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Privacy Policy

Subloom — Auto Captions Offline

Effective: 29 October 2026 · 한국어

1. What we collect

We collect and keep no personal data ourselves. There is no sign-up, no login and no account. The only thing the app sends to our server is the anonymous usage events described below, which contain no personal data. The advertising SDKs bundled in the app do collect data in order to serve ads (see section 4).

• Your videos, their audio and the captions never leave your device. Speech recognition runs entirely on your phone with a speech model that is installed from Google Play together with the app. You choose a video with the system Photo Picker (or share one to Subloom from another app); the app reads only that video, extracts its audio into its private cache, recognises the speech, and saves your captioned copy or subtitle file where shown after export (by default Movies/Subloom for videos and Download/Subloom for SRT/VTT files). Nothing is uploaded — the app works in airplane mode.
• The optional High-accuracy model is downloaded from Google Play (Play Asset Delivery) only if you choose it in Settings. It is delivered by Google, not by our server, and you can remove it any time.
• Working files created while processing (decoded audio) are kept in the app's private cache and deleted when processing finishes, is cancelled, or the next time the app starts.
• Your projects (the caption text, word timings, style and a link to the source video you picked) and your settings are stored in the app's private storage on your device so you can continue editing later. They are never sent anywhere.
• The app does not use the microphone or the camera and does not ask for access to your photo or video library — the Photo Picker gives it only the video you pick.
• The advertising identifier (GAID) is used by the ad SDKs. Our own app code neither reads nor stores it.
• Anonymous usage events — the app sends a small, fixed set of anonymous events to a server we operate: first launch, a video being opened, captioning finishing (with the model used, the caption language you picked and a coarse speed bucket) or failing (with a technical failure reason), the first caption edit of a project, an export finishing (MP4, SRT or VTT) or failing (with a technical reason), sharing a result, the Pro screen being shown and where it was opened from, purchase started, completed, cancelled or failed (with a technical failure reason), restore attempted, a rewarded ad being offered, tapped, granted or failing to display, the review prompt being shown, and whether the app was reopened on day 1 and day 7. Each event carries only an install identifier the app generates at random, an app tag, the event name, that short label and a timestamp; no advertising ID, device identifier, name, file name, video, audio or caption text is included. We use it solely to see where people drop off, and raw events are deleted within 90 days, leaving only aggregate counts. Events are not sent from emulators or Google Play's automated test devices.
• There is no third-party analytics or crash-reporting SDK in the app.

2. Where data lives

Data	Purpose	Location
Videos you pick or share to the app, and their audio	Recognising speech for captions	On device only — never uploaded
Captions, word timings, styles (projects)	Editing and exporting	On device, in the app's private storage
Captioned videos and SRT/VTT files you export	Your result	On device, in the folder shown after export
Settings	Running the app	On device
Whether Subloom Pro was purchased / subscribed	Unlocking and restoring the purchase	On device + Google Play
Free video exports used today	The daily free allowance	On device — never sent
Anonymous usage events (random install identifier only)	Seeing where people drop off	Our server — raw events for up to 90 days, then aggregates only

3. App permissions

Permission	Used for
Photo Picker (no permission)	Choosing the video to caption. The app sees only the video you pick.
Foreground service (data sync / media processing)	Keeping a long captioning or export running while the screen is off, with a progress notification.
Notifications	Showing captioning and export progress.
Storage (Android 8–9 only)	Saving exported videos and subtitle files to Movies/Subloom and Download/Subloom. Newer Android versions need no permission for this.
Internet	Showing rewarded ads, in-app purchase, the optional High-accuracy model download from Google Play, sending anonymous usage events. Captioning itself does not use the network.

4. Third-Party Services

Google Play Billing — in-app purchases and subscriptions are processed by Google, and the app only checks whether you own an item. We never see your payment details. Google's handling is covered by the Google Privacy Policy. You can cancel a subscription any time in Google Play → Payments & subscriptions.

Google Play (asset delivery and in-app review) — the speech models are delivered by Google Play, and the rating prompt is shown by Google Play's in-app review. Both are covered by the Google Privacy Policy.

Unity LevelPlay & Unity Ads (Unity Technologies / ironSource) — to serve rewarded ads via mediation, it collects and uses the advertising identifier (GAID), IP address, device information (model, OS version, language, etc.) and ad-interaction data, which may be passed to advertising partners during ad bidding. Unity's handling is covered by the Unity Privacy Policy, and you can opt out of personalized ads via the information icon shown on ads. Your videos, audio, captions and file names are never passed to the ad SDKs.

Ad mediation partners — ads are selected through Unity LevelPlay mediation, which runs a real-time auction among the networks below. Each network's SDK is included in the app and, when it takes part in an auction, may process the advertising identifier (GAID), IP address (used to estimate an approximate region), device information, ad-interaction data and SDK diagnostic/crash information for ad delivery, measurement and fraud prevention. Each partner's handling is covered by its own policy:

Partner	Privacy policy
Unity LevelPlay · Unity Ads · ironSource Ads (Unity Technologies)	unity.com
Liftoff Monetize (Vungle)	liftoff.io
Mintegral	www.mintegral.com
Pangle (ByteDance)	www.pangleglobal.com
AppLovin	www.applovin.com
Meta Audience Network	www.facebook.com
DT Exchange (Digital Turbine)	www.digitalturbine.com
InMobi	www.inmobi.com
Moloco	www.moloco.com

5. Consent in Europe (GDPR / EEA, UK, Switzerland)

On devices that appear to be in the EEA, the UK or Switzerland, the app shows the InMobi Choice consent dialog (CMP) before an ad can be offered. It follows the IAB TCF standard.

• If you do not consent, or you dismiss the dialog, the ad SDKs are not initialised at all — no ad request is sent. Captioning, editing, subtitle files and your free daily video exports work the same either way.
• You can reopen it and withdraw consent any time from Settings → "Privacy choices". After withdrawal, any already-loaded ad is discarded rather than shown.
• Outside those regions the dialog does not appear; you can still limit personalised ads by resetting or deleting the advertising ID in your device settings.

6. International transfers

We transfer no personal data ourselves. The anonymous usage events in section 1 are processed on Cloudflare infrastructure (which may be located abroad) and contain no personal data. The advertising partners listed in section 4 may process data on servers abroad (including the United States) while serving ads, under their own policies. In Europe this only happens after the consent described in section 5.

7. Ads and purchases

• The app shows only rewarded ads, and only when you choose one ("Watch an ad for 1 more video export"). There are no banner or interstitial ads.
• Free: captioning and editing, videos up to 3 minutes (longer videos get their first 3 minutes captioned), a daily allowance of captioned video exports without a watermark, and unlimited SRT/VTT subtitle files. Subloom Pro (one-time purchase, or a monthly or yearly subscription) removes the length and daily limits and exports in the original resolution; Pro shows no ads.

8. Children

This app is for a general audience and is not directed at children under 13.

9. Your rights

• Change or withdraw ad consent — Settings → Privacy choices (devices in Europe).
• Reset or delete the advertising ID — device Settings → Privacy → Ads.
• Delete a project — long-press it on the home screen.
• Delete everything — removing the app (or clearing its storage) erases projects, settings and downloaded models. Videos and subtitle files you exported stay in your folders until you delete them.
• Questions — email us at the address below.

10. Contact

Email: leehywo@gmail.com

Privacy contact: AppFactory Studio Privacy  |  leehywo@gmail.com

11. Change history

Date	Change
2026-10-29	First published (launch preparation)