- App name: Subtitle Player & Editor (also referred to as “Subtitle Tool” in this Policy)
- Developer: frog-im
- Contact: g.ns.0700g@gmail.com
- Effective date: 2025-12-12
This Policy is drafted with reference to applicable laws including the Korean Personal Information Protection Act (PIPA), the GDPR/UK GDPR, the Swiss FADP, and relevant U.S. state privacy laws. If there are jurisdiction-specific requirements, those requirements take precedence.
1. Purpose and Scope
This app provides:
- Subtitle playback and editing (e.g., SRT, VTT, ASS, SSA, LRC)
- Video + subtitle playback from files selected by the user
- Floating subtitle / lyrics overlay displayed over other apps (Android)
The app does not create a user account and does not upload user media or subtitle content to our own servers.
Processing is performed on the user’s device by default.
However, for advertising, consent management, and legal compliance purposes, third-party partners (such as Google Mobile Ads SDK (AdMob) and Google UMP) may collect and process information including advertising identifiers and related signals.
Consent collection and privacy choices follow the Google UMP (User Messaging Platform) specifications where applicable.
2-1) Files Explicitly Chosen by the User
The app interacts only with files the user explicitly selects, such as:
- Subtitle files
- Examples:
.srt, .vtt, .ass, .ssa, .lrc
- Use:
- Displaying subtitles/lyrics in a floating overlay or inside the app
- Editing subtitle timing and text and saving to a new file
- Processing: Performed locally on the device (parsing and saving via libraries such as
subtitle)
- Media files (optional)
- Examples: local video/audio files selected by the user (e.g., via file picker)
- Use: Playing video/audio together with selected subtitles inside the app
- Processing: Decoding and playback are done locally (e.g., using
better_player or similar libraries)
Important:
- The app does not upload user-selected subtitles or media files to our own servers.
- Paths and contents are used strictly for playback, overlay display, and user-initiated editing.
2-2) Local Settings and Stored Values
For the app to function and provide a consistent user experience, certain settings are stored locally on the device using SharedPreferences or equivalent OS mechanisms.
These values are not sent to our own servers and are removed when the app or its data is deleted.
(1) Overlay position, size, and style (SharedPreferences)
| Type |
Key (example) |
Purpose |
Storage |
Deletion |
| Overlay position (Y) |
overlay_box_y |
Restore vertical position of subtitle overlay box |
Device SharedPreferences |
Removed when app data or app is deleted |
| Overlay position (X / left alignment) |
overlay_box_x |
Horizontal alignment / offset (typically fixed or 0) |
Same |
Same |
| Overlay font size |
overlay_text_font |
Keep user-selected subtitle font size for both overlay and in-app player |
Same |
Same |
| Overlay font color |
overlay_text_color |
Keep text color for overlay |
Same |
Same |
| Overlay outline usage |
overlay_outline_enabled |
Whether to draw outline around overlay text |
Same |
Same |
| Overlay outline color |
overlay_outline_color |
Color of the text outline |
Same |
Same |
| Overlay outline width |
overlay_outline_width |
Thickness of the text outline |
Same |
Same |
| Overlay width/height |
overlay_box_w, overlay_box_h |
Default or user-tuned overlay size in dp |
Same |
Same |
| Overlay ad counter |
overlay_interstitial_count |
Internal counter for showing ads periodically (e.g., every 3rd overlay launch) |
Same |
Same |
These keys are used to:
- Restore the last used overlay position on the screen
- Synchronize subtitle style between Overlay Box Editor, video player, and Android overlay app
- Control how often full-screen or rewarded ads are attempted (e.g., “every third overlay usage”)
Depending on your region and app settings, the app may store flags such as:
pref_npa_always (non-personalized ads preference)
pref_us_rdp (U.S. Restricted Data Processing)
pref_child_directed / pref_under_age (child-directed / age-related tagging for ads)
pref_max_ad_rating (maximum allowed ad content rating)
Purpose:
- To remember your privacy and ad-related choices, and to configure AdMob / UMP in a way that respects those choices.
Storage / deletion:
- Stored locally through
SharedPreferences.
- Removed when app data is cleared or the app is uninstalled.
(3) Temporary files
During normal operation, the app may create temporary files, for example:
- Parsed/converted subtitle contents used internally
- Small caches created by third-party libraries or file pickers
These temporary files:
- Reside in OS-managed cache or temporary folders
- Are deleted by the app where practical, and may also be cleaned up by the OS over time
- Are not uploaded to our own servers
(4) User-selected save locations
When you use “Save As” or similar features:
- The app may write subtitle files to a directory you choose (e.g., Downloads or another folder chosen via a system file picker).
- Such files reside in external or user-managed storage and may remain after app deletion.
- You can delete these files manually via your file manager or cloud storage interface.
(5) Consent State (UMP SDK Cache)
In certain regions (EEA/UK/CH and others as determined by Google UMP):
- The UMP SDK may cache your ad consent state locally on the device.
- This can typically be reset by:
- Clearing the app’s data, or
- Using an in-app Privacy Options / Consent screen where provided.
The app uses Google Mobile Ads SDK (AdMob) and Google UMP for:
- Displaying ads (including rewarded ads for some operations such as subtitle saving)
- Managing ad-related consent where required by law
These third-party SDKs may collect or process, for example:
- Advertising identifiers (e.g., AAID / IDFA)
- IP-based information, approximate location, and general network info
- Device and app information (OS version, app version, language, crash logs relevant to ads)
- Ad interaction and engagement signals (e.g., impressions, clicks, completed views in rewarded ads)
- Consent choices recorded via UMP
Purposes:
- Ad delivery and reporting
- Frequency capping
- Fraud and abuse prevention
- Legal compliance (e.g., consent and age-related flags)
Regions such as EEA/UK/CH:
- Consent is requested through UMP prompts where required.
- A Privacy Options button may be shown to revisit your choices.
Regions without such explicit legal requirements (e.g., Korea):
- The UI may not show a separate Privacy Options button if not required,
but OS-level settings (e.g., ad ID reset) remain available.
3. Processing and Retention
- Local settings (SharedPreferences):
- Retained on the device until you clear app data or uninstall the app.
- Temporary files:
- Created and used during subtitle operations and playback.
- Deleted where practical by the app; also subject to OS-level cache cleanup.
- User-saved subtitle files:
- Written to destinations you choose (e.g., Downloads, other folders, or cloud locations).
- Remain under your control, and are not removed automatically when uninstalling the app.
- Ads / consent data (third-party):
- Stored, processed, and retained in accordance with Google’s policies and applicable law.
4. Third-party Transfers and Cross-Border Data Flows
For advertising and consent management, certain data is processed by Google and its partners.
| Item |
Details |
| Recipient |
Google LLC and its affiliates/sub-processors |
| Destination |
The United States and other regions where Google’s infrastructure is located |
| Purpose |
Ad delivery, performance measurement, fraud prevention, consent management, and legal compliance |
| Data |
Advertising identifiers, IP-based info, device/app info, ad interaction signals, consent state, etc. |
| Retention |
Per Google’s policies and applicable laws |
| Effect of refusal |
Personalized ads may be limited; non-personalized ads or fewer ads may be shown |
We aim to keep our Google Play Data safety disclosures consistent with how the app and its SDKs actually process data.
5. Your Rights and How to Exercise Them
Depending on your jurisdiction, you may have rights such as:
- Access to your personal data
- Rectification or erasure
- Restriction of processing
- Data portability
- Objection to certain processing
- Withdrawal of consent (where consent is the legal basis)
In practice:
- Ads and consent choices
- In UMP-supported regions (e.g., EEA/UK/CH): adjust choices in Settings → Privacy Options (if provided in the app UI).
- Otherwise, use OS settings to reset the advertising ID or limit ad personalization.
- Local settings and overlay configuration
- Clearing app data or uninstalling the app resets:
- Overlay coordinates and size
- Font size, color, outline settings
- Stored ad/privacy preferences
For ad-related data processed by Google, please refer to and use Google’s own tools and processes (e.g., Google account ad settings, UMP dialog, etc.).
6. Children’s Privacy
This app is not directed to children.
- The app’s primary purpose is subtitle/lyrics editing and floating overlay, which presumes use by older teens or adults.
- If a child under the legally required minimum age uses the app, they should stop using it and use OS-level ad-limiting features with a guardian.
Where appropriate, the developer may enable child-directed flags (e.g., TFUA) or equivalent settings in ad SDKs to better protect minors, in line with platform policies.
7. Security Measures
Within the app’s architecture and scope, we seek to:
- Minimize data collection to what is necessary for subtitle and overlay functionality
- Keep processing on-device wherever possible
- Limit file access strictly to files you explicitly choose through system file pickers
- Use system-level permissions transparently (e.g., overlay permission, notification permission on Android)
- Rely on TLS or equivalent encryption in transit for network traffic handled by third-party SDKs (such as ad and consent frameworks)
8. Data Safety (Google Play)
For distribution through app stores such as Google Play, we:
- Prepare and maintain a Data safety section that accurately reflects how the app and its third-party SDKs handle data
- Update the disclosure without undue delay if there are material changes in processing (e.g., enabling analytics or crash reporting SDKs in future versions)
9. Open-source Notices
This app uses open-source software (for example, libraries for:
- Subtitle parsing and serialization
- Video playback
- Overlay windows
- WebView integrations
- Localization and UI components)
Open-source licenses and notices are provided inside the app (e.g., in an “Open Source Licenses” section).
Where required, source code access instructions for relevant components will be provided in the corresponding notice files.
If you have questions about this Policy or privacy-related requests:
Please include the app name “Subtitle Player & Editor (Subtitle Tool)” in your inquiry so we can identify the correct app.
11. Changes to This Policy
We may update this Policy due to:
- Changes in laws or regulations
- Updates to app features (for example, adding new SDKs or services)
- Internal policy adjustments
Minor updates:
- Will be posted within the in-app privacy section and on the policy page.
Material changes:
- We will provide notice at least 7 days before the new effective date, where required by law or platform policy.