Privacy Policy
Version 2026-10-27-draft3 (DRAFT) · Controller: Kitepond Studio · Address: Bảo An, Phan Rang, Khánh Hòa · Contact: kitepondstudio@proton.me
DRAFT — not yet reviewed by a licensed Vietnamese lawyer.
1. Who we are
ClipForge is operated under the name Kitepond Studio by an individual operator at Bảo An, Phan Rang, Khánh Hòa, Viet Nam ("we", "us"). We are the controller of the personal data described here, under the Law on Personal Data Protection No. 91/2025/QH15, Decree No. 356/2025/NĐ-CP and other Vietnamese law. Contact for privacy requests: kitepondstudio@proton.me. We have not appointed a separate data-protection officer; the operator handles requests personally.
2. What we collect, why, and on what basis
| Data | Why | Basis |
|---|---|---|
| Account: email, password (only as a salted scrypt hash), email-verification status | Create and secure your account, send verification, reset and security emails | Contract; security |
| Consent records: which documents/versions you accepted, time, IP address and browser user-agent | Prove your consents | Legal obligation; evidence |
| Inputs: prompts, uploaded images, video settings | Generate your videos | Contract; your consent to the cross-border transfer |
| Outputs: generated videos, thumbnails and job metadata | Deliver your videos and apply the AI label | Contract; legal obligation |
| Transactions: orders, payment status and reference, credit ledger. We never receive card numbers or bank logins | Take payment, keep credits, handle refunds and invoice requests | Contract; accounting and tax duties |
| Free-credit claim records: one-way hashes of your normalised email address and your sign-up IP address, the amount and date (no plaintext email or IP) | Allow one free signup bonus per person and stop repeat claims | Our legitimate interest in preventing abuse |
| Technical: IP address and user-agent with your sessions, login-attempt counters, server logs | Security, abuse and fraud prevention | Security; legal obligation |
| Messages you send us | Answer you | Contract |
We do not sell personal data, show advertising, or use your Inputs or Outputs to train our own models. We make no automated decisions with legal effect on you; automated moderation may block a prompt and you can ask us to review that. We do not knowingly collect sensitive personal data. Do not put sensitive data, children's data or other people's personal data (including identifiable faces) into prompts or images unless you have the person's consent.
We send optional product news only if you opt in on the Account page (we do not currently send any).
3. Who receives your data
| Recipient | What | Where | Why |
|---|---|---|---|
| fal.ai (Features and Labels, Inc.) and the developers of the models it runs: MiniMax, Google, Lightricks, Alibaba | Prompts, images, parameters; the result video | United States; depending on the model, also servers of the developer in China, Israel or the United States | Run the model |
| Resend (Resend, Inc.) | Your email address and the email content | United States | Verification, reset and security emails |
| payOS | Order amount, order code, description, and the transfer details your bank shares | Viet Nam | Take VietQR / bank-transfer payments |
| Oracle Cloud Infrastructure | The application and its database | Singapore | Hosting |
| Cloudflare R2 (Cloudflare, Inc.) | Videos, thumbnails, uploaded images, database backups | Cloudflare's global network | Private file storage |
| Proton (Proton AG) | Emails you send us | Switzerland | Receive and answer your messages |
| Advisers, accountants, competent authorities | As needed or as requested | Viet Nam | Legal, accounting and tax compliance; lawful requests |
| A successor of the business | All, with notice to you | Business transfer |
Providers work under their own terms and privacy policies. We use no advertising, analytics or CAPTCHA providers.
4. Sending data abroad
Our model and infrastructure providers are outside Viet Nam, mainly in the United States and, for some models, China or Israel. Using the Service therefore sends your Inputs abroad. We do this on the basis of your separate consent at sign-up (recorded with version and time) and the providers' published terms. We are required to prepare and file a cross-border transfer impact assessment with the Ministry of Public Security's data-protection authority [TO BE CONFIRMED: filing of this dossier must be completed before sign-ups open]. Foreign countries may protect data differently than Viet Nam, and foreign authorities may be able to access it under their law. If you do not consent you cannot use generation. You can withdraw consent at any time (section 7); we then stop sending new Inputs abroad, which ends the Service for you.
5. Cookies
Only strictly necessary cookies: a session cookie (__Host-vg_session or vg_session; keeps you signed in; up to 14 days, ends after 7 days idle) and vg_csrf (protects against cross-site request forgery). No advertising, analytics or tracking cookies or third-party scripts. If that changes, we will update this policy and ask for consent where required.
6. How long we keep data
| Data | Retention |
|---|---|
| Account data, prompts and job records | Until you delete your account |
| Videos, thumbnails and uploaded images | 30 days after the video is created, unless you press Keep (then until you remove it or delete your account). Account deletion removes them immediately |
| Credit ledger and payment orders | Kept in anonymised form after account deletion (your identity is removed) for accounting and tax records, for up to 10 years |
| Consent records | At account deletion the IP and user-agent are removed; document, version and time are kept as evidence for up to 5 years |
| Free-credit claim hashes | Kept after account deletion so a deleted account cannot claim again; they cannot be turned back into your email or IP |
| Server logs | Rotating, size-limited files; old entries are overwritten (typically days to weeks) |
| Database backups | A snapshot every 24 hours in Cloudflare R2, newest 14 kept, so deleted data leaves backups within about 14 days. Backups hold the database only, not videos |
| Data at providers | Under their own policies |
| Anything we must keep by law or for a dispute or investigation | As long as required |
7. Your rights
You have the rights in Article 4 of the Law on Personal Data Protection, including to be informed, consent or withdraw consent, access, correct, receive a copy, delete, restrict, object, complain and claim compensation.
- Self-service (Account page): change email or password, download your data (JSON), sign out everywhere, delete your account (this anonymises your personal data and forfeits unused credits).
- By email: write to kitepondstudio@proton.me. We reply within 2 working days and finish within the legal periods (up to 10 days for access or correction, 15 days to withdraw consent, restrict or object, 20 days to delete), extendable once with reasons where the law allows.
- Withdrawing consent or deleting data may stop us providing the Service and does not affect lawful processing already done.
- You can also complain to the Ministry of Public Security's data-protection authority (Department of Cybersecurity and High-Tech Crime Prevention, A05) or go to court.
8. Security and breaches
We use scrypt password hashing, hashed one-time tokens, httpOnly cookies, CSRF protection, login rate limiting and lockout, role-based access and TLS. Cloudflare R2 encrypts stored files and backups at rest. No system is perfectly secure. If a breach is likely to harm your rights, we will notify you and the authority as the law requires (including within 72 hours to the authority).
9. Children
The Service is for people 18 or older. You confirm your age at sign-up; we do not verify it by default. If you think a minor uses the Service, tell us and we will delete the account.
10. Changes
We publish changes here with a new version and notify you of material ones, and ask you to accept new versions. Current version: 2026-10-27-draft3.