Privacy Policy

1. Overview

SCHMUGG Realtime Translation is a browser-based tool for video calls with real-time translation (subtitles, chat, optional voice output). There is no registration and there are no user accounts. We do not permanently store any conversation content.

2. Data we process

When you use the app we process: the display name you choose, the room code and your selected language; audio and video streams (only while you actively enable microphone or camera – both are off by default); transcripts, translations and chat messages (transient, for immediate processing); technical data such as IP address, browser type and hosting server logs.

Local preferences (e.g. chat height) are stored in your browser's localStorage. No cookies are used for tracking or advertising.

Transmission: the connection to our servers is TLS-encrypted throughout; audio and video are transmitted encrypted via LiveKit (DTLS-SRTP). True end-to-end encryption – where only the participants themselves could read the content – is not possible for translation: for OpenAI to transcribe and our server to translate, both must process the content in plain text (see section 4).

3. Purposes and legal bases

Processing is carried out to provide the service (Art. 6(1)(b) GDPR) and based on our legitimate interest in security and stability (Art. 6(1)(f) GDPR). Microphone and camera are used only after you actively grant permission in your browser (consent, Art. 6(1)(a) GDPR); you can switch both off at any time using the controls.

4. Recipients and processors

Hosting: Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. The application is served from Frankfurt am Main, Germany (EU region); Vercel processes application delivery and server logs.

Audio/video transport: LiveKit (cloud infrastructure for real-time media streams).

Transcription and translation: OpenAI (audio or text content is transmitted to the OpenAI API for immediate processing; under OpenAI's API terms this content is not used to train models).

Data processing agreements or equivalent privacy arrangements are in place with these providers.

Recording feature: the app offers the option to record a call (video, audio of all participants, chat history and translations). The recording is created and stored solely on the recording person’s device; it is not transmitted to SCHMUGG, and SCHMUGG has no access to it. Under Art. 4(7) GDPR, the recording person is the controller for that recording, not SCHMUGG.

A recording only starts once all participants have actively consented beforehand (Art. 6(1)(a) GDPR). Consent can be withdrawn at any time with effect for the future; the recording then stops immediately. If someone joins, everyone is asked again. A consent record is stored locally alongside the recording on the recording person’s device.

Note: in Germany, recording the non-public spoken word without the consent of everyone involved is a criminal offence under section 201 of the Criminal Code. The app therefore only records after explicit consent from everyone and permanently displays an indicator to all participants while recording. Where used by companies with employees, section 26 BDSG and section 87(1)(6) BetrVG may also apply.

5. Transfers to third countries

The application itself is hosted in the EU (Frankfurt am Main). Nevertheless, OpenAI (transcription/translation), LiveKit and Vercel as a US company may process data in the USA. Such transfers are based on EU Standard Contractual Clauses (Art. 46 GDPR) or, where certified, the EU-US Data Privacy Framework.

6. Retention

We do not store conversation content. The chat history exists only in the participants' browsers for the duration of the session. Technical logs held by our providers are deleted after a short time in accordance with their policies.

7. Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21 GDPR), as well as the right to withdraw consent at any time.

You also have the right to lodge a complaint with a supervisory authority, e.g. the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg, Germany.

8. Supplementary notice for users in China (PIPL)

For users in the People's Republic of China, the Personal Information Protection Law (PIPL) applies in addition. The processor responsible is the controller named above. Processing takes place outside the People's Republic of China: hosting in Germany (EU) and – for transcription and translation – processing by OpenAI, possibly in the USA.

By joining a room and actively enabling microphone or camera, you give your separate consent within the meaning of Art. 39 PIPL to this cross-border transfer of the data described (display name, voice and text content, technical data) to the recipients named. You may withdraw this consent at any time by switching off microphone and camera or leaving the room.

Under the PIPL you have the right to access and copy, rectification, deletion, restriction and withdrawal of consent. Contact: info@schmugg.gd.

9. Changes

We will update this privacy policy when the service or the legal situation changes. The version published here applies.