سياسة الخصوصية

Smart Clip (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, process, and safeguard your personal information when you use the Smart Clip application and related services, including our iOS, Android, and macOS apps as well as our browser extensions (collectively, the “Service”).

By accessing or using Smart Clip, you acknowledge that you have read and understood this Privacy Policy and agree to the data practices described herein.

Owner and Data Controller: Pedro Manfredi (Clutch Developer), Pau Alsina 64, bloque A, 3, 1, Barcelona 08024, Spain. Contact: info@clutchdeveloper.com.

We collect only the minimum data necessary to provide and improve the Service:

• Personal Data — your email address and name, provided voluntarily during account registration or sign-in.
• Usage Data — information about how you interact with the Service, used in aggregated, anonymized form.
• Device Data — technical identifiers such as OS type/version, app version, device model, screen resolution, and language settings.
• Payment Data — handled entirely by third-party processors (Apple App Store, Google Play Store, RevenueCat). We do not store payment card details.
• Crash & Diagnostic Data — crash reports and performance metrics collected automatically.

We do NOT collect, store, transmit, or retain the content of your writing. Text is processed entirely in real-time on-device or via secure, ephemeral API calls.

Personal data is processed using IT systems following procedures strictly related to the purposes indicated in this policy. Our primary servers are hosted on Google Cloud Platform in Frankfurt, Germany (EU). All data processing takes place within the European Union unless explicitly stated otherwise.

• Account data — retained while your account is active; deleted within 30 days of account deletion.
• Usage analytics — up to 24 months in anonymized, aggregated form.
• Crash and diagnostic data — up to 12 months.
• Payment records — as required by tax/financial regulations, typically up to 7 years.
• Support communications — up to 3 years.

• Provide and maintain the Service — performance of a contract.
• Process payments and manage subscriptions — performance of a contract.
• Send service notifications — legitimate interests / contract.
• Analyze anonymized usage patterns — legitimate interests.
• Diagnose technical issues — legitimate interests.
• Prevent fraud and abuse — legitimate interests / legal obligation.
• Comply with legal obligations — legal obligation.
• Marketing communications (with explicit consent only) — consent.

• Analytics — Google Firebase Analytics, Mixpanel (SCCs applied).
• Crash Reporting — Firebase Crashlytics, Sentry (SCCs applied).
• Payments — RevenueCat, Apple App Store, Google Play Store.
• Hosting — Google Cloud Platform (Frankfurt, EU).
• Authentication — Firebase Authentication, Sign in with Apple.
• Push Notifications — Firebase Cloud Messaging.

We never sell your personal data to any third party.

• Encryption in transit — TLS 1.3.
• Encryption at rest — AES-256.
• Access controls — strict RBAC.
• MFA — required on all internal systems.
• Regular security audits — penetration testing and vulnerability assessments.
• Incident response — supervisory authorities notified within 72 hours of a breach per GDPR.

When we transfer personal data outside the EEA, we use Standard Contractual Clauses (SCCs) approved by the European Commission. You may request a copy of relevant safeguards by contacting info@clutchdeveloper.com.

If you are in the EEA, UK, or Switzerland, you have the right to: access, rectification, erasure, restriction of processing, data portability, objection, withdrawal of consent, and to lodge a complaint with the Agencia Española de Protección de Datos (AEPD) at www.aepd.es.

Smart Clip is not intended for children under 13 (or 16 in applicable EU states). We do not knowingly collect data from minors. Contact info@clutchdeveloper.com if you believe a child has provided us data.

We use strictly necessary, functional, and anonymized analytics cookies. We do not use cookies for advertising or cross-site behavioral tracking. You can manage cookies through your browser settings.

We may update this policy periodically. Significant changes will be communicated via email and in-app notification. Continued use after notification of non-material changes constitutes acknowledgment of the updated policy.

• Email: info@clutchdeveloper.com
• Postal: Pedro Manfredi (Clutch Developer), Pau Alsina 64, bloque A, 3, 1, Barcelona 08024, Spain.