Privacy Policy
Last updated: May 2026
ClipHow SAS (hereinafter "ClipHow", "we") is committed to protecting the privacy of its users. This privacy policy describes how we collect, use, store and protect your personal data in connection with the use of the ClipHow platform, available at https://cliphow.com.
This policy is drafted in accordance with the General Data Protection Regulation (GDPR — EU Regulation 2016/679) and the French Data Protection Act of January 6, 1978, as amended.
1. Data Controller
ClipHow SAS
12 Rue de la Part Dieu, 69003 Lyon
RCS 104 954 961 Lyon
Email : contact@cliphow.com
Data Protection Officer (DPO) : Vincent Charles
Email : dpo@cliphow.com
2. Data Collected
In connection with the use of the ClipHow platform, we collect and process the following categories of data:
Identification data:
last name, first name, professional email address, role in the organization, organization name, login credentials.
Content data:
uploaded videos, AI-generated transcriptions, training courses created, quizzes, quiz results, progress data.
Technical data:
connection logs, audit logs, usage and analytics data, technical embeddings (search vectors).
Security data:
login attempts (IP address, user-agent, result), trusted devices (fingerprint, approximate geolocation), MFA/TOTP factors.
3. Purposes and Legal Bases for Processing
| Purpose | Legal Basis |
|---|---|
| Provision and management of the ClipHow service | Performance of the contract |
| User account management | Performance of the contract |
| Video transcription and structuring | Performance of the contract |
| Course and quiz generation | Performance of the contract |
| AI conversational agent | Performance of the contract |
| Usage statistics and service improvement | Legitimate interest |
| Security and incident prevention | Legitimate interest |
| Compliance with legal obligations | Legal obligation |
4. Data Recipients
Your personal data is accessible to the following persons:
- The ClipHow team, limited to what is necessary for operating the service.
- The administrators and managers of your organization, for the purpose of training management.
We use the following subprocessors, all contractually committed to GDPR compliance:
| Subprocessor | Role | Data Location |
|---|---|---|
| Supabase Inc. | Database hosting and storage | European Union (Frankfurt, Germany) |
| Vercel Inc. | Website and application hosting | European Union (Frankfurt, Germany) |
| Mistral AI | AI processing (transcription, generation) | European Union (France) |
| Resend (optional, not deployed) | Sending transactional emails (invitations, notifications) | European Union |
5. Transfers Outside the European Union
Supabase and Vercel are entities headquartered outside the European Union. However, data is stored and processed on servers located within the European Union.
Standard Contractual Clauses (SCCs) approved by the European Commission govern any potential data transfers outside the EU, in accordance with Articles 46 et seq. of the GDPR.
6. Data Retention
| Data Type | Retention Period |
|---|---|
| Active account data | Duration of the contract between ClipHow and the client organization |
| Connection and audit logs | 12 months |
| Deactivated accounts | 6 months after deactivation |
| AI conversations | 365 days by default (configurable per organization) |
| Login attempts | 90 days |
| Trusted devices | 30 days |
| Deleted videos (trash) | 30 days before permanent deletion |
| Contact requests (marketing form) | 24 months |
| All data at end of contract | Deletion within 30 days after the end of the contract |
7. Data Security
We implement the following technical and organizational measures to protect your data:
- Data encryption at rest (AES-256).
- Data encryption in transit (TLS 1.2 or higher).
- Access control per organization (Row Level Security).
- Access and action logging (audit logs).
- Access limited to authorized ClipHow team members.
8. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right of access : obtain confirmation that your data is being processed and receive a copy.
- Right to rectification : have inaccurate or incomplete data corrected.
- Right to erasure : request the deletion of your data, subject to our legal obligations.
- Right to restriction : request the suspension of processing in certain cases.
- Right to data portability : receive your data in a structured, machine-readable format.
- Right to object : object to the processing of your data on legitimate grounds.
To exercise your rights, contact our DPO at : dpo@cliphow.com
We commit to responding to your request within one month. This period may be extended by two months in case of complexity.
9. Cookies
ClipHow uses cookies strictly necessary for the operation of the platform (session cookies, authentication cookies, cookie consent). No advertising or marketing tracking cookies are used.
The Tarteaucitron consent banner is displayed in accordance with CNIL recommendations (maximum 13-month duration, Do Not Track compliance). For more details, see our Cookie Policy.
10. Complaint to the CNIL
If you believe that the processing of your personal data does not comply with regulations, you may file a complaint with the French Data Protection Authority (CNIL):
- Website : https://www.cnil.fr
- Address : CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07
11. Changes to This Policy
ClipHow reserves the right to modify this privacy policy. In the event of a substantial change, users will be notified via the platform or by email. The last update date is indicated at the top of this document.