Privacy Policy

Last updated: June 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 data that ever leaves your device is (i) at purchase or restore time, the billing identity and entitlement state needed to unlock Pro (see §5), and (ii) if you join the creator program, the account and payout data described in §6. We, as the provider, cannot 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, optional)

With your permission, UGCut can save exported videos to your photo library and optionally import footage. Your media stays in your library; nothing is uploaded to us. You can grant full or limited photo access, or none at all.

Legal basis: Art. 6(1)(a) GDPR (consent via the iOS Photos permission prompts).

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).

4. Notifications

UGCut may use local and push notifications (for example, to let you know an export has finished). Where push notifications are used, they are delivered through Apple Push Notification service (APNs); APNs handles only a device token and the notification payload, not your video content. You can disable notifications at any time in iOS Settings.

Legal basis: Art. 6(1)(a) GDPR (consent via the iOS notifications prompt).

5. Purchases (UGCut Pro)

UGCut is free to download, and the full core loop is never gated. UGCut Pro is optional and can be bought through two channels. In both cases, no payment card details ever reach us — Apple and our third-party payments provider are the processors.

a) In-app, via Apple

Pro is available as an auto-renewing subscription (monthly or annual, with a free trial on the annual plan) 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; we receive only Apple's entitlement confirmation tied to your Apple ID so the app can unlock Pro features. Apple's processing is governed by Apple's Privacy Policy.

Legal basis: Art. 6(1)(b) GDPR (performance of the purchase contract).

b) On the web (creator / web channel)

Pro can also be purchased as a subscription through our website, processed by a third-party payments provider. To bind a web purchase to your app and unlock Pro, you sign in with Sign in with Apple; the data shared is limited to your Apple-relayed identity/email and your entitlement state, handled by our entitlement provider. The payments provider's and Apple's processing are governed by their own privacy policies. No card details reach us on this channel either.

Legal basis: Art. 6(1)(b) GDPR (performance of the subscription contract).

6. Creator / affiliate program (optional)

This section is relevant only if you choose to join our creator program. To join, you sign in with Sign in with Apple (the sole identity provider). If you become a creator, our third-party affiliate provider processes the data needed to attribute referrals and pay commissions: your account identity, referral and click attribution, web-channel subscription events, payout details, and any tax forms required by law (such as W-9/1099 or EU DAC7/VAT forms), which that provider collects rather than us.

Commission applies only to web-channel subscriptions; in-app Apple purchases are never commissionable. Creator promotion happens on the creator's own external channels.

Legal basis: Art. 6(1)(b) GDPR (the creator agreement) and Art. 6(1)(c) GDPR (tax and legal obligations the provider fulfils).

7. No analytics, tracking, or ads

We do not use any analytics SDKs, advertising networks, cross-app tracking, or fingerprinting in the app. UGCut does not include the App Tracking Transparency tracking mechanism because it does not track you across apps or websites. We do not build profiles, and we do not sell or share your data. The only external parties are Apple (App Store, StoreKit, Sign in with Apple, and on-device frameworks), our third-party payments provider (web payments), and our entitlement provider and affiliate provider (web channel and creator program only). The web channel involves real processors, but the core app loop remains free of all of them.

8. This website

This marketing website may process minimal technical data (such as your IP address and request metadata) that is necessarily transmitted when your browser loads a page, for the purpose of delivering the site securely and stably, plus your email address if you submit the waitlist form. If you start a web subscription or join the creator program, the site hands off to our third-party payments provider and to our billing and affiliate providers (above). You can ask us to delete a waitlist email at any time by emailing privacy@ugcut.com.

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).

9. 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. For the web channel, account and billing data is retained by Apple, our third-party payments provider, and our providers under their own policies and applicable legal retention periods (such as tax records). You can request deletion of account data by emailing privacy@ugcut.com, subject to mandatory retention obligations.

10. 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 web-channel account and billing data, exercise these rights by contacting privacy@ugcut.com. You also have the right to lodge a complaint with a supervisory authority — for us, the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit).

11. 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.

12. 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.

13. Contact

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