Privacy Policy

1. Who we are

Cutroom is the controller of the data processed by this app and this website (GDPR, art. 4(7); LGPD, art. 5, VI). For anything about privacy, write to the contact at the end of this policy or use the options inside the app.

2. The essentials

• Sorting your photos (swipe to delete, keep, favorite or skip) happens on your device.
• No photo or video is uploaded unless you turn the backup on.
• We don’t sell data, we have no ads and we don’t use advertising trackers.
• You can export your data and delete your account and backup right in the app.

3. What data we process

We only process what the app needs to work:

• Account: email (used to sign in with a code), name (optional), language, time zone and app preferences (theme, color, notifications, quiet hours).
• Device: an app identifier for this device (generated by the app itself, not the system identifier), model, platform, app version and, if you allow notifications, the notification token.
• Usage, as numbers only: per day, how many items you reviewed, deleted, kept, favorited and skipped, and how much space you freed. No content, file name or album is sent in these numbers.
• Backup (only if you turn it on): the files you choose to keep before deleting, their thumbnails and file details (name, type, size, dimensions, duration and creation date). With end-to-end encryption on, the content, thumbnails and file name are encrypted on your device before upload, and the creation date is not sent.
• Subscription: what the store and RevenueCat report about the purchase (customer identifier, product, dates and status). We never receive card numbers.
• Invites: your code, who invited you and the status of your invites (friends’ names appear abbreviated, like “Ana S.”).
• Technical and security: IP address and access and error logs, kept for a limited time.

4. What we don’t do

• We don’t read, analyze or upload your gallery. The app only shows and decides on what is on the device.
• We don’t collect location, contacts, microphone or camera.
• We don’t show ads, sell or rent your data, or build advertising profiles.

5. Photos and videos: the backup

The app asks for access to your photo library so you can review it, and that access stays on your device. The backup is optional: if you turn it on, before deleting the selected items the app uploads a copy to private cloud storage over a secure connection (HTTPS) so you can restore them.

The copy expires on its own: 7 days on the free plan (up to 50 items) and 30 days on Premium (up to 3,000 items). You can restore to your gallery, delete items or clear the whole backup anytime, and expired copies are removed automatically.

Backup files sit in a private bucket at our storage provider, encrypted in transit and, at rest, with the encryption the provider applies. We don’t use your photos to train models and we don’t analyze them.

End-to-end encryption (optional): in Settings you can encrypt new backups on the device itself, with AES-256-GCM and a key that stays only on your device (Keychain or Keystore). We and the provider store only encrypted bytes and cannot open or recover your files. The server still sees the size, the type (photo or video), the dimensions, the upload time and how many items you keep. If you lose the device and the recovery code, encrypted backups cannot be opened by anyone.

6. Why we use data and the legal basis

• To provide the service you asked for: account, backup, subscription, restore, syncing preferences and stats across devices (performance of a contract).
• Security and fraud prevention, including in the invite program (legitimate interests).
• To send notifications, when you allow them and per the categories you choose (consent, which you can withdraw in settings).
• To comply with legal obligations and respond to authorities where the law requires (legal obligation).
• To improve app stability from error logs (legitimate interests).

7. Who we share data with

We use providers that process data on our behalf, only for what we need from them:

• Cloud and network providers: API hosting, backup storage (Cloudflare R2) and website delivery.
• RevenueCat, Apple and Google: processing of subscriptions and purchases, and notification delivery.
• Expo: sending push notifications.
• Email service: sending the sign-in code and the data export file.
• Error monitoring tool: technical logs used to fix failures.

8. International transfers

Some providers may process data outside your country. When that happens, we rely on the safeguards in the GDPR (standard contractual clauses or an adequacy decision) and in the LGPD (art. 33).

9. How long we keep data

• Account and preferences: as long as the account exists.
• Backup: for your plan’s period (7 or 30 days) or until you delete it.
• Technical and security logs: for a limited time, up to 90 days.
• When you delete your account we erase your data and backup; internal safety copies cease to exist within 30 days. We may keep the minimum required by law (for example, purchase records).

10. Your rights

At any time you can: confirm we process your data, access it, correct it, request portability, request erasure, know who we share it with, withdraw consent and object to processing (GDPR, arts. 15 to 22; LGPD, art. 18).

In the app: Settings → Privacy and data → Export my data (we email you a file) and Delete account (deletes your account and cloud backup). If you subscribed to Premium, cancel the subscription in the store too. Or write to the contact below; we reply within 15 days.

You can also complain to your country’s data protection authority.

11. Security

We use secure connections (HTTPS), sessions with rotating renewal, restricted access to systems and private storage for the backup, with optional end-to-end encryption. In the app you can turn on lock with Face ID, fingerprint or passcode and hide content in the app switcher. No system is infallible; if an incident affects your data we will notify you and the authorities as the law requires.

12. Children

Cutroom is not directed at children under 13 and we don’t knowingly collect their data. If you believe a child created an account, contact us so we can delete it.

13. This website

The website uses only what it needs to work. We don’t use advertising cookies or third-party analytics cookies. The invite page calls our API to confirm the code and show the first name of whoever invited you.

14. Changes to this policy

If something important changes, we update the date at the top and tell you in the app when the change affects your rights. The version in force is always the one on this page.