Privacy Policy

1. Data Controller

The data controller is:

• Caption Desk - BN : 145311478
• Montreal, Quebec, Canada
• Email: desk@captiondesk.app

2. Scope

This policy applies to all Caption Desk users, regardless of their country of residence.

It is intended to ensure compliance with:

• the GDPR (European Union)
• PIPEDA (Canada)
• the CCPA/CPRA (California, United States)

3. Data We Collect

3.1 Data You Provide

• Name, email address
• Subscription information
• Uploaded images
• Editorial descriptions and context

3.2 Technical Data

• IP address
• Session data
• Technical and error logs

4. Purposes of Processing

Data is used solely to:

• Provide the service (IPTC metadata generation)
• Manage accounts and subscriptions
• Ensure security and service stability
• Diagnose errors

No advertising use and no profiling.

5. Legal Basis (GDPR)

We process data on the following legal bases:

• Performance of a contract: provision of the service
• Legitimate interests: security, abuse prevention, and service improvement
• Legal obligations: invoicing and regulatory compliance

6. Processing of Images and Editorial Data

• Images are processed solely to generate IPTC metadata
• They are not retained long-term
• They are neither sold, reused, nor indexed

Position on Sensitive Data

• Caption Desk does not perform facial recognition for identification purposes
• No biometric profile is created
• No sensitive attributes (origin, opinions, etc.) are inferred

7. Core Commitment

User data is never used to train artificial intelligence models.

8. Processors

9. International Data Transfers

Some processing activities involve transfers outside your country (including to the United States).

These transfers are governed by:

• Standard Contractual Clauses (SCCs)
• or equivalent recognized safeguards

10. Retention Periods

• Images and series: maximum of 24 hours
• Technical logs: 30 days (configurable from 1 to 90 days)
• Account data: for the lifetime of the account
• Billing data: as required by applicable law

11. Security

We implement:

• HTTPS encryption
• Restricted access controls
• Access logging
• Anomaly monitoring

12. User Rights

You have the following rights:

• access
• rectification
• erasure
• restriction
• objection
• data portability

Contact: [to be completed]

13. Account Deletion

Deletion triggers:

• anonymization or deletion of personal data
• deletion of associated data
• deactivation of access

14. Specific U.S. Rights (CCPA/CPRA)

We do not sell or share your personal data.

You may request:

• access
• deletion
• correction

15. Minors

The service is not intended for individuals under 16 years of age.

No intentional collection of personal data from minors.

16. Cookies

Caption Desk uses only technical cookies required for the service to function.

No advertising tracking.

17. Editorial Responsibility

Caption Desk is an assistance tool.

• Users remain responsible for published content
• Metadata must be reviewed before publication

18. Changes

This policy may be updated at any time.

Material changes will be notified.