ClipKiwi Privacy Policy

This Privacy Policy explains what personal information ClipKiwi collects, why we collect it, who we share it with, how long we keep it, and what you can ask us to do with it. It covers the ClipKiwi mobile application, the ClipKiwi website, and the AI photo and video features offered through them (together, the "Service").

01Terms used in this policy

Plain definitions first, so the rest of the document reads clearly.

Input

Anything you submit to a ClipKiwi feature: a photo, a video, an audio clip where a feature accepts one, a text prompt, a template or style selection, and any editing instruction.

Output

The image, video or edited file that a ClipKiwi feature produces from your Input.

Face detection

Automatically locating a face, and the position of features such as eyes or mouth, inside an image so that an effect can be aligned to it. Face detection answers "where is a face"; it does not answer "whose face is this".

Face recognition

Comparing a face against stored face templates to work out or verify a person's identity. ClipKiwi does not do this.

Credits

The in-app unit spent when you run a generation. Credits may be included with a package, bought separately, granted in a promotion, or earned by watching a rewarded ad.

Package

A paid access period, such as a weekly or monthly package, bought through an app store or another authorized payment channel.

Processor / vendor

A company that handles data for us, under contract, and only on our instructions — for example a cloud host or an AI model provider.

02Who we are and what this covers

ClipKiwi is an AI creative app offering photo transformation, outfit and portrait style changes, image-to-video generation, photo restoration and enhancement, and general photo editing tools.

The company responsible for your personal information (the "controller", where that term applies) is:

It takes effect the first time you open or browse the Service and stays in force through registration, sign-in, anything you buy, every creative tool you use, and the permanent deletion of your account. It does not govern separate services that have their own privacy policies, including Apple, Google, Facebook, advertising networks and payment providers. Please read their notices for how they handle your data.

03Information we collect

3.1 Information you give us

• Account details. You can register with an email address and password, or sign in with Google or Facebook. For email registration we store your email address and a protected form of your password credential, never the password in plain text. For Google or Facebook sign-in we receive only what you authorize that provider to release — typically a provider account identifier, email address, display name and profile image. We never receive your Google or Facebook password.
• Profile details. An optional display name and profile image. These are not required for any creative feature.
• Your Input. Photos, videos, optional audio, prompts, template and style selections, and editing instructions. Input may show faces or contain other personal information.
• Your Output. Generated results kept in your in-app history so you can find them again.
• Support, feedback and reports. Messages, screenshots, order references, bug reports, content reports and appeals you send us.
• Survey and promotion entries. Anything you choose to give us when taking part in a survey, promotion or event.

3.2 Information collected automatically

• Device and network data. Device model, operating system, app version, language, time zone, network type, IP address, and the country or general region derived from it, plus device or app identifiers.
• Usage and diagnostics. Which features you open, generation requests and their status, credit balance changes, session timestamps, crash reports, error logs, performance data and security events.
• Advertising data. Only if advertising is enabled in the shipped build — see section 8.

3.3 Device permissions

ClipKiwi asks for a permission only when a feature needs it, and uses it only for the purpose shown at the time of the request.

You can change or withdraw any permission in your device settings at any time. The feature that relies on it will then stop working.

3.4 Purchase information

Payment is handled by the app store or by an authorized third-party payment provider, depending on where you complete the purchase. Where card details are needed you enter them on that provider's own secure page. ClipKiwi does not collect or store your full card number, expiry date or security code.

From the store or payment provider we receive only what we need to fulfil and record your order: a transaction or order identifier, the product bought, payment status, amount and currency, billing country, a payment-method summary, package status, and refund status. We use it to activate what you bought, issue receipts, provide support, handle refunds, and meet our tax and anti-fraud obligations.

04Why we use it, and our legal bases

Where the law requires us to name a legal basis, this table sets out what we do and why we are allowed to do it.

You can withdraw consent at any time. Withdrawal does not undo processing already carried out lawfully, and it may make the related feature unavailable. You can opt out of marketing messages at any time; you cannot opt out of essential transactional and security messages while your account is open.

05AI processing, faces, and model training

5.1 What happens when you run a generation

Some adjustments are applied on your device and never leave it. Anything that needs a generative model does leave your device: your selected Input and instructions are uploaded to our servers and passed to contracted cloud, rendering and AI model providers so the requested feature can run. We send only the data reasonably needed to complete the request, and we avoid attaching direct account identifiers to that data where it is technically possible.

Which parts run on device and which run in the cloud must be confirmed feature by feature before publication: [TO CONFIRM PER FEATURE].

5.2 Your responsibility for what you upload

Do not upload another person's photo, video, face or voice unless you have their permission and the legal right to do so. Do not submit sensitive information — identity documents, medical records, financial documents — that the creative task does not need.

5.3 Faces

Photos and videos you upload will often show faces, including your own. Where a portrait, outfit, animation, restoration or enhancement effect requires it, ClipKiwi or its model providers may detect a face and its landmarks in order to place the effect correctly. This detection happens as part of producing your result.

ClipKiwi does not use face data to identify or authenticate anyone, does not build or maintain a face-recognition database, does not attempt to match your face against other users or any external source, and does not use face data for advertising or marketing.

Some jurisdictions treat certain face measurements as biometric data with extra consent, notice and retention duties. Before publication, each shipped feature, SDK and model must be checked against the biometric laws of the launch markets, and this section updated to match what the build actually does: [TO CONFIRM AGAINST EVERY PRODUCTION SDK AND MODEL, AND AGAINST TARGET-MARKET BIOMETRIC LAW].

5.4 Training and other secondary use

We do not use your private Input or Output to train a general-purpose AI model, and our contracts require our processors not to use them for their own independent model training. If that ever changes, we will give you separate notice in advance and obtain any consent the law requires first. [TO CONFIRM IN EVERY VENDOR CONTRACT]

We do use aggregated, de-identified statistics — such as how often a template is chosen or how often a model fails — to improve the Service. These statistics do not identify you and do not contain your images.

5.5 What is stored, and where

Source uploads are kept only as long as needed to run the request, to support a retry, and to investigate a failure or suspected abuse; they are then cleared from our processing systems. Outputs stay in your account history until you delete them or close your account. Exact periods are in section 9.

06Public posting and the Square feed

Your Input and Output are private by default. Nothing you create becomes visible to other users unless ClipKiwi clearly offers a posting feature and you actively choose to post to it.

ClipKiwi's interface includes a Square tab. Before publication, confirm exactly what it shows and update this section to match:

• whether Square only displays ClipKiwi's own templates and showcase material, or also content posted by users;
• if users can post, who can see a post, what profile details appear next to it, and whether posts are visible outside the app;
• how a user removes a post, and what happens to copies already viewed, saved or shared by others;
• what licence a user grants ClipKiwi by posting — this must match the Terms of Service.

[TO CONFIRM SQUARE / COMMUNITY BEHAVIOUR — do not publish this section unresolved]

Where posting exists, remember that anything you post may be seen, screenshotted or re-shared by others. Removing a post stops further distribution by ClipKiwi but cannot recall copies other people already hold.

07Who we share information with

We share the minimum necessary personal information with the categories of recipient below. Each is bound by confidentiality and data-protection obligations and may not use the data for its own unrelated purposes.

Before publication, the table above must be filled in with the actual production vendor list and links to each vendor's privacy terms.

We do not sell your personal information for money, and we do not share it for cross-context behavioural advertising. If an advertising or analytics component in the shipped build would count as a "sale", "sharing" or "targeted advertising" under the law that applies to you, we will say so here and provide the opt-out that law requires. [TO CONFIRM AGAINST PRODUCTION SDK BEHAVIOUR]

We may also disclose information where the law, a court, or a competent authority lawfully requires it, or where necessary to establish, exercise or defend legal claims.

08Advertising and rewarded ads

ClipKiwi's design includes an option to earn credits by watching a rewarded ad. If that option ships, an advertising SDK will be present and the following applies:

• the ad provider may process an advertising identifier, IP address, device and app data, and events such as impressions, clicks and reward completions;
• we receive the reward-completion event so we can credit your account, plus aggregate performance figures;
• where the law or platform policy requires consent for personalized advertising or for tracking, we will request it before the SDK starts collecting, and you will be able to change your choice later;
• you can also limit ad tracking in your device settings — on iOS through App Tracking Transparency, on Android by resetting or deleting the advertising ID.

Before publication, confirm each advertising SDK, whether ads are personalized, whether any behaviour counts as a sale or share, and where the in-app privacy choice lives: [TO CONFIRM — or delete this whole section if the build ships without ads].

09How long we keep information

We keep each category of information only as long as we reasonably need it for the purposes above, taking into account your account status, feature requirements, safety and fraud risk, and legal recordkeeping duties. The periods below are the drafted rules and must be verified against the production build before publication.

Deletion takes time to propagate through backups and disaster-recovery copies, which are overwritten on their normal cycle. We may keep limited information for longer where the law requires it, to finish a transaction, to prevent fraud or abuse, to resolve a dispute, or to enforce our agreements.

10How we protect information

We use administrative, technical and organizational safeguards appropriate to the risk, including TLS encryption in transit, encryption of stored creative content, role-based access controls so that only authorized personnel can reach personal information, audit logging, vendor security review, and staff privacy and security training.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please use a strong, unique password, keep your credentials private, and contact us promptly if you suspect someone else has reached your account.

If a personal-data breach occurs, we will act on our incident-response plan and, where the law requires, notify affected users and the relevant supervisory authority within the applicable deadline, describing what happened, the likely impact, what we have done, and what you can do.

11Your rights and how to use them

The rights available to you depend on where you live. They may include getting a copy of what we hold, having it corrected, having it erased, telling us to pause or stop a particular use, taking back a consent you gave earlier, receiving your data in a portable form, stepping out of certain advertising or data-sharing practices, and challenging how we handled a request. Complaining to the data-protection regulator where you live is also open to you.

We aim to verify and answer a rights request within 15 working days, and in any case within the period the applicable law allows. We may need to confirm your identity, or an agent's authority, before we act. If we cannot do what you asked, we will explain why.

Account deletion is irreversible. Once it completes you cannot sign in, and your account details and stored creative history are deleted or anonymized as described in section 9. Unused credits and any remaining package period are forfeited. Deleting your ClipKiwi account does not cancel or refund a purchase made through an app store — see the Terms of Service.

We will not treat you worse — refuse service, charge a different price, or reduce quality — because you exercised a privacy right.

12Regional privacy notices

12.1 European Economic Area, United Kingdom and Switzerland

If you are in these regions, you have the rights described in section 11 under the GDPR, the UK GDPR or the Swiss FADP, including access, rectification, erasure, restriction, portability, and the right to object to processing based on legitimate interests. Our legal bases are set out in section 4. Where a transfer leaves the region, we use an approved mechanism such as the Standard Contractual Clauses or the UK Addendum. You may complain to your national supervisory authority. Our representative in the region, where one is required, is [TO CONFIRM].

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significant effects. Content moderation may block a generation automatically; you can ask for human review by contacting support.

12.2 United States

Residents of California and of other states with comprehensive privacy laws — including Colorado, Connecticut, Virginia, Texas, Oregon and others as they take effect — may have the right to know what we collect, access it, correct it, delete it, obtain a portable copy, opt out of sale, sharing, targeted advertising and certain profiling, and appeal a refusal. Sections 3 to 7 describe the categories of personal information we collect, why, and who receives them.

We do not sell personal information and we do not share it for cross-context behavioural advertising. If that changes, we will publish a clear "Do Not Sell or Share My Personal Information" control before the practice starts. Sensitive personal information is used only to provide the feature you requested and for the security and legal purposes in section 4, not to infer characteristics about you.

To appeal a decision on a request, reply to our response or email [PRIVACY EMAIL] with "Privacy Appeal" in the subject line.

12.3 Canada and Australia

If PIPEDA or the Australian Privacy Principles apply to you, you may request access to and correction of your personal information, and complain to the Office of the Privacy Commissioner of Canada or to the OAIC. We use the safeguards described in section 10 and the transfer mechanisms in section 14.

12.4 Other regions

Additional notices, consents or local-representative details may be required where you live, and we will provide them where the law requires. Launch markets must be confirmed before publication: [TO CONFIRM].

13Users under 16

ClipKiwi is intended for people aged 16 or older and is not directed to children under 16. If you are under 16, do not create an account and do not use the Service. We do not knowingly collect personal information from anyone under 16.

If you are 16 or 17, use ClipKiwi only if you can legally agree to our Terms where you live. Where local law requires it, your parent or legal guardian must read this policy with you, consent to your use of the Service, and authorize any purchase.

Should it come to our attention that a person under 16 has supplied us with personal information, we will move to erase it and shut the account down, keeping only what a legal obligation forces us to keep. A parent or guardian who believes this has happened can write to [PRIVACY EMAIL]; after we verify the request we will act as soon as reasonably practicable.

This age rule must match ClipKiwi's store age rating, its onboarding age statement, its content controls and its account flow. [TO CONFIRM]

14International transfers

ClipKiwi relies on cloud and AI providers that may operate in countries other than yours, so your personal information may be processed and stored outside your own jurisdiction, including in the United States. Those countries may give data a different level of legal protection. Where a transfer needs a legal mechanism, we use an adequacy decision, the Standard Contractual Clauses, the UK Addendum, or another lawful route, together with contractual and technical safeguards, and we obtain your individual consent where the law requires it. Production hosting and processing regions must be disclosed here before publication: [TO CONFIRM].

15Cookies and similar technologies

The ClipKiwi app uses local storage and device identifiers to keep you signed in, remember your settings, protect your account and measure performance. Where a ClipKiwi website exists, cookies, browser storage, embedded SDKs and pixels may serve those same purposes there, falling into the categories below:

• Strictly necessary — sign-in, security, load balancing and fraud prevention. These cannot be switched off without breaking the site.
• Preference — remembering your language and display choices.
• Analytics — aggregated statistics about how the site is used, so we can improve it.
• Advertising — only where disclosed, permitted by law, and consented to where consent is required.

You can manage non-essential cookies through the consent control on the website, where one is shown, and through your browser settings. Blocking or clearing strictly necessary cookies means you may need to sign in and set preferences again, and some features may stop working. We will not use cookies for purposes outside those listed here.

16Changes to this policy

We may update this policy when the Service, the law, or our practices change. We will not reduce your rights under this policy without your explicit consent. When we update it we will change the "Last updated" date, publish the new version, and — for a material change — give notice in the app, by email or by announcement before it takes effect, and obtain fresh consent where the law requires. If you do not agree with an updated policy, stop using the Service. Earlier versions are kept as required by law or our records policy.

17How to contact us

This Privacy Policy is governed by the law stated in ClipKiwi's Terms of Service. Nothing in it takes away any mandatory protection you have under the law of the place where you live.