Privacy Policy
Effective 17 September 2026
This Privacy Policy explains how Arcada LLC (Business ID 7682190, 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, USA) processes personal data when you use the Subtl applications, subtl.me and app.subtl.me. For the data described here, Arcada is the controller. Questions and requests: privacy@subtl.me.
The short version: call audio is never stored; transcripts stay on your device unless you turn on cloud history; context files expire; we do not sell personal data or use your calls to train models; and you can export or delete your data from the cabinet at any time.
1. What we process and why
| Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Call audio from your device's output and microphone | Real-time transcription and translation while a session runs | Contract | Not stored. Held in memory and sent over TLS to the transcription provider; not written to disk by the app or kept on our servers. |
| Transcripts, translations and suggested replies | Showing them to you during and after the call | Contract | Kept on your device. Copied to our servers only if you enable cloud history, until you delete them or the account. |
| Call details: time, duration, languages, minutes used, and the generated summary | Your history, minutes accounting, summaries | Contract | Until you delete the meeting or the account. The full transcript used to write a summary is discarded after the summary is created, unless cloud history is on. |
| Presets and context files you upload | Grounding suggestions in your documents | Contract | Files are split into text passages and embeddings, encrypted at rest, and deleted 30 days after the last meeting that used them. |
| Account: email, name if provided, sign-in method, language, plan and minutes | Providing the account and the plan | Contract | Until you delete the account. |
| Devices: platform, device name, last seen | Sessions and the device limit | Contract | Until you remove the device or delete the account. |
| Sign-in history: time, method, IP address, browser or app; last activity time and IP | Security, fraud and abuse prevention, support | Legitimate interests | Until you delete the account. |
| Payments: subscription status, Stripe customer and subscription identifiers, invoices | Billing, tax and accounting | Contract; legal obligation | For the account's lifetime, and invoices for as long as tax law requires (typically 7 years). Card details are handled by Stripe and never reach us. |
| Your own AI provider keys | Routing requests to your provider | Contract | Stored in your device keychain. When routed through our server, sealed to our server key; decrypted only in memory per request, never logged. Deleted when you remove the key. |
| Support messages: emails to @subtl.me addresses and messages from the cabinet | Answering you, improving the Service | Contract; legitimate interests | Up to 3 years after the last message, or earlier on request. |
| Website statistics: page, referring site, campaign tags, page language, device class, browser-language region | Understanding how the site is used | Legitimate interests | 25 months. No cookies; visits are grouped by a hash that changes every day, and IP addresses are not stored. Do Not Track and Global Privacy Control are honoured. |
| Product telemetry and error reports: counters, timings, crash traces, app version, platform | Reliability, performance and fixing bugs | Legitimate interests; consent where required | 12 months for usage counters, 90 days for error reports. Never includes call audio or transcript text. Can be switched off in the app's privacy settings. |
2. What we do not do
- We do not sell or rent personal data, and we do not share it for cross-context behavioural advertising.
- We do not use your call audio, transcripts or context files to train machine-learning models, and our model providers are contractually barred from doing so.
- We do not listen to or read your calls. Staff access to account data is limited to what support, security and billing require, and actions taken in our admin tools are logged.
- We do not store call audio.
3. Who processes data for us
We use service providers (subprocessors) for hosting, model processing, payments, email and sign-in. Each one processes data only on our instructions and under a data processing agreement. The current list, with what each one sees and where, is on the Subprocessors page. We may disclose data if the law requires it, to protect rights and safety, or to a successor in a merger or acquisition, which would remain bound by this policy.
4. Where data is processed
Our servers and database run in Google Cloud data centres in the European Union (Belgium and Poland). Some providers, including model providers and Stripe, process data in the United States and other countries. Where personal data leaves the EEA, the UK or Switzerland, we rely on the European Commission's Standard Contractual Clauses, the EU–US Data Privacy Framework where the provider is certified, or another lawful transfer mechanism.
5. Security
- TLS for all traffic; encryption at rest for the database and backups.
- Short-lived access tokens, refresh tokens stored hashed, and device-bound sessions.
- Least-privilege access for staff, with an audit log of administrative actions.
- Database backups are kept for 30 days, so deleted data can remain in a backup for up to 30 days before it is overwritten.
6. Your rights
Depending on where you live, you may have the right to access your data, receive it in a portable format, correct it, delete it, restrict or object to processing, and withdraw consent at any time without affecting earlier processing.
- Export: download everything we hold about your account from the cabinet (Your data → Export).
- Delete: delete your account from the cabinet; it is removed at once and purged within 24 hours, apart from backups (30 days) and records we must keep by law.
- Telemetry: switch it off in the app's privacy settings.
- Anything else: write to privacy@subtl.me. We answer within 30 days and may ask you to confirm that the account is yours.
- If you are in the EEA or the UK you may complain to your data-protection supervisory authority. We would appreciate the chance to resolve your concern first.
7. United States privacy rights
Residents of California and other US states with comprehensive privacy laws may request to know, access, correct and delete personal data and to obtain a copy of it. We do not sell personal data or share it for targeted advertising, and we do not use sensitive personal data to infer characteristics. You may use an authorised agent, and we will not discriminate against you for exercising your rights. The categories of data, sources, purposes and recipients are set out in sections 1–3 above.
9. Children
Subtl is intended for people aged 18 and over. We do not knowingly collect data from children. If you believe a child has created an account, write to privacy@subtl.me and we will delete it.
10. Automated processing
Subtl uses automated models to transcribe, translate, suggest replies and summarise, at your request and for your use. It does not make decisions about you that produce legal or similarly significant effects.
11. Changes to this policy
We will post changes here with a new effective date. Material changes are announced by email or in the Service at least 30 days before they take effect.
12. Contact
- Arcada LLC, 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, USA
- Privacy requests: privacy@subtl.me
- Support: hello@subtl.me