DMBox Privacy Policy

Last updated: 2026-05-12

1. Who we are

DMBox ("the Service") is operated by Gad1001 ("we", "us"). For GDPR purposes we act as the data controller for account data and as the data processor for campaign Content that customers upload.

2. What we collect

Account data (you provide this directly):

• email address
• account name / display name
• authentication credentials (hashed; we do not store plaintext passwords)
• billing identifiers (Stripe customer ID; we do not store full card numbers)

Service data (generated when you use the Service):

• campaign Content you upload (notes, characters, audio, etc.)
• transcripts and AI-generated output derived from your inputs
• usage counters (transcription minutes, AI tokens consumed) for quota enforcement

Technical data (collected automatically):

• IP address (used for rate limiting, fraud prevention, and approximate geolocation; not used for advertising)
• browser user-agent
• request logs (URL, status, latency) retained for up to 30 days for operational debugging
• error reports (via Sentry) including stack traces and request context

3. Why we process it (legal basis under GDPR Art. 6)

• Performing our contract with you — to deliver the Service you signed up for (account data, Service data).
• Legitimate interests — to secure the Service, prevent abuse, and debug errors (technical data). You may object to this processing at any time.
• Consent — for any optional feature that requires it, and for marketing email to free-tier users, who receive it only after an explicit opt-in; you may withdraw consent at any time (see §3.1).
• Legitimate interests (direct marketing to existing customers) — we send product/marketing email to paying customers about our own similar products by default, on the soft opt-in basis permitted by PECR Reg. 22(3); every such message carries one-click unsubscribe and you may object at any time (see §3.1).
• Legal obligation — to retain billing records for tax/accounting purposes.

3.1 Marketing communications

We keep marketing email to a minimum and apply the following rules, which are enforced in code:

• Paying customers (soft opt-in). If you have a paid subscription, we may send you product and marketing email about our own similar products by default, without separate consent (PECR Reg. 22(3) soft opt-in). Every such message carries a one-click unsubscribe link; once you unsubscribe we do not send you marketing again unless you opt back in.
• Free-tier users (explicit opt-in). If you have never paid, we send you marketing email only after you have explicitly opted in (for example, by ticking the marketing box at sign-up). The default is no marketing.
• Transactional email is always sent and is never consent-gated. Sign-in links, receipts, subscription confirmations, payment-failure and dunning notices, security alerts, and account-action notices are necessary to operate your account and are sent regardless of any marketing preference. They do not carry an unsubscribe link.
• Frequency cap. We cap marketing/engagement email at no more than about one message per 14 days, with a hard ceiling of two per calendar month. A send that would exceed the cap is skipped, not queued.
• Dormant paying customers. We suppress marketing to a paying customer who has gone dormant (no usage in the current period and no recent sign-in); we will not email such a customer marketing to "win them back". Transactional and billing email (including dunning) is unaffected.

Onboarding email sent to new users in their first weeks (a getting-started nudge) is not treated as marketing for the consent rules above, but it still respects the frequency cap and carries a one-click unsubscribe link.

4. Subprocessors

We share data with the following third parties strictly as necessary to operate the Service. Each subprocessor receives only the categories of data listed and is bound by a data-processing agreement that restricts use to the stated purpose.

"SCCs" means the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914). "DPF" means the EU–US Data Privacy Framework certification of the receiving entity, where applicable. Where neither applies for a transfer, we rely on the derogations of GDPR Art. 49 only where lawful and as a last resort.

A current list of subprocessors is maintained at /legal/subprocessors and updated when changes occur; material additions are announced at least 30 days in advance.

5. International transfers

Where data is transferred outside your jurisdiction (for example to US-based AI providers), we rely on Standard Contractual Clauses (SCCs) or the EU–US Data Privacy Framework, as applicable. A copy of our SCCs is available on request.

6. Retention

Deletion from primary storage is immediate on user request or scheduled purge. Deleted records age out of rolling backups within the backup window (typically 35 days). Where statutory retention applies (billing, tax), the record is retained in a restricted-access archive and is not used for any other purpose.

Audit logs are purged at 12 months as published above, with two exceptions where a separate lawful basis requires us to keep a narrow subset for longer. We retain beyond 12 months, as the pseudonymous accountability record:

• Security and account-integrity events — account creation and deletion, API-token issue and revocation, and email-address changes — kept under our legitimate interest in being able to demonstrate who took which security-relevant action (GDPR Art. 6(1)(f), and the Art. 30 record of processing).
• Consent-change events — when you opt in to or out of marketing — kept as the durable record that we honoured your choice (the accountability principle, GDPR Art. 5(2)).

These retained events carry only a pseudonymous user identifier and the action/timestamp; the IP address and user-agent on the same record are deleted at the 30-day request-log window above, and on account erasure the remaining identifiers are anonymised. All other audit-log entries (for example routine admin views and profile/preference edits) are purged at 12 months. Financial/billing events follow the 7-year statutory window in the table above, not this 12-month rule.

7. Your rights

7.1 If you are in the EEA (GDPR)

• Access (Art. 15) — obtain a copy of the personal data we hold about you and information about how it is processed.
• Rectification (Art. 16) — correct inaccurate or incomplete data.
• Erasure (Art. 17) — request deletion ("right to be forgotten"), subject to exceptions for legal obligations.
• Restriction (Art. 18) — limit how we process your data while a dispute is resolved.
• Portability (Art. 20) — receive your data in a structured, machine-readable format (we provide JSON exports).
• Object (Art. 21) — object to processing based on legitimate interests, including for direct marketing.
• Withdraw consent (Art. 7) — for processing based on consent, with no effect on processing already carried out.
• Lodge a complaint with your local supervisory authority (a list is available at edpb.europa.eu).

7.2 If you are in the United Kingdom (UK GDPR)

You have the same rights as listed in §7.1. You may lodge a complaint with the Information Commissioner's Office (ico.org.uk).

7.3 If you are in California (CCPA / CPRA)

• Right to know what categories of personal information we have collected, the sources, the purpose, and the categories of third parties with whom we share it.
• Right to access a copy of your personal information.
• Right to delete your personal information, subject to statutory exceptions.
• Right to correct inaccurate personal information.
• Right to limit use of sensitive personal information.
• Right to opt out of sale or sharing — we do not sell or share personal information as those terms are defined under the CPRA.
• Right to non-discrimination for exercising your rights.

To exercise rights, email [email protected]. Authorized agents may submit requests on your behalf with verifiable authorization.

7.4 If you are elsewhere

Other jurisdictions (Brazil's LGPD, Canada's PIPEDA, Australia's Privacy Act, etc.) provide similar rights. Contact us using the address below and we will honor applicable rights to the extent required by your local law.

7.5 How to exercise your rights

Email [email protected] from the email address associated with your account, or use the in-product "Privacy" page to generate an authenticated request. We respond within 30 days (extendable by a further 60 days where the request is complex, with notice).

7.6 Identity verification

To prevent unauthorized disclosure, we may ask you to confirm control of the account email before fulfilling access, deletion, or portability requests. For account-less requests (for example, from a person whose data appears in another customer's Content), we may ask for sufficient information to locate the records and confirm identity. We will not ask for more information than is necessary to verify the request.

7.7 Automated decision-making

We do not make decisions about you based solely on automated processing that produces legal or similarly significant effects (GDPR Art. 22). The Service uses AI to generate suggested content, transcripts, and summaries, but these outputs are surfaced for human review and do not by themselves determine your access to the Service, your pricing, or any other matter affecting your rights.

8. Children

The Service is not directed to children under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, contact us and we will delete it.

9. Security

We use industry-standard technical and organizational measures including TLS in transit, encryption at rest for sensitive fields, scoped access controls, and audit logging. No system is perfectly secure; in the event of a personal data breach affecting you we will notify you and the relevant supervisory authority as required by law.

10. Cookies

We use the minimum cookies necessary to operate the Service:

Strictly necessary cookies do not require consent under the ePrivacy Directive. We do not use third-party advertising cookies and do not embed third-party trackers in the authenticated cockpit. Optional analytics, if enabled in a future release, will be documented in the in-product cookie banner and require opt-in consent.

11. Changes to this Policy

Material changes will be communicated by email or in-product notice at least 14 days before they take effect.

12. Contact

• Operator: Gad1001
• Email: [email protected]
• EU representative (where required by GDPR Art. 27): TBD before launch
• UK representative (where required by UK GDPR): TBD before launch