Privacy Policy

Last Updated: November 3, 2025

This Privacy Policy describes how Lightspark Games LLC (“Subtext,” “we,” “our,” or “us”) collects, uses, and protects your personal data when you use our website (www.subtextai.app) and related AI-powered content creation services (the “Services”).

We value your privacy and are committed to protecting your information. By using Subtext, you agree to the practices described below.

1. Overview

Who we are: Lightspark Games LLC operates Subtext, an AI-powered marketing and content creation platform.

What we collect: Account, billing, usage, and content data you provide or generate.

Why we collect it: To deliver, improve, and secure the Services; to process payments; and to comply with law.

Your rights: You may access, correct, delete, or restrict your personal data, and opt out of marketing.

Contact: support@subtextai.app

2. Information We Collect

A. Information You Provide

We collect the following data when you use Subtext:

  • Account Information: Name, email, password, and organization details (if applicable).

  • Payment Details: When purchasing subscriptions or AI credits, you provide billing data (processed securely by third-party providers such as Stripe). Subtext does not store full credit card numbers.

  • Content and Prompts: Any text, files, or data you enter into Subtext for content generation (“User Content”).

  • Feedback and Support Requests: When you contact us via email or forms, we store your message and contact details.

B. Information Collected Automatically

When you use our site or app, we automatically collect:

  • Device and browser information (IP address, OS, and version).

  • Usage data such as page views, session length, and interaction patterns.

  • Cookies and similar technologies to remember your preferences and analyze performance.

You can manage cookies through your browser settings. Essential cookies are required for site functionality.

C. Information From Other Sources

We may receive information about you from:

  • Payment processors for transaction verification.

  • Analytics and marketing partners (e.g., Google Analytics) for performance measurement.

  • Affiliates or integrations you connect to your account.

3. Google User Data (OAuth Integration Disclosure)

If you connect your Google account (e.g., Google Drive or Google Docs), we may request limited OAuth permissions to perform actions you explicitly authorize.

What we collect from Google:

  • File metadata (such as document names and IDs).

  • Document text or content only when you choose to generate or edit it through Subtext.

  • We never collect Google passwords, contacts, or unrelated data.

How we use Google user data:

  • To create, read, or update Google Docs content only at your request.

  • To display your connected files within Subtext for editing or AI-generation purposes.

  • To maintain functionality of integrations you’ve enabled.

We do not use Google user data for advertising, analytics, or profiling.

Limited Use Policy Compliance: Subtext’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

  • Data obtained from Google APIs is used only for the feature you authorize and is not shared with third parties except as necessary to provide or secure the Services.

  • We do not sell, rent, or transfer Google user data for independent marketing purposes.

  • Google user data is stored securely and deleted when you disconnect your account or request deletion.

4. How We Use Your Information

We use personal data to:

  • Provide, maintain, and improve the Subtext platform.

  • Authenticate users and secure accounts.

  • Process payments for subscriptions or AI credits.

  • Generate AI-powered content at your request.

  • Communicate with you about updates or support.

  • Detect, prevent, and address fraud or abuse.

  • Comply with legal obligations.

  • Personalize your experience and recommend relevant features.

We do not sell or rent personal data to third parties.

5. AI-Generated and User Content

When you use Subtext to create AI-generated content:

  • Your input text (“User Content”) may be processed by third-party AI models.

  • Generated outputs (“Generated Content”) may be stored temporarily to deliver results and improve quality.

  • You retain ownership of your Generated Content.

  • We may analyze anonymized usage patterns to improve performance.

  • We never use User Content for public AI training without your explicit consent.

6. Legal Bases for Processing (EEA/UK Users)

If you reside in the EEA, UK, or Switzerland, processing is based on:

  • Contract performance: To provide the Services.

  • Legitimate interests: To improve and secure our Services.

  • Consent: For marketing communications or integrations.

  • Legal obligations: To comply with applicable law.

You may withdraw consent at any time without affecting prior processing.

7. Sharing of Information

We share data only when necessary and under strict confidentiality agreements with trusted service providers and partners who help us operate Subtext. These include:

  • Supabase (USA): Provides managed Postgres database, authentication, and storage services.

  • Google Cloud / Firebase (USA): Provides cloud hosting, serverless runtime infrastructure, logging, and monitoring.

  • Stripe (USA): Processes payments and subscriptions securely.

  • OpenAI, xAI, and Google (USA): Supply AI language model APIs used for generating marketing content.

  • Brevo (Sendinblue, EU): Handles transactional and customer email delivery through EU-based data centers.

We may also disclose information in limited circumstances:

  • Legal compliance: When required by law, subpoena, or valid government request.

  • Corporate transactions: If Subtext is involved in a merger, acquisition, or sale of assets, your data will remain protected under this Privacy Policy.

  • Affiliates: Other entities under the control of Lightspark Games LLC may access data solely to support or improve the Services.

We do not sell, rent, or transfer Google user data or personal data for marketing or advertising purposes.

8. Retention of Data

We retain your data only as long as necessary:

  • Account and billing data: For the duration of your account and as required by tax or legal obligations.

  • User and Generated Content: Retained until deleted or anonymized.

  • Google user data: Retained only while connected and deleted when access is revoked.

  • Support and communication logs: Up to 24 months after last contact.

When deletion is requested, backups and stored copies are purged within a reasonable timeframe.

9. Your Privacy Rights

For All Users
You have the right to:

  • Access or export your personal data.

  • Correct inaccurate information.

  • Request deletion (“Right to be forgotten”).

  • Object to processing or restrict use.

  • Opt out of marketing communications.

For EEA/UK/Swiss Residents
You also have:

  • The right to data portability.

  • The right to lodge a complaint with your local supervisory authority.

Requests can be sent to support@subtextai.app with the subject “Privacy Request.” We may verify identity before fulfilling requests.

10. Data Transfers

Subtext operates primarily in the United States. We use recognized safeguards such as Standard Contractual Clauses (SCCs) and comply with the EU–U.S. Data Privacy Framework for cross-border transfers.

11. Security

We implement industry-standard security measures:

  • Encrypted HTTPS connections.

  • Secure cloud storage with strict access controls.

  • Regular vulnerability scans and audits.

If a data breach occurs, we will notify affected users and authorities as required by law.

12. Cookies and Tracking Technologies

Subtext uses cookies to:

  • Maintain login sessions.

  • Measure traffic and performance.

  • Personalize experience and save preferences.

You can disable non-essential cookies through your browser settings. Essential cookies are required for operation.

13. Communications Preferences

You may unsubscribe from marketing emails at any time via the “Unsubscribe” link or by contacting support@subtextai.app.We may still send essential service or billing notices.

14. U.S. State Privacy Disclosures

Residents of California, Virginia, Colorado, and other U.S. states have rights to:

  • Know what personal data is collected or shared.

  • Request deletion or correction of data.

  • Opt out of sale (Subtext does not sell personal data).

Requests may be sent to support@subtextai.app.

15. Children’s Privacy

Subtext is not directed toward children under 13 (or under the minimum age required in your jurisdiction).

We do not knowingly collect children’s data; if discovered, it will be promptly deleted.

16. Data Retention and Deletion Summary

We keep personal data only as long as needed to:

  • Provide and maintain the Services.

  • Meet legal, accounting, or auditing obligations.

  • Resolve disputes and enforce agreements.

After that, data is securely deleted or anonymized.

17. Changes to This Policy

We may update this Privacy Policy periodically. The latest version will appear at www.subtextai.app/privacy with an updated “Last Updated” date.

If we make material changes, we will notify you by email or in-app message.

18. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or how your data is handled, please contact:
📧 support@subtextai.app
📍 Lightspark Games LLC – Delaware, United States