Privacy Policy

A legal disclaimer

This Privacy Policy describes how TM Media LLC, doing business as Rough Cut ("Rough Cut," "we," "us," or "our"), collects, uses, processes, stores, discloses, and protects information in connection with the Rough Cut website, desktop application, integrations, APIs, AI-powered features, subscriptions, communications, and related products and services collectively referred to as the "Services."

By accessing or using the Services, you acknowledge the practices described in this Privacy Policy.

This Privacy Policy should be read together with our Terms of Service and any other notices presented when information is collected.

1. SCOPE

This Privacy Policy applies to personal information processed through Rough Cut, including information collected through:

• the Rough Cut website;

• the Rough Cut desktop application;

• account creation and authentication;

• subscription and trial enrollment;

• customer support;

• software licensing;

• analytics and diagnostic systems;

• integrations with video-editing applications;

• AI-powered media analysis;

• uploaded or locally selected media;

• APIs and backend infrastructure; and

• communications between users and Rough Cut.

This Policy does not govern third-party products, websites, or services that maintain their own privacy policies, except to the extent Rough Cut itself receives or processes information from them.

2. INFORMATION WE MAY COLLECT

We seek to collect only information reasonably necessary and proportionate to provide, secure, maintain, improve, and administer the Services.

Depending on how you interact with Rough Cut, we may collect the following categories.

A. Account and Identity Information

This may include:

• name;

• email address;

• username;

• account identifier;

• license identifier;

• subscription status;

• authentication information;

• organization or company name; and

• information you voluntarily provide to us.

We do not need or intentionally request government identification numbers, Social Security numbers, health information, biometric identifiers, or similarly sensitive information for ordinary use of Rough Cut.

B. Payment and Subscription Information

When you purchase a subscription, payment information may be processed by our payment processor.

Rough Cut may receive transaction-related information such as:

• subscription plan;

• payment status;

• transaction identifier;

• billing date;

• renewal date;

• last four digits or payment-method descriptor where supplied by the processor; and

• other transaction metadata.

We do not intend to directly store complete payment-card numbers or card security codes when those are handled by a third-party payment processor.

C. Video, Audio and Other User Content

Rough Cut is an AI-assisted video-editing product. Accordingly, users may select, submit, transmit, or otherwise make available:

• video files;

• audio files;

• images;

• extracted video frames;

• thumbnails;

• transcripts;

• captions;

• filenames;

• file metadata;

• timecodes;

• project information;

• editing instructions;

• prompts;

• clip descriptions;

• timeline information;

• media-analysis results; and

• other content necessary to perform requested editing or analysis operations.

We refer to this collectively as "User Content."

Depending upon the feature used, Rough Cut may process all or portions of User Content locally on your device, through Rough Cut-operated infrastructure, or through third-party service providers acting on our behalf.

D. AI Inputs and Outputs

Rough Cut uses artificial intelligence and machine-learning technologies as part of its Services.

Information processed by AI systems may include:

• selected video frames;

• portions of video;

• audio;

• transcripts;

• prompts;

• editing instructions;

• metadata;

• scene descriptions;

• clip classifications;

• timestamps; and

• other information necessary to provide the requested feature.

AI systems may generate information such as clip classifications, scene descriptions, transcripts, editing recommendations, selections, timelines, scores, and other analysis.

Rough Cut does not represent that AI-generated results are always accurate.

E. Device and Technical Information

We may automatically collect information such as:

• IP address;

• operating system;

• application version;

• browser type;

• device type;

• language;

• timestamps;

• crash information;

• error messages;

• diagnostic information;

• installation information;

• session information;

• API activity; and

• general technical information necessary to operate and secure the Services.

F. Usage Information

We may collect information concerning how the Services are used, including:

• features accessed;

• actions performed;

• processing requests;

• token or usage consumption;

• application events;

• errors;

• performance metrics;

• session activity; and

• interaction with our website or application.

G. Communications

If you contact us, we may retain your message and related information, including correspondence concerning:

• support requests;

• bug reports;

• billing;

• feature requests;

• complaints;

• privacy requests; and

• other communications.

3. INFORMATION WE DO NOT NEED

Rough Cut follows a principle of data minimization.

We do not intentionally request personal information that is unrelated to providing the Services.

Users should not provide sensitive personal information unless it is genuinely necessary for content they are editing.

The current California framework expressly incorporates purpose limitation and data minimization: covered businesses must limit collection, use, and retention to reasonably necessary and proportionate purposes. California Privacy Protection Agency

4. HOW WE COLLECT INFORMATION

We may collect information:

Directly from you, such as when you register, purchase a subscription, contact support, submit a form, or provide User Content.

Automatically, through the website, application, server infrastructure, logs, cookies, SDKs, or similar technologies.

From service providers, such as payment processors, authentication providers, analytics providers, infrastructure providers, and AI providers.

Through integrations, when you authorize Rough Cut to interact with compatible software or services.

We will not intentionally begin collecting a materially different category of personal information for an incompatible purpose without providing additional notice where required by applicable law.

California's 2026 regulations specifically require covered businesses to provide a new Notice at Collection before collecting additional categories or using information for incompatible purposes in circumstances governed by the CCPA. California Privacy Protection Agency

5. HOW WE USE INFORMATION

We may process information to:

• provide Rough Cut;

• analyze media at the user's request;

• generate edits, selections, transcripts, classifications, or other outputs;

• communicate with compatible editing software;

• authenticate accounts;

• issue and validate software licenses;

• administer trials and subscriptions;

• calculate usage and token consumption;

• process transactions;

• prevent unauthorized use;

• detect abuse, fraud, or security threats;

• diagnose crashes and software errors;

• provide customer support;

• maintain and improve performance;

• understand aggregate product usage;

• develop or evaluate features;

• comply with applicable law;

• enforce our agreements;

• protect Rough Cut, our users, and others; and

• establish, exercise, or defend legal claims.

We will not use personal information for materially incompatible purposes without providing notice or obtaining consent when required by law.

6. ARTIFICIAL INTELLIGENCE

Rough Cut uses artificial intelligence as a core component of the Services.

When a user requests an AI-powered function, relevant User Content may be processed by Rough Cut and, where necessary, transmitted to third-party AI or infrastructure providers.

For example, portions of footage may be converted into frames, audio may be transcribed, and those materials may be analyzed by AI systems to identify or describe content and assist with editing.

We seek to transmit only information reasonably necessary to perform the requested operation.

Where third-party AI providers process information on Rough Cut's behalf, their processing may also be subject to contractual terms governing their services.

We do not authorize our service providers to independently use Rough Cut customer content for unrelated purposes merely because they receive it while providing services to Rough Cut.

Important: Rough Cut's production configuration and contracts with each AI provider must actually support the statement above. If a provider is permitted to train its models on customer content, this section must be changed.

7. THIRD-PARTY SERVICE PROVIDERS

Rough Cut may use third-party companies to perform functions necessary to operate the Services.

Categories may include:

• artificial-intelligence/model providers;

• cloud-computing providers;

• hosting and storage providers;

• authentication providers;

• payment processors;

• email providers;

• software licensing providers;

• error-monitoring providers;

• analytics providers;

• security providers;

• customer-support systems; and

• infrastructure providers.

These companies may process information only to the extent reasonably necessary to provide their respective services, subject to their contractual obligations and applicable law.

We periodically evaluate third-party SDKs and integrations and seek to avoid unnecessary collection of personal information.

Before publishing this policy, Rough Cut should maintain an internal vendor list identifying every production SDK/service and exactly what data each receives.

8. USER CONTENT AND OWNERSHIP

Your use of Rough Cut does not transfer ownership of your original User Content to Rough Cut.

Rough Cut processes User Content only as permitted by our agreements and as reasonably necessary to provide and operate the Services or as otherwise disclosed to you.

Nothing in this Privacy Policy grants Rough Cut ownership of a customer's original footage, audio, photographs, or other underlying creative material.

9. RETENTION AND DELETION OF UPLOADED MEDIA

Rough Cut seeks to retain User Content only for as long as reasonably necessary for the purpose for which it was processed, unless longer retention is required or permitted by law.

Temporary files, extracted frames, audio, intermediate processing files, or other media transmitted to Rough Cut's infrastructure should be deleted after the applicable processing operation or after a limited operational retention period.

Certain information may remain longer where necessary for:

• security;

• fraud prevention;

• backups;

• billing;

• dispute resolution;

• legal compliance;

• enforcing agreements; or

• establishing or defending legal claims.

Deletion from active systems may not immediately remove information from encrypted backups. Backup copies may remain until overwritten according to normal backup cycles.

Before this goes live, your developers need to establish an actual retention schedule. Do not advertise "we immediately delete uploads" unless you can prove that your storage, logs, AI-provider retention, temporary directories, backups, and processing infrastructure actually do so.

10. SECURITY

We use administrative, organizational, and technical safeguards designed to protect information against unauthorized access, destruction, alteration, disclosure, or misuse.

Depending on the relevant system, safeguards may include:

• encrypted network connections;

• access controls;

• authentication;

• least-privilege access;

• restricted production credentials;

• secure credential management;

• monitoring and logging;

• infrastructure security controls; and

• reasonable vendor-security practices.

User uploads and storage locations intended to contain private customer media should not be configured as publicly accessible storage buckets.

No electronic system is completely secure. Therefore, we cannot guarantee absolute security.

Users are responsible for protecting their account credentials and should notify us promptly if they believe their account has been compromised.

11. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies or similar technologies for purposes including:

• authentication;

• security;

• remembering preferences;

• maintaining sessions;

• essential website functionality;

• analytics; and

• measuring website performance.

Where required by applicable law, non-essential cookies will not be activated until appropriate consent has been obtained.

Users must be provided appropriate mechanisms to accept or reject non-essential cookies where required.

Rough Cut should not design consent mechanisms to manipulate users into accepting optional tracking.

12. COOKIE CONSENT

Where legally required, Rough Cut will provide a cookie-consent interface allowing users to make applicable choices regarding non-essential technologies.

Rejecting optional cookies should be reasonably as accessible as accepting them.

Changing or withdrawing consent should also be reasonably accessible.

13. DO NOT TRACK AND GLOBAL PRIVACY CONTROL

Some browsers provide "Do Not Track" signals. Because there is not a universally applied standard for all such signals, our response may depend upon the signal and applicable law.

Where required, Rough Cut will recognize legally applicable opt-out preference signals, including qualifying Global Privacy Control (GPC) signals.

California specifically requires covered businesses to honor qualifying opt-out preference signals as requests to opt out of sale/sharing. California Privacy Protection Agency

14. SALE AND SHARING OF PERSONAL INFORMATION

Rough Cut does not sell personal information for money.

Rough Cut also does not intend to sell customer footage, audio, transcripts, prompts, editing projects, or AI-analysis results.

If Rough Cut engages in activity legally defined as "selling" or "sharing" personal information—including certain forms of cross-context behavioral advertising—we will provide any notices and opt-out mechanisms required by applicable law.

If our practices materially change, we will update this Policy before applying the new practice where legally required.

15. TARGETED ADVERTISING

Rough Cut may market its own Services.

If Rough Cut later uses personal information for third-party targeted or cross-context behavioral advertising, we will provide disclosures and opt-out mechanisms where required.

16. EMAIL COMMUNICATIONS

Transactional communications concerning accounts, purchases, security, licenses, subscriptions, or requested services may be necessary to provide the Services.

Marketing communications will provide an appropriate unsubscribe mechanism where required.

Unsubscribe requests will be honored in accordance with applicable law.

Unsubscribing from marketing does not necessarily prevent transactional communications necessary to administer an account or subscription.

17. CHILDREN

Rough Cut is not directed to children under 13.

We do not knowingly collect personal information directly from children under 13 without legally required parental consent.

If you believe a child has provided personal information to Rough Cut in violation of applicable law, contact us and we will investigate and take appropriate action, including deletion where required.

If Rough Cut ever intentionally offers a service directed toward children, appropriate age verification, parental notice, and verifiable parental consent mechanisms must be implemented before collecting covered children's information.

18. INFORMATION ABOUT OTHER PEOPLE IN USER CONTENT

Video and audio uploaded to Rough Cut may contain personal information about individuals other than the account holder.

The user is responsible for ensuring that they possess the rights, permissions, notices, releases, consents, or other lawful basis necessary to submit and process such content.

Rough Cut processes such content on the user's instructions to provide the Services.

19. YOUR PRIVACY RIGHTS

Depending upon where you live, applicable law may provide rights concerning your personal information.

These may include the right to:

• know whether we process your personal information;

• request access to personal information;

• obtain information about categories of data collected;

• obtain information about sources of information;

• learn the purposes for processing;

• learn categories of recipients;

• request correction of inaccurate information;

• request deletion;

• obtain a portable copy where applicable;

• opt out of certain sales or sharing;

• opt out of certain targeted advertising;

• limit certain uses of sensitive personal information;

• withdraw consent where processing relies upon consent;

• appeal certain privacy decisions; and

• exercise privacy rights without unlawful discrimination.

California currently recognizes rights including knowing, deleting, correcting, opting out of sale/sharing, limiting certain sensitive-information uses, and nondiscrimination. California DOJ Attorney General

These rights are subject to applicable exceptions.

20. PRIVACY AND DATA-DELETION REQUESTS

Users may contact Rough Cut to request access, correction, deletion, or other applicable privacy actions.

Contact: Tristan@RoughCut.online

Please include enough information for us to understand the request and identify the relevant account.

We may need to verify your identity before fulfilling a request to protect users against fraudulent or unauthorized requests.

Where legally permitted, we may deny or limit requests that we cannot reasonably verify or that fall within a statutory exception. If so, we will provide any explanation required by applicable law.

Deleting an account may not require deletion of information we are legally permitted or required to retain.

Rough Cut will respond within the time required by applicable law.

21. AUTHORIZED AGENTS

Where applicable law permits, you may designate an authorized agent to submit certain privacy requests on your behalf.

We may request evidence establishing the agent's authority and may verify the user's identity as permitted by law.

22. CALIFORNIA PRIVACY DISCLOSURES

California residents may have additional rights under the CCPA/CPRA where those laws apply to Rough Cut.

During the applicable reporting period, Rough Cut may collect the categories described in this Privacy Policy, including:

• identifiers;

• commercial information;

• internet or electronic network activity;

• account information;

• audiovisual information;

• professional information voluntarily provided;

• inferences or AI-generated classifications associated with use of the Services; and

• other information qualifying as personal information under California law.

The categories of sources, business purposes, and categories of recipients are described throughout this Policy.

California consumers may request information regarding personal information collected, used, disclosed, sold, or shared as provided by law.

They may also request correction or deletion and may exercise applicable opt-out rights.

Rough Cut will not unlawfully discriminate against a consumer for exercising a privacy right.

The California Attorney General explains that covered privacy policies should disclose what information is collected, its sources, purposes, recipients, consumer choices, correction/deletion mechanisms, and security practices. California DOJ Attorney General

23. NOTICE AT COLLECTION

At or before relevant points of collection, Rough Cut may provide additional notices describing:

1. the categories of personal information being collected;

2. the purposes for collecting or using that information;

3. applicable retention information; and

4. links or mechanisms necessary to exercise applicable privacy choices.

This Policy supplements those notices.

California requires covered businesses to provide specified information at or before collection rather than burying all disclosures solely in a general privacy policy. California DOJ Attorney General

24. INTERNATIONAL USERS

Rough Cut is operated from the United States.

If you access the Services from another country, your information may be processed in the United States or other jurisdictions in which our service providers operate.

Where required, Rough Cut will use appropriate safeguards for international transfers of personal information.

Users in jurisdictions including the European Economic Area, United Kingdom, or Switzerland may have additional rights under applicable law.

25. LEGAL BASES FOR PROCESSING

Where applicable law requires a legal basis, Rough Cut may process personal information based upon:

Performance of a contract — when processing is necessary to provide Rough Cut.

Legitimate interests — including maintaining, securing, improving, and protecting the Services where those interests are not overridden by applicable rights.

Consent — where the user has affirmatively consented.

Legal obligations — where processing is necessary to comply with applicable law.

Users may withdraw consent where applicable, subject to processing already lawfully performed.

26. DISCLOSURE REQUIRED BY LAW

We may preserve or disclose information when we reasonably believe doing so is necessary to:

• comply with applicable law;

• respond to valid legal process;

• enforce our agreements;

• investigate fraud or abuse;

• protect the security of Rough Cut;

• protect the rights or safety of users or others; or

• establish, exercise, or defend legal claims.

We will seek to limit disclosures to what is reasonably necessary under the circumstances.

27. CORPORATE TRANSACTIONS

If Rough Cut or TM Media LLC participates in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction subject to applicable law.

Where required, users will receive notice of material changes affecting their personal information.

28. DATA RETENTION

We retain categories of personal information only for periods reasonably necessary and proportionate to:

• provide the Services;

• maintain accounts;

• satisfy contractual obligations;

• maintain security;

• resolve disputes;

• comply with applicable laws;

• maintain appropriate business records; and

• establish or defend legal claims.

Retention periods may vary according to the type of information and purpose of processing.

When information is no longer reasonably necessary, we may delete, de-identify, or aggregate it, subject to applicable legal and technical limitations.

29. DE-IDENTIFIED AND AGGREGATED INFORMATION

We may create statistical, aggregated, or de-identified information that cannot reasonably be associated with an identifiable individual.

Where information is maintained as legally recognized de-identified information, we will not intentionally attempt to re-identify it except as permitted by law.

30. THIRD-PARTY LINKS

The Services may contain links to third-party websites or services.

Rough Cut is not responsible for the independent privacy practices of third parties. Users should review the privacy policies of services they choose to use.

31. ACCESSIBILITY

We intend for our privacy disclosures to be reasonably accessible to users with disabilities.

Users who require this Privacy Policy in an alternative format may contact us at:

Tristan@RoughCut.online

California's 2026 regulations specify that online privacy disclosures should be reasonably accessible and reference WCAG 2.1 as an applicable recognized standard. California Privacy Protection Agency

32. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy as Rough Cut, applicable laws, or our processing practices evolve.

When we make changes, we will update the "Last Updated" date.

If a change materially affects how we process personal information, we will provide additional notice or obtain consent where required by applicable law.

We will not retroactively apply materially incompatible processing practices where doing so would violate applicable law.

33. CONTACT US

Questions, concerns, complaints, and privacy requests concerning this Privacy Policy or Rough Cut's handling of personal information may be submitted to:

TM Media LLC d/b/a Rough Cut
Email: Tristan@RoughCut.online
Website: Rough Cut

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