Privacy Policy
This Privacy Policy explains how ELD MEDIA SRL (CUI 53072768, J2025095567005), Sat Apa, Satu Mare, Romania ("we", "us", "our") collects, uses, and protects personal data in connection with the ezsubs platform. This policy complies with the EU General Data Protection Regulation (GDPR) and Romanian data protection law.
1. Data Controller
The data controller responsible for your personal data is:
- ELD MEDIA SRL
- CUI: 53072768 | Nr. Reg. Com.: J2025095567005
- Sat Apa, Satu Mare, Romania
- Email: [email protected]
2. Data We Collect
Account Data
When you create an account, we collect your email address and a hashed password. If you register via Google OAuth, we receive your name and email from Google.
Content Data
We store the video files, audio files, generated captions, and project settings you upload or create on our platform. This content is stored in your account and processed solely to provide the service to you.
Usage Data
We collect information about how you use the service, including pages visited, features used, export history, and session duration. This data is used to improve the platform.
Payment Data
Payment information is processed by our payment processor (Paddle). We do not store your full credit card details. We receive a transaction reference and subscription status from Paddle.
Technical Data
We automatically collect your IP address, browser type, operating system, and device information when you access our service. This data is used for security and service optimization.
3. Legal Basis for Processing
| Purpose | Legal Basis |
|---|---|
| Providing the service (account, projects, exports) | Performance of contract (Art. 6(1)(b) GDPR) |
| Processing payments and managing subscriptions | Performance of contract (Art. 6(1)(b) GDPR) |
| Sending transactional emails (account, billing) | Performance of contract (Art. 6(1)(b) GDPR) |
| Security, fraud prevention, and abuse detection | Legitimate interests (Art. 6(1)(f) GDPR) |
| Analytics and service improvement | Legitimate interests (Art. 6(1)(f) GDPR) |
| Marketing communications | Consent (Art. 6(1)(a) GDPR) |
| Legal obligations (tax, accounting) | Legal obligation (Art. 6(1)(c) GDPR) |
4. Third-Party Processors
We share your data with the following trusted third-party service providers who process data on our behalf:
| Processor | Purpose | Location |
|---|---|---|
| Supabase Inc. | Database, authentication, and file storage | USA (EU Standard Contractual Clauses) |
| Cloudflare Inc. | Content delivery network and domain services | USA (EU Standard Contractual Clauses) |
| OpenAI LLC | AI transcription and speech-to-text processing | USA (EU Standard Contractual Clauses) |
| ElevenLabs Inc. | AI voice generation (text-to-speech) | USA (EU Standard Contractual Clauses) |
| Paddle.com Market Ltd. | Payment processing and subscription management | United Kingdom |
All third-party processors are bound by data processing agreements and required to protect your data in accordance with GDPR requirements.
5. International Data Transfers
Some of our processors are located outside the European Economic Area (EEA), specifically in the United States and United Kingdom. Data transfers to these countries are protected by:
- EU Standard Contractual Clauses (SCCs) adopted by the European Commission
- The EU-U.S. Data Privacy Framework where applicable
- UK GDPR adequacy decisions where applicable
6. Data Retention
- Account data: Retained for as long as your account is active, plus 30 days after account deletion
- Project and media files: Retained for as long as your account is active; free plan files may be deleted after 90 days of inactivity with prior notice
- Payment records: Retained for 10 years as required by Romanian accounting law
- Usage logs: Retained for a maximum of 12 months
7. Your Rights Under GDPR
As a data subject in the EU/EEA, you have the following rights:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Request correction of inaccurate or incomplete data
- Right to erasure ("right to be forgotten"): Request deletion of your personal data, subject to legal obligations
- Right to restriction: Request that we limit the processing of your data in certain circumstances
- Right to data portability: Receive your data in a structured, machine-readable format
- Right to object: Object to processing based on legitimate interests or for direct marketing
- Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
8. Supervisory Authority
You have the right to lodge a complaint with the Romanian data protection supervisory authority:
- Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
- Website: www.dataprotection.ro
- Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 București, România
9. Cookies
We use cookies and similar technologies to operate and improve the service. For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.
10. Children's Privacy
ezsubs is not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected].
11. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include encrypted data transmission (TLS), encrypted storage, access controls, and regular security reviews.
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and no later than 72 hours of becoming aware of the breach.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by email or by posting a prominent notice on the platform. The updated policy will take effect upon posting, unless we state otherwise.
13. Contact
For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us:
- Email: [email protected]
- Company: ELD MEDIA SRL, CUI 53072768
- Address: Sat Apa, Satu Mare, Romania