Privacy Policy

1. Introduction

Welcome to DubbiOvi, an open-access AI-assisted audiovisual translation platform developed by the University of Oviedo (Spain) to support teaching, research, and knowledge transfer in the field of audiovisual translation.

DubbiOvi has been designed according to the principles of Privacy by Design and Privacy by Default (Article 25 of Regulation (EU) 2016/679, the General Data Protection Regulation – GDPR). Its local-first architecture minimises the collection, processing and storage of personal data by ensuring that users' audiovisual materials remain on their own devices unless they explicitly choose to use external services.

This Privacy Policy explains:

• what personal information may be collected;
• why it is collected;
• the legal basis for processing;
• how it is processed and protected;
• how long it is retained;
• with whom it may be shared; and
• the rights available to users under applicable data protection legislation.

Where processing is based on consent, such consent is obtained through a clear affirmative action during the registration process.

2. Data Controller

The University of Oviedo is the Data Controller for the personal data processed in connection with the administrative management of the DubbiOvi project.

University of Oviedo

C/ San Francisco 3
33003 Oviedo
Spain
Website: https://www.uniovi.es

The day-to-day operational management of the project is coordinated by:

Operational Project Contact

Alfonso C. Rodríguez Fernández-Peña
Department of English, French and German Philology
University of Oviedo
Email: rodriguezalfonso@uniovi.es

The University of Oviedo has appointed a Data Protection Officer (DPO) who may be contacted regarding any matter relating to the processing of personal data:

Data Protection Officer

Email: delegadopdatos@uniovi.es
Website: University of Oviedo Privacy Portal

Processing activities are carried out in accordance with:

• Regulation (EU) 2016/679 (GDPR);
• Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD);
• the University of Oviedo's institutional data protection policies.

3. Personal Data We Collect

When users voluntarily register to download DubbiOvi, the following information may be collected:

• First name
• Last name
• Email address
• Institution or organisation
• Country
• Operating system (Windows or macOS)
• Downloaded software version
• Date and time of registration

No payment information, banking details, government-issued identification documents or audiovisual project materials are requested or stored.

Only the minimum amount of personal information necessary for project administration is collected, in accordance with the GDPR principle of data minimisation.

4. Data We Do Not Collect

DubbiOvi follows a local-first computing model.

The application does not automatically collect, upload, monitor, analyse or transmit:

• audiovisual files;
• videos;
• audio recordings;
• subtitles;
• scripts;
• translations;
• terminology databases;
• translation memories;
• exported projects;
• documents;
• behavioural analytics;
• telemetry;
• keystrokes;
• screen recordings.

Users retain full control over their work, which remains stored locally on their own computers unless they intentionally choose to use external services.

5. Purpose and Legal Basis of Processing

Administrative registration data are processed exclusively for purposes related to the University's teaching, research and knowledge-transfer activities, including:

• managing software downloads;
• administering the DubbiOvi project;
• communicating software updates and security notices;
• evaluating dissemination and academic impact;
• producing anonymised statistical information for research, institutional reporting and knowledge-transfer activities;
• improving future versions of the software.

The processing of personal data for these purposes is based on Article 6(1)(e) GDPR, as it is necessary for the performance of a task carried out in the public interest within the framework of the University of Oviedo's academic activities.

Where users voluntarily subscribe to receive communications beyond those strictly necessary for project administration, processing is based on the user's consent in accordance with Article 6(1)(a) GDPR.

Personal data are never processed for commercial advertising, profiling or marketing purposes.

6. Use of External Artificial Intelligence Services

Some optional DubbiOvi features allow users to interact with third-party Artificial Intelligence providers (for example, Google Gemini or other AI services selected by the user).

When these services are used:

• only the information necessary to process the user's request is transmitted;
• processing is governed exclusively by the privacy policy and terms of service of the selected provider;
• the University of Oviedo and the DubbiOvi project do not intercept, monitor, archive or permanently store the information exchanged with those services.

Users should not submit personal data, confidential information or special categories of personal data to external AI services unless they have an appropriate legal basis and sufficient safeguards to do so.

The University of Oviedo does not control the processing carried out independently by third-party AI providers and cannot be held responsible for their data processing practices.

7. Data Storage and Security

Administrative registration data are stored within the University of Oviedo's institutional Google Workspace environment.

The information stored is limited to registration records:

• name;
• surname;
• email address;
• institution;
• country;
• operating system;
• downloaded software version;
• registration date and time.

Google Workspace provides the cloud infrastructure under the contractual and security guarantees applicable to the University's institutional Google Workspace services.

Access is restricted to authorised project personnel using authenticated institutional accounts and is protected through appropriate technical and organisational security measures.

These measures include, where applicable:

• authenticated institutional access;
• password-protected accounts;
• encrypted HTTPS communications;
• regular software updates;
• secure version control;
• restricted administrative permissions;
• periodic backups where appropriate.

8. Data Sharing

Personal information is never sold, rented, licensed or disclosed to third parties for commercial purposes.

Only fully anonymised and aggregated statistical information may be used for:

• scientific publications;
• conference presentations;
• institutional reports;
• funding applications;
• dissemination activities;
• impact assessment;
• knowledge-transfer activities.

No individual user can be identified through these statistics.

9. Data Retention

Administrative registration data are retained only for as long as necessary to fulfil the purposes described in this Privacy Policy.

As a general rule, registration data will be retained while the DubbiOvi project remains active or until the user requests deletion of their personal data, unless a longer retention period is required by applicable legal obligations.

When personal information is no longer required, it will be securely deleted or irreversibly anonymised where appropriate.

10. Your Rights

Subject to the applicable provisions of the GDPR and other relevant legislation, users may exercise the following rights:

• access;
• rectification;
• erasure;
• restriction of processing;
• objection;
• data portability, where applicable;
• withdrawal of consent where consent constitutes the legal basis for processing.

Requests may be submitted through the University of Oviedo or the Project Contact indicated below.

If you consider that your personal data have not been processed in accordance with applicable data protection legislation, you have the right to lodge a complaint with the:

Spanish Data Protection Authority (Agencia Española de Protección de Datos – AEPD)

Website: https://www.aepd.es

11. Contact

12. Changes to this Privacy Policy

This Privacy Policy may be updated as the DubbiOvi project evolves or as required to reflect changes in applicable legislation or institutional data protection requirements.

The latest version will always be available through:

• the official DubbiOvi website;
• the project's GitHub repository.

Where significant modifications affect the processing of personal data, the updated policy will replace previous versions and the document version and revision date will be updated accordingly.