This document is a draft
It has not been approved yet and may change before launch. Fields in square brackets are still to be filled in.
What Scribe does with your data, who is responsible for it, whom it is shared with, how long it is kept, and how to exercise your rights. The French version is the reference.
Version of 5 October 2026 · to be reviewed before launch
Scribe by Swalent is operated by Swalent (Edmond Ivanov), a self-employed individual, Rue de la Limite 60, 1970 Wezembeek-Oppem, Belgique, enterprise number 1042.844.426.
Contact for any question about your data: contact@swalent.com or the contact form. No data protection officer is appointed, as the law does not require one for this activity.
Swalent is the controller only for the data needed for your account and for running the service: sign-in identity, settings, billing, security, technical logs and contact messages.
For everything you record, import or have processed in Scribe (audio, video, transcripts, documents, notes, people mentioned), you are the controller. Swalent acts as your processor, only on your instructions, under the data processing agreement, which is part of the terms.
You alone decide who is recorded, on what legal basis, and what is done with the recording. Swalent does not and cannot check that you informed the people recorded or obtained their consent, and is not liable for it. The rules you must follow are in the terms.
If you record a conversation for purely personal purposes, the GDPR may not apply to you (art. 2.2.c). Swalent handles that content with the same safeguards.
As controller, Swalent processes:
As processor, on your behalf: audio and video, links you paste and the media fetched, transcripts and their corrections, names given to voices, notes, images, documents, the glossary, people, projects, actions and knowledge entries, and the email addresses of the people you share with.
Scribe creates no voiceprint. A name given to a voice is a simple label you choose. A recording may contain sensitive data (health, opinions): processing it is your responsibility as controller.
No advertising, no profiling, no sale of data. Swalent does not use your content to train any AI model.
Scribe runs on your own keys. You open an account with the AI provider of your choice (ElevenLabs, Mistral, AssemblyAI, OpenAI, Anthropic or Google), accept its terms, and it bills you directly.
When you start a transcription, a document or a translation, Scribe sends, on your instruction and with your key, the audio or text needed to that provider. The provider processes that data under the contract you concluded with it: that contract decides whether it keeps the data, for how long, and whether it uses it to train its models. Swalent is not a party to that contract and is not liable for it.
What their API terms provide by default, as checked on 6 October 2026: Anthropic, OpenAI and Google (paid tier, and free tier in the European Economic Area) do not train their models on the data they receive; Mistral, ElevenLabs and AssemblyAI do unless you opt out in your account with them. All keep data for a short period, often 30 days, to detect abuse; zero retention exists on request or for enterprise accounts. Check these settings with your provider.
Should Swalent one day offer a plan using its own keys, it will choose providers contractually committed not to train on your data, with the shortest retention available, and this policy will be updated beforehand.
Minutes and knowledge entries are written by an AI model and marked as such. Any AI-produced content may contain errors.
Nobody at Swalent reads your content, except at your request to help you, to handle a security incident, or where the law requires it. These providers process data to run Scribe:
Telegram only receives a notice that a contact message arrived, with no name, no address and no content.
The AI providers you choose receive what you have Scribe send them, under your contract with them: ElevenLabs and AssemblyAI (United States, DPF certified), OpenAI (OpenAI Ireland for Europe), Anthropic (Anthropic Ireland for Europe), Google Gemini (DPF certified), Mistral AI (France, hosted in the EU by default).
The people you share a recording with see what you share. A tool you connect to Scribe yourself with your personal key sees what that key can read.
Your files are stored in the European Union and the database is in Frankfurt. Several providers are American companies that may access them from the United States for operations or support.
These transfers rely on the adequacy decision for the EU-US Data Privacy Framework (Decision (EU) 2023/1795) for certified companies, and on the Commission’s standard contractual clauses (Decision (EU) 2021/914), included in each data processing agreement.
For the data Swalent is responsible for, you can at any time:
Write to contact@swalent.com. We answer within one month and may ask you to confirm your identity.
You can lodge a complaint with the Belgian Data Protection Authority, rue de la Presse 35, 1000 Brussels, dataprotectionauthority.be, or with the authority of the country where you live.
If you were recorded by a Scribe user, that user is the controller: address your request to them. If you send it to us, we pass it on without delay, as the data processing agreement provides.
In the event of a data breach, we inform the Data Protection Authority and the people concerned within the legal deadlines (GDPR, art. 33 and 34) and, for your content, we notify you as the data processing agreement provides.
Scribe is reserved for people aged 16 and over.
We tell you by email or in the app before a significant change applies. The version date at the top of the page shows the last update.