Privacy Policy

Last updated: October 26, 2026

Functionsoft LLC is responsible for the operation of the Service and the processing of personal data connected with its use. FRESHCODE LTD acts as Functionsoft’s Bulgarian commercial partner and may support distribution, billing coordination, customer support and related operational activities.

This Privacy Policy applies to the Dubwise web application, the website at dubwise.app, and related services (the “Service”). If you have any questions, contact us at support@dubwise.app.

1. Data we process

2. How we use data and our legal bases

We process personal data to: provide and operate the Service, including transcribing, translating, voicing and lip-syncing Your Content (performance of a contract); process payments, enforce plan limits and prevent fraud and abuse (contract and our legitimate interests); maintain, secure, and improve the Service and understand usage (our legitimate interests, and, where required by law, your consent); communicate with you and provide support (contract and legitimate interests); and comply with legal obligations such as tax and accounting (legal obligation). Where we rely on consent, you can withdraw it at any time.

Where Your Content contains other people’s voices or faces, you are responsible for having a lawful basis for uploading it and for having their consent to clone a voice or alter a face, as our Terms require; we process their data on your instructions to provide the Service to you.

3. Cookies and similar technologies

Strictly necessary cookies keep you signed in and the Service secure; they are set by our sign-in provider on our domain. The app also stores data in your browser so that it works: references to the video files you picked, and a local copy of the voices it has played. For analytics, we use PostHog, which keeps a random identifier in a first-party cookie and in your browser’s local storage; its requests go through our own domain. To measure which of our ads lead to a purchase, we use Google Ads, whose tag sets advertising cookies and reports a completed purchase (its amount and an order reference) to Google. You can manage or delete cookies and site data at any time through your browser settings; if you disable some of them, parts of the Service may not work as intended.

4. How we share data

When you make a purchase, your payment and billing information is processed by the Merchant of Record identified at checkout. The Merchant of Record acts independently for checkout, payment processing, taxes, invoicing, fraud prevention, refunds and transaction support under its own privacy notice.

We also share personal data with: service providers (subprocessors) who process data on our behalf, as listed below; authorities or third parties where required by law or to protect our rights; and a successor entity in the event of a merger, acquisition, or reorganization. We do not sell your personal data, and we do not use it for third-party advertising.

5. Subprocessors

We use the following providers, only as necessary to provide, support, and secure the Service:

ProviderWhat forWhere
Hetzner Online GmbHHosting the Service and storing your uploaded videos and everything made from themGermany
Clerk, Inc.Sign-in and account managementUSA
Groq, Inc.Transcribing the speech in your video’s audioUSA
OpenRouter, Inc., and the model providers it routes requests toTranslating and editing the text; making the synthetic base voice for each lineUSA
RunPod, Inc.GPU computing for voice conversion and lip syncUSA and other regions
Cloudflare, Inc.DNS, and delivering the website’s demo mediaUSA, global network
PostHog, Inc.Product analytics, on its EU cloudEU
Google Ireland LimitedGoogle Ads: measuring which ads lead to a purchaseEU and USA
The Merchant of Record identified at checkoutCheckout, payments, taxes, invoicing and refundsIdentified at checkout

We also use providers for email and customer support. We require each subprocessor to safeguard personal data and to process it only on our instructions and in line with this Privacy Policy. Some voice conversion and lip-sync work also runs on servers we operate ourselves.

6. International transfers

Some providers are located outside Ukraine, the EU, or the EEA. Where personal data is transferred internationally, we rely on appropriate safeguards, such as the European Commission standard contractual clauses or an adequacy decision.

7. Data retention

8. Security

We use appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or misuse, including encrypted connections and access to your files only through your signed-in account or short-lived links. No method of transmission or storage is completely secure, but we work to protect your data and to address incidents promptly.

9. Your rights

Subject to applicable law, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent where processing is based on consent. To exercise your rights, contact support@dubwise.app. You also have the right to lodge a complaint with a data protection supervisory authority, including in your country of residence.

10. Children

The Service is not directed to children, and we do not knowingly collect personal data from children below the age required by applicable law. If you believe a child has provided us with personal data, contact us, and we will take appropriate steps.

11. Changes to this Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last updated” date, and where changes are material, we will provide reasonable notice.

12. Contact

The Service is developed and operated by Functionsoft LLC.
Bulgarian commercial partner: FRESHCODE LTD, UIC 205729768, VAT No. BG205729768, registered office at 8 Tsar Kaloyan Street, floor 3, office 2, Sredets District, Sofia 1000, Bulgaria.
Email: support@dubwise.app