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Draft. Under legal review. This text is not final and is not legal advice. 29 open items are marked [VERIFY] and left visible on purpose.

Just Cut Privacy Policy

On this page
  1. 1. Who we are
  2. 2. The short version
  3. 3. What stays on your iPhone
  4. 4. What leaves your iPhone, and why
  5. 5. What we do not do
  6. 6. Who receives information
  7. 7. How long we keep it
  8. 8. Your choices and your rights
  9. 9. Why we use it: purposes and legal bases (EU, EEA and UK)
  10. 10. Transfers outside your country
  11. 11. Children and age
  12. 12. Do Not Track and Global Privacy Control
  13. 13. Security
  14. 14. Just Cut's AI
  15. 15. Changes
  16. 16. Contact

Effective date: [VERIFY: the launch date]
Last updated: [VERIFY: the date you publish it]

1. Who we are

Just Cut is an iPhone app made by Levron Films LLC, a Florida limited liability company ("Levron Films", "we", "us"). We decide why and how the personal information described here is used: we are the "controller" under the EU and UK General Data Protection Regulation (GDPR) and the "business" under US state laws.

Our representatives in Europe (GDPR Article 27 and UK GDPR Article 27). Because we are not established in the EU or the UK, we have appointed representatives you can contact about this policy instead of, or as well as, us:

[VERIFY with the lawyer: whether Levron Films must appoint a data protection officer. Our understanding is that it does not, because it does not monitor people on a large scale or process special categories of data on a large scale.]

2. The short version

The rest of this page gives the details.

3. What stays on your iPhone

These stay on your iPhone, inside Just Cut's own storage or your Photos library, and are not sent to us:

If you delete Just Cut, iOS deletes this data from the app's storage. Reels you saved to Photos or Files stay there until you delete them. Some small counts (how many free reels you used) are kept in your iPhone's keychain so that deleting and installing the app again does not reset them.

4. What leaves your iPhone, and why

4.1 Words for Just Cut's AI (only with your consent)

The consent sheet. The first time you ask Just Cut's AI for something, free or paid, Just Cut shows a sheet that says Just Cut's AI writes with Anthropic, what is sent and what stays on your iPhone, with two buttons: Allow and Not now. Nothing is sent to the AI until you tap Allow. If you tap Not now, recording, cutting, captions, looks and exports keep working; only the AI writing stays off. You can change your answer at any time in Settings, [VERIFY: the exact row name once built, for example Just Cut's AI]. Turning it off stops new requests from that moment; it does not undo requests already answered.

When you have allowed it and you ask Just Cut to write or read something (a script, hooks, captions, ideas, reading a brief, finding lines in your take), the app sends:

It goes over an encrypted connection (HTTPS) to our server, which runs on Cloudflare, and from there to Anthropic, PBC, the company whose AI model writes the answer. The answer comes back to your iPhone.

4.2 Still frames, only when you ask

In Match a reel, Just Cut reads a video you pick on your iPhone. If you then tap the button that asks Just Cut's AI to name effects the phone could not recognise, the app sends up to 8 small still frames (low resolution JPEG images) from that video, on the same path as 4.1 and only if you allowed the AI (4.1). They are held in memory to answer and are not stored by our server. Nothing is sent unless you tap that button.

4.3 Checking your plan

When you have the subscription, the app sends Apple's signed record of your purchase (a "signed transaction") to our server so it can confirm your plan. Apple also tells our server directly when a purchase is refunded or revoked (App Store Server Notifications). From these, our server keeps:

We use this only to give you the AI your plan includes, to apply the fair use limit described in our Subscription Terms, and to stop misuse.

4.4 Proving the app is real (App Attest and DeviceCheck)

To stop people from using our AI with fake copies of the app, Just Cut uses two Apple services:

For the free AI, our server keeps, per App Attest key: how much free AI was granted and used, and request counts (the "free AI record").

4.5 Effect counts

[VERIFY: true once lane F's change is in the build (CHECKLIST.md item P6).] This version of Just Cut does not send counts of the effects you use. If a later version offers it, it will be off until you turn it on, and this policy will say so first.

4.6 Downloads you ask for

If you turn on "Better word accuracy", the app downloads a speech model from Hugging Face. Like any download, Hugging Face sees your iPhone's internet address and the file requested. Nothing of yours is uploaded, and nothing is downloaded unless you turn the option on. [VERIFY: keep only if this option is in the release build; if not, delete this section and Hugging Face in section 6.]

4.7 Things you send yourself

4.8 Our website

[VERIFY: complete once the waitlist form is connected.] If you join the waitlist, we keep the email address you give to send you one email when Just Cut is on the App Store, through [VERIFY: waitlist email service name]. The legal basis is your consent; you can unsubscribe from any email or ask us to delete your address. Our web host Cloudflare processes standard request information (such as IP address and browser type) to serve and protect the site [VERIFY: the site is on Cloudflare Pages]. The site uses no advertising or tracking cookies [VERIFY: true once the form and any analytics are added].

5. What we do not do

6. Who receives information

Only these service providers, by name, and only to run Just Cut:

On the website only, once chosen: [VERIFY: the waitlist email service].

We may also disclose information if the law requires it, to protect people's safety, to enforce our terms, or as part of a sale or merger of our business, in which case the buyer must keep this policy's promises.

7. How long we keep it

We keep a record longer only if the law requires it or to deal with a legal claim.

8. Your choices and your rights

On your iPhone. Delete a reel, a client or a project in the app, or delete the app to remove everything it stored. Turn off camera, microphone, photos or speech access any time in iPhone Settings, Just Cut.

Withdrawing your AI consent. Turn off the AI switch in Settings, [VERIFY: the exact row name once built]. From then on nothing is sent to Anthropic. Withdrawing does not affect requests made before, and recording, cutting and captions keep working.

Your rights. Depending on where you live, you have the right:

To use a right, write to contact@levron.co, or to our EU or UK representative (section 1). Because we have no account and keep only one way codes, we often cannot tell which server record belongs to you. If you want us to find one, tell us roughly when you bought the plan and which App Store country you use, and we will do what we can. We will not ask for more information than we need. We answer within one month (EU and UK law) or 45 days (US state laws), and tell you if we need more time. We will not treat you differently for using your rights.

Complaints to a supervisory authority. If you are in the EU or EEA, you can complain to the data protection authority in the country where you live, work or think your rights were broken (the list is at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en). In the UK, you can complain to the Information Commissioner's Office (https://ico.org.uk/make-a-complaint/). In Switzerland, to the Federal Data Protection and Information Commissioner. We would like the chance to help first, but you do not have to come to us before you complain.

US state privacy rights. Depending on where you live (for example California, Colorado, Connecticut, Virginia, Texas and other states), you may have the rights above, and the right to opt out of the sale of personal information, targeted advertising and profiling. We do none of these. You may use an authorized agent; we may ask the agent for proof. If we refuse a request, you can appeal by replying to our answer, and we will answer the appeal within the time the law allows.

9. Why we use it: purposes and legal bases (EU, EEA and UK)

You can ask us for the balancing test behind any use based on legitimate interests.

Do you have to give us this information? No law requires it. The purchase record is needed to give you the plan. Consent for the AI is optional: if you do not give it, the AI writing is off and everything that runs on your iPhone keeps working.

10. Transfers outside your country

We are in the United States, and our providers (section 6) process data in the United States and other countries where they operate. When personal information from the EU, EEA, UK or Switzerland goes to the United States, we rely on:

[VERIFY with the lawyer: Cloudflare's data processing addendum, Apple's terms for App Attest and DeviceCheck, and each provider's current listing on https://www.dataprivacyframework.gov.] You can ask us for a copy of the safeguards by writing to contact@levron.co.

11. Children and age

Just Cut is a tool for creators who make videos for brands. It is for people 13 and older, it is not directed to children, and it is rated [VERIFY: the final App Store rating, 13+ recommended] on the App Store.

The age check. At first launch, Just Cut asks Apple for your age range through Apple's Declared Age Range feature. Apple tells the app only an age range, never your birth date. If the range is under 13, Just Cut stops and cannot be used. Just Cut uses the age range only for this check and for any parent's consent the law requires, and keeps it on your iPhone [VERIFY: true in the build; the age range is not sent to our server].

We do not knowingly collect personal information from children under 13. If we learn that we did, we delete it. If you believe a child under 13 gave us personal information, write to contact@levron.co.

Teens in the EU and UK. Some EU countries set the age at which a person can consent alone to an online service between 13 and 16 (GDPR Article 8); the UK sets it at 13. Where you are under that age, a parent or guardian must agree before you allow the AI. [VERIFY with the lawyer: how Just Cut meets Article 8 for 13 to 15 year olds in countries that set a higher age, for example by the consent sheet asking that a parent agrees when Apple's age range is under 16.]

12. Do Not Track and Global Privacy Control

We do not track people across websites or apps, so there is nothing for a Do Not Track signal to switch off. If our website receives a Global Privacy Control signal, we treat it as a request to opt out of sale and sharing, which we already do not do.

13. Security

Connections use HTTPS. The app holds no AI keys or passwords; our server keeps its keys as protected secrets. Purchase numbers are stored only as one way codes. App Attest keys stay in your iPhone's secure hardware. No system is perfectly secure, and we will tell you and the authorities about a breach where the law requires.

14. Just Cut's AI

Just Cut's AI writes suggestions: scripts, hooks, captions and ideas. You are told that you are dealing with AI before you use it: the consent sheet says that Just Cut's AI writes with Anthropic, and text the AI writes is marked in the app as written by Just Cut's AI [VERIFY: the label in the build] (EU AI Act Article 50). It does not make decisions about you, and it is not used for profiling. AI can be wrong, so read what it writes before you post it. The AI is provided by Anthropic and is called Just Cut inside the app. If the AI writes something harmful or wrong, report it from Settings, Help, "Report something Just Cut wrote".

15. Changes

If we change this policy, we will update the date at the top and, for an important change, tell you in the app before it takes effect. If we ever want to use information in a new way that needs your consent, we will ask first.

16. Contact

Levron Films LLC, contact@levron.co, [VERIFY: phone], [VERIFY: business address].
EU representative: [VERIFY: EU representative]. UK representative: [VERIFY: UK representative].