Privacy Policy
Last updated: 6 May 2026
This Privacy Policy describes how Caply ("we", "us", "the app") handles your information when you use the Caply iOS application. By using Caply you agree to the practices described here.
1. Data Controller
The controller of your personal data within the meaning of the EU General Data Protection Regulation 2016/679 ("GDPR") is:
Panda Unit sp. z o.o.
ul. Złota 75A lok. 7
00-819 Warszawa, Poland
NIP: 5272950764
KRS: 0000885005
Email: caply@pandaunit.com
2. Data we collect
Caply is designed to keep your data on your device wherever possible. Specifically:
- Videos and audio you import are stored locally on your device. We do not upload, copy, or retain your video files on our servers.
- Audio sent for transcription. When you generate captions, the app extracts the audio track and sends it to OpenAI's Whisper API for transcription. We do not store this audio. See "Third-party services" below for OpenAI's policy.
- Subscription and purchase data is handled by Apple and our subscription provider, RevenueCat. We receive only an anonymous user identifier and entitlement status — never your Apple ID, payment method, or billing address.
- Diagnostics. If you opt in to Apple's "Share With App Developers" setting, we may receive anonymous crash reports through Apple. We do not run our own analytics or tracking SDKs.
3. Data we do not collect
- We do not collect your name, email, phone number, or address.
- We do not collect device identifiers (IDFA, IDFV) for advertising.
- We do not track your activity across apps or websites.
- We do not collect location data. Caply explicitly strips GPS metadata from exported videos.
4. Legal basis for processing
We process personal data on the following legal bases under GDPR Article 6:
- Art. 6(1)(b) — performance of a contract. Sending audio to OpenAI to generate captions, and processing subscription state via RevenueCat, are necessary to deliver the service you have purchased or activated.
- Art. 6(1)(f) — legitimate interests. Receiving anonymous crash diagnostics through Apple's opt-in channel, where it helps us keep the app stable and secure, without overriding your rights.
Caply does not run advertising, analytics, or marketing trackers, so we do not rely on consent (Art. 6(1)(a)) for any processing.
5. Third-party services
Caply uses a small number of third-party services to function:
- OpenAI — audio is sent to the Whisper API for transcription. OpenAI's API privacy terms apply: openai.com/policies/privacy-policy. Per OpenAI's API data policy, audio sent through the API is not used to train their models. Transfers to OpenAI take place to the United States and are covered by Standard Contractual Clauses approved by the European Commission.
- RevenueCat — handles subscription state and entitlements. RevenueCat's privacy policy: revenuecat.com/privacy.
- Apple — purchases, App Store delivery, and any opt-in diagnostics are handled by Apple under their privacy policy.
6. Data retention
- Videos and captions on your device — kept until you delete them or uninstall the app.
- Audio sent to OpenAI — not retained by us; processed in real time and discarded after the response is returned.
- Subscription identifiers (RevenueCat App User ID, entitlement status) — retained while your subscription is active and for the period required by Polish tax and accounting law (currently 5 years after the end of the relevant tax year).
- Crash diagnostics (Apple-mediated, opt-in) — retained for up to 12 months for stability investigations.
7. Your rights
Under the GDPR you have the following rights with respect to your personal data:
- Right of access — to obtain a copy of the data we hold about you.
- Right to rectification — to correct inaccurate or incomplete data.
- Right to erasure ("right to be forgotten") — to request deletion of your data.
- Right to restriction of processing — to limit how we process your data.
- Right to data portability — to receive your data in a structured, machine-readable format.
- Right to object to processing based on legitimate interests.
Because Caply stores almost nothing about you on our side, most requests are satisfied by deleting the app from your device. For anything else, email caply@pandaunit.com and we will respond within 30 days.
You also have the right to lodge a complaint with a supervisory authority. In Poland, this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) — uodo.gov.pl.
8. International transfers
Some of the third parties we rely on (notably OpenAI and RevenueCat) are based outside the European Economic Area. Where personal data is transferred internationally, we rely on safeguards approved under GDPR — primarily the European Commission's Standard Contractual Clauses — to ensure your data continues to be protected to EU standards.
9. Children
Caply is not directed at children under the age of 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect data from children.
10. Changes to this policy
We may update this Privacy Policy occasionally. Material changes will be reflected in the "Last updated" date above and, where appropriate, surfaced in the app.
11. Contact
Questions about this policy or your data? Email caply@pandaunit.com.