1. Scope and Who Is Responsible

This policy describes how Cutpace ("we", "us") processes personal data of users of the Service. It applies to visitors and registered users of Cutpace, across the jurisdictions where the Service is offered.

The data controller is Excerpo LLC, a limited liability company organised under the laws of the State of Delaware, United States, which operates Cutpace. For every question about your data, write to [email protected].

2. Data We Collect

We collect:

• account data: email address, name if provided, and, when you sign in through Google or Apple, the account identifier and the email and name that provider shares with us;
• usage data: device, browser and feature-usage information, and the country derived from your IP address, which decides the seller and the tax applied at checkout;
• the material you upload for editing, together with what is derived from it: transcripts, recognised on-frame text, working frames, the reels and subtitles produced, and the contents of your chat with the editing assistant;
• billing data: selected plan, payment history, amount, payment status and the country of the purchase. For tax law we also keep, for each purchase, the country of the billing address, the country of the card and the country of the IP address at checkout. We do not store card details, which are processed directly by Stripe (see Section 5);
• support correspondence: what you write to us and our replies.

3. How We Use Your Data

We use your data to: provide and operate the Service; process payments and calculate tax; support you and respond to inquiries; improve the product and develop new features; detect and prevent fraud and abuse; and meet legal requirements.

The material you upload, its transcripts, and the outputs produced from it are used solely to perform the editing you request (speech recognition, recognition of text on frames, locating the face and speaker position in frame for cropping without identifying the person and without biometric templates, assembling the reel, and subtitles). We do not use them to train models, neither our own nor those of our processors, which are engaged on terms that exclude training on your data. Product improvement relies only on technical operation data (operation statuses and durations, error codes), never on the content of your material. Our staff do not view your material or chat contents, except when you request a review of a specific session and explicitly consent to it in the feedback form. Any other use of your material requires your separate explicit consent, which you may withdraw at any time.

4. Legal Basis for Processing

Where the law of your country requires a legal basis, including in the European Economic Area, the United Kingdom and Switzerland, we rely on: performance of our contract with you (account, editing, payments, support); our legitimate interests in operating, securing and improving the Service and in preventing fraud, where those interests are not overridden by your rights; compliance with legal obligations (tax and accounting records, responses to lawful requests); and your consent, for non-essential cookies and analytics and for any use of your material beyond the editing you request. You may withdraw consent at any time without affecting processing that took place before.

5. Data Sharing and Processors

We share data with processors acting on our instructions: payment processors, to bill you (see "Payments" below); cloud infrastructure and storage providers, to host the Service and store your uploads, currently Vultr (servers in the United States) and Cloudflare (edge network, object storage, email delivery and protection from automated sign-ups); AI processing providers (speech-recognition, language-model, and image-recognition APIs), to perform the automated editing you request, on terms that exclude training on your material; and email providers, to send service messages. Product analytics is first-party and is not sent to third parties. All processors act under agreements that require confidentiality and appropriate technical and organizational safeguards.

We may also disclose data where the law requires it, to protect the rights, safety or property of Cutpace or others, or to a successor in a merger, acquisition or sale of the business, who takes it over under this policy. We do not sell personal data and do not share it for third-party advertising.

Payments. For every purchase, Stripe, Inc. and its affiliates ("Stripe") process payment data on our behalf: they take the payment, calculate tax and screen payments for fraud. Stripe's privacy policy is at https://stripe.com/privacy.

For a purchase where the checkout page names Link as the seller, Sold through Link, LLC ("Link") is the seller and processes the payment and billing data it needs as an independent controller: it takes the payment, handles taxes, disputes about the payment and support with the payment, under its own privacy policy at https://link.com/privacy. From Stripe and Link we receive only what we need to run your subscription (plan, amount, payment status and the country used for tax), never full card details.

6. International Transfers

Cutpace is operated from the United States, and your data is stored and processed there and in the other countries where our processors operate. If you are in the European Economic Area, the United Kingdom or Switzerland, transfers of your data outside those territories are made under the European Commission's Standard Contractual Clauses, with the UK International Data Transfer Addendum where it applies, or to recipients certified under the EU-US Data Privacy Framework and its UK and Swiss extensions. You can request a copy of the safeguards in place at [email protected].

7. Data Retention

Uploaded video and everything derived from it (transcript, recognised on-frame text, working files) is kept for 180 days from last use in a chat or reel. Each use restarts the countdown. Two weeks before deletion we write to your email and to in-Service notifications. You can delete material sooner in the Library; the card shows how long it will be kept.

A finished reel is kept until you delete it. Variants you did not choose, and export files no longer tied to any live reel, are kept for up to 365 days. Chat preview drafts are kept for one day.

Product analytics events are kept for 180 days. Records of security-relevant events (sign-in, password reset, account deletion, payments) are kept for at least one year. Billing and tax records, including the country evidence described in Section 2, are kept for as long as tax and accounting law requires, up to 10 years.

Account deletion is carried out on request to [email protected]. We delete or anonymize your data within 30 days of the request, except where retention is required by law, in particular for payment and tax records.

8. Security Measures

We apply technical and organizational measures designed to protect your data against unauthorized access, loss, or alteration, including encryption in transit, encryption of stored credentials and tokens, access controls, and monitoring of access to systems that process your data. If a breach affects your data and the law requires it, we notify you and the competent authority.

9. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or export your data, to restrict or object to certain processing, to withdraw consent, and not to be discriminated against for exercising these rights. To exercise them, write to [email protected] from the email address of your account; we answer within one month, or within the shorter period your law sets. We may ask you to confirm your identity first.

If you are in the European Economic Area, the United Kingdom or Switzerland, you may also lodge a complaint with the data protection authority of your country of residence.

If you are a California resident, you have the rights described above under the California Consumer Privacy Act. We do not sell personal information and do not share it for cross-context behavioral advertising, and we do not use or disclose sensitive personal information for purposes other than providing the Service.

10. Children's Privacy

The Service is not directed at individuals under 18. We do not knowingly collect personal data from minors; if we learn we have done so, we delete it.

11. Cookies

See our separate Cookie Policy for details on the cookies we use and how to manage your preferences.

12. Changes to This Policy

We may update this policy. The current version, its number and its effective date are shown on this page; material changes will be additionally communicated by email or in the Service where required by law.

13. Contact

The data controller is Excerpo LLC, a Delaware limited liability company, United States; the company's site is excerpo.ai. For privacy questions and to exercise your rights, contact [email protected].