Privacy Policy - DUBULAR S.A.S.

DUBULAR S.A.S. (hereinafter "Dubular" or "the Company") is the data controller responsible for the processing of the personal data you provide when using the platform and the automatic dubbing services. This privacy policy is established as a legal and technical instrument through which DUBULAR S.A.S., a simplified joint-stock company domiciled in Bogotá D.C., clearly, concretely, and transparently informs users about the processing of their personal data and the mechanisms available for the exercise of their rights as data subjects, in accordance with Colombian law.

Based on Law 1581 of 2012, Decree 1377 of 2013, and any other regulations that amend, supplement, or replace the Colombian Personal Data Protection Regime, I freely, consciously, expressly, knowingly, and voluntarily authorize DUBULAR S.A.S. to process, handle, and manage my personal data, including but not limited to multimedia files in audio and video formats provided to the platform for the purpose of carrying out technological automation processes such as audio separation, transcription, diarization, translation, voice cloning, voice generation and synthesis, synchronization, editing, and file export for video dubbing.

This policy applies to all data processed in Colombia and in any other country where the Company operates.

Principles Applied

Data is processed in accordance with the principles of legality, purpose, freedom, accuracy, transparency, restricted access and circulation, security, and confidentiality. Processing will be proportional and necessary for the purposes described.

Purpose and scope

This policy aims to establish the legal, technical, and administrative guidelines under which DUBULAR S.A.S., in its capacity as the data controller, carries out the collection, storage, use, circulation, transfer, transmission, updating, and deletion of the information provided by its users through the various services, forms, digital platforms, and other means made available by the company for the operation of its technological solutions.

Its scope covers all processing activities carried out by DUBULAR S.A.S. within its own technological infrastructures and digital channels related to its software services, particularly those aimed at automated dubbing, transcription, translation, synthesis, voice cloning, and voice generation through artificial intelligence technologies.

Special authorization for the processing of sensitive data:

I hereby declare that I have been fully informed by DUBULAR S.A.S. regarding the processing of my sensitive personal data, understood as those defined in Law 1581 of 2012 and Decree 1377 of 2013 as information that may affect the data subject’s privacy or whose misuse could result in discrimination.

I freely, consciously, expressly, and knowingly authorize DUBULAR S.A.S. to collect, store, process, circulate, transfer, and use my biometric data, including voice recordings, audio samples, audiovisual files, or other identifying elements required for automated dubbing, voice cloning, synthesis, acoustic analysis, translation, editing, or synchronization processes carried out within the scope of the company’s corporate purpose and its artificial intelligence–based technological infrastructure.

DUBULAR S.A.S. guarantees that the collected data will not be used for purposes other than those expressly communicated nor disclosed without the prior consent of the data subject, adopting all necessary technical, organizational, and legal measures to prevent unauthorized access to or use of the information.

Likewise, the user accepts and, under oath, affirms that the personal data entered into DUBULAR’s platform belong to them or that they have the express authorization of the data subject to provide such information. Consequently, the user assumes full, irrevocable, and exclusive responsibility for the use, accuracy, and legitimacy of the data provided, releasing DUBULAR S.A.S. from any legal, civil, administrative, or criminal liability that may arise from the improper or unauthorized processing of personal data provided on the platform.

This authorization has no specific geographical limitation; therefore, the processing may include the transfer and transmission of personal data to other countries, always ensuring adequate levels of protection and security in accordance with legal standards and the internal policies of DUBULAR S.A.S., available at [Terms of Service].

Categories of Data Collected

• Identification and contact: name, email, country, IP address, device identifiers.
• Account and billing: billing data, transaction history.
• Usage and operation: access logs, activity logs, usage metrics, cookies.
• User-generated content: audio and video files, transcriptions, subtitles, metadata (timestamps, tags), and text entered on the platform.
• Models and artifacts: voice models/clones generated from user-uploaded files.

Voice data that can identify a person may be considered high-risk/biometric data; therefore, enhanced safeguards apply.

Purposes of Processing and Legal Bases

The purpose of this policy is to establish the legal, technical, and administrative guidelines under which DUBULAR S.A.S., in its capacity as the data controller, carries out the collection, storage, use, circulation, transfer, transmission, updating, and deletion of the information provided by its users through the various services, forms, digital platforms, and other means made available by the company for the operation of its technological solutions.

Its scope covers all processing activities carried out within the company’s technological infrastructures and digital channels related to its software services, particularly those aimed at automated dubbing, transcription, translation, synthesis, voice cloning, and voice generation through artificial intelligence technologies.

In particular, it is limited to:

• Service provision: transcription, diarization, translation, voice generation/cloning, synchronization, and audio export.

  Legal basis: execution of the service requested by the user.

• Creation and storage of voice models (cloning): authorized through specific consent granted by the user during account registration or the cloning flow, as provided in the voice cloning permission.

  Legal basis: explicit and documented consent from the user for processing audio samples to create and store the voice model.

• Account management, billing, and payment processing.

  Legal basis: contractual execution.

• Security, fraud prevention, and legal compliance.

  Legal basis: legitimate interest and legal obligations.

Voice Cloning - Specific Rules

Evidence, Claims, and Takedown Procedure

• Acceptable proof: signed document (physical or digital), recording with verifiable consent, verifiable email from the voice owner, or public and verifiable authorization.
• Deadline for submitting proof: the user must provide the proof within the maximum term indicated by the platform (default: seven (7) calendar days from the request).
• Third-party claims: Dubular maintains a public procedure for receiving claims; in the event of a substantiated claim, it may suspend access, block exports, and delete models/clones following verification. Dubular will cooperate with competent authorities.

Retention and Preservation

Original audios and models/clones may be retained indefinitely on the platform until: the content owner requests their deletion, the user explicitly deletes the files or closes their account, or a valid authority order requires otherwise.

Dubular will maintain forensic records (hashes, metadata, generation and export logs, consent records) for the periods necessary to handle claims, audits, and legal obligations.

Revocation and Deletion

The user may revoke consent and request the deletion of content and models. Dubular will process such requests and execute deletion to the extent technically possible. When full technical removal is not possible, Dubular will apply reasonable and documented compensatory measures (access blocking, playback/export deactivation, model obfuscation, deletion of feasible copies, and, when applicable, credits or alternative services). Technical limitations will be communicated to the requester.

Data Transfer and Use of External Providers

The user expressly authorizes DUBULAR S.A.S. to directly or through third parties provide their personal data for activities such as marketing, promotion, and advertising of its own or third-party products and services; sales, billing, collection management, and debt recovery; scheduling and technical support; market intelligence; service improvement; verifications and inquiries; control, behavioral and habit analysis; payment method enablement and fraud prevention; as well as any other activity related to current and future products and services, all for the fulfillment of the company’s contractual obligations and corporate purpose.

Data Subjects' Rights (ARCO)

Rights: access, correction, deletion, objection to processing (where applicable), consent revocation, and portability when applicable. Requests must be submitted to the Data Protection Officer (DPO) through the published channels and will be handled within the legal timeframes.

Minors and Persons with Limited Legal Capacity

Voice cloning of minors or persons with limited legal capacity is prohibited without verifiable consent from their legal representative. Any cloning detected without authorization will be deleted and the account disabled.

Security Incidents and Notification

In the event of incidents affecting personal data, Dubular will activate its response plan, document the incident, and notify the competent authority and affected data subjects within the legally required timeframes and forms.

Policy Changes

Dubular may update this policy for legal, technical, or operational reasons. Any changes will be communicated through the channels made available by DUBULAR S.A.S. Continued use of the Services after the publication of such changes shall constitute the user’s express and irrevocable acceptance of the policy.

If the user does not agree with the modifications, they may suspend or discontinue the use of the services as stipulated.

Data Protection Officer (DPO) Contact

Contact for inquiries, ARCO requests, and claims: privacy@dubular.com

(subject to confirmation and publication on the platform). Legal address and phone number will be published in the "Privacy" section of the website.

Applicable Legal Framework

Statutory Law 1581 of 2012 and its regulations; applicable guidelines of the Superintendence of Industry and Commerce regarding data processing and AI systems; complementary regulations concerning the RNBD and data protection in Colombia.