Privacy Policy

Last updated: July 2026

1. Controller

The controller responsible for data processing within the meaning of the EU General Data Protection Regulation (GDPR) and other applicable data protection laws is:

2. How UGCut handles your data

UGCut is an on-device application. The core loop (write a script, record it with the teleprompter, auto-cut per sentence, add captions, and export a platform-ready video) requires no UGCut account and no backend that stores your video content. There is no server that holds your scripts, recordings, or projects.

Where your data lives is precise and easy to summarize:

• On your iPhone. Your scripts, recordings, takes, transcripts, captions, and exported videos are stored in the app's own on-device storage.
• Not synced to any cloud. UGCut does not sync or upload your media, projects, scripts, or transcripts anywhere. Nothing about your videos leaves the device through us.

The only app data transmitted automatically is completed-transaction purchase history sent to RevenueCat for subscription functionality and analytics (see §4). If you deliberately send us a support email, the message and diagnostics described below also leave your device with your approval. We cannot otherwise read, retrieve, or analyze your scripts, recordings, transcripts, or videos. They never reach us.

3. Data the app processes on your device

The following processing happens entirely on your device. Each permission is requested in context the first time it is needed, and most are optional. None of this data is uploaded to us.

a) Camera & Microphone

With your permission, UGCut uses your camera and microphone to record your video and audio for the teleprompter recorder. Captured media is written to the app's on-device storage and is never uploaded. You can revoke camera or microphone access at any time in iOS Settings.

Legal basis: Art. 6(1)(b) GDPR (the core recording function you requested), together with your consent via the iOS camera and microphone prompts.

b) Speech recognition & on-device transcription

UGCut transcribes your recording on your device (using Apple's iOS 26 SpeechAnalyzer) to align cuts to your script and generate captions. The audio and the resulting transcript are processed on the device and are never sent to a server.

Legal basis: Art. 6(1)(b) GDPR (performance of the auto-cut and caption function you requested).

c) Photo Library (save / import)

With add-only permission, UGCut can save finished videos to your photo library. When you import footage, Apple's system photo picker gives the app only the item you choose;UGCut does not request permission to browse your library. Your media is never uploaded to us.

Legal basis: Art. 6(1)(b) GDPR (the save or import action you requested), together with your consent for add-only access via the iOS Photos prompt.

d) Scripts and app content

The scripts, captions, and rendered videos you create are stored on your device. They are content you control and are never sent to us.

Legal basis: Art. 6(1)(b) GDPR (performance of the app's core function that you requested).

e) Optional feedback and support email

If you choose Send feedback, UGCut prepares an Apple Mail draft to our support address. The draft contains the message you write and a diagnostic footer with the UGCut version, iOS version, device model, and locale. You can review, edit, or cancel the draft; nothing is sent until you approve it in Mail. We use a received message only to answer your request, troubleshoot the reported issue, and improve app reliability. We keep it only as long as needed for those purposes or to meet applicable legal obligations, and you may request deletion at privacy@ugcut.com.

Legal basis: Art. 6(1)(b) GDPR (support you requested) and Art. 6(1)(f) GDPR (legitimate interest in diagnosing faults and improving reliability).

4. Purchases (UGCut Pro)

UGCut is free to download, and the full core loop is never gated. UGCut Pro is optional and is sold in-app through Apple. No payment card details ever reach us.

Pro is available as an auto-renewing subscription (monthly or annual) or as a one-time lifetime purchase, sold and processed by Apple via the App Store and StoreKit. Apple handles all payment data, billing, and receipts. StoreKit provides verified transaction state so the app can unlock Pro; UGCut does not receive your Apple ID or payment-card details. RevenueCat, our subscription analytics provider, receives completed-transaction purchase history under a randomly generated anonymous app user ID for receipt validation, subscription operation, customer history, charts, cohorts, churn, and lifetime-value analytics. We do not provide a name, email address, advertising ID, or creator content to that provider. Under the current configuration, purchase history is not linked to your identity and is not used to track you across apps or websites. UGCut's Pro entitlement continues to come from Apple's verified StoreKit transaction state; RevenueCat observes completed purchases and does not complete the purchase. Apple's processing is governed by Apple's Privacy Policy; RevenueCat's processing is described in its Privacy Policy.

Legal basis: Art. 6(1)(b) GDPR (purchase and subscription functionality) and Art. 6(1)(f) GDPR (legitimate interest in understanding subscription performance and improving Pro).

5. Limited purchase analytics; no creator-content analytics, tracking, or ads

The app uses RevenueCat for the purchase-history purposes in §4. We use no analytics on your scripts, footage, voice, transcripts, captions, projects, or editing behavior, and no advertising network, cross-app tracker, or fingerprinting. UGCut does not include the App Tracking Transparency prompt because it does not track you across apps or websites. We do not build advertising profiles, and we do not sell your data. The app's automatic external services are Apple (App Store, StoreKit, and on-device frameworks) and RevenueCat (completed in-app Purchase History). Neither receives creator content from UGCut. A support email is sent only when you approve the prepared draft in your Mail app, as described in §3(e).

6. This website

This marketing website uses Ahrefs Web Analytics, a cookie-free, non-persistent traffic analytics service. The service processes page URL, referrer, user agent, language, approximate city/country, and page/link/form events. It derives a daily visitor count from a salted hash of IP address and user agent; the raw IP address is discarded and the salt rotates daily. It does not follow a visitor across days, devices, apps, or other websites. The site also processes your email address if you submit the waitlist form. You can ask us to delete a waitlist email at any time by emailing privacy@ugcut.com. Ahrefs does not receive creator content or app purchase history from UGCut.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operating a secure website) and Art. 6(1)(a) GDPR (your consent, for the email notification list).

7. Data retention and deletion

Because your content lives on your device, you decide how long it is kept. You can delete individual scripts, recordings, or projects, or remove all UGCut data, directly in the app at any time; deleting the app from your device removes its local data. Apple and RevenueCat retain purchase records under their policies and applicable legal requirements. Support emails are kept only as long as needed to answer the request, troubleshoot, improve reliability, or meet applicable legal obligations. You can request access to or deletion of data controlled by us by emailing privacy@ugcut.com, subject to mandatory retention obligations.

8. Your rights under the GDPR

As a data subject, you have the following rights:

• Right of access (Art. 15): your on-device content is directly accessible in the app.
• Right to rectification (Art. 16): you can edit your scripts and projects in the app.
• Right to erasure (Art. 17): you can delete any or all data in the app.
• Right to restriction (Art. 18) and objection (Art. 21).
• Right to data portability (Art. 20).
• Right to withdraw consent (Art. 7(3)): revoke any permission at any time in iOS Settings, with no effect on prior lawful processing.

On-device content is directly accessible, editable, and deletable in the app. For purchase-history analytics or other data controlled by us, exercise these rights by contacting privacy@ugcut.com. You also have the right to lodge a complaint with a supervisory authority. For us, that is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit).

9. Children

UGCut is not directed at children and we do not knowingly collect personal data from children. Because the app stores your content only on your own device, no such data is collected by us through the core app in any case.

10. Changes to this policy

We may update this privacy policy as the app evolves or as legal requirements change. The current version is always available on this page with its "last updated" date. Material changes will be communicated within the app where appropriate.

11. Contact

For any privacy question, contact us at privacy@ugcut.com or support@ugcut.com.