Privacy Policy

1. Scope and Controller Information

This Policy applies to all users of the CaptionFit website, mobile applications, APIs, and any other offerings under the CaptionFit brand. The data controller responsible for your personal information is:

Where the General Data Protection Regulation (GDPR) applies, TVIBO LLC acts as the data controller. Where the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) applies, TVIBO LLC acts as the "business" as defined therein.

2. Information We Collect

We collect information in the following categories:

2.1 Information You Provide Directly

Account registration data: name, email address, password (stored as a secure hash), and profile details. Payment information: billing name, address, and payment card details. Payment card data is processed directly by our payment processor and is not stored on our servers. User Content: captions, media files, text, and other materials you submit to or generate through the Service. Communications: messages, support tickets, and survey responses you send to us.

2.2 Information Collected Automatically

Log data: IP address, browser type, operating system, referring URLs, pages visited, and timestamps. Device data: device identifiers, hardware model, and operating system version. Usage data: features accessed, actions taken within the Service, session duration, and crash reports. Cookies and similar technologies: see Section 6 (Cookies) for details.

2.3 Information from Third Parties

Authentication providers: if you sign in via a third-party service (e.g., Google, Apple), we receive your name and email address from that provider. Analytics providers: aggregated and pseudonymized usage metrics from our analytics tools.

2.4 Sensitive Personal Information

We do not intentionally collect sensitive personal information such as government IDs, financial account numbers (beyond what is necessary for payment processing), health data, racial or ethnic origin, or biometric identifiers. Please do not submit such information through the Service.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Providing and Improving the Service

Creating and managing your account and subscription. Processing payments and sending transactional communications (receipts, invoices). Operating AI-powered features to generate and process captions — your content is used solely to return results to you and is not retained for model training. Diagnosing technical issues and improving Service performance.

3.2 Communications

Sending Service-related notices (security alerts, policy updates, billing confirmations). Responding to your support requests and inquiries. Sending marketing communications where you have opted in; you may opt out at any time.

3.3 Safety, Security, and Compliance

Detecting, investigating, and preventing fraudulent, abusive, or illegal activity. Enforcing our Terms and Conditions. Complying with applicable legal obligations and responding to lawful requests from authorities.

3.4 Analytics and Research

Understanding how users interact with the Service in order to improve features and user experience. Conducting internal research using aggregated and anonymized data only. We do not sell your personal information, and we do not use your personal information or User Content to train AI models.

4. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR to process your personal data: Contract performance: processing necessary to provide the Service under our Terms and Conditions (e.g., account management, payment processing). Legitimate interests: processing for fraud prevention, security, Service improvement, and direct marketing to existing customers, where our interests are not overridden by your rights. Legal obligation: processing required to comply with applicable laws (e.g., tax and accounting requirements, responding to lawful governmental requests). Consent: where we rely on your consent (e.g., optional marketing emails), you may withdraw it at any time without affecting the lawfulness of prior processing. We do not engage in solely automated decision-making that produces legal or similarly significant effects on you without human review.

5. Sharing and Disclosure of Information

We do not sell, rent, or trade your personal information. We may share your information in the following limited circumstances:

5.1 Service Providers and AI Sub-Processors

We engage trusted third-party vendors who process data on our behalf solely to provide the Service. These vendors are bound by confidentiality obligations and are engaged to process your data only to deliver the Service. Our principal sub-processors are:

• ElevenLabs, Inc. — speech-to-text transcription. Receives the audio you submit in order to generate a transcript.
• Anthropic, PBC — AI processing used to segment and refine captions. Receives transcript text to return formatted results. Anthropic does not train its models on data submitted through its commercial API.
• Stripe, Inc. — payment processing. Receives billing and payment-card details directly; we do not store card numbers.
• Google LLC — analytics and advertising measurement (Google Analytics / Google Ads), subject to your cookie choices.
• Our cloud hosting and database providers — store your account data and content to operate the Service.

We do not authorize these providers to use your personal information or User Content for their own independent purposes, including to train their own AI models, except where they act as an independent controller for limited operational data (e.g., a payment processor's fraud-prevention obligations). We may update this list as our providers change; the current list is available on request.

5.2 Business Transfers

If the Company is involved in a merger, acquisition, asset sale, or similar transaction, your personal information may be transferred as part of that transaction. We will notify you via email or prominent in-app notice before your information is transferred and becomes subject to a different privacy policy.

5.3 Legal Requirements

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.

5.4 With Your Consent

We may share your information with third parties for any other purpose with your prior consent.

5.5 Aggregated or Anonymized Data

We may share aggregated or anonymized information that cannot reasonably be used to identify you with partners, researchers, or the public for any purpose.

6. Cookies and Tracking Technologies

We use cookies and similar technologies (web beacons, pixel tags, local storage) to operate and improve the Service.

6.1 Types of Cookies We Use

Essential cookies: required for core Service functionality (e.g., session management, authentication). Cannot be disabled. Analytics cookies: help us understand how users interact with the Service. We currently use Google Analytics. Data collected is pseudonymized and used in aggregate. Preference cookies: remember your settings and choices (e.g., language preference).

6.2 Your Cookie Choices

You can manage or disable non-essential cookies through the cookie preference center available on our website, or through your browser settings. Disabling certain cookies may affect Service functionality. For information on how Google Analytics uses data, visit: policies.google.com/technologies/partner-sites.

6.3 Do Not Track

Our Service does not currently respond to browser "Do Not Track" signals. We will update this policy if that changes.

7. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Account data: retained for the duration of your account and for up to 90 days after account deletion, to allow for recovery and dispute resolution.
• User Content (uploaded media, transcripts, renders): retained for as long as the associated project or account remains active, so that you can return to and re-edit your work. You may delete a project at any time, which removes its files from our servers. Upon account deletion, associated User Content is deleted within 30 days unless retention is required by law.
• Log and usage data: typically retained for 12 months and then aggregated or deleted.
• Financial records: retained for up to 7 years as required by applicable tax and accounting laws.

When retention is no longer necessary, we securely delete or anonymize your information.

8. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit (TLS/HTTPS), encryption at rest, access controls, and regular security assessments. Despite these efforts, no security system is impenetrable. We cannot guarantee the absolute security of your information. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by applicable law.

9. International Data Transfers

TVIBO LLC is based in the United States. If you access the Service from outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that differ from those in your country. Where required by the GDPR, we ensure that transfers of personal data to third countries are protected by appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other valid transfer mechanisms.

10. Your Privacy Rights

10.1 Rights Under GDPR (EEA / UK / Switzerland Residents)

If you are located in the EEA, UK, or Switzerland, you have the following rights:

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object
• Right to withdraw consent
• Right to lodge a complaint with your local data protection authority (e.g., the ICO in the UK)

10.2 Rights Under CCPA / CPRA (California Residents)

If you are a California resident, you have the following rights:

• Right to know
• Right to delete
• Right to correct
• Right to opt out of sale or sharing (we do not sell or share your personal information for cross-context behavioral advertising)
• Right to limit use of sensitive personal information (we do not use beyond what is necessary)
• Right to non-discrimination

To exercise any of these rights, please contact us at tvibo@tvibo.com. We will respond within the timeframes required by applicable law (generally 30 days for GDPR; 45 days for CCPA).

11. Children's Privacy

The Service is not directed to children under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected information from a minor, please contact us immediately at tvibo@tvibo.com and we will promptly delete such information.

12. Third-Party Links and Services

The Service may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by updating the effective date at the top of this document and, where required by law, by sending an email notification or displaying a prominent in-app notice at least 14 days before the changes take effect.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Privacy team:

For GDPR-related inquiries, you may also contact us to request information about our EU representative, if applicable.

By using CaptionFit, you acknowledge that you have read and understood this Privacy Policy.