Draft. This text is not finished. The company details are missing and no lawyer has read it yet, so nothing here can be relied on.
This statement explains what CutLink does with personal data. It is
written to be read, not to be survived. If something in it is unclear, write to
privacy@cutlink.studio and we will explain it
in plain words.
01Who we are
CutLink is a service of INVULLEN, registered in Nederland under
Chamber of Commerce number INVULLEN, at INVULLEN, INVULLEN.
For questions about your data, or to exercise any of the rights in section 10,
write to privacy@cutlink.studio.
02Two different roles
This is the part that people usually get wrong, so it comes first. CutLink
handles two kinds of data and our responsibility is different for each.
Your account is ours to answer for. Your name, your email
address, how you sign in, which plan you are on: we decide why we hold that and
what we do with it. In the language of the GDPR we are the controller,
and this statement covers it.
What you upload is yours to answer for. The films, stills,
designs and audio you put in a project, the names and email addresses of the
people you send a link to, and what those people write back: you decide that, not
us. We only store and show it because you asked us to. There we are the
processor and you are the controller. The
data processing agreement sets out that side, and it applies
automatically from the moment you create an account.
The practical consequence: if a client of yours asks us to delete something they
appear in, we will not decide that ourselves. We pass the request to you, because
it is your call.
03What we hold about account holders
As controller
| What | Why |
|---|
| Name and email address |
To give you an account, to show who did what inside a studio, and to
reach you about the service. |
|---|
| Password, stored as a hash |
To let you sign in. We never hold the password itself and cannot read
it. If you sign in with Google we hold no password at all, only the
account identifier Google gives us. |
|---|
| Profile photo and studio logo |
Only if you set one. If it came from your Google account we record that
fact so we do not fetch it again on every sign-in. |
|---|
| Session records |
A random session identifier, when it was created, when it expires, and
a shortened version of your browser's user-agent string. That last one
is there so you can recognise your own sessions and so we can spot a
session that does not look like you. |
|---|
| Your plan and payment status |
To know what your account may do. Card details never reach us; see
section 6. |
|---|
| Four answers about your work |
Only if you give them. When you first sign in we ask what you do, what
you deliver most, whether you work alone, and how you found us. It is
there so we know who our makers are and build for the right people, and
it may be used in aggregate to decide what to work on next. You can skip
it, change it, or empty it later under your profile. We do not ask what
you earn, what you charge, or who your clients are. |
|---|
04What we hold about people who open a delivery link
Someone who opens a link you sent does not have an account and does not create
one. What gets stored about them is limited to what the page needs to work:
- The name and email address you entered when you invited them, if you invited
them by email.
- The name they type next to a comment, and the comment itself.
- A record of which file was downloaded and when, with the country the request
came from. Not the full IP address.
For all of this you are the controller and we are the processor. We do not
profile these people, we do not build a picture of them across projects, and we do
not use anything they leave behind for anything other than showing it back to you
inside your own project.
05Cookies and similar techniques
CutLink sets no tracking cookies, runs no analytics, and carries no advertising
pixels. There are exactly two things stored in your browser:
| Name | What it does | How long |
|---|
cl_session |
Keeps you signed in. Marked HttpOnly,
Secure and SameSite=Lax, so no script can
read it and it is not sent along from other sites. |
30 days |
|---|
cl_lang |
Remembers which language you chose. Stored in the browser itself, never
sent to us. |
Until you clear your browser data |
|---|
Both are strictly necessary for a function you asked for, so under article
11.7a of the Dutch Telecommunications Act no consent is required, and that is why
you will not find a cookie banner on this site. We host our own typefaces rather
than loading them from a font service, so opening a page on
cutlink.studio does not hand your IP address to a third party.
The sign-in page is the one exception: it loads Google's sign-in code, because
that is what makes the Google button work. That page does nothing until you click
something.
06Who else touches the data
We keep this list short on purpose. Every name here is a company we have to
trust, so there are as few as we can manage.
| Who | What for | Where |
|---|
| Cloudflare |
Hosting, the database, and storage of the uploaded files. |
Files and database in Western Europe. |
|---|
| Google |
Only for signing in with a Google account, and only if you choose that. |
United States, under the EU-US Data Privacy Framework. |
|---|
| Resend |
Sending the emails the service produces: an invitation to a delivery
page, a notification that feedback came in. |
European Union. |
|---|
| Stripe |
Payment. Card details go straight to Stripe and never pass through our
systems. |
United States, under the EU-US Data Privacy Framework. |
|---|
We do not sell data, we do not trade it, and we do not hand it to anyone else
unless a Dutch court or a law obliges us to.
07Where it is stored
The files you upload sit in object storage with its location set to Western
Europe. The database with projects, accounts and comments runs in the same region.
Neither is reachable from the public internet: a file can only be fetched through
a link that our own code hands out.
08How long we keep it
- Sessions expire after 30 days, or immediately when you sign
out.
- Projects on the free plan stay up for seven days. After that
the link stops working and the files are removed.
- Projects on a paid plan stay up for as long as you say, and
are removed when you remove them or when you stop paying and the grace period
in the terms has passed.
- Your account stays until you delete it. Deleting it removes
your projects and files with it.
- Invoices we have to keep for seven years. Dutch tax law
leaves us no choice there.
09How it is protected
- Everything travels over TLS. There is no unencrypted route in.
- Passwords are stored as a hash with a per-account salt, so a copy of the
database does not hand anyone a password.
- The file storage is not public. Every download goes through our code, which
checks that the link is valid and has not expired.
- A delivery link can be given a password and an expiry date.
- A link that is guessed at repeatedly locks itself for a while.
No system is beyond reach. If something does go wrong and your data is involved,
we will tell you, and where the law requires it we will report it to the Dutch
Data Protection Authority within 72 hours.
10What you can ask of us
Under the GDPR you may ask to see what we hold about you, to have it corrected,
to have it deleted, to have it handed to you in a portable form, to restrict what
we do with it, and to object to it. Write to
privacy@cutlink.studio and you will hear from us
within a month, usually a good deal sooner.
If you think we are handling this badly, we would rather hear it from you first.
You also have the right to complain to the Autoriteit Persoonsgegevens, the Dutch
Data Protection Authority, at autoriteitpersoonsgegevens.nl.
11Changes
If this statement changes in a way that matters, we will email account holders
before it takes effect. Smaller corrections we simply make, and the version number
and date at the top of this page will tell you when.