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Privacy Policy

Last updated: October 10, 2026　Effective date: October 10, 2026

This Privacy Policy explains how ShineSoft (Guangzhou Shi'er Software Technology Co., Ltd., "we," "us") collects, uses, shares, and protects your personal information when providing the Sublyric subtitle software (the "Application"). We are the controller of the personal information described in this Policy.

1. Information We Collect

1.1 Information you provide to us:

  • Name and email address: used for identification, and to send your activation code, order confirmationss, and support replies;
  • Machine ID (device identifier): an identifier generated locally on your device by applying an encryption algorithm to certain hardware information. You send it to us yourself; the Application does not upload it automatically. It is used only to generate the activation code bound to your device ("one device, one code"). Once associated with your name and email, the Machine ID is personal information and is protected under this Policy;
  • Feedback materials: text excerpts, screenshots, and similar materials you choose to send us when reporting an issue, used only to handle your feedback.

1.2 Payment information: we do not directly collect or store your payment details. Payment is processed by Paddle, which shares with us the transaction information needed to perform our contract with you (such as order number, amount, billing email, and country).

1.3 Information that stays on your device: your audio and video files, project files, subtitle files, and any third-party API key you enter to use translation services are stored only on your device (API keys are stored encrypted). We do not collect, upload, or access them.

2. How We Use Information and Legal Bases

We use your information only for the following purposes:

  • Creating and managing your License, verifying activation, and processing device migration requests — necessary for the performance of our contract with you;
  • Customer support, including responding to inquiries and feedback — necessary for the performance of our contract, or our legitimate interest in supporting our users;
  • Orders and refunds, coordinated with Paddle — necessary for the performance of our contract;
  • Tax, accounting, and fraud prevention — compliance with legal obligations, or our legitimate interest in preventing fraud;

Providing your name, email, and Machine ID is necessary for us to issue and activate a License; without them, we cannot provide the Paid Features. We do not use your personal information for advertising, and we do not sell it to any third party.

3. Sharing of Information

We do not share, sell, or rent your personal information to third parties, except:

  • Paddle, as Merchant of Record, to complete payments, refunds, and tax obligations. Paddle processes this information as an independent controller under its own privacy policy;
  • Feishu, a service provider that stores and displays customer records on our behalf and on our instructions (see Section 5);
  • With your consent; or
  • Where required by law or by a lawful request from a judicial or administrative authority.

4. Speech Recognition and Third-Party Translation

4.1 Speech recognition is performed entirely on your device. Your audio and video files are never uploaded to any server.

4.2 Subtitle translation requires you to select and connect a third-party translation service. Currently supported providers are:

  • DeepSeek — provided by Hangzhou DeepSeek AI Basic Technology Research Co., Ltd., with servers in mainland China; requires your own API key;
  • Google Translate — provided by Google LLC (United States);
  • MyMemory — provided by Translated S.r.l. (Italy).

Contact details and privacy policies for each provider are available on their official websites.

When you translate, the subtitle text you select is sent directly from your device to the provider you chose, without passing through our servers. It is used only to generate the translation and is processed by that provider under its own terms and privacy policy. We do not send the provider your name, email, or other account information.

Before you first use a translation provider, the Application asks for your consent and identifies the provider and its location. You can turn off translation or withdraw your consent at any time in the Application's settings; this does not affect the other features of the Application.

Please note: MyMemory is a public translation memory. Text you submit may be added to its public corpus and become visible to others. If you do not want your content to become public, do not use MyMemory.

5. Storage and International Transfers

Your name, email, and Machine ID are stored on servers located in mainland China, on Feishu (a workplace platform provided by Beijing Feishu Technology Co., Ltd.). Feishu acts as our data processor and only stores and displays your information on our instructions. As part of the Feishu suite, it holds China's Multi-Level Protection Scheme (MLPS) Level 3 and ISO 27001 certifications; data is stored encrypted, with master keys isolated between enterprise tenants. We have configured access controls so that only personnel who need to handle customer information can access it.

If you are located outside mainland China, your personal information will therefore be transferred to mainland China, and Paddle may process it in the jurisdictions where it operates. We make these transfers because they are necessary to perform the contract you request from us. Where applicable law requires additional safeguards, we will implement reasonable measures using the compliance mechanisms available at the time.

6. Retention and Security

We retain your personal information for as long as your License remains in use, so that we can support device migration and activation code recovery. You may ask us to delete your information at any time; after deletion, we will no longer be able to provide these services. When the information is no longer necessary for its purpose, we will delete it proactively. Records we are legally required to keep (such as transaction records for tax purposes) are deleted once the statutory retention period expires.

We use reasonable technical and organizational measures (such as encrypted transmission and access controls) to protect your information, though no method of internet transmission is completely secure.

7. Your Rights

Depending on the data-protection law applicable to you (including China's Personal Information Protection Law and the EU/UK GDPR), you may have the right to access, correct, or delete your personal information, restrict or object to certain processing, request data portability, request an explanation of our processing rules, withdraw consent (for translation, directly in the Application's settings), or lodge a complaint with a competent data protection authority. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us below; we will respond within fifteen (15) business days. If your request is complex and requires more time, we will tell you why and how long it will take.

8. Children's Privacy

Our Service is not directed at children under sixteen (16), or such higher minimum age as required under the law of your jurisdiction. We do not knowingly collect personal information from such children, and will delete it promptly if we learn it was collected inadvertently.

9. Changes to This Policy

We may update this Policy from time to time, and will notify you of material changes (such as significant changes to the information we collect or how we use it) via a website announcement.

10. Contact Us

If you have any questions about this Policy, or wish to exercise your rights, please contact us:

ShineSoft (Guangzhou Shi'er Software Technology Co., Ltd.)