Privacy Policy

Last updated: October 26, 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 keeps editing on your device. Some online features are coming soon. Project sharing and portfolio upload have the data flows described below.

The app stores data locally and sends data for the online features you choose:

• On your iPhone. Your scripts, recordings, takes, transcripts, captions, and exported videos are stored in the app's own on-device storage.
• Online uploads are your choice. While project sharing is on, UGCut receives plans and status for all projects in your account, including authored script text. If you choose portfolio upload, UGCut receives the selected video, including embedded sound, plus security and technical verification metadata.
• Scheduled posting is in internal testing. When you schedule a post, the app uploads the exported video, including its sound, and UGCut stores your caption and options. At the scheduled time, UGCut sends the video and caption to the platform you chose (see the scheduled posting section below).

In internal posting tests, the UGCut server sends completed-transaction purchase history to RevenueCat for subscription functionality and analytics (see §4). The app itself does not contact RevenueCat. If you sign in, it also exchanges authentication data with Apple and UGCut. If you deliberately send us a support email, the message and diagnostics described below leave your device with your approval. Editing computation and speech recognition run on your device. While project sharing is on, UGCut receives plans and status for all projects in your account, including authored script text.

3. Data the app processes on your device

The following processing happens on your device during local editing. Each permission is requested in context the first time it is needed, and most are optional. Selected content can be sent only for the online feature you choose.

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 during editing. A selected portfolio video can include embedded sound and leaves your device only when you choose that online feature. 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 during editing. A selected portfolio video can include embedded sound and is sent only after you confirm that online feature.

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. A selected portfolio video can include embedded sound and leaves your iPhone only when you choose that online feature.

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 during editing. While project sharing is on, UGCut receives plans and status for all projects in your account, including authored script text.

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 not publicly available yet. The planned free tier includes the full core loop. UGCut Pro is optional and will be sold in-app through Apple. No payment card details ever reach us.

Pro is planned as an auto-renewing subscription (monthly or annual), sold and processed by Apple via the App Store and StoreKit. Apple handles all payment data, billing, and receipts. StoreKit verifies the purchase on your iPhone so the app can unlock Pro; UGCut does not receive your Apple ID or payment-card details. The app does not include the RevenueCat SDK. Builds without the internal posting test keep purchases in StoreKit on your iPhone and send no purchase receipts to the UGCut server. Export features use the purchase state that StoreKit verifies on your iPhone. A purchase made while signed out stays on your device, is not linked to an account later, and does not unlock Pro for posting.

In internal posting tests, a purchase made while signed in carries a random ID that UGCut issues for your account. The app uploads the signed purchase record that Apple issues, and UGCut stores it encrypted. After the UGCut server verifies the record with Apple, it sends completed-transaction purchase history to RevenueCat, our subscription analytics provider, from the UGCut server, not from the app, under an account-specific customer ID. UGCut sends only Apple-verified purchases that carry that ID, and UGCut can link the customer ID to your UGCut account. RevenueCat uses it for receipt validation, subscription functionality, customer history, charts, cohorts, churn, and lifetime-value analytics, and does not receive creator content from UGCut. The UGCut server reads your subscription status back from RevenueCat. Pro for scheduled posting uses that UGCut server check. Purchases in TestFlight builds are Apple sandbox purchases. UGCut does not use purchase history for advertising or cross-app tracking. 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 UGCut server uses RevenueCat for the purchase-history purposes in §4. Apart from the screens, steps and purchases the app counts with Revtrail (§6), 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 uses Apple for App Store, StoreKit, on-device frameworks, and optional Sign in with Apple; RevenueCat, through the UGCut server, for completed in-app purchase history; and UGCut's account service when you choose to sign in. RevenueCat does not receive creator content from UGCut. An online feature may inspect selected content for security or technical verification. A support email is sent only when you approve the prepared draft in your Mail app, as described in §3(e).

6. This website and app usage events

This marketing website uses Revtrail, our own analytics service, which we run on Cloudflare Workers. Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, processes the data for us under its data processing addendum with EU standard contractual clauses. Cloudflare is also certified under the EU-US Data Privacy Framework. Revtrail records the page address, referrer, UTM parameters, browser, operating system, device type, country, region and city derived from the IP address, clicks on marked buttons and outbound links, and time on page. It does not store the IP address. It combines the IP address, the user agent and a salt that changes every day into a hash, so a visit cannot be linked to the same person on another day. Revtrail sets no cookies and stores nothing else on your device, so we ask for no consent. We keep the raw data for up to 24 months. On the website, Revtrail does not load on the sign-in, account, brand, marketplace and project pages.

The UGCut app also sends usage events to Revtrail. The events name the screens you open (Home, Plan, Grow, Settings, scene cards, recorder, editor, export and the Pro screen) and the steps of making a first video. They also record whether you reach the Pro screen, tap buy, cancel, see an error or restore a purchase, when you create a video, finish an export or send a cut to your agent, and whether you allow or refuse the camera, microphone, speech and Photos prompts. For each App Store purchase, the app sends the signed record Apple issues. Revtrail's server checks it with Apple and keeps the product, price, currency and transaction IDs. The signed record also holds the random purchase ID that UGCut issues for a signed-in account (see §4). Revtrail does not know which account that ID belongs to. Each event carries the app version, the iOS version, the device model and your language and region setting. Revtrail derives country, region and city from the IP address of each upload and does not store the address. Each app launch gets a new random ID that stays in memory. The app stores no analytics ID on your iPhone, so we ask for no consent, and it sends no name, email address, script, footage, caption, title or file name. Revtrail never receives creator content. We use these events to see where new creators stop and how many open the Pro screen and buy. We do not use them for advertising or for tracking across apps. Cloudflare processes them on the terms above, and we keep the raw data for up to 24 months.

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.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operating a secure website and in understanding which pages, channels, app screens and steps work) and Art. 6(1)(a) GDPR (your consent, for the email notification list). You can object to the app usage events at any time at privacy@ugcut.com.

Optional account and connected clients

You can use the core app without an account. If you sign in, UGCut stores your verified Apple or email identity, device identifier, sign-in security data such as an IP-address hash and user agent, account profile, sign-in sessions, and the clients and scopes you approve through OAuth. Apple handles Sign in with Apple. Resend delivers one-time email sign-in links. Marketplace features may store your profile display name, biography, country, niches, languages, and the timestamp of your eighteen-and-over declaration. The account page lets you review and revoke sessions and connected clients.

Marketplace and delivery data

While project sharing is on, UGCut receives plans and status for all projects in your account, including authored script text. If you choose portfolio upload, UGCut receives the selected video, including embedded sound, plus security and technical verification metadata. An authorized download creates a download-audit record. Delivery features keep a delivery acknowledgement tied to the account and delivery. Payout setup opens Stripe's hosted page outside the app; UGCut receives payout status and a provider account identifier.

Scheduled posting (internal testing)

Connecting TikTok, Instagram or YouTube and scheduling posts is in internal testing with approved test accounts and is not available to the public. You sign in on the platform page, and UGCut stores the encrypted access credentials the platform issues, a hash of the platform account identifier, the connected account display name and profile-picture URL, and the connection status. When you schedule a post, the app uploads the exported video, including its sound, to UGCut private storage. UGCut also stores the caption text, the platform options you chose, the scheduled time and the post status. At the scheduled time UGCut sends the video and caption to the platform you chose, which handles them under its own terms and privacy policy. After a post is published, UGCut stores the platform post link and reads view, like, comment and share counts daily for 30 days. Scheduling needs an active Pro subscription that the UGCut server has verified.

Optional plan handoffs

If you ask a supported client to create a handoff, UGCut stores an encrypted plan for up to 72 hours so you can open it on another device. A handoff contains authored plan text, including script text, and no local media files.

7. Data retention and deletion

Because your local content lives on your device, you decide how long it is kept. You can delete individual scripts, recordings, or projects, or remove all local 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. UGCut deletes a stored scheduled-post video 30 days after the last scheduled post that uses it reaches a final status. An upload that is unfinished, or verified but not used by any scheduled post, is queued for deletion 24 hours after it was created. Disconnecting a platform removes the grant UGCut stores and turns queued posts into reminders. UGCut cannot revoke access on Instagram, so remove it in your Instagram settings as well. If you request account deletion, it is scheduled no earlier than 14 days and you can cancel by signing in during that window. Requesting deletion cancels your queued scheduled posts. When deletion runs, UGCut removes the account identity, sessions, credentials, grants, tokens and profile data it controls. Stored scheduled-post videos go into a deletion queue and are not removed at that moment. UGCut does not delete posts already published on a platform, and it keeps encrypted platform credentials in a cleanup queue so it can ask the platform to revoke access where the platform supports that. Open deals can delay deletion. Retained deal and provider records follow separate rules. Uploaded portfolio videos and related download-audit records remain held pending cleanup and retention review; no fixed period is stated. Expired plan handoffs are removed after their retention window. 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 your local 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. The account flow asks users to confirm that they are at least 16 before an account is created. Editing happens on your iPhone. Some online features are coming soon. Project sharing and portfolio upload have the data flows described in this policy.

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.