1. Who is responsible
Marcel Labs Sàrl, Route du Burenoz 45, 1092 Belmont-sur-Lausanne, Switzerland, which operates Scrivio, is the controller for the personal data described here. For data-protection matters, write to the address on the Contact page.
2. What we collect
Account data: your email address, first and last name, interface language and account status. We keep no password: a sign-in code is stored only as a hash and expires after ten minutes. Content data: the audio and video files you upload, the transcripts produced from them, and the corrections, highlights, comments and tags you add. Usage data: how many audio-minutes you have transcribed, when, and against which file. Technical data: a log of each request — timestamp, route, HTTP status, duration, your IP address and a limited set of request headers — kept as a security and audit record.
3. Why we process it
To provide the service you asked for: storing your files, transcribing them and showing you the result. To operate a fair free tier, which requires counting the minutes you use. To keep the service secure and to investigate abuse. To send you transactional email: sign-in codes, notification that a transcript is ready, quota warnings and retention warnings. We do not send marketing email and do not sell or share personal data with anyone for their own purposes.
4. Legal basis
Under the GDPR: performance of a contract (Art. 6(1)(b)) for providing the service and its transactional email; legitimate interests (Art. 6(1)(f)) for security, abuse prevention and audit logging; and consent where we specifically ask for it. Under the revised Swiss Data Protection Act, processing is carried out in accordance with the principles of Art. 6 FADP. Your recordings may contain sensitive personal data — that is your decision to upload, and we handle it accordingly.
5. Audience measurement
To know the audience of the public site and where accounts come from, we record on our servers, for each page of the site you read, the data described under Audience measurement in the Cookie Policy: the page, the referring site and the campaign parameters, the characteristics of the browser and the screen, the performance, the engagement and a few interactions, along with your IP address, your user agent, the language your browser announces and, if you are signed in, your account. The IP address is also used to place the visit (country, region, city, the organisation of the network) with the DB-IP Lite databases, queried on our servers. When an account is created, we attach to it the first and the last visit of the same browser in the previous 90 days. No cookie and no browser storage are used for this measurement. Legal basis: our legitimate interest in knowing the audience of our site (Art. 31 FADP; Art. 6(1)(f) GDPR). This data is kept for three years and is passed to no third party. You can object to it by turning on your browser’s Do Not Track or Global Privacy Control signal: it then sends us nothing, and our server ignores any measurement request carrying either signal.
6. Where your data is
The application servers, the database and uploaded files are hosted on the Infomaniak cloud in Switzerland, and none of it is replicated to another country. Transactional email — sign-in codes, transcript-ready notices, quota and retention warnings — is delivered by Mailgun from the European Union: the one processing that takes place outside Switzerland.
7. How long we keep things
Transcripts and audio: on the free plan, a transcript is deleted automatically after a period that starts at its last opening, or at its creation if it has never been opened. 30 days before the deletion, we send an email listing the transcripts concerned; opening one restarts its retention period. Unless you reopen it, its files are deleted on the date given, with no further email. Paid plans are exempt. Account data and usage records: for as long as your account exists. Technical request logs and system logs: 365 days. Audience measurement: 3 years.
8. What deletion actually removes
This is the section worth reading carefully, because "delete" means two different things here and we would rather be precise than comfortable. When you delete a single transcript — or after the 14-day period following the expiration email if you have not reopened it — we permanently remove the audio recording and the generated transcript files from disk. The transcript text itself is retained in your account record, together with the usage entry, so that the monthly minute accounting remains correct and cannot be reset by deleting files. That text is not visible to you afterwards and is not shared with anyone, but it is present in our database and in our backups, and we are telling you so rather than claiming otherwise. When you delete your account, everything goes: the files on disk, the transcripts and their text, your annotations, your tags and your usage records are erased. Your email address is retained only in an archived form so the address can be reused for a new account, and technical request logs are kept in an anonymised form with no link to you.
9. Sub-processors
We use Infomaniak (Switzerland) for hosting and storage, and Mailgun (European Union) for outbound email. That is the entire list, and it is published on the Sub-processors page; we will update it before adding anyone new.
10. No model training
Your recordings, transcripts and corrections are never used to train, fine-tune or evaluate any machine-learning model, ours or a third party's, and are never sold or licensed to anyone. Transcription runs on our own infrastructure; your audio is not sent to an external transcription API.
12. Your rights
You may request access to your personal data, correction of it, deletion of it, a portable copy of it, restriction of processing, and you may object to processing based on legitimate interests. You can exercise most of these directly in the application: correct your transcripts in the editor, export your content at any time, and delete individual files or your entire account from your account settings. For anything else, write to the address on the Contact page; we will respond within 30 days. You also have the right to complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, if you are in the EU or EEA, to your national supervisory authority.
13. Security
Traffic is encrypted with TLS 1.2/1.3 and HSTS is enabled. There is no password: you sign in with a single-use code, valid for ten minutes, tied to the browser that asked for it, of which only a hash is stored. Access to every transcript is checked on each request rather than only in the interface. Internal services communicate over a private network that is not exposed to the internet. No system is perfectly secure, and we will notify you and the competent authority without undue delay if a breach affects your personal data.
14. Children
Scrivio is not directed at children and we do not knowingly create accounts for anyone under 16. If you believe a child has created an account, tell us and we will delete it.
15. Changes to this policy
We will publish any updated version here with its date. If a change materially affects how we handle your personal data, we will tell you by email before it takes effect.
16. Contact
For any privacy question or to exercise a right, use the address on the Contact page. We answer every request and confirm receipt.