Last updated: July 14, 2026 · Version 1.2

Privacy Policy
& Cookies

This Privacy Policy explains how personal data is processed when you visit our website, use the SmartSubs Pro software, or make a purchase.

100% Privacy-First: The primary function of SmartSubs Pro (transcribing audio) happens entirely offline on your local computer. We do not run servers, nor do we receive your audio or video files.

Section 1

Data Controller

The entity responsible for processing your personal data on this website and in relation to the licensing of the Software is:

Antonio Pennino

Independent Developer · Natural Person

Country: Italy

Email: antonio.pennino.mail@gmail.com

Section 2

Local Data Processing (OpenAI Whisper)

The core processing pipeline of the SmartSubs Pro software executes exclusively on your local computer.

  • Audio/Video Files: Your project media, client work, and recorded audio are processed locally by the OpenAI Whisper model running on your CPU or GPU.
  • No Cloud Uploads: No audio or video data is ever uploaded to the internet, to our servers, or to third-party servers by the Software.
  • Fully Offline: Once installed, the transcription pipeline runs entirely offline without requiring an internet connection.

Section 3

Optional AI Services (Google Gemini API)

The Software offers an optional "Gemini Hook Detection" feature to automatically highlight high-impact words in your timeline by analyzing vocal intonation and emphasis.

  • Multimodal Audio Processing: If (and only if) you enable this feature, the Software exports a temporary, localized .wav audio file of the voice track from your DaVinci Resolve timeline and uploads it directly to Google Gemini APIs. This allows Gemini to analyze actual speech features (pitch variations, volume shifts, syllable elongation, and speed) rather than relying on a simple text-only script scan.
  • Immediate Data Deletion: The temporary audio file is protected under strict try...finally script blocks and is deleted permanently from Google's servers immediately after the emphasis analysis completes. We do not store, access, or log any audio files.
  • API Keys: You must configure the Software with your own Google Gemini API key. We do not collect, store, or have access to your API key.
  • Third-Party Terms: Google processes this audio data as an independent processor. By using this optional feature, you agree to the Google AI Terms of Service and the Google Privacy Policy.

Section 4

Payment Processing (Lemon Squeezy)

Our checkout transactions are handled securely by Lemon Squeezy, LLC (Merchant of Record).

When you purchase a license, you enter into a contract directly with Lemon Squeezy. Lemon Squeezy collects personal information necessary to complete the sale, including your name, email address, physical billing address, and credit card or payment details.

Lemon Squeezy is the independent Data Controller for this transaction data and processes it under their own privacy guidelines. For details on how Lemon Squeezy stores and protects your financial and personal info, please review the Lemon Squeezy Privacy Policy.

Section 5

Review Invitations (Trustpilot)

After a purchase we may invite you to leave a public review of the Software on Trustpilot. To do this, a copy of the welcome email we send you is forwarded to Trustpilot A/S, which then sends the invitation on our behalf.

  • What is shared: your email address, and your name where you provided it. No payment data, no audio, and no video is ever shared with Trustpilot.
  • Why: to collect genuine feedback from real customers. Our legitimate interest under Article 6(1)(f) GDPR is to improve the Software and to let prospective customers read honest, verified opinions.
  • Invitations are neutral: every customer receives the same invitation. We do not select who is invited, we do not offer any reward in exchange for a review, and we cannot edit or delete the reviews you write.
  • Opting out: if you would rather not be invited, reply to any of our emails and we will exclude you. You can also ignore the invitation, it is only sent once.

Trustpilot acts as an independent Data Controller for the reviews and account data you provide to them. See the Trustpilot Privacy Policy for details.

Section 6

Website Hosting & Server Logs

Our website is hosted on the Cloudflare Pages platform. When you browse this site, Cloudflare automatically collects standard technical logs from your browser.

This information includes your IP address, browser type, operating system, pages viewed, and access times. We utilize these server logs purely for technical diagnostics, site security, and ensuring stable network delivery. Cloudflare processes this data in compliance with data privacy regulations (GDPR/CCPA).

Section 7

Cookie Policy

Our website uses a minimal number of cookies, primarily to manage the shopping cart and ensure checkout integrity.

Source Purpose Type
Lemon Squeezy Handles shopping cart states, checkout overlay functions, and transaction security. Essential / Functional
Cloudflare Used for routing security and content delivery load balancing. Essential / Functional

Anonymous analytics (no cookies): We use Umami, a privacy-focused analytics service with data stored in the European Union, to count page views and see which pages are actually useful. Umami does not set cookies, does not store your IP address, and does not track you across other websites. It records only aggregated, anonymous information such as the page visited, the referring site, browser, operating system, device type and country. Because no cookies are used and no personal profile is built, this site does not require a cookie consent banner.

No Marketing Pixels: We do not deploy advertising trackers, remarketing pixels (e.g. Meta Pixel), or behavioral profiling cookies on our website.

Section 8

Your Data Protection Rights (GDPR & CCPA)

Depending on your location (e.g., if you reside within the European Union or California), you hold legal rights regarding your personal data:

  • Right of Access: You can request a copy of the personal data we hold about you.
  • Right of Rectification: You can request correction of inaccurate data.
  • Right to Erasure (Deletion): You can ask us to delete your contact or support email logs.
  • Transaction Data: For requests regarding purchase receipts, billing invoices, or transaction refunds, you should contact Lemon Squeezy support directly, as they manage the billing database.

Section 9

Contact Information

If you have any questions about this Privacy Policy, your data, or want to exercise your rights, please reach out directly: