Privacy Notice

This notice explains which personal data ClipWill processes, why, on what legal basis, who receives it, how long it is kept and what rights you have. It covers clipwill.com, the ClipWill app at clipwill.com/app and the partner programme. It is written to meet the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

1. Who is responsible

See also our legal notice. We are not required to appoint a data protection officer. For anything about your data, write to the address above.

2. What we process, why, and on what legal basis

Visiting the website. When you open a page, our server receives your IP address, the time, the page requested, the referring page and your browser’s user-agent. This is needed to deliver the page and to protect the service against abuse. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in a secure, working website). We count page steps (for example “landing opened”, “signup form opened”) together with the interface language only; these counts contain no IP address, no cookie and no identifier and cannot be linked to you.

Your account. Your email address, to create the account and send one-time login codes, and your interface language. Legal basis: Art. 6(1)(b) GDPR (contract).

Your channels and videos. What you enter to set up a channel or a video - niche, topic or script, style, format, voice, avatar and other settings - any files you upload, and the scripts, audio and videos the service produces for you. Legal basis: Art. 6(1)(b) GDPR. Please do not put personal data of other people into topics or scripts unless you are allowed to.

Payments. Plan, order, payment and subscription status. We never see or store your card number: card details go directly to our payment provider. From the provider we receive and store a card fingerprint - a code that cannot be turned back into a card number. Legal basis: Art. 6(1)(b) GDPR, and Art. 6(1)(c) GDPR for records we must keep under tax and commercial law.

Preventing misuse of the free trial and of the login. On signup, login and when a trial starts we store the IP address, user-agent, email and card fingerprint, and we limit how often codes can be requested. If the same card, email or network has already used a free trial, the new subscription starts on the paid plan without a free week. This decision is made automatically; if you think it is wrong, write to us and a person will review it. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in preventing fraud and abuse).

Service emails. Login codes and notices about your account, channels, videos and payments. We do not send marketing email. Legal basis: Art. 6(1)(b) GDPR.

Support. If you write to us, we process your message and contact details to answer. Legal basis: Art. 6(1)(b) or (f) GDPR.

Partner programme. If you arrived through a partner link, we store which partner referred you so the partner can be paid a commission; the partner sees payment amounts, not your email or name. If you are a partner, we process your email, your partner code, commissions and the payout details you give us. Legal basis: Art. 6(1)(b) GDPR, and Art. 6(1)(c) GDPR for payout records.

You are not legally obliged to provide any data. Without an email address we cannot create an account, and without payment data we cannot start a paid plan.

3. Who receives your data

We do not sell personal data and we do not use advertising or third-party analytics. We use the following service providers, bound to us by data processing agreements (Art. 28 GDPR) where they act on our behalf:

• Hosting - netcup GmbH, Karlsruhe, Germany. Our servers are located in Germany. Everything above is stored here.
• Payments - Stripe Payments Europe, Ltd., Dublin, Ireland. Receives your card details and billing information. Stripe also acts as an independent controller for its own fraud prevention and legal obligations; see stripe.com/privacy.
• Email delivery - Resend (Plus Five Five, Inc.), USA. Receives your email address and the content of service emails.
• AI text generation - Google (Gemini API). Receives the channel description, topics and settings you enter, to draft your channel setup, plan and scripts. It does not receive your email or payment data.
• Voice synthesis - ElevenLabs and Fish Audio. Receive the script text to be read out. They do not receive your email or payment data.
• AI image and video generation - only if you switch on generated shots or an on-screen avatar: the providers that make those shots receive the text description of the shot. They do not receive your email or payment data.

We also disclose data to authorities where the law requires it.

4. Transfers outside the EU

Some providers above are based in, or process data in, the USA or other countries outside the EU/EEA. Where the recipient is certified under the EU-U.S. Data Privacy Framework, the transfer relies on the European Commission’s adequacy decision (Art. 45 GDPR); otherwise it relies on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can ask us for a copy of the safeguards.

5. How long we keep it

• Login codes - 15 minutes. Login sessions - 30 days.
• Server logs - a short period for security, then overwritten automatically.
• Abuse and trial-misuse data (IP, user-agent, card fingerprint) - 12 months after it was collected.
• Account, channel settings, scripts and videos - while your account exists. When you ask us to delete your account, we delete this data within 30 days, including from backups.
• Invoices, payment and payout records - as long as German tax and commercial law requires (Section 147 AO, Section 257 HGB), up to 10 years.

6. Your rights

You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16), deleted (Art. 17) or restricted (Art. 18), to receive it in a portable format (Art. 20), and to object at any time to processing based on our legitimate interests, on grounds relating to your particular situation (Art. 21). Write to support@clipwill.com; we answer within one month.

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the EU country where you live or work. The authority responsible for us is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany, www.lda.bayern.de.

7. Cookies and local storage

We use no advertising, tracking or analytics cookies, so we do not ask for cookie consent. We only use what is strictly necessary for the service you request (Section 25(2) TDDDG):

• cw_session - a session cookie set after you log in, so you stay logged in. httpOnly, secure, expires after 30 days or when you log out.
• Local storage - your chosen interface language, and, if you arrived through a partner link, that partner’s code for 60 days so the referral can be credited.

Fonts are served from our own server; the website does not load content from Google or other third-party servers.

8. Children

ClipWill is not meant for people under 16, and we do not knowingly process their data.

9. Changes

If we change this notice materially, we will email account holders before the change takes effect. The current version is always on this page. If this notice is shown in another language, the English version prevails.

Questions about your data: support@clipwill.com