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Privacy Policy

Last updated: 4 October 2026

Introduction

Welcome to Subturtle. This Privacy Policy explains how CodeBridger LTD ("Subturtle," "we," "us," or "our") collects, uses, and discloses information about you when you access or use our website, browser extension, and services (collectively, the "Service").

We are committed to protecting your privacy. By using our Service, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

We collect several different types of information for various purposes to provide and improve our Service to you.

a) Information You Provide to Us:

  • Account Information: When you register for an account, we collect personal information, such as your name and email address.
  • Payment Information: If you subscribe to our Pro Plan, our third-party payment processor (e.g., Stripe) will collect your payment card information. We do not store this information on our servers.
  • User Content: We collect the words, phrases, and any associated notes you save while using the Service. This is essential for providing features like flashcards and personalized practice.
  • Communications: If you contact us directly, we may receive additional information about you, such as the contents of your message and any other information you may choose to provide.

b) Information We Collect Automatically:

  • Usage Data: We automatically collect information about your interactions with our Service. This includes your activity on the user dashboard, which features you use, the phrases you save and practice, your performance in review sessions, and your interactions with the AI Coach.
  • Device and Log Information: We collect information from your device, including your IP address, browser type, operating system, and the dates and times of your access.
  • Information from Third-Party Services: When you use our browser extension on sites like YouTube or Netflix, we collect information about the subtitles you interact with to provide our Service. We do not collect your viewing history from these platforms.

2. How We Use Your Information

We use the information we collect for various purposes, including to:

  • Provide, operate, and maintain our Service.
  • Process your transactions and manage your subscription.
  • Personalize your learning experience by identifying language areas for improvement and suggesting relevant practice.
  • Communicate with you, including responding to your inquiries and sending service-related announcements.
  • Analyze usage to understand how our Service is used and to improve it.
  • Enforce our Terms of Service and prevent fraudulent activity.

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

  • With Service Providers: We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, hosting, and providing the technology for our AI Coach.
  • For Legal Reasons: We may disclose your information if we believe it is required by applicable law, regulation, or legal process.
  • With Your Consent: We may share your information for any other purpose with your consent.

4. Your Data Protection Rights under UK GDPR

If you are a resident of the United Kingdom, you have certain data protection rights. CodeBridger LTD aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

  • The right to access, update or delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CodeBridger LTD relied on your consent to process your personal information.

5. Data Security and Retention

We use appropriate technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure.

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, or to comply with our legal obligations.

6. Third-Party Services

Our Service integrates with third-party services like YouTube and Netflix. This Privacy Policy does not apply to the practices of these third parties, and we encourage you to review their privacy policies.

7. Children's Privacy

Our Service is not intended for use by children under the age of 13. We do not knowingly collect personally identifiable information from children under 13.

8. Cookies on Our Website

Our website, subturtle.app, uses cookies and similar technologies only if you agree in the cookie banner.

  • Analytics (Mixpanel): We measure how people use the website, for example which pages they visit and which buttons they click. Mixpanel stores a cookie with a random identifier. If you later sign in to the Subturtle dashboard, this identifier can be linked to your account.
  • Advertising measurement (Google Ads): We measure whether our ads bring people to Subturtle. Google may set cookies and receive information about your visit, as described in Google's own privacy policy.

If you choose "Decline", we do not load these tools. We remember your choice in your browser's local storage, so we do not ask you again. You can change your choice at any time with "Cookie settings" at the bottom of every page.

Our film plays from YouTube (youtube-nocookie.com), and only after you press play. YouTube's privacy policy applies to the video player.

9. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

10. Contact Us

If you have any questions about this Privacy Policy, please contact us info@codebridger.co.uk

CodeBridger LTD