Subly is a cloud-based video and audio transcription software tool, which we supply through our website to registered users. It uses speech recognition technology to automatically add subtitles, in any language, to your videos uploaded to or recorded with Subly. It enables users to edit and translate text, and download your video for sharing on any platform.
You can either scroll down to read this policy in its entirety (which we recommend), or click on one of the links below to go straight to the section you are interested in.
For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.
If you have any questions in regard to any part of this policy, (including any requests to exercise your legal rights) please contact us either by:
We are committed to protecting your privacy and safeguarding your personal data. Our use of your personal data is subject to the data protection laws applicable in the United Kingdom, which on the date of the publication of this policy includes the EU General Data Protection Regulation, the UK Data Protection Act 2018 and other relevant UK and EU legislation concerning personal data (together Data Protection Legislation).
Even though the United Kingdom has left the European Union, the EU General Data Protection continues to apply in the United Kingdom during the transition period, until the end of 2020.
Personal data means information which relates to an identified or an identifiable individual.
Who can see your videos
As a registered user of Subly, you will be able to upload videos to Subly and record videos using Subly. Only you, your authorised staff, and the Subly Team (by which we mean our staff consisting of our employees and contractors) will be able to view your videos. Our team may view your videos for the purpose of resolving technical issues and for the purpose of enhancing Subly’s features. We will treat such content as confidential in accordance with our Terms of Website Use.
We may also collect, use, and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website to calculate the percentage of users accessing a specific website feature.
We collect most of this information from you direct. However, we may also collect information from other sources.
Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so, for example: consent, contact, legitimate interests, or legal obligation.
Consent. We may process your data based on your consent to:
Where we want to use your data on the basis of your consent, we will ask for such consent separately and clearly.
Right to withdraw consent
You have the right to withdraw consent at any time by:
Even if we are not required to obtain your consent for marketing purposes, you can still opt-out of receiving marketing communications at any time, so you are still in control.
Contract. We will use your personal data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:
Legitimate interests. We may process your personal data when we (or third party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests. For example:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or structure of our business.
Legal obligation. We may process your personal data to comply with our legal obligation. For example, to:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may also anonymise your personal data (so that it can no longer be associated with you) for analytics, research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).
If you would like to exercise any of those rights, please contact us at firstname.lastname@example.org. Please let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern you may raise about our use of your information. You may contact us by using the contact methods set out in the Who we are and how to contact us section of this policy.
The Data Protection Legislation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or the European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns, telephone on 0303 123 1113, or by post to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.