Privacy Policy

1. Overview and Scope

Subtile is a Twitch clip aggregator and editing tool for clip farmers and content creators. It is operated by YUKARI LABS SRL, a company registered in Belgium under enterprise/VAT number BE1033402366, with its registered office at Cantersteen 47, 1000 Brussels, Belgium. Subtile is accessible at https://app.subtile.ai (the "Service"). YUKARI LABS SRL is the controller of the personal data described in this Privacy Policy.

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you disagree with any part of it, please do not use the Service.

2. Information We Collect

2.1 Account and authentication data

You can sign in with email and password, Google, or Twitch. We store your email and a password hash for email sign-in, and your provider account ID, name, email, and profile image for Google sign-in. Matching verified emails link sign-in methods to the same account. Resend receives your email address to deliver verification and password-reset codes. We do not store your password in plain text. When you authorize Subtile, Twitch shares, and we store: your Twitch user ID, login and display name, profile image, and (where you have granted it) your email address. We also store the OAuth access and refresh tokens issued by Twitch so the Service can call the Twitch API on your behalf — for example, to read the channels you follow and to fetch clip and VOD data. You can revoke this authorization at any time from your Twitch account's Connections settings.

2.2 Workflow and content data

Data you create or upload in the Service: the boards you build, the streamers you add to them, your clip queue, drafts, settings, any media you upload, and the editing projects and rendered outputs you produce. This is stored in our database to provide the Service to you.

2.3 Clip and VOD media

To let you preview, download and edit clips, the Service fetches clip and VOD media from Twitch. We process, and may store or cache, this media as needed to provide the features you use (such as preview, download, editing and rendering). We follow a data-minimization, least-privilege approach: we limit this media to what is needed for those features and restrict access to it.

2.4 Audio processed for subtitles

When you generate subtitles, the audio of the clip you are working on is sent to our speech-to-text provider for transcription and returned to you as captions. That extracted clip audio is processed for transcription only and is deleted as soon as the transcript is produced. Transcribing a full VOD works differently: we first create an audio-only copy of the whole recording in our own storage and transcribe from there, so that copy is retained under the media retention rule in section 8 rather than deleted immediately.

2.5 Technical data

We automatically collect limited technical data: device and browser information, your IP address (used transiently for rate limiting and abuse prevention and not stored as part of your profile), and error and diagnostic logs used to keep the Service reliable.

2.6 Product usage and auto-reframe data

We keep first-party usage logs to operate and improve the Service. This includes logs of which automatic-reframe suggestion you accept or adjust when editing, which we use to improve the reframing feature. These logs are kept in our own database; we do not use a third-party advertising or cross-site tracking network.

2.7 Accounts and data moved from the previous Subtile platform

Subtile AI is operated by YUKARI LABS SRL. If you had an account on the previous Subtile platform (subtile.ai), we did not collect the data below through the Service: we moved it from that platform into the Service so that you can keep working with it. What we moved:

• Your account: email address, name, profile image, and your sign-in methods, including your existing password in hashed form (never in plain text) and the link to your Google sign-in
• Your projects, with their transcripts, captions and word timings
• Your subtitle presets
• Your files: the videos you uploaded and the videos you exported
• Your waitlist sign-up, if you joined the Subtile waitlist. We do not send marketing email based on it unless you confirm that you want updates.

We also keep a complete copy of the previous platform's data (a full database export and all stored files, including records such as billing history that the Service does not use) in a private, access-restricted archive on Cloudflare R2. The archive is not public and is not used to provide the Service. We keep it only to check that the move is complete and correct, to fix errors, and to restore anything that was missed. Section 8 explains how long it is kept, and section 9 how to have your data in it erased.

3. How We Use Your Data

We use the information we collect to:

• Provide, maintain and secure the Service
• Authenticate you and act on your behalf with Twitch as you direct
• Aggregate and display clips for the boards you curate, and provide the editing, subtitle and rendering features
• Prevent abuse, fraud and excessive automated requests
• Diagnose and fix problems and improve features such as automatic reframing
• Showcase examples of creations made with the Service (such as clips and edits) to promote Subtile and other YUKARI LABS products, under the content license in our Terms of Use
• Communicate essential Service notices, and — unless you opt out — news about Subtile and other YUKARI LABS products that may interest you
• Comply with our legal obligations

Our commitment: We do not sell your personal data, and we do not share it with unaffiliated third parties for their own marketing. Your data is used to provide and improve the Service and, within the YUKARI LABS group, to tell you about products that may be useful to you — not sold or rented.

AI model training. We do not use your content (the media you upload, your transcripts, captions, subtitle presets and projects, including those moved from the previous Subtile platform) to train AI models. Separately, as described in section 2.6, we use data about how automatic reframing suggestions are accepted or adjusted to improve that feature.

4. Lawful Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data on the following lawful bases:

5. Twitch Data and Third-Party Content

Subtile is a tool for working with content on Twitch. Access to Twitch data is performed through the authorization you grant via Twitch OAuth and is subject to Twitch's own terms and privacy notice. Clips and VODs are the content of Twitch and the respective streamers and rights-holders; Subtile does not own this content and provides only tooling to discover, download and edit it. If you revoke the access you granted from your Twitch account settings, the Service can no longer act on your behalf with Twitch.

6. Cookies and Local Storage

Subtile uses only strictly necessary cookies and local storage to keep you signed in and to maintain your session. We do not use advertising cookies, analytics cookies, or third-party cross-site tracking, and the Service sets no non-essential tracking cookies.

One exception, stated plainly. When you export a video, the rendering toolkit we use (Remotion) sends one usage event from your browser to www.remotion.pro. It contains only our hostname, our licence identifier, and whether the export was a still and whether it succeeded — no cookie, no identifier for you, and none of your media, which never leaves your device during rendering. It is how the toolkit is licensed. We consider this a licence-metering call rather than tracking, but it is a request to a third party that your browser makes, so we name it here rather than leave it out.

Third-party assets. Some features load files directly from third-party hosts: web fonts from Google Fonts, and — whenever you use automatic reframing — the on-device detection model from jsDelivr and Google Cloud Storage. Larger optional detection models come from Hugging Face. Those hosts necessarily see your IP address and browser user agent, as any host you request a file from does. They receive no account data and none of your media: the detection itself runs on your device, on video that never leaves it.

7. Service Providers (Subprocessors)

We rely on service providers that process data on our behalf under appropriate confidentiality and data-protection terms. Every third party our systems send anything to is named below, with what it is for — including the two that receive no personal data or media at all, so that the list is complete rather than flattering:

• Convex — database and backend that stores your account, boards, workflow data and logs. Privacy policy
• Vercel — application hosting, content delivery, and the server-side functions that process clip and VOD media. Privacy policy
• Cloudflare — object storage and CDN delivery for clip, VOD and upload media. Privacy policy
• Twitch — the source platform and OAuth provider; we call Twitch on your behalf as you direct. Privacy notice
• Resend — delivery of account verification and password-reset emails. Privacy policy
• Deepgram — speech-to-text transcription of clip and VOD audio for subtitles. Privacy policy
• OpenRouter — routes most of our AI requests — transcript text and video frames — to the model providers that run them. Privacy policy
• Google — optional Google sign-in, and AI-assisted editing features using Gemini models (reached through OpenRouter). Privacy policy
• Anthropic — AI-assisted clip selection using Claude models, called directly rather than through OpenRouter. Privacy policy
• OpenAI — AI-assisted editing features, including the camera detection that sends frames from your clip (reached through OpenRouter), and fallback speech-to-text transcription. Privacy policy
• Apify — resolves download links for third-party video URLs you paste (TikTok, Instagram, YouTube). Privacy policy
• Remotion — the video-rendering toolkit used to export your videos. Rendering happens in your browser and no media is sent to Remotion, but their toolkit sends them one usage event per export (see section 6). Privacy policy
• Modal — GPU hosting for an optional camera-detection model. Currently disabled; named here because the integration is present and enabling it must not be a silent change. Privacy policy

Business transfers. If YUKARI LABS SRL, or the part of its business that runs the Service, is merged, acquired or transferred, personal data may be transferred to the successor. The successor must keep protecting it as this Privacy Policy describes, and we will tell you before your data becomes subject to a different privacy policy.

8. Data Retention

• Account & workflow data: kept for the life of your account. In Settings, you can choose “Erase now” to start permanent erasure without a recovery period, or explicitly choose a 30-day recovery period. Both choices deactivate access and stop new processing immediately. During recovery, data is retained only to restore your account. Sign in and select “Restore account” before the displayed deadline; signing in alone does not cancel closure. Erasure starts automatically when that deadline passes.
• Clip / VOD media: stored or cached for as long as needed to provide the features you use, and kept no longer than necessary for those purposes.
• Subtitle audio: clip audio extracted for transcription is deleted once the transcript is produced. The audio-only copy of a full VOD is media, and follows the media rule above — currently up to 30 days after you last use it, and sooner if you never do.
• Technical / diagnostic logs: typically retained for around 90 days.
• Product-usage and auto-reframe logs: retained in pseudonymized form to improve the Service.
• Creations featured in marketing materials: may be retained as part of those materials under the content license in our Terms.
• Private migration archive:the copy of the previous Subtile platform's data (section 2.7) is kept only as long as needed to check and correct the move, and never longer than 12 months after it. It is then deleted. Your part of it is erased sooner if you ask us (section 9).
• Payment records: if and when paid plans are introduced, retained as required by Belgian tax law (currently 7 years for accounting records).

9. Your Privacy Rights

Under the GDPR and applicable Belgian data-protection law, you have the right to:

• Access your personal data
• Correct inaccurate information
• Request erasure of your data
• Restrict or object to certain processing
• Receive your data in a portable format
• Opt out of marketing communications, and withdraw consent where processing is based on consent

How to exercise your rights: You can close your Subtile account from Settings, choosing optional 30-day recovery or “Erase now”. Permanent erasure runs in the background, including stored media and CDN copies; existing uploads and processing requests must finish or expire before the final cleanup. For erasure requests, other privacy rights, or help with a pending request, email contact@subtile.ai and we will respond without undue delay, normally within one month. You can opt out of non-essential marketing at any time via the unsubscribe link or the same email, and you can revoke the Service's access to your Twitch account at any time from Twitch's Connections settings.

Accounts moved from Subtile: the same rights apply. You can close an imported account from Settings as described above, which erases it from the Service. You can also ask for deletion by emailing contact@subtile.ai from the address on the account. When you ask by email, we erase your data from the Service and from the private migration archive, and we will not import it again.

Right to lodge a complaint: If you believe our processing of your personal data infringes the GDPR, you may lodge a complaint with the Belgian Data Protection Authority:

Autorité de protection des données (APD) / Gegevensbeschermingsautoriteit (GBA)
Rue de la Presse 35, 1000 Brussels, Belgium
Phone: +32 (0)2 274 48 00
Email: contact@apd-gba.be
Website: www.dataprotectionauthority.be

10. Data Security

• Encryption of data in transit and at rest
• Access controls and authentication
• Rate limiting and abuse prevention
• Monitoring for suspicious activity
• Least-privilege handling of Twitch OAuth tokens

11. International Data Transfers

We are based in Belgium and operate under EU law. Some of our service providers may process data outside the European Economic Area. Where that happens, we rely on appropriate safeguards (such as the European Commission's Standard Contractual Clauses) to protect your data.

12. Age Restrictions

Subtile is not directed to individuals under 18, and we do not knowingly collect data from them. If we learn we have, we will delete it.

13. Changes to This Policy

We may update this Privacy Policy for operational, legal or regulatory reasons. We will post the updated policy here and revise the "Last Updated" date. Material changes will be communicated through the Service where appropriate.

14. Contact Information

For privacy-related inquiries or to exercise your rights, contact:

YUKARI LABS SRL
Cantersteen 47, 1000 Brussels, Belgium
Enterprise/VAT number: BE1033402366
Email: contact@subtile.ai