DATA PROCESSING AGREEMENT
Last updated April 15, 2026
This Data Processing Agreement ('DPA') forms part of the
Terms and Conditions ('Agreement') between
SubDownload.com ('Processor', 'we',
'us', or 'our') and you
('Controller', 'you', or
'your') for the use of our services at
https://subdownload.com
and our API at
https://api.subdownload.com
(collectively, the 'Services').
This DPA applies where and only to the extent that we process personal
data on your behalf as a data processor in the course of providing the
Services, and such personal data is subject to data protection laws
including the EU General Data Protection Regulation ('GDPR'),
the UK GDPR, the California Consumer Privacy Act ('CCPA'),
or other applicable privacy regulations.
By using our Services, you agree to the terms of this DPA. If you are
entering into this DPA on behalf of an organisation, you represent that
you have the authority to bind that organisation to this DPA.
TABLE OF CONTENTS
- Definitions
- Scope and Purpose of Processing
- Processor Obligations
- Controller Obligations
- Data Subject Rights
- Sub-Processors
- Security Measures
- Data Breach Notification
- International Data Transfers
- Data Retention and Deletion
- Audit Rights
- Limitation of Liability
- Term and Termination
- Contact Us
1. DEFINITIONS
In this DPA, the following terms have the meanings set out below:
- 'Personal Data' means any information relating to an identified or identifiable natural person that is processed by us on your behalf through the Services.
- 'Processing' means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, combination, erasure, or destruction.
- 'Controller' means you, the entity that determines the purposes and means of the Processing of Personal Data.
- 'Processor' means SubDownload.com, which processes Personal Data on behalf of the Controller.
- 'Sub-Processor' means any third party engaged by the Processor to assist in Processing Personal Data.
- 'Data Subject' means the identified or identifiable natural person to whom the Personal Data relates.
- 'Data Breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.
2. SCOPE AND PURPOSE OF PROCESSING
2.1 Nature of the Services. SubDownload.com provides
YouTube transcript retrieval and download services, including a web
interface and a REST API. In providing these Services, we may process
certain Personal Data on your behalf.
2.2 Categories of Data Subjects. The Personal Data
processed relates to the following categories of Data Subjects:
- Your end users who access the Services through your integration
- Your account users and API token holders
2.3 Types of Personal Data Processed. The following
types of Personal Data may be processed:
- IP addresses
- Email addresses (when authenticated via Google Sign-In)
- Google account profile information (name, profile picture)
- API usage logs (video IDs requested, timestamps, request metadata)
- Browser user agent strings
- Page view and referrer data
2.4 Purpose of Processing. We process Personal Data
solely for the following purposes:
- Providing and operating the transcript retrieval Services
- Authenticating users and managing accounts
- Enforcing usage quotas and billing
- Maintaining service security and preventing abuse
- Generating aggregated, non-identifying analytics
2.5 Duration of Processing. We process Personal Data
for the duration of the Agreement, unless otherwise required by
applicable law.
3. PROCESSOR OBLIGATIONS
We shall:
- Process Personal Data only on your documented instructions, unless required to do so by applicable law. In such a case, we shall inform you of that legal requirement before processing, unless prohibited by law.
- Ensure that persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
- Implement and maintain appropriate technical and organisational measures to protect Personal Data, as described in Section 7.
- Assist you, taking into account the nature of processing, in responding to requests from Data Subjects exercising their rights under applicable data protection laws.
- Assist you in ensuring compliance with your obligations regarding security of processing, notification of Data Breaches, data protection impact assessments, and prior consultations with supervisory authorities.
- At your choice, delete or return all Personal Data after the end of the provision of Services, and delete existing copies unless applicable law requires storage of the Personal Data.
- Make available to you all information necessary to demonstrate compliance with this DPA and allow for and contribute to audits as described in Section 11.
- Immediately inform you if, in our opinion, an instruction from you infringes applicable data protection laws.
4. CONTROLLER OBLIGATIONS
You shall:
- Ensure that you have a valid legal basis for the processing of Personal Data and that any necessary consents or notices have been obtained or provided to Data Subjects.
- Provide us with documented processing instructions and promptly notify us of any changes to such instructions.
- Ensure that the Personal Data you provide to us for processing is accurate and up to date.
- Be responsible for the security of your account credentials, API tokens, and any access you grant to third parties.
5. DATA SUBJECT RIGHTS
5.1 We shall, to the extent legally permitted, promptly
notify you if we receive a request from a Data Subject to exercise their
rights under applicable data protection law (including rights of access,
rectification, erasure, restriction, data portability, and objection).
5.2 We shall provide reasonable assistance to you in
fulfilling your obligation to respond to Data Subject requests, taking
into account the nature of the processing.
5.3 Data Subjects and users may exercise their rights
directly by visiting
subdownload.com/dsar
or by contacting us at contact@subdownload.com.
6. SUB-PROCESSORS
6.1 Authorised Sub-Processors. You provide general
written authorisation for us to engage Sub-Processors. We currently use
the following Sub-Processors:
| Sub-Processor | Purpose | Location |
|---|---|---|
| Google OAuth | User authentication | United States |
| PostgreSQL (self-hosted) | Data storage | United States |
| Cloudflare | CDN, DNS, and DDoS protection | Global |
| Dodo Payments | Payment processing | United States |
6.2 Notification of Changes. We shall notify you of any
intended changes to the Sub-Processors by updating this DPA. You may
object to such changes within 14 days of being notified. If you object
and we cannot reasonably accommodate your objection, either party may
terminate the Agreement.
6.3 Sub-Processor Obligations. We shall ensure that each
Sub-Processor is bound by data protection obligations no less protective
than those set out in this DPA.
7. SECURITY MEASURES
We implement and maintain appropriate technical and organisational
security measures to protect Personal Data, including:
- Encryption in transit — All data is transmitted over TLS/HTTPS.
- Authentication and access control — JWT-based authentication, API key management with hashed token storage, and role-based admin access.
- Database security — Encrypted connections to PostgreSQL, parameterised queries to prevent SQL injection.
- Rate limiting and abuse prevention — IP-based quota enforcement, bot detection, and cooldown mechanisms.
- Data minimisation — We only collect data necessary to provide the Services. Traffic logs are automatically purged after 7 days.
- Infrastructure security — Cloudflare DDoS protection, firewall rules, and regular security updates.
- Soft deletion — User account deletion is reversible (soft delete) to prevent accidental data loss, with permanent deletion available upon request.
8. DATA BREACH NOTIFICATION
8.1 We shall notify you without undue delay (and in any
event within 72 hours) after becoming aware of a Data Breach affecting
Personal Data processed on your behalf.
8.2 Such notification shall include, to the extent
available:
- A description of the nature of the Data Breach, including the categories and approximate number of Data Subjects and records affected
- The name and contact details of our point of contact
- A description of the likely consequences of the Data Breach
- A description of the measures taken or proposed to address the Data Breach, including measures to mitigate its possible adverse effects
8.3 We shall cooperate with you and take reasonable
steps to assist in the investigation, mitigation, and remediation of
each Data Breach.
9. INTERNATIONAL DATA TRANSFERS
9.1 Personal Data may be processed in the United States,
where our servers are located. If you are located in the European
Economic Area (EEA), United Kingdom, or Switzerland, we ensure that
appropriate safeguards are in place for any transfer of Personal Data
outside these regions.
9.2 Where required, we rely on the following transfer
mechanisms:
- Standard Contractual Clauses (SCCs) as approved by the European Commission
- UK International Data Transfer Agreement or Addendum, where applicable
- Any other valid transfer mechanism under applicable data protection law
9.3 You may request a copy of the applicable transfer
mechanism by contacting us at contact@subdownload.com.
10. DATA RETENTION AND DELETION
10.1 We retain Personal Data only for as long as
necessary to fulfil the purposes of processing, unless a longer retention
period is required by law.
10.2 Specific retention periods:
- Traffic logs — Automatically deleted after 7 days
- Usage logs — Retained for the duration of your account for billing and audit purposes
- Account data — Retained until account deletion is requested
- Page view data — Retained in aggregated form for analytics
- IP usage records — Used for quota enforcement only, not linked to personal identity
10.3 Upon termination of the Agreement, or upon your
request, we shall delete or return all Personal Data within 30 days,
except where retention is required by applicable law.
10.4 You may request deletion of your data at any time
by visiting
subdownload.com/dsar
or by contacting us at contact@subdownload.com.
11. AUDIT RIGHTS
11.1 We shall make available to you, on request, all
information reasonably necessary to demonstrate compliance with this DPA.
11.2 You may conduct an audit (or appoint a qualified
third-party auditor) to verify our compliance with this DPA, subject to
the following conditions:
- You must provide at least 30 days' written notice
- Audits shall be conducted during normal business hours
- Audits shall not unreasonably interfere with our business operations
- You shall bear the costs of any audit
- Audit frequency shall be limited to once per calendar year, unless a Data Breach has occurred or a supervisory authority requires an additional audit
12. LIMITATION OF LIABILITY
Each party's liability under this DPA shall be subject to the limitations
and exclusions of liability set out in the Agreement. Nothing in this DPA
shall limit either party's liability for breaches of applicable data
protection law to the extent such limitation is not permitted by law.
13. TERM AND TERMINATION
13.1 This DPA shall remain in effect for the duration of
the Agreement and shall automatically terminate upon termination of the
Agreement.
13.2 Sections 7 (Security Measures), 8 (Data Breach
Notification), 10 (Data Retention and Deletion), and 11 (Audit Rights)
shall survive termination of this DPA.
13.3 Upon termination, we shall comply with Section 10.3
regarding deletion or return of Personal Data.
14. CONTACT US
If you have any questions about this DPA, or if you would like to
exercise any of your rights, you may contact us:
- By email: contact@subdownload.com
- By visiting our data request page: subdownload.com/dsar