Privacy Policy

1. Who the controller is

The data controller is Secure Online Managements SL (NIF ESB01794866), with registered address at C/ Creueta 20, 08870 Sitges (Barcelona), Spain, and contact email clipmix@som.company. In this policy we call it “ClipMix” or “we”.

This policy applies to the ClipMix app for Android, to the service that makes it work (our server) and to this website.

2. Summary

3. What data we process

3.1 Your anonymous account

When you open the app for the first time, an account is created with no name, no email and no password. We store:

• a random identifier of the installation and an internal identifier of the account;
• your account ID (in the form CM-XXXX-XXXX), which you see in Profile and which we ask for if you write to support or ask to delete your account from the website;
• the app language, your plan and its dates, and whether the app has passed the Google Play Integrity check, which tells us that the app is genuine and has not been modified.

3.2 Your device fingerprint

The app calculates on your phone a SHA-256 hash of ANDROID_ID (an identifier that Android gives each app on each device) together with a fixed salt. ANDROID_ID doesn’t leave the phone: only that hash is sent, and our server in turn stores another hash of it.

We use it for two things only:

• to prevent abuse of the free minutes, which are one per device;
• to recover your account (minutes, purchases and projects) if you uninstall and reinstall the app on the same phone.

We don’t read the IMEI or the serial number, we don’t use it for advertising and we don’t give it to AppsFlyer or AdMob.

3.3 Sign-in with Google (optional)

You don’t need it to use ClipMix. If you link your Google account when the app offers it, we store the identifier that Google gives your account and your email address, to recognize you.

3.4 Your video: what doesn’t leave your phone

You pick the video from your gallery or your files and the file is not uploaded. To analyze it, the app sends us:

• a fingerprint of the file, calculated on the phone from its size, its duration and a few fragments, which is used to recognize a video that has already been analyzed and not charge you twice;
• technical data about the video: duration, resolution, frames per second, rotation, whether it is HDR, and size.

Face detection, shot changes and editing happen on your phone, offline.

3.5 The audio we analyze

The app extracts the audio of the section you choose to analyze (mono AAC at 16 kHz, about 14 MB per hour) and uploads it to our temporary storage. From there it is sent to a transcription provider.

The audio is deleted as soon as it has been transcribed. If the analysis fails or is interrupted, it is deleted within 24 h at most.

3.6 The transcript and the suggested clips

From the audio we obtain the transcript: the text, with the timing of each word and who is speaking. From that text, a language model suggests the clips: where each one starts and ends, a title, the reason and a hook score.

In addition, we automatically review the text to detect sexual content involving minors (section 4) and we store the result of that review.

The transcript and the suggestions don’t expire: they are kept so that you can edit or extend the project again, until you delete the project or the account.

3.7 The piece of video of each clip you export

When you export, the app uploads only the piece of video of that clip and its edit document (cut, framing, captions, style). Our server renders the clip, and your phone downloads it and checks that it has arrived in full.

The piece and the rendered clip are deleted as soon as your phone confirms the download or, if it doesn’t confirm it, after 24 h. The finished clip is saved in your phone’s gallery (Movies/ClipMix): it’s yours and we don’t keep it.

The edit document of each clip you export (cut, framing, caption text and style) does stay on our server, together with the record of that export, until you delete the project or the account.

3.8 Purchases and minutes

Purchases are charged by Google Play and managed by RevenueCat. We don’t see your card details. RevenueCat notifies us of each purchase, renewal or refund (product, dates, transaction identifier and status) and we credit the minutes you are entitled to.

We store your minute balance and its movements (free minutes, purchase, analysis, refund), and we record on each project which purchases paid for its analysis, because that determines whether its clips carry a watermark.

3.9 The rewarded ad and its verification

If you export a free clip, you first watch a rewarded ad from Google AdMob. When you finish it, Google notifies our server (AdMob’s “server-side verification”) with the reward identifier, your anonymous account identifier and a single-use code generated by the app. We check Google’s signature and keep that reward for 7 days.

3.10 The advertising ID and your consent

AdMob and AppsFlyer use your phone’s Google advertising ID (GAID) according to what you chose in Google’s consent form (UMP). We explain it in section 7. Firebase Analytics may also collect the advertising ID (section 3.12).

3.11 Notifications

If you allow notifications, we store the identifier that Firebase Cloud Messaging gives your phone, to let you know when an analysis or a clip finishes or fails.

3.12 Analytics and crashes

We use Firebase Analytics to understand how the app is used (for example, when a video is picked, an analysis finishes, a clip is exported or the plans are opened) and Firebase Crashlytics to receive crash reports with technical data about the phone and the app. We don’t send them your account identifier, but Firebase Analytics uses its own installation identifier and may also collect your phone’s advertising ID. Today, analytics works without going through the consent form.

3.13 Campaign measurement

AppsFlyer tells us which campaign each installation comes from. We explain it in section 7.3.

3.14 Support and deletion requests

If you write to us at clipmix@som.company, we store your email, your message and, if you include it, your account ID, only to reply to you. If you ask to delete your account, we store your account ID and your email to handle the request.

3.15 Technical connection data

Like any Internet service, our server receives the IP address of each request. We use it for the security of the service and to limit abuse, for example, the number of new accounts created from the same network.

3.16 This website

This website is hosted on Firebase Hosting, by Google. To serve and protect it, Firebase Hosting logs technical data of each visit: the IP address, the browser and the page requested. Google keeps them according to its own policy.

The website uses no cookies or analytics, and the fonts are served from the website itself, without requesting them from third parties. It doesn’t send data to our server either.

4. Why we use them and on what legal basis

You can object to processing based on legitimate interest by writing to us (section 10). In the EEA, the United Kingdom and Switzerland you can withdraw your consent at any time in Profile › “Privacy and ads”.

Artificial intelligence chooses which moments of your video work as a clip. It doesn’t make decisions about you with legal or similarly significant effects.

5. Artificial intelligence and providers

All calls to artificial intelligence providers go through a single point on our server, which uses a main provider and, if it fails, the next one.

• Artificial intelligence providers don’t receive your video, your email or your account ID.
• They act as processors: they can only use the data to provide their service to us. They don’t use it to train or fine-tune their models, and they don’t keep it longer than needed for each request.

6. Who we share them with

We don’t sell your data or give it to anyone else, unless a law or an authority requires us to.

7. Advertising and measurement

7.1 The rewarded ad

ClipMix has only one type of ad: Google AdMob’s rewarded ad, and only to export a free clip. It always appears because you ask for it with a tap. There are no interstitial, banner or native ads, and with an active plan there are never any ads.

7.2 Your consent in the EEA, the United Kingdom and Switzerland

In those countries the app shows you Google’s consent form (UMP) at startup. There you decide whether AdMob can personalize the ads and whether AppsFlyer can measure your installation. You can change it at any time in Profile › “Privacy and ads”.

You can delete or reset your phone’s advertising ID in Android settings.

7.3 Campaign measurement with AppsFlyer

AppsFlyer works for us as a processor and tells us which campaign each installation comes from.

• In the EEA, the United Kingdom and Switzerland it only works if you give your consent in Google’s form. If you withdraw it, AppsFlyer stops. If you don’t give it, it doesn’t start.
• Outside that area it works from the first launch.
• What it receives: the installation and the advertising ID; four usage events (that the account is ready, that an analysis finished, that you exported your first clip and that you opened the plans); and what the advertiser pays for each rewarded ad.
• Purchases are sent to it by RevenueCat together with your anonymous account identifier. The app doesn’t give it any other identifier of yours: neither ANDROID_ID nor its fingerprint. Since your anonymous account is recovered when you reinstall, AppsFlyer can tell that two installations are from the same phone.
• AppsFlyer may send this data to the networks where we advertise the app (for example, Meta) to measure the campaigns.

Deleting your ClipMix account doesn’t yet delete your data at AppsFlyer, RevenueCat, Firebase or Google AdMob (which receives your anonymous account identifier in each ad verification): it isn’t propagated automatically. If you want us to delete it there too, ask on Support with your account ID and we’ll ask each of them.

8. International transfers

Some providers process data outside the European Economic Area, mainly in the United States. We only do so with appropriate safeguards: an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework, if the provider is certified under it) or the Commission’s standard contractual clauses. You can ask us for a copy of the applicable safeguards by writing to clipmix@som.company.

9. How long we keep them

10. Your rights

You can ask us for access to your data, to rectify it, to erase it, to object to a processing, to restrict it and to take it with you (portability), and you can withdraw your consent at any time.

• Delete the account: instantly, in Profile › Delete account. Without the app, by writing to us at clipmix@som.company (see Delete account).
• Consent for ads and measurement: in Profile › “Privacy and ads”, where the law requires it.
• Everything else: write to us on Support. Since your account is anonymous, we need your account ID (in Profile) to know which data is yours. We reply within one month at most.

When you delete the account your data is deleted, except what is explained in Delete account › What we keep and why. In short:

• The device free-minutes record: a device fingerprint and the dates of the last free minutes, without any account data. It ensures that deleting the account and coming back doesn’t bring the next free minutes forward.
• A record of the account marked as deleted, with the random installation identifier, the plan and the dates. If you keep using the app on that phone without uninstalling it, that record is reused for your new account, with the same internal identifier (the one RevenueCat and AppsFlyer know), and it is linked again to your device fingerprint. Your new account starts empty; the free minutes don’t come again until the next ones are due, 30 days after the previous ones.

If you believe we haven’t handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (AEPD), at www.aepd.es, or with the data protection authority of your country.

11. Security

• All communications between the app and our server are encrypted (HTTPS).
• The audio and the video pieces are uploaded and downloaded with signed links that expire.
• ANDROID_ID doesn’t leave the phone and we only store a fingerprint of it, from which the original cannot be recovered.
• Minutes, the watermark and ad verification are decided on the server, not in the app.

If we suffered a security breach that put your data at risk, we would notify the AEPD within 72 hours and, where the law requires it, you as well.

12. Minors

ClipMix is not directed at minors under 16 years of age. If we learn that an account belongs to a minor under that age without the consent of their parents or guardians, we will delete it.

13. Residents of California and other US states

We process these categories of data: identifiers (your anonymous account, the device fingerprint and the advertising ID), commercial information (your purchases), app activity (analytics), audio information (the audio we analyze) and approximate location data inferred from the IP address. We don’t sell your data for money. We do “share” it within the meaning of California law (CCPA/CPRA): AppsFlyer receives the advertising ID, the activity and the purchases and may pass them on to ad networks to measure campaigns, AdMob uses the advertising ID for ads and Firebase Analytics may also collect it. The “Privacy and ads” option in Profile only exists today in the EEA, the United Kingdom and Switzerland; in the United States, to opt out, delete the advertising ID in Android settings and write to us on Support with your account ID, and we will handle it manually. You have the right to know what data we hold, to ask us to delete or correct it and not to be discriminated against for exercising these rights.

14. Changes to this policy

If we change this policy, we will publish the new version on this page with its number and its effective date. If the change is significant, we will also let you know in the app.

15. Contact

Secure Online Managements SL, NIF ESB01794866, C/ Creueta 20, 08870 Sitges (Barcelona), Spain, clipmix@som.company. You can also write to us from Support or request deletion from Delete account.