PRIVACY POLICY

This policy explains what personal data BUBLEDUB collects, why, on what legal basis, who it is shared with, how long it is kept, and what rights you have.

If you connect Facebook, Instagram, TikTok or YouTube, also read our Connected channels privacy supplement for the data, permissions, retention and disconnection controls used by optional social publishing.

1. Controller

The data controller is SIA RODLEN, a company registered in the Republic of Latvia.

• Registration number: 42103078116
• Registered address: Ģenerāļa Baloža iela 13–21, Liepāja, LV-3414, Latvia
• Correspondence address: Gubu iela 6, Medemciems, Olaines pagasts, Latvia
• Privacy contact: info@rodlen.com

We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR. Privacy requests are handled at the address above.

2. What we collect

2.1 Account data

• Email address and the identifier supplied by your sign-in provider (Google).
• If you link Telegram: your Telegram user ID and chat ID. We do not need or store your phone number.
• Your settings: target languages, voice preset, caption mode.

2.2 Media and derived content

• The video or audio you upload or send to the bot.
• Content derived from it during processing: the extracted audio track, the transcript of the speech, the translation, the synthesised voice-over, subtitle files, a thumbnail frame, and the finished output file.

2.3 Transaction data

• Credit balance, ledger entries, job history and cost accounting.
• Purchase records: pack purchased, amount, currency, Stripe identifiers, payment status. We never receive or store your card number — card data goes directly to Stripe.

2.4 Technical data

• Server logs with request metadata, timestamps, error codes and job identifiers, used to operate, debug and secure the Service. We deliberately keep transcripts, file URLs and tokens out of logs.
• Optional analytics and advertising measurement (see section 7): pseudonymous browser and session identifiers, page visits, sign-up, upload and job completion, checkout and confirmed purchase events (amount, currency, product and a transaction identifier). Purchase events are verified by our server. These events do not include recordings, transcripts, filenames, email addresses or card details.

3. Why we process it, and on what legal basis

• To provide the Service — hosting your upload, transcribing, translating, synthesising speech, rendering and delivering the output, maintaining your credit balance. Legal basis: performance of a contract (Art. 6(1)(b)).
• To take payment — creating checkout sessions, recording purchases, handling refunds and chargebacks. Legal basis: performance of a contract (Art. 6(1)(b)) and legal obligation for accounting records (Art. 6(1)(c)).
• To keep the Service secure and prevent abuse — rate limiting, fraud and abuse detection (including Firebase App Check with Google reCAPTCHA Enterprise on pages that use your account), enforcing our Terms. Legal basis: legitimate interests (Art. 6(1)(f)) in protecting our service and our users.
• To improve the product — aggregated performance, reliability and cost metrics. Legal basis: legitimate interests (Art. 6(1)(f)).
• Analytics cookies and similar technologies — Legal basis: your consent (Art. 6(1)(a)), which you can withdraw at any time.

We do not sell personal data, and we do not use your media or transcripts to train machine-learning models.

4. Who receives and processes data

• Google Cloud / Firebase (Google Ireland Limited) — hosting, authentication, database, file storage, and the AI models used for speech recognition, translation and speech synthesis. Our infrastructure and stored files are located in the EU (europe-west4, Netherlands). Firebase App Check with reCAPTCHA Enterprise evaluates browser and interaction signals to confirm that sign-in, database and storage requests come from our genuine website rather than automated abuse; Google processes these signals under its own terms and may do so outside the EEA.
• Stripe (Stripe Payments Europe, Ltd.) — payment processing and payment records.
• Google Analytics / Google Ads — optional product analytics and, with your separate permission, measuring which advertisements lead to visits and purchases. Google may process measurement data outside the EEA under its applicable data protection terms. We do not upload customer contact lists or use these events for personalized audiences.
• Meta Pixel and Conversions API (Facebook and Instagram) — only after your advertising measurement opt-in, Meta receives browser/device and network information (including IP address), advertising cookie/click identifiers, visits to eligible pages, account creation, checkout start, completed dubbing and confirmed purchases (product, amount and currency). Eligible events are sent from your browser and our server, using a shared event identifier to avoid counting the same action twice. Purchase events come from verified Stripe payments, including consented subscription renewals. We use this to measure our ads and help Meta improve their delivery. Automatic advanced matching and automatic form/button tracking are disabled; we do not send email addresses, account IDs, recordings or transcripts. Meta may associate this information with a Meta account and process it outside the EEA under its Privacy Policy and Business Tools Terms. Card details and billing addresses are never sent to Meta. You can withdraw advertising consent in Cookie preferences; this stops future browser and server events linked to that browser's consent. Global Privacy Control also prevents Meta measurement.
• Telegram (Telegram FZ-LLC) — only if you use the bot: message delivery and temporary storage of the files exchanged with the bot, under Telegram’s own privacy policy.

BUBLEDUB uses YouTube API Services for its optional connected-channel features. The Google Privacy Policy also applies to Google services.

4.1 Google user data: access, use and sharing

Google sign-in provides your account identifier and email address, and may provide your name and profile image, to create and display your BUBLEDUB account. If you separately connect YouTube, we also receive the permissions and OAuth tokens you grant, channel identifiers and profile information, video metadata, upload status and channel analytics. We use YouTube data to identify your selected channel, detect new video metadata for routes you enable, publish videos you approve and display your channel's analytics. We do not download YouTube videos.

We share, transfer or disclose Google user data only to the following recipients for these purposes:

• Google Cloud / Firebase — our infrastructure provider processes account information and connected YouTube records on our behalf to authenticate users, host the application, store data and run scheduled tasks. YouTube OAuth access and refresh tokens are encrypted on our servers, with the encryption key held in Google Cloud Secret Manager.
• Google / YouTube API Services — we send the authorization credentials, channel or video identifiers and API requests needed to retrieve the information you authorize. For a YouTube publication you approve, we send your selected video file, title, description, language, audience, privacy and disclosure settings to YouTube. Google also receives token refresh and revocation requests needed to manage your connection.
• Stripe — when you choose to pay through Stripe, your BUBLEDUB account email address, which may have come from Google sign-in, is sent with the payment request for checkout and billing. Stripe does not receive your YouTube OAuth tokens, channel analytics or video metadata.
• Authorized SIA RODLEN personnel and legally required recipients — human access to Google API data is limited to your explicit agreement, necessary security investigations, compliance with applicable law, or aggregated internal operations permitted by Google's Limited Use requirements. We disclose data to competent authorities or courts only when required by applicable law, and limit disclosure to what is required.

Other connected platforms. Meta (Facebook/Instagram) and TikTok receive the original or BUBLEDUB-produced media and publication text you choose to send to them. We do not automatically forward your Google sign-in profile, YouTube tokens, channel analytics or API video metadata to those platforms. The files you supply for dubbing are processed separately from connected YouTube API data, as described in sections 2.2 and 4.

We do not sell Google user data or disclose it to data brokers or advertising networks. Google account profile fields and YouTube API records are not included in the optional analytics or advertising events described in this policy, even if you consent to those events. We do not use Google API data to train AI or machine-learning models, and do not transfer or disclose it for purposes other than those stated above.

BUBLEDUB's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements. See the Google Privacy Policy and our Connected channels privacy supplement for YouTube retention, disconnection and deletion controls.

4.2 YouTube access, retention and deletion

Disconnect and revoke: open Publishing → Channels, choose Disconnect & delete data beside the channel and confirm. We immediately disable that connection and stop new publishing work. We remove its stored channel profile, analytics, discovered video metadata, source bindings, upload receipts and upload-session data. Original media that you uploaded and your own publication drafts remain yours; already published posts are managed on YouTube. A request already in flight may still finish on YouTube.

We immediately request revocation of the YouTube authorization with Google. If Google is temporarily unavailable, the encrypted credential is retained solely for automated revocation retries for up to 24 hours, then erased. It cannot be used for reading or publishing after disconnection. You can also revoke BUBLEDUB's access directly at any time in Google Account → Third-party connections.

Refresh and automatic deletion: while connected, scheduled checks run approximately every 15 minutes, channel profile metadata is refreshed daily and analytics every six hours. Source-video discovery runs only for enabled routes. Analytics show their last successful refresh; unavailable figures are not replaced by estimates. Expired access tokens are refreshed before use. If Google reports that authorization has been revoked, we disable the connection and erase its stored API data. Network failures are retried and are not treated as new consent.

Channel metadata must be refreshed within 29 days or the connection and its stored API data are removed. Analytics snapshots, discovery events, source bindings and upload receipts expire after at most 29 days without renewal. A separate maintenance sweep actively deletes expired data, including for accounts whose beta or reviewer access has expired. OAuth setup tickets last at most 10 minutes; publication media links last at most one hour. Working authorization tokens are encrypted and retained only while the connection is authorized, subject to the limited revocation-retry period above.

Requests: you may also request deletion of stored YouTube API data at info@rodlen.com from your account email, or delete your BUBLEDUB account in Studio → Account → Delete account. We process verified YouTube API data deletion requests as soon as possible and within seven calendar days. The separate financial retention rules below apply to billing records, not to connected-channel API data.

5. International transfers

Our storage, database and compute run in the European Union. However, one component — the speech-synthesis model used for the highest-quality voice — is currently offered by Google only through a global endpoint, which means the text sent for synthesis may be processed outside the European Economic Area.

Such transfers are covered by the European Commission’s Standard Contractual Clauses within our data processing agreement with Google, together with Google’s supplementary technical measures. Only the text to be spoken and technical parameters are sent for synthesis; your account identifiers are not.

6. How long we keep it

• Meta advertising attribution — consent and checkout attribution expire after 90 days; delivery records expire after 7 days. A minimal withdrawal record remains for 180 days to prevent delayed requests from restoring consent. Account deletion removes owner-linked attribution and delivery records.
• Library originals and their reusable analysis — kept until you delete the original or your account. Saving originals and compatible analysis, such as transcripts, uses your storage allowance. They can be reused for later jobs and additional languages. Deleting a result does not delete its saved original; deleting an original also removes its reusable analysis but leaves separately created results available under their own retention period.
• Other uploaded source copies, rendered outputs, subtitles and thumbnails — deleted automatically 30 days after creation by a storage lifecycle rule. This automatic period does not apply to originals saved in your Library. Scratch files and temporary processing caches are deleted within days.
• Job records (status, timings, transcript and translation text, usage) — kept while your account exists, so you can see your history; deleted when the account is deleted.
• Credit ledger and payment records — retained for up to 5 years after the transaction to meet Latvian accounting and tax obligations, even after account deletion.
• Server logs — retained for up to 30 days.
• Account data — kept until you ask us to delete the account.

7. Cookies and local storage

We keep this minimal.

• Strictly necessary — your sign-in session is stored in your browser (local/session storage) by Firebase Authentication so you stay logged in. Without it the studio cannot work, so it needs no consent. On the sign-in, studio and account pages, and on product pages while you are signed in, Google reCAPTCHA Enterprise (used by Firebase App Check) may also store cookies and local data to protect those requests from abuse; this security protection is strictly necessary.
• Analytics (optional) — Google Analytics for Firebase loads only after you choose analytics. If you decline, we do not initialize analytics or create analytics identifiers. Optional measurement cookies are configured for up to 90 days.
• Advertising measurement (optional) — a separate choice allows Google Analytics, Google Ads and Meta Pixel to associate advertising interactions with the events described above. Choosing analytics alone does not enable advertising measurement. Google personalization stays disabled. We do not create Meta remarketing audiences or upload customer lists. Meta's _fbp and _fbc cookies can last up to 90 days. An earlier Google-only choice does not enable Meta: we ask for a new choice. A browser Global Privacy Control signal prevents Meta Pixel from loading.
• Changing your choice — use Cookie settings at any time. Withdrawal stops future browser measurement, removes measurement cookies and asks our server to suppress pending events associated with that browser. If your device is offline, the withdrawal is retried when you next visit online. Previously collected data is not automatically erased; contact us to exercise your deletion rights.
• Server measurement records — consent and attribution records are retained for up to 90 days since your latest consented activity; delivery records for up to 7 days. A withdrawal marker may be retained for 180 days to prevent delayed requests from restoring collection. Essential billing records follow the separate retention period in section 6.

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased (“right to be forgotten”);
• restrict or object to processing based on legitimate interests;
• receive your data in a portable, machine-readable format;
• withdraw consent at any time, without affecting processing already carried out.

To exercise any of these, write to info@rodlen.com from the email address on your account. We respond within one month. Note that we may keep records we are legally required to retain (section 6).

If you believe we handle your data unlawfully, you may complain to the Latvian supervisory authority — Datu valsts inspekcija (dvi.gov.lv) — or to the authority in your country of residence.

9. Security

Access to production data is restricted to the operators of the Service. Traffic is encrypted in transit and files are encrypted at rest by our cloud provider. Website requests to our sign-in, database and file storage services carry Firebase App Check attestation. Client applications can read only their own records; all writes go through our backend. Internal processing endpoints are not publicly reachable. No system is perfectly secure, and we cannot guarantee absolute security.

10. Children

The Service is not directed at children. You must be at least 18 years old to use it. If you believe a child has provided us with personal data, contact us and we will delete it.

11. Changes

We may update this policy. The current version and its effective date are always published here. Material changes will be announced by email or in the Service before they take effect.

Privacy questions and requests: info@rodlen.com