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Dubformer
Data Processing Agreement

Dubformer
Data Processing Agreement

Current version. Last updated on 01.11.2025.

RECITALS

RECITALS

A. Dubformer, Inc. ("Dubformer") operates and provides an online platform, available at https://studio.dubformer.ai/ (the “Platform”, “Dubformer Studio”), offering services related to AI Dubbing and localization.

B. The Client is a media company, content creator, agency, or individual seeking to use the Services as defined herein.

For the purposes of this Agreement, "Dubformer" refers to Dubformer, Inc., a legal entity organized and existing under the laws of the United States of America.

We reserve the right to modify or update any part of this Agreement at our sole discretion. Notice of changes will be provided by posting an updated version of the Agreement on the Platform. Continued use of the Platform after such changes have been posted constitutes your acceptance of the revised Agreement. If you are using a corporate account, only the designated administrator of that account will receive such notifications. The administrator is solely responsible for informing other members of the corporate account about any changes.

By completing the required registration fields to create a Client profile and accepting this Data Processing Agreement, you represent and warrant to Dubformer that:

(i) you have full authority to bind yourself and/or your organization to this Agreement;

(ii) you agree to be bound by Dubformer's Terms of Service

(iii) you acknowledge and agree that you are considered a Client under this Agreement.

If you do not agree to the terms of this Agreement, you are not authorized to submit Service Requests on the Platform.

For purposes of this Agreement, the "Client" means any User of the Platform who submits a Service Request and remits payment for such Services.

  1. DEFINITIONS

1.1. “Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with Dubformer.

1.2. “Content” means any file, data, document, text, audio, video, multimedia, or other material—including spoken or written content—that the Client submits to Dubformer via the Platform for processing (e.g., dubbing, translation, subtitling) by uploading it.

1.3. “Controller” means the entity that determines the purposes and means of processing Personal Data.

1.4. “Client” means a User of the Platform who has entered into a Service Agreement with Dubformer.

1.5. “Data Protection Laws” means all applicable data protection, privacy, and data security laws and regulations, including (without limitation) the UK General Data Protection Regulation (“UK GDPR”), the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and any similar or equivalent applicable laws or regulations.

1.6. “Data Subject” means an identified or identifiable natural person to whom Personal Data relates.

1.7. “EEA” means the European Economic Area.

1.8. “EU” means the European Union.

1.9. “GDPR” / “General Data Protection Regulation” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC.

1.10. “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored, or otherwise processed.

1.11. “Personal Data” means any information relating to an identified or identifiable natural person (Data Subject).

1.12. “Processing” / “Processing of Personal Data” means any operation or set of operations performed on Personal Data, whether by automated means or not, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure, or destruction.

1.13. “Processor” means Dubformer, when it processes Personal Data on behalf of the Controller.

1.14. “Security Measures” means the administrative, physical, and technical safeguards implemented within Dubformer’s systems to protect Personal Data. The specific Security Measures are detailed in section 6.1 of this Agreement.

1.15. “Service Agreement” means the contractual agreement between the Client and Dubformer governing the provision of services as a signed master services agreement.

1.16. “Services” means Dubformer’s suite of AI dubbing and related services, including but not limited to subtitling, dubbing, voice-over, audio description, transcription, and translation.

1.18. “Dubformer Studio” / “Platform” means Dubformer’s website and proprietary technology platform for AI dubbing workflow automation, accessible at https://studio.dubformer.ai/.

1.19. “Dubformer” means Dubformer Inc., a legal entity incorporated under the laws of the United States of America, with its registered office at 251 Little Falls Drive, Wilmington, DE 19808, United States.

1.20. “Standard Contractual Clauses” / “SCCs” means the standard contractual clauses adopted by the European Commission for the transfer of Personal Data to countries outside the EU/EEA.

1.21. “Subprocessor” means any third party engaged by Dubformer to process Personal Data on Dubformer’s behalf in connection with the Services.

1.22. “Supervisory Authority” means an independent public authority established under Data Protection Laws with responsibility for monitoring compliance with such laws.

1.23. “UK International Data Transfer Agreement or Addendum” / “UK IDTA” means either (a) the International Data Transfer Agreement under the UK GDPR, or (b) the International Data Transfer Addendum to the EU SCCs issued by the UK Information Commissioner, as in force from March 21, 2022.

1.25. “User” means a Client registered on the Platform.

  1. DURATION OF THIS DPA

2.1. This Data Processing Agreement (“DPA”) shall remain in force for the duration of the Terms of Service or any applicable Service Agreement between you and Dubformer. It will automatically terminate upon the expiration or termination of those agreements, unless otherwise required by applicable law.

  1. ROLES

3.1. For the purposes of this DPA, Dubformer acts as a “Processor” as defined under Article 4 of the GDPR, and you, as the Client, act as the “Controller.”

  1. PROCESSING OF YOUR PERSONAL DATA

4.1. This section outlines key details regarding the processing of your Personal Data:

a) Subject matter and duration: The subject matter and duration of the processing are described in the Terms of Service, the Service Agreement, and this DPA.

b) Nature and purpose: The processing of your Personal Data is carried out to provide software-as-a-service (SaaS) solutions for AI dubbing and related media localization services.

c) Types of Personal Data processed: Personal Data may include your first name, last name, and email address.

  1. PERSONAL DATA IN CONTENT UPLOADED TO THE DUBFORMER PLATFORM

5.1. You acknowledge and agree that Dubformer may not have visibility into whether Personal Data is included in the content you upload to the Dubformer Studio, unless you explicitly inform Dubformer of its presence. In such cases, you retain full responsibility for ensuring that any Personal Data within the uploaded content is processed in compliance with applicable Data Protection Laws.

  1. CCPA

6.1. To the extent that the California Consumer Privacy Act (CCPA) applies to the processing governed by this DPA, Dubformer acknowledges that it acts as a service provider or contractor, as applicable, with respect to the Personal Data processed under this Agreement. Dubformer further acknowledges that the Controller is disclosing Personal Data solely for the specific services described in the Service Agreement.

6.2. Dubformer additionally acknowledges and agrees that:

  • Dubformer will retain, use, or disclose such Personal Data only as necessary to fulfill the Business Purpose and will not use Personal Data outside the direct business relationship with the Controller or combine it with Personal Data collected from other sources;

  • Dubformer will not sell or “share” (as defined under the CCPA) the Personal Data, nor use it for any other purpose unless explicitly permitted under the CCPA;

  • Dubformer will promptly notify the Controller if it determines that it can no longer comply with its obligations under this section of the DPA; and

  • The Controller reserves the right, upon notice, to take reasonable and appropriate measures to stop and remediate any unauthorized use of Personal Data by Dubformer.

  1. SUBPROCESSORS

7.1. You acknowledge and agree that:

a) Dubformer’s Affiliates may be engaged as Subprocessors; and

b) Dubformer and its Affiliates may appoint third-party Subprocessors as necessary to support the provision of the Services.

7.2. You hereby authorize Dubformer to engage the Subprocessors listed below, with the understanding that, where applicable, if you have entered into Standard Contractual Clauses (SCCs) or a UK International Data Transfer Agreement (UK IDTA), this authorization shall constitute your prior written consent to Dubformer’s use of Subprocessors for the processing of Personal Data, where such consent is required under the SCCs or UK IDTA.

Name

Name

Name

Location

Location

Location

Purpose

Purpose

Purpose

Amazon AWS

Amazon AWS

Amazon AWS

EU data center – Personal Data of all Dubformer Users provided upon registration and content uploaded by Clients in Europe (EEA), Australia, Africa. USA data center – Content uploaded by Clients in North and South America. China data center – Content uploaded by Clients in the APAC region.

EU data center – Personal Data of all Dubformer Users provided upon registration and content uploaded by Clients in Europe (EEA), Australia, Africa. USA data center – Content uploaded by Clients in North and South America. China data center – Content uploaded by Clients in the APAC region.

EU data center – Personal Data of all Dubformer Users provided upon registration and content uploaded by Clients in Europe (EEA), Australia, Africa. USA data center – Content uploaded by Clients in North and South America. China data center – Content uploaded by Clients in the APAC region.

Hosting

Hosting

Hosting

Nebius

Nebius

Nebius

EU data center

EU data center

EU data center

Hosting

Hosting

Hosting

Google

Google

Google

EU, USA

EU, USA

EU, USA

Machine translation, text-to-speech

Machine translation, text-to-speech

Machine translation, text-to-speech

OpenAI

OpenAI

OpenAI

EU, USA

EU, USA

EU, USA

Machine translation

Machine translation

Machine translation

Microsoft Azure

Microsoft Azure

Microsoft Azure

EU, USA

EU, USA

EU, USA

Text-to-speech

Text-to-speech

Text-to-speech

DeepL

DeepL

DeepL

EU

EU

EU

Machine translation

Machine translation

Machine translation

Anthropic Claude

Anthropic Claude

Anthropic Claude

USA

USA

USA

Machine translation

Machine translation

Machine translation

ElevenLabs

ElevenLabs

ElevenLabs

EU, USA

EU, USA

EU, USA

Text-to-speech

Text-to-speech

Text-to-speech

Speechmatics

Speechmatics

Speechmatics

EU, USA

EU, USA

EU, USA

Speech recognition

Speech recognition

Speech recognition

7.3. Dubformer may update the list of Subprocessors from time to time to reflect new engagements or changes.

7.4. Each Subprocessor will access and process Personal Data provided by you or uploaded to the Dubformer Platform solely to the extent necessary to perform the specific services subcontracted to it.

7.5. Dubformer remains fully responsible for the performance of all obligations subcontracted to its Subprocessors, as well as for their acts and omissions.

7.6. If you object in writing to the appointment of a new Subprocessor on reasonable data protection grounds within 15 days of receiving notice of the change, the Parties will engage in good faith discussions to resolve your concerns. If a mutually satisfactory resolution cannot be reached, your sole and exclusive remedy shall be the right to terminate this DPA and the applicable Service Agreement.

  1. INTERNATIONAL DATA TRANSFERS

8.1. Dubformer (and its Affiliates) may process and transfer Personal Data globally as necessary to provide the Services.

8.2. For clarity, if you are located in the European Union, your content will be stored in Dubformer’s EU data center and will not be transferred outside the EU unless:

8.2.1. You assign a Service Request to a Supplier (Subcontractor) located outside the EU, in which case your content will be made available to that non-EU Supplier.

8.2.2. You instruct Dubformer to utilize non-EU servers of machine translation engines or AI dubbing services listed in the table under section 7.2.

8.2.3. You independently select a machine translation engine or AI dubbing service listed in the table under section 9.2 that operates non-EU servers.

8.3. The Standard Contractual Clauses (SCCs) or UK International Data Transfer Agreement (UK IDTA) are incorporated by reference into this DPA and will apply where required by applicable Data Protection Laws to govern the transfer of Personal Data. The SCCs or UK IDTA are deemed completed as follows:

8.3.1. As stated above, you act as the Controller and Dubformer acts as the Processor with respect to your Personal Data; therefore, Module 2 of the SCCs applies.

8.3.2. Clause 7 (the optional docking clause) is not included.

8.3.3. Under Clause 9 (Use of Subprocessors), the parties select Option 2 (General written authorization). The notice period for any intended changes to the list of Subprocessors shall be at least 24 hours in advance.

8.3.4. Clause 11 (Redress) will not apply.

8.3.5. Under Clause 17 (Governing Law), the parties choose Option 1 and designate the law of the Netherlands.

8.3.6. Under Clause 18 (Choice of Forum and Jurisdiction), the parties designate the courts of the Netherlands.

  1. DATA SUBJECT RIGHTS

Taking into account the nature of the processing, Dubformer shall assist you by implementing appropriate technical and organizational measures to support your obligations—understood reasonably by you—regarding the fulfillment of Data Subject rights under the General Data Protection Regulation (GDPR) and any other applicable Data Protection Laws.

9.1. Dubformer shall promptly notify you if it receives a request from a Data Subject or a Supervisory Authority under any Data Protection Law concerning your Personal Data. Dubformer will also cooperate with you, as reasonably requested, to assist in fulfilling your obligations under applicable Data Protection Laws.

9.2. If Dubformer receives a request from a Data Subject relating to Personal Data provided by you or uploaded by you to the Dubformer Studio, and unless otherwise specified in section 10.1, you shall remain responsible for responding to such requests. Where appropriate, you may utilize the available functionalities of the Dubformer Studio to address the request.

  1. PERSONAL DATA BREACH

10.1. Dubformer shall notify you without undue delay, and in any case no later than forty-eight (48) hours after becoming aware of a Personal Data Breach affecting your Personal Data. The notification will include sufficient details to enable you to meet any legal obligations to report the breach to Supervisory Authorities or to inform Data Subjects, as required under applicable Data Protection Laws. Dubformer will cooperate with you and take all reasonable commercial steps, including those reasonably directed by you, to assist with the investigation, mitigation, and remediation of the breach.

10.2. Dubformer’s obligation to report or respond to a Personal Data Breach shall not be interpreted as an admission of fault or liability by Dubformer regarding the breach.

10.3. Dubformer clarifies, and you agree, that unsuccessful security incidents will not be reported. An unsuccessful security incident is one that does not result in unauthorized access to Personal Data or to Dubformer’s systems or facilities where Personal Data is stored. Such incidents may include, without limitation: firewall or edge server pings, port scans, unsuccessful log-in attempts, denial-of-service attacks, or similar events that do not compromise Personal Data.

  1. DATA PROTECTION IMPACT ASSESSMENT

11.1. Dubformer shall provide reasonable assistance to you in connection with data protection impact assessments and, where applicable, prior consultations with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or any other relevant data protection authority, where you reasonably determine such assessments or consultations are required under Articles 35 or 36 of the GDPR, or under equivalent provisions of other applicable Data Protection Laws. This assistance will be provided solely in relation to the processing of your Personal Data by Dubformer and its Subprocessors, taking into account the nature of the processing and the information reasonably available to Dubformer.

  1. DATA RETURN OR DELETION

12.1. During the term of the Service Agreement or Terms of Service, you may delete any uploaded Content yourself at any time using the available features of the Platform.

12.2. Upon termination, and upon your written request, Dubformer shall securely delete or return to you any Personal Data or Content provided by you, within a maximum of 30 days from receipt of the request.

12.3. Notwithstanding the above, Dubformer may retain copies of your Personal Data or Content: (i) as required to comply with applicable Data Protection Laws, or (ii) in accordance with its standard data backup procedures, in which case such data will be deleted in the ordinary course of the backup lifecycle. In either case, Dubformer will (x) maintain the confidentiality of retained Personal Data and Content and continue to comply with applicable provisions of this DPA, and (y) refrain from further processing of retained Personal Data and Content except as strictly necessary for compliance with legal obligations.

  1. YOUR WARRANTIES, COVENANTS, AND UNDERTAKINGS

13.1. You covenant and undertake to Dubformer that:

  • You will comply at all times with applicable Data Protection Laws relevant to your role as Controller or Processor (as applicable) in relation to any Personal Data you provide to Dubformer and/or upload to the Dubformer Platform under the Terms of Service and Service Agreement.

  • Where required by law, you will enter into SCCs, the UK IDTA, or any other applicable cross-border data transfer mechanisms.

  • You are solely responsible for complying with any incident notification obligations applicable to you, including notifying Supervisory Authorities and affected Data Subjects in the event of a Personal Data Breach.

13.2. You warrant to Dubformer that:

  • If you are acting as a Processor, your instructions and actions with respect to Personal Data provided to Dubformer have been duly authorized by the relevant Controller.

  • The Security Measures implemented and maintained by Dubformer, as set out in this DPA, provide a level of security appropriate to the risk associated with the Content you provide and/or upload to the Dubformer Platform.

  • The Content you provide does not include special categories of Personal Data (as defined under applicable Data Protection Laws), unless you have notified Dubformer in writing in advance.

  1. WARRANTIES, COVENANTS, AND UNDERTAKINGS OF DUBFORMER

14.1. Dubformer covenants and undertakes to you that it will:

  • Comply at all times with applicable Data Protection Laws in relation to any Personal Data provided to Dubformer and/or uploaded by you to the Dubformer Platform under the Terms of Service or Service Agreement.

  • Promptly notify you if, in Dubformer’s opinion, any instruction you provide regarding the processing of Personal Data appears to contravene applicable Data Protection Laws.

  • Inform you in writing if Dubformer becomes unable to comply with its obligations under this DPA, in which case you may terminate this DPA or take other reasonable steps, including suspending the processing of Personal Data.

  1. GENERAL TERMS

15.1. Liability. All liabilities of Dubformer under this DPA are strictly limited to the liability cap specified in the Service Agreement.

15.2. Notices. All notices required or permitted under this DPA must be in writing and addressed to the parties’ designated email addresses, unless another address has been formally specified. Notices to the User will be sent to the email address listed in the User’s account dashboard. Notices to Dubformer should be sent via support@dubformer.ai.

15.3. Order of Precedence. In the event of any conflict or inconsistency between documents, the following order of precedence shall apply: (1) any Standard Contractual Clauses (SCCs) or other agreed-upon cross-border transfer mechanisms, (2) this DPA, and (3) the Service Agreement and Terms of Service. To the fullest extent permitted by applicable Data Protection Laws, any claims arising under this DPA will be governed by the terms and conditions (including any exclusions and limitations of liability) set forth in the Service Agreement.

15.4. Amendments. Dubformer reserves the right to amend or update this DPA at any time. You will be notified of any amendments either by email or via the Platform. Your continued use of the Platform following the effective date of any changes will constitute your acceptance of the updated DPA, unless you have otherwise expressly accepted the changes earlier. If you are using a corporate account, only the account administrator will receive such notifications and is solely responsible for informing other members of the corporate account.

Our Details and Contact Information

Our Details and Contact Information

Dubformer, Inc.

Place of business: 251 Little Falls Drive, Wilmington, DE 19808, United States

Email for notificationssupport@dubformer.ai
This document is valid if published at: https://dubformer.ai/data-processing