Privacy Policy
In short: your videos stay on your iPhone. To make captions we send only the audio to speech recognition, and we do not store it. There are no accounts, no sign-in, no ads and no tracking. On our side we keep only a counter of used minutes, linked to an Apple purchase identifier or a device identifier, not to your name or email address.
1. Data controller
DARIUSZ NIEMCZAK F.H.U. ITAMA
ul. Starowiejska 16 lok. 2, 81-356 Gdynia, Poland
VAT ID (NIP): PL9581479203
Email: kontakt@itama.pl, phone: +48 451 461 949
2. What stays on your phone
Videos, projects, captions, transcripts and exports are stored only on your iPhone (you can see them in the Files app, in the CutNeo folder). We have no access to them. The app reads only the video you choose and does not ask for access to your whole photo library. Deleting the app deletes this data from your phone.
3. What we send and why
| Data | Purpose | Retention |
|---|---|---|
| The audio track of the chosen video (sound only, no picture) | Speech recognition to make captions | Not stored. Processed only during recognition and never written to server logs. |
| Transcript text, when you ask for a title, description and hashtags | Writing the post description | Not stored. Processed only while the answer is prepared. |
| Apple purchase identifier (subscription transaction number), product, expiry date and subscription status | Checking that you have CutNeo Pro and applying the monthly limit | For the life of the subscription and afterwards as long as accounting and abuse prevention require. |
| Device key identifier from Apple App Attest and DeviceCheck | The free allowance per device (also after reinstalling) and confirming that requests come from the genuine app | As long as needed for the free allowance. |
| Counters: minutes of audio, number of videos (as cryptographic hashes, no file names), number of descriptions, date of last use | Free and subscription limits | The counter covers the current billing period. |
| IP address | Protection against too many requests in a short time | Kept only in memory for the current minute, then discarded. |
We do not collect your name, email address, phone number, location, contacts or advertising data. We do not link these identifiers to your identity, and we have no way to do so.
4. Consent before anything is sent
Before anything leaves your phone, the app shows a consent screen: only the audio is sent to speech recognition, the video stays on your phone, the audio is not stored. Without consent the app does not connect to our server at all (except purchases and restoring purchases, which you start yourself and which contain no audio). You can withdraw consent in the app: Settings, Privacy.
5. Legal bases (GDPR)
- Speech recognition, AI descriptions and the subscription: performance of the contract to use the app (Art. 6(1)(b) GDPR) and your consent to sending audio (Art. 6(1)(a)).
- The free allowance, abuse prevention and request limits: our legitimate interest in running the service and protecting it from abuse (Art. 6(1)(f)).
- Accounting: legal obligation (Art. 6(1)(c)).
- Replying to your messages: our legitimate interest (Art. 6(1)(f)).
6. Who processes data for us
- Cloudflare, Inc. (USA) processes data on our behalf: the relay server, the database with counters, and speech recognition and AI descriptions in Cloudflare Workers AI. Transfers outside the European Economic Area rely on the European Commission's standard contractual clauses and the EU-US Data Privacy Framework.
- Apple handles payments, subscriptions, refunds, App Attest and DeviceCheck as an independent controller under its own privacy policy. We do not receive your personal or card details from Apple, only a confirmation of the purchase.
We do not sell data and do not share it with advertisers.
7. The cutneo.com website
The website uses no cookies, no scripts, no analytics and no advertising tools. It is hosted by Cloudflare, which, like any web server, processes the visitor's IP address to deliver the page and protect it from attacks.
8. Your rights
You have the right to access, rectify and erase your data, to restrict processing, to data portability, to object to processing based on legitimate interest, and to withdraw consent at any time (without affecting earlier processing). Write to kontakt@itama.pl. As we do not know who you are, for access or deletion requests we may ask for the order number from Apple's purchase receipt so we can find the right counter.
You may also lodge a complaint with a data protection authority, in Poland the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl), or with the authority in your country.
9. Children
CutNeo is not directed at children and we do not knowingly collect children's data.
10. Changes
If the way we process data changes, we will update this policy and the date at the top. We will announce significant changes in the app.