Privacy Policy

1. Introduction

This Privacy Policy ("Policy") explains how our audio transcription service (hereinafter "Service", "we", "us", or "our") collects, uses, processes, and protects information in connection with your use of our Service. This Policy applies to all users of the Service globally.

We are committed to protecting your privacy and ensuring transparency about our data practices. This Policy is designed to be GDPR-compliant and respects applicable data protection regulations worldwide.

2. Data Controller and Processor Relationship

For the purposes of data protection regulations including the General Data Protection Regulation (GDPR):

• You are the data controller of any personal data or audio content you provide to the Service
• We are the data processor acting on your behalf
• Google Cloud (via Google Cloud Speech-to-Text) is a sub-processor that processes audio content

By using the Service, you acknowledge and accept that we process data as your processor and that third-party sub-processors, including Google Cloud, may have access to audio content for transcription purposes.

3. Information We Collect

3.1 Anonymized Client Data

We collect the following anonymized data from your desktop client application:

• Feature Usage Metrics: Information about which features you use and how frequently
• Crash Reports: Technical data about application crashes or errors (without personal identifiers)
• Performance Metrics: System performance data including processing speed, latency, and resource usage
• Device Specifications: Information about your operating system, device type, and hardware specifications (without identifying your device)
• Token Consumption: Data about the volume of transcription tokens you use

3.2 Transcription Processing Metadata

During audio transcription processing, we collect and retain the following anonymized metadata only:

• Processing Timestamps: The date and time transcription occurred
• Language Used: The language(s) detected and processed in the audio
• Processing Region: The geographic region where transcription was processed
• Transcription Length: The duration or length of the transcription
• Transcription Latency: The time taken to complete transcription

3.3 What We Do NOT Collect

We explicitly do not collect or retain:

• Audio Content: The actual audio files you provide for transcription
• Transcription Content: The text output generated by the transcription process
• Personal Information: Names, email addresses, phone numbers, IP addresses, or other identifying information
• Biometric Data: Voice patterns, speaker identification, or other biometric identifiers
• Content-Related Data: Information about what is being discussed in your audio

4. Legal Basis for Processing

We process anonymized data and metadata for the following lawful purposes:

• Contract Performance: To provide the Service you request
• Legitimate Interests: To improve service quality, prevent fraud, and identify anomalies in system performance
• Compliance: To comply with applicable laws and regulations

Since we process only anonymized data that cannot identify you as a data subject, much of our processing falls outside the scope of GDPR. However, any residual personal data is processed with your consent through your acceptance of this Policy and the Terms of Service.

5. How We Use Your Data

5.1 Service Improvement

We use anonymized data and metadata to:

• Analyze feature usage patterns
• Identify performance bottlenecks and optimize system efficiency
• Debug technical issues and improve reliability
• Understand user behavior trends (in anonymized form only)

5.2 Fraud Detection and Prevention

We use metadata and anonymized data to:

• Detect unusual patterns that may indicate fraud or abuse
• Monitor for token consumption anomalies
• Identify potential paid service fraud
• Prevent circumvention of payment mechanisms

5.3 Service Administration

We use data to:

• Maintain and operate the Service
• Respond to technical issues
• Process appeals regarding account termination

6. Data Retention

• Anonymized Metrics and Metadata: Retained for a reasonable period necessary to analyze performance, detect anomalies, and prevent fraud. This typically ranges from 3 to 12 months, after which data is deleted or further anonymized.
• Audio Content: Not retained by us. Audio is processed in real-time and immediately deleted after transcription.
• Transcription Content: Not retained by us. Content is generated by Google STT and your responsibility.
• Account Data: Retained while your account is active and for a reasonable period after termination to manage appeals and maintain audit trails.

7. Third-Party Data Sharing

7.1 Google Cloud Speech-to-Text

We share audio content with Google Cloud for transcription purposes. Google's processing is governed by:

• Google Cloud's Terms of Service
• Google Cloud's Privacy Policy
• Your acceptance that audio will be processed by Google's infrastructure

You are responsible for ensuring you have the legal right to provide audio to Google Cloud for processing.

7.2 No Other Third-Party Sharing

We do not share your anonymized data, metadata, or personal information with any other third parties, advertisers, or marketing partners.

7.3 Legal Requirements

We may disclose data if required by law, court order, or government authority. We will attempt to provide notice where legally permitted.

8. International Data Transfers

Since the Service is global and we use Google Cloud infrastructure, your data may be processed in multiple jurisdictions outside your country of residence. By using the Service, you consent to such transfers. We ensure that transfers comply with applicable data protection regulations, including GDPR adequacy decisions and Standard Contractual Clauses where applicable.

9. Data Subject Rights (GDPR)

If you are a resident of the European Union or other jurisdiction with applicable data protection laws, you may have the following rights:

9.1 Right of Access

You have the right to request what anonymized data we hold about you.

9.2 Right to Rectification

You have the right to correct inaccurate data.

9.3 Right to Erasure

You have the right to request deletion of your data, subject to legal retention obligations.

9.4 Right to Restrict Processing

You have the right to restrict how we process your data.

9.5 Right to Data Portability

You have the right to receive your data in a structured, commonly used, and machine-readable format.

9.6 Right to Object

You have the right to object to certain types of processing.

To exercise any of these rights, contact our Data Protection team at contact@equalgaming.co. We will respond to requests within 30 days or as required by applicable law.

10. Security

We implement industry-standard security measures to protect your data from unauthorized access, modification, disclosure, or destruction, including:

• Encryption of data in transit (TLS/SSL)
• Secure authentication mechanisms
• Limited access to data on a need-to-know basis
• Regular security assessments

However, no security system is completely impenetrable. While we strive to protect your information, we cannot guarantee absolute security.

11. Children's Privacy and Parental Consent

Minors (individuals under 18 years of age) may use the Service only with the consent and supervision of a legal parent, guardian, or adult representative. Parents and guardians are responsible for:

• Monitoring their child's use of the Service
• Ensuring the child complies with these Privacy Policy and the Terms of Service
• Reviewing this Privacy Policy with their child
• Authorizing any data collection and processing on their child's behalf

If you are a parent or guardian, you may contact us to exercise data subject rights on behalf of your child, including requesting access to, deletion of, or restrictions on your child's data.

12. Contact Information

For questions about this Privacy Policy, to exercise your data subject rights, or to report privacy concerns, please contact us.

13. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated to you via email or through the Service. Your continued use of the Service after changes constitutes your acceptance of the updated Policy.

14. Legal Basis for Processing Under GDPR

The following table summarizes our legal bases for processing under GDPR Article 6:

15. Data Protection Impact Assessment (DPIA)

Given that we process audio content through Google Cloud and collect anonymized metadata, we have conducted a Data Protection Impact Assessment. The assessment concluded that:

• Risks are minimal due to anonymization and lack of personal data retention
• Appropriate technical and organizational measures are in place
• Google Cloud's infrastructure provides adequate safeguards

16. Data Processing Agreement

As a data processor, we maintain a Data Processing Agreement (DPA) with you as the data controller. This DPA outlines:

• The scope and purpose of processing
• Duration and nature of processing
• Types of personal data processed
• Security obligations and sub-processor management

A copy of our DPA template is available upon request.

17. Entire Agreement

This Privacy Policy, together with our Terms of Service, constitutes the entire agreement regarding privacy and data protection.