=================================================================== --- 20260201_rev01 +++ 20260303_rev01 @@ -5,13 +5,13 @@ ## Introduction Welcome to CapCut. This Privacy Policy applies to the CapCut mobile software application ("CapCut APP"), software applications deployed on the desktop ("CapCut Desktop version"), and the oﬃcial CapCut website ("CapCut Web"), and any other website or platform that links to this Privacy Policy (collectively, the "**Services**"). This Privacy Policy also explains how we collect, use, share, and otherwise process the personal information of users and other individuals in connection with our Services. The Services are provided and controlled by Bytedance Pte. Ltd. with its registered address at 1 Raﬄes Quay, #26-10, South Tower, Singapore 048583 ("we" "us" or "our") unless otherwise indicated in the [Supplemental Terms - Jurisdiction Speciﬁc]() section to your region. -- **I. What Information We Collect** +**1\. What Information We Collect** We may collect the following information about you: ### Information You Provide Account Information. You give us information when you register on the Services, such as your date of birth, your email address and the corresponding password you set for your CapCut account, your phone number, your accounts on other social network services (where applicable), and other information you choose to disclose in your user proﬁle, such as gender. @@ -47,45 +47,33 @@ Third-Party Services. Where available, and if you choose to sign-up or log-in to the Services using a third-party service such as Apple, Facebook, Google, or TikTok, such services provide us with information such as your proﬁle information, including your username, email, and proﬁle picture. Depending on the service provided, these third party services may also share information about your use of that service. Our Corporate Group. We may obtain information about you from certain affiliated entities within our corporate group, including about your activities on their platform. Others. We may receive information about you from others, for example, where you are included or mentioned in User Content, in a complaint, appeal, request or feedback submitted by a user or third party, or if your contact information is provided to us by a user. -- **II. How We Use Your Information** +**2\. How We Use Your Information** We will use your information in order to: -● verify your age and identity; +- verify your age and identity; +- administer and provide you with the Services, including to enable you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Services, when you choose to do so; to provide services to you through related products that are connected in functionality. Some products may not be available in your region. In order to ensure a consistent service experience and to guarantee interconnection between products, these related products use a unified account service to collectively collect and process your account information across these products. The account you register for using CapCut will +- allow you to use a unified account service to use related products and access these services. +- promote your content to other users; +- communicate with you, including to notify you about changes to the Services; +- provide you with tailored or personalized information or content that may be of interest to you, such as marketing communications in accordance with your preferences; +- enforce our [Terms of Service](http://www.capcut.com/clause/terms-of-service), [Community Guidelines](https://www.capcut.com/clause/community-guideline), and other conditions and policies; +- respond to, handle and process queries, requests, applications, complaints, and feedback from you; +- improve and develop the Services by ensuring tools on the Services are presented in the most effective manner for you and your device, and by training and improving our technology, such as our machine learning models and algorithms; +- administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; +- detect abuse, fraud, and illegal activity on the Services and ensure your safety and security, including scanning, analyzing, and reviewing User Content, and associated metadata for violations of our [Terms of Service](http://www.capcut.com/clause/terms-of-service), [Community Guidelines](https://www.capcut.com/clause/community-guideline), and other conditions and policies, if permitted by applicable law; +- provide advertising services, including to serve advertising (including personalized advertising, where permitted) and to measure and understand the effectiveness of advertising; and +- comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people. -● administer and provide you with the Services, including to enable you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Services, when you choose to do so; - -to provide services to you through related products that are connected in functionality. Some products may not be available in your region. In order to ensure a consistent service experience and to guarantee interconnection between products, these related products use a unified account service to collectively collect and process your account information across these products. The account you register for using CapCut will ● allow you to use a unified account service to use related products and access these services. - -● promote your content to other users; - -● communicate with you, including to notify you about changes to the Services; - -● provide you with tailored or personalized information or content that may be of interest to you, such as marketing communications in accordance with your preferences; - -● enforce our [Terms of Service](http://www.capcut.com/clause/terms-of-service), [Community Guidelines](https://www.capcut.com/clause/community-guideline), and other conditions and policies; - -● respond to, handle and process queries, requests, applications, complaints, and feedback from you; - -● improve and develop the Services by ensuring tools on the Services are presented in the most effective manner for you and your device, and by training and improving our technology, such as our machine learning models and algorithms; - -● administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; - -● detect abuse, fraud, and illegal activity on the Services and ensure your safety and security, including scanning, analyzing, and reviewing User Content, and associated metadata for violations of our [Terms of Service](http://www.capcut.com/clause/terms-of-service), [Community Guidelines](https://www.capcut.com/clause/community-guideline), and other conditions and policies, if permitted by applicable law; - -● provide advertising services, including to serve advertising (including personalized advertising, where permitted) and to measure and understand the effectiveness of advertising; and - -● comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people. - We may also use your information for any other purposes disclosed to you at the time we collect your information, with your consent, or as otherwise permitted by applicable law. -- **III.How We Share Your Information** +**3\. How We Share Your Information** This section sets out how we may share your information, including [Information You Provide](), [Automatically Collected Information](), and [Information From Other Sources](), with third parties. **Service Providers and Business Partners** We may share the categories of personal information listed above, with our service providers and business partners in order to provide you with the Services for the purposes as set out in this Policy. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payment. For example, we may share your personal information with: @@ -115,67 +103,63 @@ We may share information collected through the use of our Services and information about how those ads performed (such as views, engagement, and clicks) with measurement and advertising partners to help measure the eﬀectiveness of advertising campaigns. We may also share aggregate reports about the performance of ad campaigns with advertisers. **Legal Obligations and Rights** We may share the types of information we collect with law enforcement agencies, public authorities, or other entities if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: -● comply with any applicable laws, regulations, codes of practice, governmental guidelines, or other legal and regulatory obligations, as consistent with internationally recognised standards; +- comply with any applicable laws, regulations, codes of practice, governmental guidelines, or other legal and regulatory obligations, as consistent with internationally recognised standards; +- enforce our [Terms of Service](http://www.capcut.com/clause/terms-of-service) and other agreements, policies, and standards, including investigation of any potential violation thereof; +- exercise or defend any legal claims, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries; +- detect, prevent or otherwise address security, fraud or technical issues; or +- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection). -● enforce our [Terms of Service](http://www.capcut.com/clause/terms-of-service) and other agreements, policies, and standards, including investigation of any potential violation thereof; - -● exercise or defend any legal claims, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries; - -● detect, prevent or otherwise address security, fraud or technical issues; or - -● protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection). - **Sale or Merger** We may also disclose your information to third parties: in the event that we sell any business or assets, in which case we may disclose your information to the prospective buyer of such business or assets; or if we sell, buy, merge with, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your user information may be among the transferred assets. **With Your Consent** We may share information with third parties with your consent or at your direction. -- **IV. International Data Transfers** +**4\. International Data Transfers** The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in Malaysia, Singapore and the United States. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws. Entities with whom we may share your data as described herein may be located outside of your country of residence. -- **V. Your Rights and Choices** +**5\. Your Rights and Choices** On some versions of the Services, you can access, view, and edit most of your proﬁle information by signing into your account, and you may also be able to control how you use the Services by visiting your in-app settings, including to decide whether you see certain types of advertising on the Services or to manage third-party services that are linked to your account. When the in-app setting is not available in your country, you may decide whether you see certain types of advertising on the Services by contacting us using the methods listed in the "Contact Us" section below, or using any other contact information applicable to your country. If you choose to login, sign up, or link to a third-party service, such as Apple, Facebook, Google, TikTok, or Youtube, you may be able to manage the type of data shared with CapCut through that service's settings. Further, your device may have controls that determine what information we collect.. You can also opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in marketing or advertising emails. As discussed further in the [Supplemental Terms - Jurisdiction Speci]()[ﬁ]()[c](), you may also be aﬀorded rights in your country under applicable laws, such as the ability to access your data, delete your data, be informed of the use of your data, revoke your consent, and ﬁle a complaint before the relevant authority. If you have any questions on how to use your in-app settings or want to know about any rights with regard to your personal information you may have in the country where you live, please contact us using the methods listed in the "Contact Us" section below and we will respond as required under applicable laws. -- **VI. Data Security** +**6\. Data Security** We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your information transmitted via the Services. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modiﬁcation, or loss. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems. We will, from time to time, include links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites. -- **VII. Data Retention** +**7\. Data Retention** We take steps to ensure that your information is retained for as long as it is necessary to provide you with the Services and for the other purposes set out in this Privacy Policy. If you choose to use the CapCut Cloud Space Service, we will delete the content or information you have actively uploaded and stored in the CapCut Cloud Space Service at your request and as otherwise permitted by law or regulation. We retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Services, and enhancing its safety, security and stability), to protect the rights of others, and for the exercise or defense of legal claims. -- **VIII. Information Relating to Minors** +**8\. Information Relating to Minors** CapCut is not directed at minors under the age of 13. The minimum age to use the Services may differ depending on the country or region you are in. If you believe that we have collected personal information from a minor under the minimum age, please contact us using the contact information found in the "Contact Us" section below. -- **IX. Privacy Policy Updates** +**9\. Privacy Policy Updates** We may amend or update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you of any material changes to this policy by updating the "Last Updated" date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing other notice required by applicable law. We recommend that you review this policy regularly to stay informed of our privacy practices. -- **X. Contact Us** +**10\. Contact Us** Questions, comments and requests regarding this Policy are welcomed and should be addressed to: \- Contact us: [Online](https://www.capcut.com/privacy-requests) or capcut.support@bytedance.com. \- Mailing Address: @@ -203,32 +187,26 @@ If you are using our Services in Brazil, the following additional terms apply: Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to beneﬁt from the mentioned rights. We will respond and/or fulﬁll your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD: -● conﬁrmation of whether your data are being processed; +- conﬁrmation of whether your data are being processed; +- access to your data; +- correction of incomplete, inaccurate or outdated data; +- anonymization, blocking or erasure of data; +- portability of personal data to a third party; +- object to the processing of personal data; +- information of public and private entities with which we shared data; -● access to your data; +information about the possibility to refuse providing personal data and the respective -● correction of incomplete, inaccurate or outdated data; +- withdraw consequences, when applicable; +- withdrawal of your consent; +- request an analysis of decisions taken exclusively based on the automated processing of personal data that aﬀect your interests, including decisions taken to deﬁne your personal, professional, consumer or credit proﬁle, or aspects of your personality. -● anonymization, blocking or erasure of data; - -● portability of personal data to a third party; - -● object to the processing of personal data; - -● information of public and private entities with which we shared data; - -information about the possibility to refuse providing personal data and the respective ● withdraw consequences, when applicable; - -● withdrawal of your consent; - -● request an analysis of decisions taken exclusively based on the automated processing of personal data that aﬀect your interests, including decisions taken to deﬁne your personal, professional, consumer or credit proﬁle, or aspects of your personality. - Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request speciﬁc information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and ﬁnally responding to your request. Limitations to your rights. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulﬁll your request. In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them. @@ -261,13 +239,13 @@ ### European Economic Area ("EEA"), Switzerland, and UK If you are using the Services in the EEA, Switzerland or the UK (the "European Region"), the following additional terms apply: Legal bases for processing. We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below. -

Personal Information categories and processing purpose	Legal Basis
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to enable us to administer and provide you with the Services including enabling you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Services, when you choose to do so; We also use this information to promote content or to provide you with tailored or personalized information or content that may be of interest to you.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to provide, support, and maintain products and features that enable users who can't enter into an enforceable contract with us to communicate, discover, and engage with content and express themselves. We also rely on the legitimate interest of our users in being able to access the platform in an easy and intuitive manner.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services, including Image and Audio Information and Auto-Caption Text; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to understand how you use the Services, and to improve and develop the Services, including to train and improve our technology, such as our machine learning models and algorithms.	The processing is necessary for our legitimate interests, namely, to improve and develop the Services.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, and share such information with advertising partners, for example: ● information collected when you use our Services; ● your location; and ● from your device or app to provide you with personalized advertising based on your combined activity on and off the Services, including across unaffiliated apps and websites.	We or our advertising partners ask for your consent to serve you with personalized advertising. You can withdraw your consent for personalized advertising by navigating to your in-app settings through the settings icon, selecting "ad network preferences" and clicking "Do Not Consent." Your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent.
We use the Information You Provide and Automatically Collected Information, and share such information with advertising partners to provide you with non-personalized advertising. We or our advertising partners may show users non-personalized advertising, including those who have chosen not to receive personalized ads.	We or our advertising partners serve you non-personalized advertising. This processing is necessary for our legitimate interests, namely to show non-personalised ads to keep the Services free of charge.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, and share such information with our measurement and advertising partners, to measure and understand the effectiveness of advertising served on the Services, and help our advertisers determine how effective their ads have been.	This processing is necessary for our legitimate interests, namely to grow our business and to enable us, advertisers, and our measurement and advertising partners to understand how ads performed and the audience that viewed or interacted with their ads. This is so that they can make informed decisions (such as what kinds of ad campaigns they may want to run, the type of audience they want to reach and the types of ads that users enjoy the most). This helps keep the advertising we show users relevant and entertaining, and keeps the Services free for all users.
The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.	This processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR. In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when contacting us; and ● from your device or app to communicate with you, on service related matters, respond to and process your queries, requests, applications, complaints, and feedback, and notify you about changes to the Services, including changes to our terms and policies.	The processing is necessary for the performance of a contract with you. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to share meaningful updates with our users who can't enter into an enforceable contract with us about service-related matters, and process their queries, claims and disputes.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● User Content and other information n collected when you use our Services; ● your location; and ● from your device or app. We may use this information to send you marketing communications in accordance with your preferences.	The processing is necessary for our legitimate interests, namely to promote new developments and features of our Services. We will obtain your consent to send you messages where required by law.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, singing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to enforce our Terms of Service, Community Guidelines, and other conditions and policies, including to ensure that you are old enough to use the Services.	The processing is necessary for the performance of a contract with you. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to share meaningful updates with our users who can't enter into an enforceable contract with us about service-related matters, and process their queries, claims and disputes.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, singing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your Location; ● when contacting us; ● from other sources; and ● from your device or app to detect abuse, fraud, illegal activity, to ensure your safety and security, including scanning, analysing and reviewing User Content and associated metadata for violations of our Terms of Service, Community Guidelines, and other conditions and policies, if permitted by applicable law. We may also use this information to conduct troubleshooting, data analysis, testing, and research.	The processing is necessary for our legitimate interests, namely, to ensure that the Services are safe and secure, to ensure compliance with our Terms of Service, Community Guidelines, and to identify misuse of the Services; and to ensure the ongoing stability and security of the Services and to ensure it is continuously available and functioning.
In some cases, we may aggregate or anonymize the Information You Provide, Automatically Collected Information, and Information from Other Sources, and use it in a way that is designed to be unable to identify you, for research, statistical, or other purposes, to the extent allowed by applicable law.	The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymization, consistent with data minimization and privacy by design principles.
We may use the Information You Provide, Automatically Collected Information, and Information From Other Sources, where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.	The processing is necessary to protect the vital interests of you or other individuals.
We may use Information You Provide, Automatically Collected Information, and Information From Other Sources, for any other purposes authorized by you. The actual information we use depends on the factual circumstances.	The processing is necessary to protect the vital interests of you or other individuals.

Personal Information categories and processing purpose	Legal Basis
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to enable us to administer and provide you with the Services including enabling you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Services, when you choose to do so; We also use this information to promote content or to provide you with tailored or personalized information or content that may be of interest to you.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to provide, support, and maintain products and features that enable users who can't enter into an enforceable contract with us to communicate, discover, and engage with content and express themselves. We also rely on the legitimate interest of our users in being able to access the platform in an easy and intuitive manner.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services, including Image and Audio Information and Auto-Caption Text; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to understand how you use the Services, and to improve and develop the Services, including to train and improve our technology, such as our machine learning models and algorithms.	The processing is necessary for our legitimate interests, namely, to improve and develop the Services.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, and share such information with advertising partners, for example: ● information collected when you use our Services; ● your location; and ● from your device or app to provide you with personalized advertising based on your combined activity on and off the Services, including across unaffiliated apps and websites.	We or our advertising partners ask for your consent to serve you with personalized advertising. You can withdraw your consent for personalized advertising by navigating to your in-app settings through the settings icon, selecting "ad network preferences" and clicking "Do Not Consent." Your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent.
We use the Information You Provide and Automatically Collected Information, and share such information with advertising partners to provide you with non-personalized advertising. We or our advertising partners may show users non-personalized advertising, including those who have chosen not to receive personalized ads.	We or our advertising partners serve you non-personalized advertising. This processing is necessary for our legitimate interests, namely to show non-personalised ads to keep the Services free of charge.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, and share such information with our measurement and advertising partners, to measure and understand the effectiveness of advertising served on the Services, and help our advertisers determine how effective their ads have been.	This processing is necessary for our legitimate interests, namely to grow our business and to enable us, advertisers, and our measurement and advertising partners to understand how ads performed and the audience that viewed or interacted with their ads. This is so that they can make informed decisions (such as what kinds of ad campaigns they may want to run, the type of audience they want to reach and the types of ads that users enjoy the most). This helps keep the advertising we show users relevant and entertaining, and keeps the Services free for all users.
The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, signing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.	This processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR. In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when contacting us; and ● from your device or app to communicate with you, on service related matters, respond to and process your queries, requests, applications, complaints, and feedback, and notify you about changes to the Services, including changes to our terms and policies.	The processing is necessary for the performance of a contract with you. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to share meaningful updates with our users who can't enter into an enforceable contract with us about service-related matters, and process their queries, claims and disputes.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● User Content and other information n collected when you use our Services; ● your location; and ● from your device or app. We may use this information to send you marketing communications in accordance with your preferences.	The processing is necessary for our legitimate interests, namely to promote new developments and features of our Services. We will obtain your consent to send you messages where required by law.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, singing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your location; ● when contacting us; ● from other sources; and ● from your device or app to enforce our Terms of Service, Community Guidelines, and other conditions and policies, including to ensure that you are old enough to use the Services.	The processing is necessary for the performance of a contract with you. If you are under the age of majority (under 18 in most relevant countries), with a limited ability to enter into an enforceable contract only, where we may be unable to process your information on the grounds of contractual necessity, we rely on legitimate interests. Namely, to share meaningful updates with our users who can't enter into an enforceable contract with us about service-related matters, and process their queries, claims and disputes.
We use the Information You Provide, Automatically Collected Information, and Information From Other Sources, for example: ● when registering an account; ● when logging in, singing up, or linking to our Services via third party accounts; ● User Content and other information collected when you use our Services; ● your Location; ● when contacting us; ● from other sources; and ● from your device or app to detect abuse, fraud, illegal activity, to ensure your safety and security, including scanning, analysing and reviewing User Content and associated metadata for violations of our Terms of Service, Community Guidelines, and other conditions and policies, if permitted by applicable law. We may also use this information to conduct troubleshooting, data analysis, testing, and research.	The processing is necessary for our legitimate interests, namely, to ensure that the Services are safe and secure, to ensure compliance with our Terms of Service, Community Guidelines, and to identify misuse of the Services; and to ensure the ongoing stability and security of the Services and to ensure it is continuously available and functioning.
In some cases, we may aggregate or anonymize the Information You Provide, Automatically Collected Information, and Information from Other Sources, and use it in a way that is designed to be unable to identify you, for research, statistical, or other purposes, to the extent allowed by applicable law.	The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymization, consistent with data minimization and privacy by design principles.
We may use the Information You Provide, Automatically Collected Information, and Information From Other Sources, where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.	The processing is necessary to protect the vital interests of you or other individuals.
We may use Information You Provide, Automatically Collected Information, and Information From Other Sources, for any other purposes authorized by you. The actual information we use depends on the factual circumstances.	The processing is necessary to protect the vital interests of you or other individuals.

International data transfers. If you normally reside in the European Region, the personal data that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we may store the information that we collect in secure servers located in the United States, Malaysia, and Singapore. When we transfer your information outside of the European Region, we ensure it beneﬁts from an adequate level of data protection by relying on: Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country oﬀers an adequate level of data protection. We transfer your information to some countries with adequacy decisions; or @@ -419,22 +397,18 @@ How we share your information. In addition to the main text of this policy, in the event we use information such as User Content and video content on our Services as part of our advertising and marketing campaigns to promote the Services, your personal information contained in such information may be disclosed to the recipients of such advertising or marketing content. Personalized Ads. We may from time to time provide personalized ads on our Services to provide you our Services for free. Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in the Policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to: Act on Consumer Protection in Electronic Commerce: -● Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years +- Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years +- Records on the handling of consumer complaints or disputes: 3 years +- Records on advertisements and labels: 6 months +- Protection of Communications Secrets Act +- Records on your visits to our website: 3 months -● Records on the handling of consumer complaints or disputes: 3 years - -● Records on advertisements and labels: 6 months - -● Protection of Communications Secrets Act - -● Records on your visits to our website: 3 months - Destruction of Personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department. Your Rights. Data Rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us through [Data Subject Request Webform](https://www.capcut.com/privacy-requests) or capcut.support@bytedance.com. @@ -449,44 +423,31 @@ If you are using our Services in Türkiye, the following additional terms apply: Data Controller Representative. You may contact our data controller representative in Türkiye by email to handle questions and complaints in connection with the processing of your personal data if you are in Türkiye. Legal bases for processing your personal data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data: -● processing is explicitly laid down or dictated by laws +- processing is explicitly laid down or dictated by laws +- processing of your personal data is necessary provided that it is directly related to the conclusion or fulﬁllment of the contract between us +- processing is mandatory for us to be able to comply with our legal obligations +- the relevant data is made available to the public by yourself +- processing is mandatory for the establishment, exercise, or protection of a right +- processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms +- your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above) -● processing of your personal data is necessary provided that it is directly related to the conclusion or fulﬁllment of the contract between us - -● processing is mandatory for us to be able to comply with our legal obligations - -● the relevant data is made available to the public by yourself - -● processing is mandatory for the establishment, exercise, or protection of a right - -● processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms - -● your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above) - Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data: -● the right to learn whether we process your personal data, +- the right to learn whether we process your personal data, +- the right to request information with regard to such processing, if we process your personal data, the right to learn the purposes of the processing and whether they are used for such purpose or not; +- the right to know the third parties within or outside the country, to whom we transfer your personal data, +- the right to request correction of incomplete or inaccurate personal data, +- the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law, +- the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items, +- the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means, +- the right to claim indemniﬁcation for damages incurred due to illegal processing of your personal data. -● the right to request information with regard to such processing, if we process your personal data, the right to learn the purposes of the processing and whether they are used for such purpose or not; - -● the right to know the third parties within or outside the country, to whom we transfer your personal data, - -● the right to request correction of incomplete or inaccurate personal data, - -● the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law, - -● the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items, - -● the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means, - -● the right to claim indemniﬁcation for damages incurred due to illegal processing of your personal data. - If you would like to exercise your rights, please contact us through [Data Subject Request Webform](https://www.capcut.com/privacy-requests) or capcut.support@bytedance.com. The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariﬀ fee determined by the Turkish Personal Data Protection Board. Language. This policy is available in English and Turkish. If there is any inconsistency or diﬀerent interpretation between the English and Turkish versions, the Turkish text shall prevail.

CapCut Privacy Policy

Full text changes — 20260201_rev01 to 20260303_rev01