Last updated: 15 September 2026
Effective from: 15 September 2026
Applies to: the Dubroll mobile app for Android.
You can object. Against any processing that rests on a legitimate interest — which processing that is, is stated in section "Legal bases by purpose" — you can object at any time by writing to contact@dubroll.app with the subject "Objection".
3. What goes to Google Gemini and why
6. Usage statistics and error reports — only with your consent
8. Identifiers, advertising and tracking
11. Subscriptions, purchases and the rights
13. Our role and Google's role
15. Transfers of data to third countries
16. Retention periods and deletion
18. Objection and withdrawal of consent
21. Security and personal data breaches
The controller of the personal data under Regulation (EU) 2016/679 ("the Regulation") is Torvyx Labs Ltd. („Торвикс Лабс“ ЕООД).
You film or pick a video; Dubroll sends it with the sound to Google Gemini, which writes a commentary in the style of the commentator you have chosen; a synthetic voice voices it and your phone assembles the clip. Every clip carries an AI marking: metadata in the file and a visible notice that the voice is generated by artificial intelligence.
The commentators are invented characters and all of them are available to everyone; which ones there are at the moment you can see in the app. None of them is a real person, and their voices are Google's synthetic voices.
Other users see nothing of yours through Dubroll; you publish, outside the app.
The commentary is written by a Google Gemini model in Google Cloud.
The video — with the sound. A copy of the recording or of the part picked from the gallery goes to the model, without the metadata of the file; the sound carries the voices of everyone in the frame and behind the camera, the music and the ambient noise. Sometimes separate frames from the video go instead of the video. One and the same video may go to Google more than once for one clip.
The text of the commentary — which describes the scene and the people in it — goes to Google separately from the video as well: to refine it, to translate it and to voice it with a synthetic voice. If Google's voice refuses, the text and the language of the clip go to your phone's own speech synthesiser — a separate provider with terms of its own, which may use the network.
Google's automated safety classifiers review the requests to Gemini — for Google's purpose, not ours. A request that is not flagged is not kept as content; its technical record stays with Google. A flagged request may be recorded for up to 90 days — solely to check for abuse — and reviewed by authorised Google staff. Google may also keep the requests in a short-term cache for up to 24 hours. Google does not use your content to train its models.
The request to Gemini goes from your phone to Google and does not pass through us; we receive no copy of the video, and the text of the commentary is not recorded with us.
The captions are fitted to the voice by the timings of the individual words.
Those timings are found by our alignment server, and the voice, too, is fitted to the length of the clip by them. The server is our own service in the European Union, and Google is our processor for the infrastructure.
What it receives. The synthetic voice, the text of the commentary and the language of the clip. For some languages the server forwards the sound of the synthetic voice to a Google speech recognition service — a processor, in the European Union, without logging the data.
What it keeps. Nothing of the content. Its logs carry no content and no IP address and are kept for 30 days.
The settings file (it travels in the Android backup in your Google account): the records of your acceptance of the documents and of your answer about age; the statements on a purchase and the data about the purchases and contracts; which documents have been saved to "Downloads"; your choice about usage statistics and error reports; the usage counters and the pause after refused clips; your preferences.
The files (they do not travel in the backup): the clips with the text of the commentary for each; the event log; the queue of the reports; the temporary files of the production; the files of Google's library for the integrity check.
Usage statistics and error reports may be sent to us only if you have switched on the relevant checkbox. Their receiver is ours, in Google Cloud in the European Union; Google is our processor.
A statistics event carries a name, the time, the version and the language of the app, the random number of the installation and the event's own fields. An error report carries the time, the type of the error and its place in the code, the versions of the app and of Android, the model of the device and the same random number.
Before a request to Google, the app asks Google to confirm that this is a genuine, unmodified copy of Dubroll on a genuine device; the check uses signals about the device and about the app, not content.
For that purpose Google's library keeps on your phone an installation identifier and the token of the check.
We do not sell personal data and we do not share it for targeted advertising.
The number of the two statements. On a purchase the app creates a unique number for the two statements and passes it to Google Play with the order. It links the order to the statements and is our proof that they were given.
The model of the phone. The app reads the model, the chipset and the memory of the device in order to choose a capture mode; what is read for that stays on the phone.
The random number of the installation. It is created only when you switch on the statistics or the error reports, and it does not travel in the Android backup. You can see it in "About & Legal"; a request by email concerning the statistics needs it.
Saving to the gallery. A copy of the clip goes into your phone's gallery.
Sharing. The clip goes to the app you have chosen, together with a short text with hashtags, which may contain words from the commentary; the same text is also copied to the clipboard. The shared file may also carry metadata of the recording, such as the time of recording.
The app asks for access to the camera and the microphone in order to record video with sound — when the camera is first opened, after you have accepted the Terms of Use and this Policy.
Purchases are paid for in Google Play. From Google Play we receive the purchase token, the order number, the product and the plan and the time of the purchase.
The sales reports from Google Play, which go into our accounts, carry the order number, the date and the time of the order, the product and the plan, the device model, the country and — where Google Play provides them — the buyer's region and postcode, the currency and the amounts.
Whether you have PRO and how many purchased clips are left to you is determined by a server of ours, which checks your purchases with Google Play. The app sends it the tokens of your purchases and the records of the two statements belonging to them, and the server returns the state of your purchases.
From Google Play the server also receives the time of expiry, the automatic renewal, the state of the purchase and the country of your Google Play profile, as well as notifications on renewal, termination and refund. If Google Play refunds an amount or voids a purchase, we learn the fact, the date and the reason code.
What it keeps. For every purchase: the token, the kind, the product and the plan, the order numbers, the country of the Google Play profile, the price and the currency, the times and the state according to Google Play, the remainder of purchased clips, the daily number of cinematic clips on PRO and the number of the two statements. It also keeps a copy of the record of the two statements: time, version of the text, language, plan or pack, number of clips, price shown, the included quantities, version of the app and the date of the accepted Terms. The copy is our proof and it remains even if you delete the data on your phone.
On withdrawal from a contract we process the text of your statement, your name (optional), the date and the time, the order number, the indicative amount to be refunded, the channel you have chosen for the confirmation and — if you withdraw by writing to us by email — your email.
In the app every clip can be reported with a reason from a fixed list. The report carries the day, the reason, the commentator and the language of the clip, the AI models, the version of the app, a random identifier of the clip, a fingerprint of the text of the commentary and its length. It does not carry the text of the commentary, the video or an identifier of the installation.
If it cannot be sent at once, the report waits on your phone.
The receiver. The reports go to a receiver of ours in Google Cloud in the European Union; your IP address is not recorded with us. We cannot link a report to a person, and that is why we cannot delete a report on request (Article 11(2) of the Regulation).
Role by service:
Other recipients. Google — the provider of our contact@dubroll.app mailbox; our professional advisers (a lawyer, an accountant).
| Purpose | Legal basis |
|---|---|
| The service itself — sending your video and sound to Google, writing and voicing the commentary, fitting the captions and the voice to the clip, the backup voice, the files and counters on the phone, the backup of the settings, the answer about age before the contract, checking the purchases and access to PRO and to the purchased clips | The contract with you — Article 6(1)(b) of the Regulation. |
| The data of the people in the frame — image, voice, behaviour, setting — in the same sending, including children | Legitimate interest — Article 6(1)(f) (ours and yours: that the clip you have asked for is made); we do not seek special categories of data and do not rely on a condition under Article 9(2). |
| The app integrity check | Legitimate interest — point (f): protection of the service from abuse. |
| The record of the statements made at purchase and their number, passed to Google Play with the order | Legal obligation — point (c): proving the statements (Article 49(10) of the Consumer Protection Act). |
| The record of the acceptance of the Terms and of this Policy | Legal obligation — point (c) (Article 147a(4) of the Consumer Protection Act). |
| Keeping the documents on purchases, statements and withdrawals after the end of the purchase | Legitimate interest — point (f): a defence in a dispute about withdrawal, refund or lack of conformity. |
| The sales reports in the accounts | Legal obligation — point (c) (Article 12 of the Accountancy Act). |
| The withdrawal function, the confirmation and the performance of the withdrawal | Legal obligation — point (c) (Articles 52 and 54 of the Consumer Protection Act). |
| The reports of AI content | Legitimate interest — point (f): safety of the product and of the people in the frame; the Google Play requirement. |
| Usage statistics and error reports | Consent — point (a). |
| Requests for access, deletion and objection; the record of the requests themselves | Legal obligation — point (c) (Articles 12 and 15–21 of the Regulation). |
| Answering a letter you have sent us yourself | Legal obligation — point (c), where you are exercising a right; otherwise legitimate interest — point (f): answering you. |
| Notifying the supervisory authority and the persons concerned of a personal data breach | Legal obligation — point (c) (Articles 33 and 34 of the Regulation). |
What is compulsory and what is not. The video and the sound are necessary for the contract itself: without them there is no commentary and no clip. Without the confirmation of age the app does not start, and without the integrity check a new clip cannot be made. Without the purchase token and the order number, which come from Google Play, the purchase cannot be checked and credited, and the statements are a condition only for a purchase with a right of withdrawal; free use does not depend on them. Reporting a clip and writing to us are your choice, and refusing takes nothing of the service away from you.
Optional too are the statistics and the error reports.
Google LLC (USA) may process your data. The safeguards: the European Commission's adequacy decision of 10 July 2023 (the EU–US Data Privacy Framework), under which Google LLC is certified, and the standard contractual clauses under Article 46(2)(c) of the Regulation in the Cloud Data Processing Addendum — copy: https://cloud.google.com/terms/data-processing-addendum.
For data subject to the UK GDPR, the safeguard is the United Kingdom's regulations of 20 September 2023 on the adequate level of protection in the USA (the UK Extension to the EU–US Data Privacy Framework), in which Google LLC is also certified.
Where your content is processed. Google processes the video, the sound and the text of the commentary in the European Union; the text of the commentary for the voice may also be processed outside it, at Google LLC, under the same safeguards.
The integrity check may also be processed outside the European Economic Area — by Google as our processor, under the same safeguards; the standard contractual clauses for it are in the Firebase Data Processing and Security Terms — copy: https://firebase.google.com/terms/data-processing-terms.
| What | Where | Period |
|---|---|---|
| The "My clips" library | your phone | until you delete the clip or the local data, or uninstall the app |
| The temporary files of the production | your phone (cache) | until the end of the production; leftovers — at a later launch of the app; on a failure the recording stays for a new attempt |
| The event log | your phone | at 1 MB the current file is archived, the previous archive is deleted |
| The queue of the reports | your phone | up to 90 days and up to 200 rows |
| The settings file | your phone and the backup in your Google account | until uninstall; deleting the local data keeps some of the records (below); in the backup — under Android's rules |
| Your video and sound, the text to the voice | Google (processor) | transient; a short-term cache of up to 24 hours; a request flagged by a classifier — up to 90 days |
| The token of the integrity check and the installation identifier | Google (processor) | under the Firebase terms; we do not record them |
| The synthetic voice and the text of the commentary for alignment | our alignment server | transit — not kept; application logs — 30 days |
| Documents on purchases, statements, withdrawal requests | our server | 3 years after the end of the last purchase; the purchase token in clear form — 90 days after the end; the messages from Google Play — 90 days; statements without a purchase — 30 days |
| Sales reports from Google Play | our accounts | 10 years from the first of January of the year following the reporting year (Article 12 of the Accountancy Act) |
| Reports of AI content | our receiver | 12 months |
| Usage statistics and error reports (with consent) | our receiver | 90 days |
| Rights requests | our server | 12 months |
| Letters to support | the mailbox | 12 months after the matter is closed |
| Backups of the server databases | Google (processor) | 7 days |
| Register of security incidents | with us | 5 years |
| The request logs of the dubroll.app website (with an IP address) | Google (processor) | a few months |
The clip and the text of its commentary are deleted when you delete the clip in the "My clips" library; the copy in the gallery stays.
"Delete my local data" in "About & Legal" deletes the app's data on the phone and asks for the backup in your Google account to be replaced. What stays is the proof — the acceptance of the Terms and of this Policy, the answer about age, the statements made at purchase and the details of the contract — and the records without which the deletion would give a new free day or a second crediting: the counters, the pause after clips blocked by moderation, the record that the cinematic welcome clip has been used and the purchases already credited. It does not delete the copies in the gallery, the PRO subscription (it is in Google Play) or the files of Google's library for the integrity check.
Uninstalling deletes the app's data on the phone, but not the copies in the gallery or the backup of the settings in your Google account — Android brings it back on a reinstall.
The data with us. The button "Erase my data at Dubroll" in "About & Legal" sends a request to delete it; by email — at contact@dubroll.app, with the order number from Google Play (it starts with "GPA.") and the date of the purchase. The documents on purchases, statements and withdrawals are not deleted before the end of their period — they are only restricted.
You have the rights under Articles 15–21 of the Regulation: access, rectification, erasure, restriction, portability and objection.
The limit. We do not hold the content sent to Google and cannot identify you in it — so for it we cannot carry out access, rectification, erasure or portability (Article 11(2) of the Regulation).
How and within what period. By a letter to contact@dubroll.app; we answer within one month of receipt, and where the matter is complex — within the extended period under Article 12(3) of the Regulation.
United Kingdom. If you are in the United Kingdom, your processing is also subject to the UK GDPR and the Data Protection Act 2018. You have the same rights under Articles 15–18, 20 and 21 of the UK GDPR and the right to make a complaint to the Information Commissioner's Office (ICO) under section 165 of the Data Protection Act 2018.
A complaint to us. You may also complain directly to us — at contact@dubroll.app; for the United Kingdom this is the route under section 164A of the Data Protection Act 2018. We acknowledge receipt within 30 days and respond on the substance without undue delay, within the period in this section, telling you what we did.
Objection. You can object at any time, on grounds relating to your particular situation, to the processing that rests on a legitimate interest (section "Legal bases by purpose"). Write to contact@dubroll.app with the subject "Objection".
You can also object to the keeping of the documents on purchases after their end.
Withdrawal of consent. The only consent we ask of you is for the statistics and the error reports.
You withdraw it at any time in "About & Legal" by switching it off; the withdrawal takes effect for the future and does not affect the lawfulness of the processing before it.
What we do not do. We do not identify anyone — there is no facial recognition and there are no voiceprints.
The information we owe the person in the frame (Article 14 of the Regulation). Controller — Torvyx Labs Ltd., contact@dubroll.app; source of the data — the user who filmed them or picked the video from the gallery of their own phone (where such a video comes from and whether it was publicly available, we do not know); categories — image, voice, behaviour, setting, and the generated commentary that describes them; purpose — writing and voicing a comedy commentary on the video at the user's request; basis — legitimate interest (Article 6(1)(f)): making the clip the user asked for; recipients — Google as our processor and, if Google's voice refuses, the phone's own synthesiser on the user's phone — for the text of the commentary; transfers to third countries — section "Transfers of data to third countries"; period — transient, section "Retention periods and deletion"; rights — objection, access and erasure, section "Your rights", and a complaint, section "Contact and complaints". We cannot provide this information to the person in the frame personally: we do not know who they are (Article 14(5)(b)).
A ready text you can show the person you are filming: "I am filming you with an app that sends the video and the sound to Google Gemini so that it can write and voice a comedy commentary. The clip stays on my phone until I publish it. What your rights are is written in the "People in the frame" section of dubroll.app/legal/privacy/en/."
The rights of the person in the frame and how to exercise them. Write to contact@dubroll.app — you need not be a user of ours. The objection under Article 21 is live even without our identifying you — the subject "Objection" is enough.
Dubroll is for persons aged 18 and over (the Terms of Use, section "Who may use Dubroll"). We do not knowingly process the data of a user under the age of 18.
On the phone, the app's files are protected by Android's isolated storage and by the encryption of your device.
Data travels to our servers over an encrypted connection and, once there, has no public or client access.
If there is a security breach of which we must notify you, we publish a notice at https://dubroll.app/security (Article 34(3)(c) of the Regulation).
Changes to this Policy follow the procedure of the Terms of Use, section "Changes to the Terms".
Which language version prevails is set out in the Language clause of the Terms of Use — and it applies to this document too.
Write to us at contact@dubroll.app.
The telephone. Calls are not recorded; what you tell us on the telephone we use only in order to answer you.
Supervisory authority. The supervisory authority in Bulgaria is the Commission for Personal Data Protection (CPDP). You have the right to lodge a complaint with it or with the supervisory authority in the Member State in which you live or work (Article 77 of the Regulation).