Privacy Policy

The controller for the information described on this page is SubtitleFlow LTD, a company registered in England and Wales under company number 17459348, whose registered office is at 167-169 Great Portland Street, London, England, W1W 5PF.

Every question about this policy, and every request under it, goes to operations@subtitleflow.org, or by post to the registered office.

Four things, and nothing else:

• What you write to us. Your name, the address you want the reply to go to, any organisation you name, and the contents of your message. The enquiry form assembles that message in your browser and hands it to your own email application; it is not stored on this website, because this website has no store to put it in.
• The recording you send, and what is in it. The video or audio file, the speech on it, the names in that speech, and any list of terms or scripts you send with it.
• The record of an order. Quotations, order confirmations, invoices, the files delivered, and the correspondence around them. Payments carry a reference from the payment provider; card numbers never reach us at all.
• Server logs. The company that hosts this site records requests to it in the ordinary way, including the network address the request came from, the time, the page and the browser's own description of itself.

A recording belongs to you, and so does responsibility for having the right to send it. When you send one, you confirm that you may lawfully do so, including so far as anyone who appears or speaks on it is concerned.

We handle it for your order and on your instructions: to transcribe it, check the text against it and time the captions. It is not published, not shown to anyone as an example of our work, not passed to anyone outside your order, and not used to train any system.

Where a recording contains information about health, beliefs, criminal matters or anything else that carries extra protection in law, tell us before you send it so that how it is handled can be agreed in writing.

• Answering your enquiry and preparing a written quotation for it.
• Carrying out an order: transcription, checking, timing, delivery and corrections.
• Invoicing, taking payment through a payment provider, and keeping the accounts.
• Answering questions and complaints afterwards, and keeping a record that it was done.
• Keeping this website available and dealing with attacks on it.

It is not used for anything else. There is no marketing list, nothing is sold to anybody, and nothing here is used to build a profile of you.

• Article 6(1)(b), the contract and the steps before it. An enquiry, a quotation, an order and its delivery all sit here.
• Article 6(1)(f), legitimate interests. Keeping a record of enquiries that did not become orders, so that a conversation can be picked up where it stopped; keeping this site secure; and being able to defend a claim if one is ever made. We have weighed those against your interests, and none of them involves contacting you for anything you did not ask about.
• Article 6(1)(c), a legal obligation. Accounting and tax records have to be kept, whatever anybody would prefer.

These, for the reasons given, and nobody else:

• the company that hosts this website, which records requests to it;
• the provider of our email, through which every message travels;
• the payment providers used to take payment, which at present are Stripe and PayPal. They handle the payment and the card details themselves; we see that a payment was made, not what it was made with;
• an accountant, for the records tax law requires;
• anybody we are obliged to disclose to by law, or by a court, which we would tell you about unless we were forbidden to.

Nothing is sold, rented or handed to an advertising network. There is no such network here.

Some of those suppliers operate outside the United Kingdom. Where information reaches them there, it goes under the protections the law provides for it: either a set of adequacy regulations covering the country in question, or the Information Commissioner's International Data Transfer Agreement, or its Addendum to the European Commission's standard contractual clauses.

Which supplier is used for what changes over time. Ask at operations@subtitleflow.org and you will be told who currently holds what, and on which of those bases.

• An enquiry that did not become an order. Kept while the conversation is live and deleted once it plainly is not, or straight away if you ask.
• Your recording and the working files. Kept while the order runs and for the period named in the order confirmation afterwards, so that a correction or a re-export does not mean sending the video again. Deleted sooner if you ask.
• The delivered files. Kept for the same period as the working files, then removed. Keep your own copy: that is the one that lasts.
• Invoices and accounting records. Six years from the end of the financial year they fall in, because tax law requires it. That period we cannot shorten, even at your request.
• Server logs. As long as the hosting provider keeps them in the ordinary course, which is short.

None of it is required by law, and there is no statutory or contractual obligation on you to provide any of it. What follows is only practical consequence: without an address to reply to there is no reply, and without a recording there is nothing to quote on or work from.

There is no automated decision-making with legal or similarly significant effects, and no profiling. Quotations are worked out by a person looking at your recording, and what happens to an enquiry is decided by a person reading it.

This site sets no cookies. It writes nothing to your browser's local storage or session storage, it carries no analytics, no advertising tags, no embedded video players and no social media buttons, and it therefore asks for no consent to storage technologies, because there is nothing to consent to.

The one thing that happens without asking is the record the hosting company's server makes of the request, which is not storage on your device at all. Fonts are served from this site rather than from anybody else's, so loading a page tells no third party that you did.

If that ever changes, this page changes with it before the thing itself is switched on, and anything requiring consent will ask for it.

Over information about you, you have the right to:

• be told what is held and get a copy of it;
• have anything inaccurate corrected, and anything incomplete completed;
• have it erased, where there is no longer a reason to hold it;
• have its use restricted while an objection or a correction is being sorted out;
• object to its use where that use rests on legitimate interests, including the record-keeping described above;
• receive what you gave us in a machine-readable form, or have it sent straight to somebody else, where that is technically possible;
• withdraw consent, where anything is ever done on the basis of consent. Withdrawing it does not unpick what was lawfully done beforehand.

Write to operations@subtitleflow.org and say which of them you are exercising. We may need to establish that you are who you say you are, since handing a recording to the wrong person is the failure this is meant to prevent. There is no charge, and the answer comes within one month, as the law requires.

Tell us first, at operations@subtitleflow.org: it is the quickest route to it being put right, and we answer every complaint in writing.

You can also complain to the Information Commissioner's Office, which regulates this in the United Kingdom, at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or through ico.org.uk. You do not have to come to us first, and nothing on this page is a condition of complaining to them.

The date of this edition is at the head of the page. A changed page is published here with a new date on it, and where a change affects an order that is already running, the customer is told about it by email rather than left to find it.