  • language
  • username
  • password

We refer to this type of personal data as "Customer Account Data".


When you are using our Services, we process personal data that you give us or that we collect automatically.


When you use or interact with our Application, you provide us with:

  • Content, data, information or material that you provide us directly
  • Content, data, information or material that you request the Application to collect or generate for you.

When you use or interact with our Services, we also collect automatically the following personal data:

  • IP address of your computer
  • IP address of the internet service provider
  • the date and time you have accessed the Website
  • the internet address of the website from which you have linked directly to the website
  • the operating system you use
  • the divs of the Website you visited
  • the Website pages you accessed
  • the information you viewed
  • the materials posted to or downloaded from the Website
  • the number of videos you upload
  • data collected through the use of cookies

We refer to this type of personal data as "Customer Data".


When you subscribe to our newsletters (or waitlist), you provide us with your email address. We refer to this type of personal data as "Marketing Data".


4. How do we use personal data?

We might use your personal data for the following purposes:

  • To create and maintain your user profile on this website;
  • To manage the identification and authentication of users;
  • To issue invoices to you;
  • To verify your user account in order to guarantee the necessary security measures;
  • To provide information about your community and/or alert you when activities on the platform may interest you.

The personal data is only stored and processed for the period required for the purpose of the processing. After that, the data will be deleted or anonymised.

5. With whom do we share your personal data?

  • (a) Our third-party vendors and service providers who process data on our behalf or for purposes described in this Notice or notified to you at the time of data collection. We share data with these vendors and service providers in areas such as invoice and payment services, customer and lead support (chat on the Website), website hosting, marketing, waitlists and newsletters, and data analytics.
  • (b) Any competent law enforcement body, regulatory, government agency, court, or other third party where we believe disclosure is necessary: (i) as required by applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
  • (c) Our auditors, advisors, legal representatives, and similar agents in connection with the advisory services they provide to us for legitimate business purposes, under contractual prohibition from using the Personal Data for any other purpose.
  • (d) A potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that the buyer is informed to use your Personal Data only for the purposes disclosed in this Notice.
  • (e) Any other person if you have provided your prior consent to the disclosure.

hCaptcha

We use the hCaptcha security service (hereinafter "hCaptcha") on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation ("IMI"). hCaptcha is used to check whether user actions on our online service (such as submitting a login or contact form) meet our security requirements. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). The data collected during the analysis will be forwarded to IMI. hCaptcha analysis in the "invisible mode" may take place completely in the background. Website or app visitors are not advised that such an analysis is taking place if the user is not shown a challenge. Data processing is based on Art. 6(1)(b) of the GDPR: the processing of personal data is necessary for the performance of a contract to which the website visitor is party (for example, the website terms) or in order to take steps at the request of the website visitor prior to entering into a contract. Our online service (including our website, mobile apps, and any other apps or other forms of access offered by us) needs to ensure that it is interacting with a human, not a bot, and that activities performed by the user are not related to fraud or abuse. In addition, processing may also be based on Art. 6(1)(f) of the GDPR: our online service has a legitimate interest in protecting the service from abusive automated crawling, spam, and other forms of abuse that can harm our service or other users of our service. IMI acts as a "data processor" acting on behalf of its customers as defined under the GDPR, and a "service provider" for the purposes of the California Consumer Privacy Act (CCPA). For more information about hCaptcha's privacy policy and terms of use, please visit the following links:https://www.hcaptcha.com/privacy and https://www.hcaptcha.com/terms


We will never sell or rent your personal data to other service providers, nor will we share your Personal Data with any service providers who are not compliant with the GDPR.

6. Cookies

We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A "cookie" is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

6.1. Session Replay

We use PostHog for session replay to help us analyze how users use the Site and to improve use.

6.2. Analytics

Among other service providers, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. We also use PostHog.

7. What rights do you have?

You have the right to view your personal data at any time, as well as the right to be informed of the use that the website makes of your personal data.

7.1. Right to rectification, erasure and restriction of processing

You are free to decide whether or not to provide your personal data to us. In addition, you always have the right to request to correct, supplement or remove your personal data. You acknowledge that a refusal to provide or a request for the erasure of personal data means that certain services can no longer be delivered. You may also request that the processing of your personal data is limited.

7.2. Right to object

You have the right to object to the processing of your personal data for serious and legitimate reasons. In addition, you always have the right to object to the use of your personal data for direct marketing purposes; in such case you do not have to state reasons.

7.3. Right to data portability

You have the right to obtain the personal data you have provided to us in a structured, typical and machine-readable form and/or have such transferred to different controllers.

7.4. Right to withdraw consent

Insofar as the processing is based on your prior consent, you have the right to withdraw this approval.

7.5. Exercising your rights

You can exercise your rights by contacting us to this end by email to [email protected], provided you enclose a copy of your identity card.

7.6. Automated decision-making and profiling

The processing of your personal data does not include profiling and shall also not be subjected by us to automated decision-making.

7.7. Right to lodge a complaint

You have the right to lodge a complaint to the Belgian Privacy Commission: Personal Privacy Protection Commission, Drukpersstraat 35, 1000 Brussels, Belgium, Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, e-mail: [email protected]. This does not affect relief before a civil court.

8. Updates of this privacy statement

We may make improvements, additions or changes to this Privacy Statement for a variety of reasons. We will post a notice of those changes on our website www.subtile.ai.

This version was drawn up on 27/11/2024.

Older versions of this Privacy Statement will be stored in our archive and can be retrieved at any time by sending an email to [email protected].