Impressum

Provider

Anton Licht
c/o Hidden Sea UG (haftungsbeschränkt)
Kolonnenstraße 8
10827 Berlin
Germany

Sole proprietor (Einzelunternehmer). Activity: game developer / software developer.

Contact

Email: support@subtext.it

VAT identification number

VAT ID according to § 27 a of the German VAT Act (UStG): DE356651719

Responsible for content

Responsible for content according to § 18 Abs. 2 MStV: Anton Licht, address as above.

Consumer dispute resolution

I am neither obliged nor willing to participate in dispute resolution proceedings before a consumer arbitration board.

Subtext AI: Terms & Conditions

1. Who we are, and what these terms cover

Subtext is an AI writing assistant that helps you draft, rewrite, proofread and understand messages. It is available as an iOS app, an Android app, and a web app at web.subtext.it.

Subtext is provided by Anton Licht c/o Hidden Sea UG (haftungsbeschränkt), Kolonnenstraße 8, 10827 Berlin, Germany (VAT ID DE356651719) — "we", "us". Full provider details are in the Impressum above. You can reach us at support@subtext.it.

These terms are the contract between you and us. By creating an account or using Subtext you accept them. If you do not accept them, please do not use Subtext.

How we handle your data is a separate topic, covered in our Privacy Policy.

2. Who may use Subtext

• You must be at least 16 years old to use Subtext.
• Subtext is licensed to you for your own personal use. If you use it for work, you confirm you are allowed to do so.
• Using Subtext requires an account. A guest account is created for you automatically the first time you open the app; you can turn it into a permanent account with Apple, Google or your email address. The account is what lets us apply subscription and fair-use limits to a person rather than to an installation.
• Keep your sign-in details to yourself. You are responsible for what happens under your account.

3. Subscription, billing and cancellation

Subtext is a paid subscription service. Some app versions include a small number of free analyses so you can see what Subtext does before you decide; beyond that, an active subscription is required to use the AI features. Available plans, prices and any free trial are always shown to you in the app before you buy.

Apple and Google are the sellers. Subscriptions are bought through the Apple App Store or Google Play. Billing, renewals, cancellation and refunds are handled through your store account, under that store's terms and refund policy. We cannot charge you and we cannot issue refunds ourselves. Your subscription works across the app and the web app, wherever you sign in with the same account.

Automatic renewal. Subscriptions renew automatically at the end of each billing period until you cancel. A free trial converts into a paid subscription unless you cancel it. In both cases, cancel at least 24 hours before the current period or trial ends, otherwise the next period is charged.

How to cancel. Cancel in your store account settings at any time — see "How do I cancel my subscription or trial through the Google Play Store?" below, or your Apple ID subscription settings. You keep access until the end of the period you have already paid for. If you have trouble, write to support@subtext.it and we will help.

Fair use. Every account has a daily processing limit so that heavy automated use cannot degrade the service for everyone else. You can see your current usage in the app's settings. The limit is generous for normal personal use, and we may adjust it.

Price changes. We may change prices or plans. Changes never apply to a period you have already paid for. We will tell you in advance, and you can cancel before the new price takes effect.

4. Your content, and what the AI produces

• Your content stays yours. You give us the limited right to process what you submit — your text, screenshots, voice recordings and files — for the sole purpose of running the service for you. That includes passing it to the AI providers listed in our Privacy Policy. We do not use it to train AI models, and neither do they.
• You must be allowed to submit it. Screenshots and messages often contain someone else's words. By submitting them you confirm you may lawfully do so.
• The output is yours to use. AI output is not unique — comparable requests can produce comparable results for other people — so we cannot grant you exclusive rights in it and we cannot promise it does not resemble existing material.
• Subtext is an AI system, and AI gets things wrong. Output can be inaccurate, misleading, biased or unsuitable for your situation. Read it before you use it. It is not legal, medical, financial, psychological or other professional advice.
• You decide what to send. Nothing leaves Subtext on its own. Once you send a message, it is your message and you are responsible for it — including telling the recipient that AI was involved, where the law requires that of you.

5. What you may not do

• Create or send content that is illegal, hateful, harassing, threatening, defamatory, deceptive or sexually exploitative — in particular anything sexualising minors.
• Impersonate someone, run scams or fraud, send spam, or manipulate people who are vulnerable or in distress.
• Reverse engineer Subtext, access it by automated means, circumvent usage limits or account requirements, or resell access.
• Use Subtext's output to develop or train a competing AI model or service.

If you break these rules we may limit, suspend or close your access. Where the breach is minor and fixable, we will normally warn you first.

6. Availability, changes and support

We work to keep Subtext available and useful, but we cannot promise it will be uninterrupted or error-free. Maintenance, provider outages and app store distribution are outside our full control. Subtext depends on third-party AI services; if one becomes unavailable, features depending on it may be limited.

We keep developing the product, so features change. If we materially reduce a feature you are paying for, we will tell you and you can cancel.

Support is provided by us at support@subtext.it. Apple and Google have no obligation to provide support for Subtext.

7. Ending the contract

• You can stop using Subtext at any time. Deleting the app does not cancel a subscription and does not delete your account — cancel the subscription in your store account settings, and delete your account in the app's settings (see "How do I delete my user account?" below).
• We may terminate this contract for good cause — in particular a serious or repeated breach of section 5 — or by giving you reasonable advance notice if we discontinue the service. If we terminate without your fault, we refund the unused part of any prepaid period.
• Afterwards, your access ends and your data is deleted as described in the Privacy Policy.

8. Liability

• We are fully liable for damages caused intentionally or through gross negligence, for injury to life, body or health, under the German Product Liability Act, and where we have given a guarantee.
• For slight negligence, we are liable only where we breach an obligation that is essential to this contract and that you may reasonably rely on us to meet. In that case our liability is limited to the damage typically foreseeable for this kind of contract.
• Any further liability is excluded. In particular we are not liable for the consequences of messages you choose to send.
• None of this limits rights you have under mandatory consumer protection law.

9. Apple and Google

If you obtained Subtext through the App Store or Google Play, that store's terms apply alongside these. Apple Inc. and Google LLC are third-party beneficiaries of these terms and may enforce them against you. They are not parties to this contract, are not responsible for Subtext or its content, and are not liable to you in connection with it.

10. Legal

• Governing law. German law applies. If you are a consumer, you also keep the protection of the mandatory law of the country you live in.
• Courts. If you are a merchant, a legal entity under public law or have no general place of jurisdiction in Germany, the courts of Berlin have exclusive jurisdiction. Consumers can sue and be sued where the law says.
• Consumer arbitration. We are neither obliged nor willing to take part in dispute resolution proceedings before a consumer arbitration board.
• Changes to these terms. We may update these terms — for example when the service or the law changes. We will tell you at least 30 days before a material change takes effect, by email or in the app. If you do not agree, you can cancel before the new version applies; continuing to use Subtext after that date means you accept it.
• The rest. If a provision turns out to be invalid, the remainder stays in force. These terms, together with the Privacy Policy, are the entire agreement between us about Subtext.

Subtext AI: Privacy Policy

This policy explains what Subtext does with your data. It covers the iOS app, the Android app, the web app at web.subtext.it and this website.

1. Who is responsible

The controller for your data is Anton Licht c/o Hidden Sea UG (haftungsbeschränkt), Kolonnenstraße 8, 10827 Berlin, Germany (VAT ID DE356651719).

Questions, requests and complaints: support@subtext.it. We are established in the EU, so no separate EU representative is required. We are not required to appoint a Data Protection Officer.

2. What we collect

• Account data. A user ID, and — if you sign in with Apple, Google, or your email address — your email address and any display name you provide. Guest accounts hold nothing but the ID.
• What you submit to be processed. The text you type or paste, screenshots and images you attach, voice recordings you dictate, and files you share into the app. This is the heart of the product: it is what Subtext analyses and writes from.
• Your settings and usage counters. Your consent choices, whether web search is enabled, whether your name may be used in requests, your daily processing usage, and how many drafts you have created.
• Subscription data. Your subscription status and plan, and purchase events from Apple and Google. Payment happens inside your store account — we never see your card details.
• Technical and diagnostic data. Device model, operating system, app version, language, IP address, crash reports and performance measurements.
• Marketing measurement identifiers. Advertising and installation identifiers used to see which campaigns bring people to Subtext. On iOS we only access the advertising identifier (IDFA) if you allow it in Apple's tracking prompt. We show no ads inside Subtext.

This website itself sets no analytics or advertising cookies. It stores your language choice locally in your browser, and nothing else.

3. Why we use it, and on what legal basis

• To run the service you asked for — processing your text, images and voice through our AI providers, storing your conversations so you can come back to them, managing your account and subscription. Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).
• Consent for AI processing. Before anything you submit is sent to an AI provider for the first time, we ask you to agree. Read-aloud (text-to-speech) is off until you switch it on. You can change both at any time in the app's settings. Legal basis: consent (Art. 6(1)(a) GDPR), withdrawable at any time with effect for the future.
• To keep the service working and safe — preventing abuse and quota circumvention, enforcing fair-use limits, diagnosing crashes, understanding in aggregate which features are used. Legal basis: our legitimate interest in a functioning, affordable and secure product (Art. 6(1)(f) GDPR).
• Marketing measurement — attributing installs and subscriptions to campaigns. Legal basis: consent, given through Apple's tracking prompt on iOS and equivalent controls elsewhere (Art. 6(1)(a) GDPR).
• Legal obligations — keeping records of transactions for tax and accounting purposes. Legal basis: Art. 6(1)(c) GDPR.

We do not sell your data, we do not show ads in the app, and we do not use what you submit to train AI models.

4. Who processes your data for us

All of these act as our processors under contract, or as independent controllers where noted.

When web search is switched on, Subtext may look something up to answer you. In that case the search terms — derived from your request — are sent through Anthropic to third-party search providers, which operate under their own privacy policies. You can turn web search off in the app's settings.

Beyond this, we share data only where we must: with authorities where the law requires it, or with an acquirer if the business is ever sold. You would be told before your data moved to a new controller.

5. How our AI providers handle what you submit

• None of them may train on your content. Their commercial API terms rule it out, and for voice we additionally set Deepgram's model-improvement opt-out on our transcription requests.
• Anthropic deletes inputs and outputs within 30 days. If its automated safety systems flag a request, it may keep that request for up to 2 years, and the related safety scores for up to 7 years.
• Deepgram, with our opt-out set, keeps your audio only for as long as it takes to transcribe it.
• OpenAI keeps read-aloud requests for up to 30 days for abuse monitoring, then deletes them.
• To be straightforward with you: we do not have a zero-retention arrangement with any of these providers, and all of them may keep data longer where the law requires it or to investigate a breach of their own policies.
• Protection. Everything travels over encrypted connections (TLS). Each provider is bound by a data processing agreement and maintains SOC 2 compliance.

6. Where your data is processed

Your account, your conversations and our server functions run on Google Firebase in the United States. Our AI providers also process in the United States. Product analytics stay in the European Union, on Mixpanel's EU servers. Adjust, our attribution provider, is a German company.

For the transfers to the United States we rely on the European Commission's Standard Contractual Clauses, and on the EU–US Data Privacy Framework where the provider is certified under it. You can ask us for a copy of the safeguards in place.

7. How long we keep it

• Conversations, including the screenshots and voice transcripts attached to them, are deleted automatically 5 days after you last used them — or 90 days if you pin the conversation.
• If you delete a conversation yourself, in the conversation list, it does not wait for that timer and it is not moved to a bin. Every message in it and every attachment it holds is erased from our servers straight away.
• Uploads awaiting processing (for example a screenshot being summarised) are deleted as soon as processing finishes, and within 24 hours in any case.
• Usage records behind the daily fair-use limit expire after 24 hours.
• Your account, settings and subscription status are kept while your account exists.
• Accounts that are never used — created but with no draft written — are deleted automatically after 7 days.
• Analytics and attribution data are kept for up to 14 months, crash reports for 90 days.
• Transaction records are kept for as long as tax and commercial law requires, which in Germany is up to 10 years.

8. Deleting your account

You can delete your account yourself, in the app's settings — see "How do I delete my user account?" below. Your account and the data linked to it are deleted within 14 days, and you get a confirmation email. Cancel your subscription first, in your store or with us, so you are not charged again. Records we must keep for tax purposes are the one exception, and they are kept only for that purpose.

9. Your rights

You can ask us at any time to give you access to your data, correct it, delete it, restrict or object to how we use it, or hand it over in a portable format. You can withdraw any consent you have given, with effect for the future, in the app's settings. Write to support@subtext.it and we will answer within one month.

You also have the right to complain to a supervisory authority. For us that is the Berlin Commissioner for Data Protection and Freedom of Information, but you may complain to the authority where you live.

10. Regional additions

• United Kingdom and Switzerland. The same rights apply under the UK GDPR and the Swiss Federal Act on Data Protection; complaints go to the ICO or the FDPIC.
• United States. Depending on your state, you may have the right to know, delete, correct and obtain a copy of your personal information, to opt out of its sale or sharing for cross-context behavioural advertising, and not to be discriminated against for exercising those rights. We do not sell personal information for money. Sharing device identifiers with our attribution partners for campaign measurement may count as "sharing" under California law; you can stop it by declining Apple's tracking prompt, by turning the equivalent setting off on your device, or by writing to us. This website sets no advertising or analytics cookies, so there is nothing to opt out of there. Exercise any of these rights at support@subtext.it.

11. Security

Data is encrypted in transit (TLS) and at rest on our infrastructure. Access to your data is restricted by authentication rules that let each account reach only its own data, and app requests are verified before our servers will answer them. If a breach ever puts your rights at serious risk, we will notify you and the competent authority as the GDPR requires.

12. Children

Subtext is offered only to people aged 16 and over. It is not directed at children, and we do not knowingly collect data from them. If you believe a child has created an account, write to us and we will delete it.

13. Automated decisions

Subtext generates suggestions; it never makes a decision with a legal or similarly significant effect on you. What you do with a suggestion is always your choice.

14. Changes to this policy

We will update this policy when the service or the law changes. Material changes are announced in the app or by email before they take effect, and the date at the top always tells you which version you are reading.

How Do I Delete My User Account?

Step-by-Step Instructions

1. If you have an active subscription, please cancel it in the App Store or Play Store first to avoid future charges.
2. Open the app drawer and tap your profile icon at the bottom to access the Settings page.
3. On the Settings page, tap Delete Account and confirm the deletion.
4. You will be automatically logged out, but you will still be able to access your account until we complete processing your account deletion.

Processing Time

We will process your request within 14 days and send you a confirmation email. Please check your spam folder as well.

How Do I Cancel My Subscription or Trial Through the Google Play Store?

Once you activate a free trial through the Google Play Store, you will need to cancel at least 24 hours before the trial ends to avoid being charged for the annual subscription.
To cancel your subscription you can follow these steps:

1. Open the Google Play app.
2. At the top right, tap the profile icon.
3. Tap Payments & subscriptions Subscriptions.
4. Select the subscription or prepaid plan you want to cancel.
5. Tap Cancel subscription.
6. Follow the instructions.

What happens after I cancel?

When you cancel a subscription you’ll still be able to use your subscription for the time you’ve already paid.