Privacy Policy

Effective Date: September 11, 2026

This Privacy Policy outlines how SubMorph ("we", "us", or "our"), developed and published by MorphWorks, collects, uses, protects, and discloses information when you download, install, or use our mobile application on Android devices (Google Play Package ID: com.submorph.translator) and our online web localization suite at https://submorph.online (collectively, the "Services").

We are dedicated to building privacy-respecting software. SubMorph operates primarily as a client-side utility. Except for the optional 72-hour ephemeral cloud archive provided exclusively to signed-in users, we do not operate persistent media storage servers, and we never commercialize or harvest your personal content.

1. Scope & Developer Identity

This Privacy Policy applies universally to:

• The SubMorph: Subtitle Translator native Android application distributed via the Google Play Store and official download channels (Package: com.submorph.translator).
• The SubMorph Web Application accessible via modern desktop and mobile browsers.

The designated Data Controller for all operations governed by this policy is MorphWorks (morphworks@proton.me).

2. Client-Side Subtitle Processing, Guest Privacy & Optional 3-Day Ephemeral Cloud Archive

SubMorph operates with two transparent privacy tiers based on user choice:

• A. Guest / Unregistered Mode (Zero Server Retention): If you do not sign in, zero subtitle files, transcripts, or translations are transmitted to our servers. When you close or refresh your browser or app, temporary in-memory buffers are instantly purged. Output SRT files are saved directly to your local device Downloads folder.
• B. Optional Signed-In Mode (3-Day Ephemeral Cloud Archive): If and only if you explicitly choose to sign in with your Google Account, SubMorph provides an optional, user-facing cross-device archive feature. When you complete a translation while signed in, a copy of the translated SRT file is saved to an encrypted, isolated object storage bucket (hosted on Cloudflare R2 and indexed via Google Cloud Firestore) under your authenticated account key. This allows you to re-download or inspect recent translations seamlessly across your phone and desktop.
• Strict 72-Hour (3-Day) Automated Purge: Every archived subtitle file has an immutable 72-hour lifespan. Our backend automated engine enforces a strict FIFO auto-deletion routine that permanently deletes files after 3 days. Users can also manually purge all archived files at any time via the in-app "Clear Saved Subtitle Session Data" button or our Account Deletion Portal.

3. Third-Party AI Translation Engines

SubMorph connects directly to leading artificial intelligence models (such as Google Gemini, Groq, OpenRouter, DeepSeek, or OpenAI) to translate subtitle dialogues.

• Direct Encrypted Telemetry: Translation requests travel directly from your device to the official API endpoints of the chosen AI provider via Transport Layer Security (HTTPS/TLS 1.3). SubMorph does not proxy, inspect, or cache your text payloads.
• User-Supplied API Keys: API keys provided in your Settings are stored exclusively on your device (or in your private Firebase user document if cloud sync is enabled). Calls are billed and authorized under your own developer accounts with those third-party providers.
• Third-Party Compliance: When subtitle text is transmitted for translation, processing is governed by the respective privacy policies of each AI provider:
  • Google Privacy Policy (Gemini API)
  • Groq Cloud Privacy Policy
  • OpenRouter Privacy Policy
  • DeepSeek Privacy Policy
  • OpenAI Privacy Policy

4. User Accounts, Cloud Sync & Subprocessors (Optional)

Using an account in SubMorph is completely optional. You can translate subtitles, configure local keys, and export SRT files without registering or signing in.

If you choose to sign in using Google Sign-In (facilitated via Google Play Services and Google Firebase), we collect only the minimal data required to synchronize your settings and provide the optional 3-day history across your phone and PC:

Data Category	Specific Data Elements	Purpose	Retention & Storage
User Identity	Google Account ID, Display Name, Email Address, Profile Picture URL.	To authenticate your account session and display your avatar.	Managed securely by Google Firebase Authentication. Stored until account deletion.
User Settings	Encrypted personal AI API keys, subtitle pacing preferences, target language selection.	Cross-device synchronization (allowing you to use your saved keys on both web and Android app).	Stored in a private, authenticated Google Cloud Firestore record protected by strict security rules accessible only by your user UID. All data is encrypted at rest using AES-256 and transmitted via TLS 1.3.
Subtitle History (Optional)	Translated SRT subtitle text, original filename, source/target language codes, creation timestamp.	Cross-device translation archive (allows re-downloading translated subtitles on your phone or PC within 3 days).	Stored in an encrypted, private Cloudflare R2 object storage bucket and referenced in your authenticated Firestore document. Encrypted at rest (AES-256) and in transit (TLS 1.3). Automatically and permanently purged after 72 hours (3 days). Can be wiped manually anytime via the in-app Clear History button or the Account Deletion Portal.

Cloud Security Architecture & Subprocessors: SubMorph utilizes industry-leading cloud infrastructure providers adhering to ISO 27001, SOC 2, and GDPR standards:

• Google LLC (Firebase & Google Cloud Platform): Authentication, Firestore database metadata, and Android Vitals diagnostics (United States / Global data centers). Covered under European Commission Standard Contractual Clauses (SCCs) and EU-U.S. Data Privacy Framework.
• Cloudflare, Inc. (Cloudflare R2 Object Storage): Private, zero-egress encrypted object storage for the optional 3-day ephemeral subtitle archive. Data in transit is secured with TLS 1.3 and at rest with AES-256.
• Google LLC (Google AdMob): Mobile banner, interstitial, and app open advertisements with IAB Europe TCF v2.2 consent management via Google UMP SDK.
• Authorized AI Translation Engine Processors: User-selected AI engines (Google LLC [Gemini API], Groq, Inc., OpenRouter, Inc., DeepSeek Technology, or OpenAI, LLC) that receive encrypted subtitle line segments ephemerally via TLS 1.3 solely to fulfill translation requests without model training or persistent retention.

5. Mobile Advertising & Consent Management (Google AdMob & UMP SDK)

To keep SubMorph 100% free for global creators, the Android mobile application integrates Google AdMob (provided by Google LLC) to serve mobile advertisements (banner ads, interstitial ads upon translation completion, and app open ads).

In accordance with Google Play's Developer Policy on Advertising and regional data protection directives:

• Google Advertising ID (GAID / AAID): AdMob may collect and process your device's resettable advertising identifier to deliver frequency capping, ad measurement, and relevant advertisements.
• Diagnostic, Performance & Crash Telemetry: SubMorph does not embed standalone invasive analytics or third-party crash reporting SDKs (such as Firebase Crashlytics or Google Analytics). Anonymous crash metrics, ANR (Application Not Responding) traces, and network diagnostic reports are provided via native Google Play Console Android Vitals and Google AdMob Diagnostics solely to monitor app stability and resolve runtime crashes.
• IP Address: Used by Google to infer general coarse location (e.g., country or city level) to serve localized ads.
• Consent Management Platform (CMP) & Google UMP SDK: For users residing in the European Economic Area (EEA), the United Kingdom, and Switzerland, SubMorph implements the Google User Messaging Platform (UMP) SDK compliant with the IAB Europe Transparency and Consent Framework (TCF v2.2). Before any advertisements are requested, users are presented with a consent dialog allowing them to grant, deny, or customize consent for personalized or non-personalized advertising and vendor cookies.
• Opt-Out & Tracking Reset: You can modify or revoke your consent preferences at any time in the app settings, or reset/delete your advertising identifier through your Android system settings: Settings > Google > Ads > Reset advertising ID or Delete advertising ID.

6. Android Device Permissions Declared in App Manifest

The SubMorph Android application (com.submorph.translator) declares only the following permissions, each strictly tied to user-facing features:

Permission	Functional Rationale
android.permission.INTERNET	Required to communicate directly with AI translation APIs, authenticate Google Sign-In, sync preferences, and load AdMob advertisements.
android.permission.ACCESS_NETWORK_STATE	Allows the app to verify active Wi-Fi or cellular connectivity before initiating multi-batch translations.
android.permission.FOREGROUND_SERVICE android.permission.FOREGROUND_SERVICE_DATA_SYNC	Ensures uninterrupted translation when users minimize the app or switch windows during long movie subtitle translations (Service: ForegroundTranslationService).
android.permission.POST_NOTIFICATIONS	Displays a non-intrusive progress notification bar while translating long files in the background and alerts you when the file is ready for download.
android.permission.WAKE_LOCK	Prevents phone CPU sleep mode during active batch translation requests.
READ / WRITE_EXTERNAL_STORAGE (API ≤ 32)	Allows reading user-selected SRT files and saving translated outputs on older Android versions (modern Android versions use the Storage Access Framework).

7. International Compliance: European Economic Area & UK (GDPR)

If you reside in the European Economic Area (EEA) or the United Kingdom, your data is protected under the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018. SubMorph processes personal data under the following lawful legal bases:

• Consent (Article 6(1)(a)): For optional Google Sign-In authentication, cloud key synchronization, and advertising consent collected via Google UMP.
• Legitimate Interests (Article 6(1)(f)): For essential crash diagnostics, software stability, and fraud prevention.

Under GDPR, you hold the following enforceable rights:

1. Right of Access & Portability: You may request an export of your cloud-stored preferences and account data.
2. Right to Rectification: You may correct or update your saved API keys and settings at any time in the Settings menu.
3. Right to Erasure ("Right to be Forgotten"): You may permanently delete your account and all associated cloud documents (see Section 10).
4. Right to Restrict or Object to Processing: You may sign out or revoke Google Sign-In permissions.
5. Right to Lodge a Complaint: You have the right to file a complaint with your national Data Protection Authority (DPA).

Statutory Response Timeline: In accordance with Article 12(3) of the GDPR, we will respond to and fulfill verified requests regarding access, rectification, portability, or restriction within thirty (30) calendar days of receipt. Account and data deletion requests are handled on an expedited schedule within 48 hours.

International Data Transfers & Standard Contractual Clauses (SCCs): SubMorph utilizes cloud infrastructure provided by Google LLC (Firebase / Google Cloud Platform) and Cloudflare, Inc. (R2 Storage). Where personal data or subtitle archives are transferred outside the European Economic Area (EEA) or the United Kingdom (such as to secure infrastructure located in the United States), such transfers are strictly governed by European Commission-approved Standard Contractual Clauses (SCCs) and participating commitments under the EU-U.S. Data Privacy Framework (DPF), guaranteeing an equivalent standard of data protection.

8. Notice to California Residents (CCPA / CPRA)

Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Categories Collected: Identifiers (Name, Email, Google UID, IP address, Device Advertising ID).
• Global Privacy Control (GPC): SubMorph recognizes and honors automated browser-level Global Privacy Control (GPC) signals. If your browser or device broadcasts a GPC signal, our web application automatically disables non-essential telemetry and honors your opt-out preference.
• Non-Discrimination: We will never discriminate against you (by denying service, charging different rates, or degrading app quality) for exercising your privacy rights.
• Request Submission: California residents can exercise their rights to know, delete, or correct personal information by submitting a request via our Account Deletion Portal or emailing us at morphworks@proton.me.

9. Google Play Store Data Safety Declaration (1-to-1 Mapping)

To assist users and Google Play reviewers in auditing our Data Safety section, the table below reflects our exact Play Console declarations:

Data Type	Collected?	Shared?	Purpose	Ephemeral / Encrypted?
Personal Info (Name, Email)	Yes (Optional)	No	Account Management & Cloud Settings Sync.	Encrypted in transit (TLS 1.3) and at rest (Firestore AES-256).
Device or Other IDs (Advertising ID)	Yes (by Google AdMob)	Yes (with Google AdMob)	Advertising, Analytics & Fraud Prevention.	Encrypted in transit. User can reset or delete GAID anytime. Controlled via Google UMP CMP.
App Info & Performance (Crash Logs & Diagnostics)	Yes	No	Diagnostics, Crash Analysis & App Reliability.	Encrypted in transit. Anonymous crash logs and ANR metrics collected via Google Play Console Android Vitals and Google AdMob diagnostics. No separate third-party analytics trackers.
Files & Documents (SRT Subtitles)	Yes (Optional)	NO	App Functionality (Optional 3-Day Ephemeral Cross-Device History for signed-in users only). 0% collected for guest users.	Encrypted in transit (TLS 1.3) and at rest (Cloudflare R2 AES-256). Strictly auto-deleted after 72 hours (3 days), or immediately via in-app Clear History / Account Deletion Portal. Subtitle lines are transmitted ephemerally to user-selected AI APIs solely for translation.

10. Dedicated Account & Data Deletion Portal

In full compliance with Google Play's mandatory Data Deletion Policy and global privacy standards, SubMorph provides an accessible web resource and in-app self-service mechanisms for users to request and execute permanent account and data deletion:

A. Instant In-App / Web Self-Service Deletion

1. Open the SubMorph app or navigate to the web tool at https://submorph.online.
2. Open the Settings panel (gear icon).
3. Click Sign Out & Wipe Cloud Data (or Clear All Local Data).
4. Your local cache, API keys, preferences, and session tokens are immediately wiped from device memory. If signed in, our synchronization engine automatically calls the Firestore deletion API to purge your user-isolated document. Alternatively, visit our Account Deletion Page while logged in to delete your Firebase Auth record in one click.

B. Direct Deletion Request via Email (Web & Account Deletion)

If you have uninstalled the app or prefer to request full deletion through developer support:

• Submit your request via our Web Deletion Portal or email us directly at: morphworks@proton.me
• Subject: SubMorph Data Deletion Request
• Body: Specify the Google Account email address you used to sign in.
• Execution Window & Data Retention: Upon receiving your request, your Firebase Auth record and all associated Cloud Firestore documents will be permanently purged within 48 hours, and you will receive a confirmation email. Following deletion, SubMorph retains 0 bytes of your data.

11. Target Audience & Age Limitation (Exclusively 18+)

SubMorph is designed as an advanced, professional AI subtitle localization and translation suite for film creators, content producers, and adult general audiences. Our services are strictly directed to, marketed for, and intended for use by individuals aged 18 and older.

We do not knowingly target, solicit, or collect personal information from individuals under 18 years of age. If a parent, legal guardian, or supervisory authority becomes aware that a minor under 18 has submitted personal information or created an account, please contact our Data Controller at morphworks@proton.me. Upon verification, we will promptly purge all associated records from our systems within 48 hours.

12. Changes to This Privacy Policy

We may update, revise, or amend this Privacy Policy periodically to reflect enhancements in SubMorph capabilities, shifts in operational workflows, or emerging international legal requirements. When updates are published, we will revise the "Effective Date" at the top of this document.

For material modifications that significantly affect your data privacy rights, we will provide prominent notification (such as an in-app notice or website banner) prior to the changes taking effect. We encourage you to review this policy periodically to stay informed about our data protection standards. Your continued use of SubMorph following the posting of an updated Privacy Policy constitutes your acknowledgment and acceptance of the revised terms.

13. Governing Law & Jurisdiction

This Privacy Policy and any disputes arising out of or in connection with SubMorph shall be governed by and construed in accordance with applicable general principles of international consumer data protection, electronic commerce standards, and fair trade practices, without prejudice to mandatory statutory consumer protections and data subject rights granted under the General Data Protection Regulation (GDPR) in the European Economic Area and the United Kingdom, or the California Consumer Privacy Act (CCPA/CPRA) in the United States.

14. Contact Information & Data Controller

If you have any questions, inquiries, regulatory requests, complaints, or feedback regarding this Privacy Policy or SubMorph's security practices, please contact our developer team:

• Developer: MorphWorks
• Application Name: SubMorph: Subtitle Translator
• Google Play Package: com.submorph.translator
• Official Support Email: morphworks@proton.me
• Official Website: https://submorph.online
• Dedicated Deletion Portal: https://submorph.online/delete-account