Privacy Policy (GDPR)

_Last updated: 2026-11-06_

This policy describes the personal data processed by Tubindex, the purposes, the sub-processors involved, and the rights you hold under the GDPR.

1. Data controller

The data controller is:

• ATOM47 EOOD
• Registered office: 18 Shipchenski prohod Blvd, Block A, floor 3, 1113 Sofia, Bulgaria
• EIK: 207674808
• Email: support@tubindex.com

2. Data collected

We process the following categories of data:

2.1 Account data

• email address (mandatory), which you also use to sign in;
• username, assigned automatically from your email address at sign-up (you do not choose it);
• interface language (FR/EN);
• subscription preferences and personal settings.

Signing in to Tubindex does not rely on any password. Passwords created before the email link sign-in was introduced are no longer used. They will be deleted from our servers after the transition period.

2.2 Usage data

• YouTube channels you subscribe to;
• videos imported and summarised;
• personal notes and hashtags you create;
• summary consultation history.

2.3 Technical data

• IP address (limited to security logs and rate-limiting);
• user agent (browser, OS);
• session identifiers;
• error and performance logs.

2.4 Analytics data

Via PostHog EU Cloud, subject to your prior consent: aggregated usage events (pages visited, key actions) associated with a technical identifier and your user ID. Neither your email nor your notes are sent to PostHog.

2.5 Billing data (paid subscribers)

• billing name and address (if provided);
• intra-EU VAT number (for business customers);
• payment history and invoices.

Bank card data is never collected or stored by Tubindex: it is processed exclusively by the payment processor.

2.6 Sign-in data

Each time you request a sign-in link, we record:

• the email address entered, including when no account exists for that address;
• a short description of your browser and operating system, derived from the user agent (for example "Chrome · Windows");
• the timestamps of the request.

This data is used to authenticate you, to secure your account and to prevent abuse. It is deleted at the latest 24 hours after the link expires.

After a successful sign-in, we also place a recognition cookie on your device (__Host-tbx_kd, 90 days). It contains a fingerprint of your email address computed with a secret server key, from which your address cannot be recovered. It lets this device keep receiving sign-in links when a third party sends a large number of requests. It cannot sign you in on its own. Signing out your other devices from the settings makes it inoperative on all your devices.

2.7 Usage time

When you are signed in, we measure the active time you spend in the app, counted per hour (the number of seconds of activity in each hour), and the time zone of your browser (for example Europe/Paris). We record nothing of what you read or click.

The measurement takes place in your browser, only while the page is visible and in use. It stops 60 seconds after your last action. No third party receives this data, and this measurement adds no cookie or tracker.

This data is used to measure the load on our servers and to size our infrastructure to it. It also serves internal statistics on the use of the Service. This measurement is necessary for the operation of the Service, so it applies to every signed-in account.

2.8 Data stored on your device (offline mode)

So that you can open Tubindex without a network connection, the app keeps some data in your browser, on your device (IndexedDB storage and the service worker cache):

• a copy of the app files (code, styles, page shell), so that the app opens offline;
• a copy of your lists (library, liked videos, trash, feed): video titles, channels, summaries and your notes, kept for at most 7 days;
• a copy of the full summaries and of the thumbnails of your most recent videos (at most the 500 videos added last to your library and the 200 newest videos of your feed), downloaded while the app is open. The thumbnails come from YouTube's image servers, as when the app shows them online. A copy is deleted when its video leaves these windows;
• the profile of the last signed-in account, as the app received it, so that the app can open offline;
• the actions you take offline (note text, read or unread status, favorites, trash and restore, summary requests), waiting to be sent to our servers, kept for at most 7 days.

This data stays on your device. It is not sent to any third party and is not used for any tracking. When the connection returns, the waiting actions are sent to our servers and processed like any other action on the Service.

• Signing out yourself deletes all of this data from the device.
• When your session ends on its own, the copies of your lists and of your profile are deleted. The waiting actions stay on the device, for the same account only, so that they can be sent when you sign in again.
• When another account signs in on the same device, the data of the previous account is deleted.

You can also delete this data at any time by clearing the site data in your browser settings.

2.9 Gift subscriptions

A signed-in user (the donor) can offer 1 to 24 months of Tubindex to another person (the recipient). Payment goes through Stripe, in full or in monthly installments over at most 9 months. For gifts, the donor has a Stripe customer record separate from the one used for their own subscription.

If you offer a gift, we process:

• the recipient's email address that you enter;
• your optional signature and your optional notes (the message shown in the invitation and the message shown at first use);
• the number of months, the payment mode, the currency, the language of the mail and the chosen send date;
• the payment history and invoices of the gift.

If the invitation cannot be delivered (bounce), we show you a masked form of the address so that you can correct it.

If you receive a gift, your data does not come from you: the donor provides it. We process:

• your email address, as entered by the donor, and a canonical form of it (lowercase, without +tag and, for Gmail, without dots), used for the anti-abuse caps and the block list;
• the invitation mail and the reminders sent to you (at day 7 and at day 30), and their delivery events (sent, delivered, bounce, complaint);
• the status of the gift (sent, claimed, expired, cancelled, refunded, among others).

The invitation mail is sent from hello@emails.tubindex.com, through our transactional email provider. The gift expires after 12 months if nobody claims it. Each mail has a link to stop all gift mails to your address (your address then goes on a block list) and a link to report an abuse.

To prevent abuse, we apply caps: at most 3 gifts per donor in 24 hours, at most 2 invitations to the same address in 24 hours, and at most 50 invitations per hour across the whole Service.

2.10 Tubi, the help assistant

When you ask a question to Tubi, our AI help assistant, we store:

• your questions and Tubi's answers;
• your Yes or No click after each answer;
• your account identifier;
• the language of your questions.

This data is used to answer you and to improve the help center and the assistant. Tubi answers from the help center and the pricing pages. It does not read your library, your notes or your videos. It receives only the state of your account (active until a date, or expired since a date).

Your questions and the earlier messages of the conversation are sent to the AI providers listed in Section 5, so that they can write the answer. We keep a conversation 30 days after its last message, then we delete it. We also delete it when your account is deleted.

3. Legal bases (GDPR Art. 6)

Each processing activity is based on an appropriate legal ground:

4. Retention periods

5. Sub-processors

We rely on sub-processors for the following purposes, acting on instructions and under a data processing agreement (GDPR Art. 28):

6. International transfers

Some sub-processors are located outside the EEA (notably in the USA). For each of these transfers, we rely on the European Commission's Standard Contractual Clauses (Decision 2021/914) and implement the supplementary technical and organisational measures recommended following the Schrems II ruling (encryption in transit, data minimisation, access control).

7. Your rights

You may at any time exercise the following rights over your data (GDPR Arts. 15 to 22):

• Access: obtain a copy of the data concerning you;
• Rectification: correct inaccurate data;
• Erasure ("right to be forgotten"): request deletion of your data;
• Restriction: limit processing in the event of a dispute;
• Portability: receive your data in a structured, commonly used, machine-readable format;
• Objection: object to processing based on legitimate interest;
• Withdrawal of consent: without affecting the lawfulness of processing carried out before the withdrawal;
• Post-mortem directives: provide instructions on the fate of your data after your death.

Gift recipients hold the same rights, in particular access, rectification, erasure and objection, even without a Tubindex account. You can ask for erasure at any time through the contact address given in Section 8. If you stopped gift mails to your address, an erasure keeps only what the block list needs to keep honouring that opt-out (the canonical form of your address). We explain this to you in our reply.

8. How to exercise your rights

Send your request by email to support@tubindex.com, specifying the right you wish to exercise. We may, in case of reasonable doubt, request proof of identity.

We reply within one (1) month of receipt, extendable by two (2) months in the event of complexity, with reasoned notice in that case.

9. Complaint to a supervisory authority

Without prejudice to any other remedy, you have the right to lodge a complaint with a supervisory authority:

• France: CNIL — Commission nationale de l'informatique et des libertés, https://www.cnil.fr.
• Bulgaria (lead authority given our registered office): CPDP — Commission for Personal Data Protection, https://www.cpdp.bg.
• Any other supervisory authority of your Member State of habitual residence.

10. Data Protection Officer (DPO)

ATOM47 EOOD has not appointed a Data Protection Officer. Under Article 37 of the GDPR, such appointment is not mandatory in our case:

• the company has fewer than 250 employees;
• our core activity does not consist of regular and systematic monitoring of data subjects on a large scale;
• we do not process special categories of data on a large scale (health data, religious beliefs, biometric data, etc.).

For any data protection question, the single point of contact is: support@tubindex.com.

11. Security

We implement appropriate technical and organisational measures to protect your data:

• HTTPS/TLS encrypted transport across the entire Service;
• passwordless sign-in through a single-use link valid for 15 minutes;
• a 6-digit code when the link is opened on a different device from the one that requested it;
• isolated database, access via API key and strong authentication;
• rate-limiting on sensitive endpoints;
• session expiry after 30 days without activity, and in any case 90 days after sign-in;
• sign-out of all your other devices, available from your settings;
• an alert email sent to your account's email address when a sign-in is confirmed with a code;
• a notice sent to your previous address when the account email changes, with a cancellation link valid for 7 days;
• logging of sensitive actions and periodic access reviews;
• encrypted backups with a 30-day rolling retention.

12. Data breach

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we:

• notify the CPDP (Bulgarian lead authority) within seventy-two (72) hours of becoming aware of it, in accordance with Article 33 of the GDPR;
• inform the data subjects concerned without undue delay where the breach is likely to result in a high risk, in accordance with Article 34 of the GDPR.

13. Minors

The Service is not intended for persons under 16 years of age. We do not knowingly collect data from minors under 16. If you notice that a minor has created an account, report it to support@tubindex.com: the account will be closed and the data deleted promptly.

14. Changes to this policy

We may amend this policy to reflect legal or technical developments. Any material change will be notified to you by email at least thirty (30) days before it takes effect, with a reminder of your right to object and, where applicable, to close your account.