Privacy Policy

1. Introduction

Revalfilm OÜ (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our browser extension SubTranslate for European TV — which translates subtitles on public broadcaster sites, currently raiplay.it, jupiter.err.ee, ardmediathek.de and zdf.de — or visit our website at https://subtranslate.revalfilm.info.

The extension supports several broadcaster sites through a shared core, and uses the same account, billing, and server infrastructure as our website — this Policy covers all of them unless a section says otherwise.

2. Company Information

Revalfilm OÜ

Pae 21 Tallinn Estonia VAT Number: EE102628267

3. Data Protection Officer

For any data protection inquiries, please contact our Data Protection Officer:

• Email: contact@revalfilm.info

4. Information We Collect

4.1 Subtitle Text and Translation Requests

To translate subtitles, the extension sends the original subtitle text to our server, which forwards it to a language model provider to produce the translation. This happens for every episode you watch with the extension enabled — there is no way to translate without sending the text.

You do not need an account, email address, or any other personal identifier to use either extension on the free tier.

4.2 Installation Identifier

On first use, the extension generates a random installation identifier (a UUID) and stores it in your browser. This identifier is sent alongside translation requests so our server can apply per-installation rate limits and detect abuse. It is not linked to your name, email, or any other personal identity, and we do not use it to build a profile of what you watch.

4.3 Paid Subscription Account

If you choose to subscribe (to translate beyond the free tier’s episode limit), we collect additional information to provide and manage that subscription:

• Account and sign-in. Creating an account requires an email address, which we use to send you a one-time sign-in link (“magic link”) — we do not store or ask for a password.
• Payment information. Payments are processed by Stripe, our payment processor. Stripe collects your payment details (such as card number) directly — we never receive or store your full card number. We receive from Stripe only what’s needed to manage your subscription: your name and email as given at checkout, the subscription status, and billing history (invoices, transaction records).
• Subscription token. Once subscribed, your browser extension is issued a bearer token that identifies your account. It carries no entitlement of its own: for each translation request our server checks whether your account has an active subscription for the source language of the page you are watching — a subscription covers one source language and every broadcaster in it, and does not unlock the others. The token is sent with translation requests instead of the free-tier installation identifier, and lets our server skip the free-tier episode limit for you.

Stripe’s own checkout page and privacy practices are governed by Stripe’s Privacy Policy — we don’t control what Stripe itself collects on that page.

4.4 Automatically Collected Information

When your browser contacts our server, we automatically receive standard web request information, including:

• IP address
• Browser type and version
• Access times and dates

We use this only for rate limiting, abuse prevention, and aggregate usage counts (e.g. how many translation requests we serve) — not to track individual users across visits.

4.5 Contact Inquiries

If you contact us by email, we collect whatever information you include in that message in order to respond to you.

4.6 Cookies

Our website sets one essential session cookie required for the site to function (it is not used for tracking or advertising). If you interact with the cookie-consent banner, your choice is also stored in a cookie so we don’t ask again. We do not use third-party analytics or advertising cookies.

5. How We Use Your Information

We use the information described above to:

• Provide the translation service (sending subtitle text to our translation provider and returning the result)
• Maintain a shared cache of translations so repeated lines don’t need to be translated again
• Enforce rate limits and prevent abuse of the service
• Create and manage your account and subscription, including processing payments and sending you sign-in links
• Monitor aggregate usage (e.g. request volume) to understand demand and cost
• Respond to inquiries sent to us directly
• Comply with legal obligations (including tax and accounting record-keeping for payments)

We do not send marketing communications, and we do not sell or trade your information.

6. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation, we process data based on the following legal grounds:

• Legitimate Interests (Article 6(1)(f)): Operating and securing the translation service, preventing abuse, and understanding aggregate usage — balanced against your rights, and limited to what’s needed for the service to work.
• Contract (Article 6(1)(b)): Creating your account and processing payments is necessary to provide the paid subscription you signed up for.
• Legal Obligation (Article 6(1)(c)): Where we must comply with legal requirements, including retaining financial records.

7. Data Sharing and Disclosure

To produce translations, subtitle text is shared with our language-model provider (currently OpenRouter, which routes the request to an underlying model provider) acting as a data processor on our behalf. No other information about you is shared with them beyond the text needed to translate it and, where applicable, the language pair.

If you subscribe, your payment and billing information is shared with Stripe, our payment processor, acting as a data processor on our behalf.

We may also share information with:

• Legal Authorities: When required by law or to protect our rights

We do not sell your information to third parties, and we do not share it for marketing purposes.

8. Your Rights

You have the following rights regarding your personal data:

GDPR Rights (EU/EEA/UK residents)

• Right to Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (“right to be forgotten”)
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests

If you’re on the free tier, translation requests aren’t tied to a personal identifier, so we may not be able to locate a specific request tied to you unless you can provide details (e.g. approximate time and content). If you have a subscription, we can locate your data by your account email.

To exercise these rights, contact our Data Protection Officer at contact@revalfilm.info.

9. Data Security

We implement appropriate technical and organizational measures to protect information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure.

10. Data Retention

• The shared translation cache (original text → translation) is retained indefinitely, since it is keyed by the text itself, not by installation or user, and lets other viewers reuse the same translation.
• Rate-limiting data tied to an installation identifier or IP address is retained only as long as needed to enforce those limits.
• A local copy of your translations is stored in your browser and stays there until you clear your browser’s extension storage.
• Account, subscription, and billing records (including invoices) are retained for as long as your account is active and afterward as needed to comply with tax and accounting obligations.

11. International Data Transfers

Our translation provider and payment processor may process your data outside the EEA (e.g. in the United States). Where this happens, we rely on the provider’s own safeguards for such transfers (such as Standard Contractual Clauses). We do not otherwise transfer personal data internationally.

12. Children’s Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

Revalfilm OÜ Pae 21 Tallinn Estonia Email: contact@revalfilm.info