Draft for legal review, not yet in force. Text in square brackets is not final.
Last updated: [EFFECTIVE DATE]
This page explains what personal data Universal Conversion processes, why, for how long, and who else sees it. It is written for the Swiss Federal Act on Data Protection (FADP) and, for visitors in the European Union and EEA, the General Data Protection Regulation (GDPR).
The controller of your personal data is the operator of Universal Conversion, a sole proprietorship under Swiss law. The operator’s name and address are given in the legal notice. [CONFIRM: naming the controller by reference to the legal notice]
Postal address: Universal Conversion, [c/o STREET ADDRESS], [NPA] Fribourg, Switzerland
Email: contact@universalconversion.ch
When you convert or edit a file, the work is done by code that runs in your browser. The file stays on your device. We don’t upload it, copy it to a server, or see it. Closing the tab discards it, unless you choose to keep work in progress (see section 3).
Before a free file is made, your browser asks our server whether you still have an allowance today. That request carries the file’s size in bytes and the two format names (for example “MKV” and “MP4”). The server uses the size to check it against the free size limit, then discards it. It doesn’t use or store the format names. It never receives the file, its name or its contents.
Some things are saved in your own browser’s storage (cookies, local storage, IndexedDB and the cache) so the site works the way you left it. These stay on your device. Most are never sent to us. The two exceptions are the anonymous identifier and the sign-in cookie (section 4).
| What | Where | Sent to us? | Why |
|---|---|---|---|
Anonymous identifier (uc_aid cookie, copy in local storage as uc.aid) | Cookie, local storage | Yes | Counting free files (4.1) |
Sign-in session (uc_sid cookie) | Cookie | Yes | Keeping you signed in (4.2) |
| Display and room preferences (for example motion, volume, number format) | Local storage | No | Remembering your settings |
| Your work, kept as you go: documents in Docs, film projects in Video, edits and presets in Photo, and the text-recognition languages Docs has downloaded | IndexedDB | No | So you can come back to them |
| Downloaded tools and models (the video converter, document readers, AI models) | Browser cache | No | So they don’t download again |
You can delete all of it at any time by clearing this site’s data in your browser settings.
The free tier allows [2] files a day without an account and [10] a day with a confirmed account, within each room’s free limits (in Convert, files up to [500 MB]). Each file you get out of any room counts as one, and a finished transcription counts once; what counts and what never does is set out in section 2 of the terms. To count, the server keeps:
Why: to give everyone a fair free allowance and to stop it being bypassed, for example by clearing cookies.
Legal basis (GDPR): performance of the free-use terms you accepted (art. 6(1)(b)), and our legitimate interest in preventing abuse of the free tier (art. 6(1)(f)).
Our legitimate interest, weighed: without a count, the free tier could be used without limit by clearing cookies, and could not be offered at all. The count uses the least that works: no name, no address stored, a hash that cannot be matched back to anyone once the day’s secret is destroyed after three days, and nothing used for anything else. It cannot cost you more than today’s free files. We have written this assessment down and keep it. [CONFIRM]
How long: rows older than three days are deleted by an automatic clean-up that runs once a day, and the day’s secret with them.
If you create an account, we store:
When you sign in, we store a session record: a hash of the random value in your uc_sid cookie, your account ID, and when the session started and when it expires.
For email confirmation and password reset, we store a hash of the one-time link, what it is for, and when it was made, expires and was used.
Why: to give you an account, keep you signed in, confirm your address and let you reset your password.
Legal basis: contract (GDPR art. 6(1)(b)).
How long:
To slow down password guessing and mass sign-ups, the server counts, per network and per day (using the same hashed network identifier as in 4.1): failed sign-ins, password-reset requests, new accounts created, and confirmation emails sent again. After a limit, it refuses more attempts until the next day.
Legal basis: legitimate interest in security (GDPR art. 6(1)(f)).
How long: three days, as in 4.1.
Payments are handled by Stripe. You enter your card or other payment details in Stripe’s form or on Stripe’s page, and we never receive or store them.
Stripe’s two roles. Stripe processes payment data on our behalf (as our processor), and is also an independent controller for its own purposes, such as preventing fraud, meeting anti-money-laundering and other legal duties, and running its services; for those, Stripe’s own privacy policy applies (stripe.com/privacy). [With Stripe Managed Payments:] the subscription is sold to you through Link, Stripe’s merchant-of-record service, which then acts as the seller and an independent controller for the sale, the tax and the receipts, and lets you manage the subscription at link.com. [CONFIRM]
We store:
We also keep a record of the notifications Stripe sends us (an event ID, its type and when it arrived), so that no payment is counted twice.
Stripe gives us access to its own records of your payments (amount, date, currency, country, the last four digits of your card, invoices and receipts). We use them for accounting and support.
Why: to sell and run your subscription, to show what you asked for if a withdrawal is disputed, and to keep the accounting records the law requires.
Legal basis: running the subscription: contract (GDPR art. 6(1)(b)). Keeping accounting records for 10 years under Swiss law (Code of Obligations art. 958f): our legitimate interest in meeting our legal obligations (GDPR art. 6(1)(f)), and, where EU or member-state tax law applies to us (for example EU VAT through the One-Stop Shop), legal obligation (art. 6(1)(c)). [CONFIRM]
How long:
We send email only to confirm your address, to reset your password, to confirm a subscription (with its terms, renewal and withdrawal information), and to acknowledge a withdrawal. We don’t send newsletters or marketing.
Automated emails come from hello@universalconversion.ch and are sent through Cloudflare Email Service. Replies go to our contact address, whose mailbox is hosted by Infomaniak in Switzerland. The providers process your email address and the message content to deliver it.
Legal basis: contract (GDPR art. 6(1)(b)), and for the subscription confirmation and the withdrawal acknowledgement, the law that requires them.
If you email us, we receive your address and whatever you write. We use it only to answer you. Our mailbox is hosted by Infomaniak in Switzerland.
How long: [DECISION: e.g. 2 years after the conversation ends, longer if it concerns a contract dispute].
Please don’t send us your files. We’d rather not have them.
Feedback and bug reports. “Improvements or a bug” in the settings, and the optional question after you cancel or withdraw, send us what you write, any reasons you tick, and an email address only if you give one for a reply. A bug report also carries technical details, all shown to you before you send it: the room, your browser and its version, your system, your screen and window size, which version of the site answered, and the last few script errors on the page (with anything that looks like a file name taken out). Never a file, a file name, a picture, or anything typed into a document. If you cancel in Stripe’s customer portal and answer its question why, Stripe passes that answer on to us. Each message is emailed to the operator and kept on our server for 12 months, then deleted by the daily clean-up. To limit abuse we count messages per network per day, with the same daily hash as in 4.1. Legal basis: our legitimate interest in improving the service and fixing faults (GDPR art. 6(1)(f)). [CONFIRM]
Our server runs on Cloudflare Workers. Like any web server, it processes technical data with every request: your IP address, the address requested, the time, your browser’s user-agent and your approximate country. It processes this data to deliver the request and to protect the service from attacks.
Cloudflare keeps request logs for our account for 7 days. We use them only to find faults and abuse. [CONFIRM the 7 days against the plan bought] Cloudflare also processes connection data for its own security services. For that it acts under its own privacy policy.
Legal basis: legitimate interest in running a secure, working service (GDPR art. 6(1)(f)).
The AI tools (background removal, subject and face finding, denoising, depth, upscaling and transcription) run on your device. The first time you use one, your browser downloads the engine and model it needs from this site, like any other file of the site. They are stored in Cloudflare’s file storage (R2) and delivered by Cloudflare as our hosting provider (section 5). No other company receives the request.
That request is processed like any other request to the site (section 4.7). It doesn’t include your file, your recording or anything you type. After the first time, your browser keeps the download in its cache, so later uses don’t download it again unless the cache is cleared.
Legal basis: legitimate interest in delivering the tool you asked for and running a secure, working service (GDPR art. 6(1)(f)), as for every other file of the site. [CONFIRM]
We don’t sell, rent or share your data for anyone’s marketing. We use these providers:
| Recipient | What for | Data | Where |
|---|---|---|---|
| Cloudflare, Inc. (USA), with its global network | Hosting the site, database, server code, logs, sending email, security, and storing and delivering the AI tools’ engines and models [CONFIRM] | Everything in section 4 that is stored on the server | Database in western Europe [CONFIRM: location hint, not a legal guarantee]; requests handled at the Cloudflare location nearest you; company in the USA |
| Stripe (Stripe Payments Europe, Limited, Ireland; Stripe, LLC, USA), as our processor and, for its own purposes, an independent controller; with Managed Payments also Link, Stripe’s merchant-of-record service, as the seller | Payments, invoices, receipts, the subscription portal, refunds, tax calculation and collection | Email, payment details, billing country and address as Stripe asks for them, subscription and payment history | Ireland, USA and Stripe’s other locations |
| Our email providers: Cloudflare Email Service (sending) and Infomaniak Network SA (mail hosting) | Sending account and subscription emails; receiving and storing the emails you send us and our replies | Your email address, message content | Cloudflare: see above; Infomaniak: Switzerland |
| [FIDUCIARY / ACCOUNTANT] | Bookkeeping and tax | Invoice and payment records | Switzerland |
We may also disclose data where the law requires it, for example to a court or authority, or to defend legal claims.
Some recipients are in the USA, and Cloudflare serves from many countries. [CONFIRM]
You can ask us for a copy of the safeguards that apply.
No tracking. We use only two cookies, both needed for the site to work: one to count free files, one to keep you signed in.
| Cookie | Purpose | Lasts |
|---|---|---|
uc_aid | Random anonymous identifier, used only to count free files | 400 days |
uc_sid | Keeps you signed in | 60 days, or until you sign out |
Both are first-party, HttpOnly (scripts can’t read them), sent only over HTTPS, and not used
for advertising or tracking. There are no analytics, advertising or social-media cookies, and no third-party
cookies set by this site.
The anonymous identifier also has a copy in your browser’s local storage, so clearing cookies alone does not reset the free allowance.
You can block or delete cookies in your browser. If you do, you can’t stay signed in, and you’ll be counted only by the network identifier.
[CONFIRM: whether EU visitors must consent to the counting identifier]
You can ask us at any time:
Write to contact@universalconversion.ch. We may need to confirm the request comes from you, normally by replying from the email address on the account. We answer free of charge, normally within 30 days.
Some data we must keep despite a deletion request, such as accounting records, for as long as the law requires (section 4.4). We’ll tell you if that applies.
We don’t make automated decisions that have legal or similarly significant effects on you. The daily free limit is a fixed rule applied to everyone.
If you think we’ve handled your data wrongly, please tell us first so we can put it right. You can also contact:
We protect data with encryption in transit (HTTPS only), password and link hashing, secure cookies, limits on sign-in attempts, and by giving access to the database and provider accounts only to the operator. No system is perfectly secure. If a breach is likely to put you at high risk, we’ll tell you, and the authorities, as the law requires.
An account is for people aged 16 or older; a subscription for people aged 18 or older, or younger with a parent’s or guardian’s consent. [CONFIRM] We don’t knowingly hold accounts of children under 16. If you believe we do, tell us and we’ll delete it.
We’ll update this page when what we do changes, and change the date at the top. If a change matters to account holders, for example a new recipient or a new purpose, we’ll tell them by email before it takes effect.
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