Privacy Policy

1. Who We Are

CallSubs is operated by CallSubs Inc. For the purposes of the General Data Protection Regulation (GDPR) and other privacy laws, we act as the Data Controller of your personal information.

2. Information We Collect

We collect data to facilitate the "pipe" between Viewers and Streamers.

A) Information You Provide

• Account Information: Name, email address, username, and password.
• Verification Data: If you are a Streamer, we may collect ID verification documents for KYC (Know Your Customer) compliance.
• Payment Information: We do not store full credit card numbers. Transactions are processed by third-party providers (e.g., Stripe), who provide us with a tokenized reference to your payment method.

B) Audio & Voice Data (The "Transient" Nature)

• Real-Time Transmission: When you participate in a Call, we process your voice data in real-time.
• Transient Buffering: We do not permanently store your voice recordings on our servers. Your audio is buffered in volatile memory for a technical duration of approximately 2 seconds (the "Safety Buffer") to enable AI moderation and stream protection, after which it is immediately overwritten and permanently deleted from our infrastructure.

C) Collected Automatically

• Device attributes (browser type, operating system).
• Usage logs (time of call, duration, potential technical errors).
• Cookies and local storage (for session management).

3. How We Use Your Information

We use your data strictly to operate the marketplace:

• Service Delivery: To establish the WebSocket/WebRTC connection between Viewer and Streamer.
• Safety & Moderation: To detect automated bot activity (not content moderation of voice).
• Transactions: To process payments and calculate Streamer payouts.
• Legal Compliance: To satisfy tax, AML (Anti-Money Laundering), and COPPA requirements.

4. The "No AI Training" Guarantee

We recognize the sensitivity of voice data in the age of Generative AI.

• No Training on User Data: CallSubs does not use your voice data, audio logs, or interaction history to train, fine-tune, or improve Artificial Intelligence (AI) or Machine Learning (ML) models.
• No Sale of Voice Data: We do not sell, license, or lease your voice data to third parties for the purpose of voice cloning, deepfake generation, or AI model training.

5. How We Share Information

We do not sell your personal data. We share data only as necessary to provide the service:

• With the Streamer (The "Merchant"): When a Viewer books a call, the Streamer receives the Viewer's username and the real-time audio feed. The Streamer does not receive the Viewer's payment details or real name.
• Service Providers: Companies that provide cloud hosting (e.g., AWS), payment processing (e.g., Stripe), and fraud detection. They are contractually bound to confidentiality.
• Legal Obligations: We may disclose data if compelled by a subpoena, court order, or valid law enforcement request.

6. Data Retention

• Audio Data: Retained for 2 seconds (Transient Processing), then deleted.
• Account Data: Retained as long as your account is active.
• Transaction Records: Retained for 7 years to comply with tax and accounting laws.

7. Children's Privacy (COPPA & GDPR-K)

CallSubs is not intended for children under 13.

• Under 13: We do not knowingly collect personal information from children under 13. If we become aware that we have collected data from a child under 13, we will delete it immediately.
• Minors (13–17): Users aged 13–17 may use the service only with Verifiable Parental Consent. By allowing a minor to use their payment method, the parent/guardian consents to the processing of the minor's data under this policy.

8. International Data Transfers

CallSubs is based in the United States. If you access the service from the EEA or UK, your data is transferred to the US. We rely on the Data Privacy Framework (DPF) or Standard Contractual Clauses (SCCs) to ensure your data remains protected under GDPR standards.

9. Your Rights (GDPR/CCPA)

Depending on your location, you have the right to:

• Access: Request a copy of the data we hold about you.
• Deletion: Request that we delete your account and data (excluding data we are legally required to keep, such as tax records).
• Correction: Update your inaccurate personal data.

10. Security

We use enterprise-grade encryption (TLS 1.2+) for all data in transit. However, no transmission over the internet is 100% secure. You acknowledge that you provide your personal information at your own risk.

11. Changes to This Policy

We may update this policy. If we make material changes (e.g., changing how we handle voice data), we will notify you via email or a prominent in-app notice prior to the change taking effect.