Cutout Studio Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how FlashSoft OÜ, a private limited company (osaühing) incorporated under the laws of the Republic of Estonia ("Company", "we", "us" or "our"), processes information in connection with the mobile application Cutout Studio: BG Remover AI for iOS (the "App").

For the purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, the Company is the controller of Personal Data processed through the App, except where an App Store Provider or a Third-Party Service acts as an independent controller, as described in this Privacy Policy.

This Privacy Policy applies solely to Cutout Studio. By downloading, installing, accessing, or using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the App and must delete it from your Device.

This Privacy Policy forms an integral part of, and should be read together with, our End User License Agreement (Terms of Use) available at https://flashsoftapps.com/cutout-studio-eula.html and Apple's Standard EULA at https://www.apple.com/legal/internet-services/itunes/dev/stdeula/.

2. Core Principle: Private by Design

Cutout Studio is engineered using Apple's local on-device machine learning frameworks (including CoreML, Vision, and Metal Performance Shaders). Automatic background segmentation, edge fine-tuning (Erase, Restore, Magic Wand), object erasing, generative AI inpainting, batch cutouts, and video background removal execute entirely within the local hardware of your iPhone or iPad. At no point are your visual files transmitted over the internet to the Company or to any third party for editing or rendering.

3. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Processing" means any operation performed on Personal Data, such as collection, recording, organization, storage, use, or erasure.
• "Device" means your Apple iPhone, iPad, or iPod touch on which the App is installed.
• "Third-Party Services" means software development kits (SDKs), infrastructure, and analytics providers integrated into the App.
• "App Store Provider" means Apple Inc., operator of the iOS App Store.

4. Information We Collect and Process

4.1 Visual Content (Photos and Videos)

The App requests access to your iOS Photo Library strictly to allow you to select images or video clips you wish to edit, and to save your final cutout creations (transparent PNGs, high-resolution JPGs, or processed video files) back to your Photos or Files app.

• Selective Permission: You may grant the App access to your "Full Library" or use iOS "Limited Photo Access" to select individual photos. The App only accesses photos you explicitly choose.
• Local Storage of Projects: In-progress projects, mask layers, and adjustment settings are stored locally on your Device in sandboxed application storage. You can delete projects at any time within the App or by uninstalling the App.
• No Biometric Templates: While the AI detects people, products, pets, or signatures to generate cutouts, it does not identify any individual person or create facial recognition templates, faceprints, or biometric identifiers.

4.2 Information Collected Automatically

To maintain stability, diagnose crashes, and improve functionality, the App and its integrated SDKs collect limited technical and diagnostic data:

• Device and Operating System Data: Device model (e.g. iPhone 15 Pro), iOS version, language, country/region locale, screen resolution, available memory, and CPU/GPU architecture.
• Identifiers: Apple Vendor Identifier (IDFV), anonymous Firebase Installation ID, and an anonymous Apphud User ID. We do not use the Advertising Identifier (IDFA) unless explicitly consented to under Apple's App Tracking Transparency (ATT) prompt.
• Usage Events: Feature interaction metrics, such as whether a background cutout, object erasure, batch export, or gradient backdrop was applied. Usage telemetry never includes image contents, pixel data, or photo metadata.
• Crash Reports: Stack traces, exception logs, memory status at the moment of a crash, and device orientation provided via Firebase Crashlytics.

4.3 Purchases and Subscription Data

All financial transactions, subscriptions (weekly, yearly), and one-time Lifetime purchases are conducted directly by Apple Inc. through the App Store and StoreKit. The Company does not receive or store your credit card numbers, banking details, or Apple ID passwords. We receive validated cryptographic transaction receipts through Apphud to confirm your active entitlement status and enable Premium features.

4.4 Customer Support

If you contact us for technical assistance via email (support@flashsoftapps.com) or our in-app feedback tool, we process your email address and message contents solely to troubleshoot your inquiry and provide customer assistance.

5. Third-Party Services

We integrate the following vetted service providers to support the operation and monetization of the App:

6. Legal Bases for Processing (GDPR & UK GDPR)

If you reside in the European Economic Area (EEA), United Kingdom, or Switzerland, our processing of your Personal Data is grounded in the following legal bases under Article 6(1) of the GDPR:

• Contractual Necessity (Art. 6(1)(b)): To provide the App's features, process transactions, and fulfill our terms under the EULA.
• Legitimate Interests (Art. 6(1)(f)): To maintain application stability, prevent abuse, ensure security, and optimize user experience, provided these interests are not overridden by your fundamental rights.
• Consent (Art. 6(1)(a)): For optional permissions (such as photo library access and push notifications) and personalized tracking where requested.
• Legal Obligation (Art. 6(1)(c)): To comply with mandatory statutory obligations under applicable Estonian and EU laws.

7. Data Retention and Storage

Because Cutout Studio does not maintain user accounts or cloud storage for photos, your editing projects and imported media exist solely on your local device for as long as you choose to keep them. Anonymized crash logs and telemetry collected by Firebase and Apphud are retained in accordance with their respective retention schedules (typically 90 days for crash logs and up to 14 months for high-level aggregate analytics) before automated deletion.

8. Your Privacy Rights

Under applicable data protection laws, you possess significant rights regarding your information:

• Access, Rectification and Erasure: You have the right to request access to any personal information we hold, to rectify errors, or request erasure. Since photo processing is strictly on-device, deleting the App instantly wipes all local project history.
• Permission Revocation: You can revoke photo library access at any time via iOS Settings > Cutout Studio > Photos.
• California Privacy Rights (CCPA / CPRA): We do not sell or share your personal information for monetary or other valuable consideration. We do not use sensitive personal information for inferring characteristics.
• Right to Lodge a Complaint: If you believe our processing infringes data protection laws, you have the right to file a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or your local supervisory authority.

9. Children's Privacy

The App is not directed to children under the age of 13 (or under 16 in the European Union). We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information without parental consent, please contact us at support@flashsoftapps.com so we can delete the information immediately.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our legal obligations, features, or architecture. Any revisions will be published on this page with an updated "Last Updated" date. Continued use of the App following the posting of modifications indicates your acknowledgement of the updated terms.

11. Contact Us

If you have any questions, inquiries, or privacy requests regarding Cutout Studio, please contact our Data Protection team: