Privacy Policy

1. Introduction

Crew-Clip (“Crew-Clip,” “we,” “us,” or “our”) is a service operated by X Inc., a company headquartered at Toranomon Hills Business Tower 15F, 1-17-1 Toranomon, Minato-ku, Tokyo 105-6415, Japan. This Privacy Policy describes how we collect, use, disclose, and otherwise process personal information in connection with the Crew-Clip website at crew-clip.com and the Crew-Clip services (collectively, the “Service”).

This Policy applies to personal information of users in the United States. Because our practices are designed to meet the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), we extend the rights and protections described here to all U.S. users. Residents of other U.S. states with comprehensive privacy laws may have similar rights, described in Section 11.

This Policy is a notice describing our data practices; it does not itself create contractual rights. Your use of the Service is governed by the applicable Master Services Agreement or Terms of Service between you and us, which contain the governing-law and dispute-resolution provisions.

2. Personal Information We Collect

Over the past 12 months, we have collected the following categories of personal information (as defined under the CCPA). Personal information includes business-contact information about individuals acting in a professional or employment capacity, which we treat as personal information subject to this Policy.

We do not intentionally collect Social Security numbers, government IDs, precise geolocation, biometric information, health information, or other sensitive personal information (see Section 12).

3. Sources of Personal Information

We collect personal information: directly from you (for example, when you register, complete forms, or contact support); automatically (for example, through cookies, logs, and usage data); from content that you or your organization upload to or create with the Service; and from third parties such as our payment processor and analytics providers.

4. How We Use Personal Information

We use personal information to provide, maintain, protect, and improve the Service; create and manage accounts and verify identity; process payments and billing; measure traffic and usage; respond to inquiries and provide support; detect, investigate, and prevent security incidents, fraud, and violations of our terms; comply with legal obligations; communicate changes to our terms and policies; and conduct first-party marketing and communications. We do not use personal information for materially different, unrelated purposes without providing notice.

5. How We Disclose Personal Information

We disclose personal information to the following categories of recipients:

• Service providers and contractors who process personal information on our behalf under written contracts that limit their use of the information, including cloud hosting and infrastructure providers (hosted in the United States), payment processors, analytics providers (configured so they act as service providers and do not use the data for their own purposes), customer-support tools, and third-party artificial-intelligence providers that perform translation, video generation, and voice processing. Our AI providers process content solely to deliver these features and do not use your content to train their models or for their own independent purposes.
• Other parties as required by law, to protect our rights, our users, or the public, or in connection with a corporate transaction such as a merger or acquisition.

6. Sale and Sharing of Personal Information

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We do not exchange personal information for monetary or other valuable consideration.

Because we do not sell or share personal information, we are not required to provide a “Do Not Sell or Share My Personal Information” link. We nonetheless respect opt-out preference signals as described in Section 7.

7. Cookies, Tracking Technologies, and Opt-Out Signals

We use strictly necessary cookies (for login, security, and core functionality) and analytics cookies (to understand how the Service is used). We do not use advertising or cross-context behavioral advertising cookies.

Do Not Track (DNT) and Global Privacy Control (GPC): Because browsers do not use a uniform standard for “Do Not Track,” our Service does not respond to DNT signals. We honor Global Privacy Control (GPC) signals. Since we do not sell or share personal information, there is no advertising-related data flow to suppress; where technically applicable, we treat a GPC signal as an opt-out preference.

8. De-identified and Aggregated Data

We may create and use de-identified or aggregated data that cannot reasonably be used to identify you. Such data is not personal information. We may use and retain de-identified or aggregated data for any lawful purpose, including analytics and improving the Service, and we will maintain it in de-identified form and will not attempt to re-identify it, except as permitted by law.

9. User-Generated Content

The Service allows you and your organization to upload or create content — including video, images, and audio — that may contain personal information of third parties, such as your employees or workers appearing in footage. You are responsible for obtaining all rights, permissions, and consents necessary from individuals who appear in or are identifiable from content you upload or create, and for ensuring that your use of the Service complies with applicable laws. With respect to such content, you act as the party that determines the purposes and means of processing (the business/controller), and we process the content on your behalf and in accordance with your instructions as a service provider.

10. Data Retention

We retain personal information only for as long as necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law. In general:

• Account and usage data: for the duration of your account.
• After account closure or cancellation: up to 90 days (to allow reactivation and data export), after which it is deleted or anonymized; we will delete it sooner upon a valid request.
• Billing, tax, and transaction records: up to 7 years, as required for financial and legal purposes.
• Server and security logs: approximately 90 days.
• Product analytics data: approximately 13 months, or in aggregated/anonymized form thereafter.
• User-generated content: for the duration of your account, and deleted within 90 days after account closure.

11. Your Privacy Rights and How to Exercise Them

Depending on your state of residence, you may have the right to know and access the personal information we have collected about you; delete your personal information; correct inaccurate personal information; obtain a portable copy of your personal information; opt out of the “sale” or “sharing” of your personal information (note: we do not sell or share — see Section 6); limit the use of sensitive personal information (we do not collect sensitive personal information — see Section 12); and not be discriminated against for exercising your rights.

How to submit a request. You may submit a request through our online request form at [request form URL], or email us at info@crew-clip.com. We will respond within 45 days (which may be extended by an additional 45 days where permitted). We may need to verify your identity before fulfilling certain requests.

Authorized agents. You may use an authorized agent to submit requests on your behalf. We may require the agent to submit written proof of authorization, and we may require you to verify your own identity directly with us or to confirm that you provided the agent permission to act on your behalf.

Appeals. If we decline to take action on your request, you may appeal our decision by contacting us at info@crew-clip.com within a reasonable time after receiving our response. We will respond to your appeal in writing within 45 days (extendable where permitted) and explain the reasons for our decision. If your appeal is denied, you may contact the attorney general in your state to submit a complaint.

12. Sensitive Personal Information

We do not collect or process sensitive personal information (such as Social Security numbers, precise geolocation, biometric information, or health information) for purposes that would require us to offer a “Limit the Use of My Sensitive Personal Information” option.

13. Children’s Privacy

The Service is intended for businesses and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it.

14. International Data Transfers

Crew-Clip is operated by X Inc., which is located in Japan. Personal information is hosted on cloud infrastructure located in the United States. Personnel of X Inc. located outside the United States, including in Japan, may access personal information to operate and support the Service. By using the Service, you understand that your personal information may be accessed from, and processed in, jurisdictions outside your own, including Japan.

15. Data Security

We maintain reasonable administrative, technical, and organizational measures designed to protect personal information, including access controls, encryption in transit and (where appropriate) at rest, and confidentiality obligations and training for personnel. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

16. California “Shine the Light”

California Civil Code Section 1798.83 permits California residents to request information about the disclosure of their personal information to third parties for those third parties’ own direct-marketing purposes. We do not disclose personal information to third parties for their own direct-marketing purposes.

17. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy with a revised “Effective Date,” and, where changes are material, we will provide additional notice (such as by email). We review this Policy at least once every 12 months.

18. Contact Us

If you have questions or requests regarding this Policy or your personal information, contact us at:

Appendix A — Notice at Collection

This short notice is provided at or before the point where we collect personal information (for example, at sign-up and via our cookie banner), as required by the CCPA. It summarizes the full Policy above.

• Categories we collect: identifiers; customer records; commercial information; internet/network activity; approximate (coarse) geolocation; audio/visual content you provide; professional/business-contact information; and inferences.
• Purposes: to provide, maintain, secure, and improve the Service; billing; support; analytics; legal compliance; and first-party marketing.
• Sale/Sharing: We do not sell or share your personal information.
• Sensitive personal information: We do not collect sensitive personal information.
• Retention: We keep personal information only as long as necessary for these purposes (see Section 10).
• More information: See the full Privacy Policy at [policy URL] or contact info@crew-clip.com.