Privacy Policy

This Privacy Policy explains how MJP Sp. z o.o. processes personal data in connection with the tellclip.com website, the macOS application, the web application and related features of the Tellclip service. It also explains when MJP acts as a data controller and when it processes data on behalf of a user or organisation. Where we process personal data on a customer’s instructions, this Privacy Policy does not replace the information that the relevant controller must provide to data subjects.

1. Who We Are

Tellclip is operated by MJP Sp. z o.o., with its registered office at ul. Zbożowa 2B lok. 12, 30-002 Kraków, Poland, entered in the Polish National Court Register under KRS number 0001061247, tax identification number (NIP) 6772499706 (“MJP”, “Tellclip”, “we”, “us” or “our”). For data protection enquiries, please contact [email protected].

MJP is a controller only for processing operations for which it determines the purposes and essential means of processing. For content submitted to Tellclip by users or organisations, MJP may act as a processor. The distinction is explained below.

2. When MJP Acts as a Controller

MJP is a controller of personal data used to create and operate Accounts, authenticate users and manage access to the service, maintain relationships with customers and users, communicate and provide support, carry out internal analyses of product operation and development, detect misuse, maintain security, and establish, exercise or defend legal claims. We use contact details for newsletters and marketing only where the user has given the required consent. This also applies to individuals using Tellclip on behalf of a business, such as its employees or contractors. Creem sells Subscriptions in its own name and may act as an independent controller for data relating to its transactions. MJP is separately a controller of billing and transaction information it receives from Creem and processes in its own systems for its own purposes.

3. When MJP Acts as a Processor

Where an organisation or another user decides whom to record and for what purpose, what personal data to include in Clips, with whom to share them and when to delete them, and MJP provides the technical storage, processing and sharing of that content on the relevant party’s instructions, MJP generally acts as a processor in respect of personal data contained in that content. Depending on the instructions and features used, this may include recordings, transcripts, comments, imported material, AI-generated summaries, Clip sharing, and the export and deletion of content.

In a business Organisation, the controller of personal data contained in Clips may be an employer, client or another entity that determines the purposes of recording and sharing. It is not necessarily the person who created the Account or made the recording. Using a work email address does not, by itself, transfer control of a separate Organisation or its content to an employer.

Tellclip may also be used by individuals for personal or household purposes. In that case, the exemption under Article 2(2)(c) of the General Data Protection Regulation (“GDPR”) may apply to the individual’s own activities, but it does not exempt MJP’s activities as a service provider from the GDPR. Personal use of Tellclip does not automatically mean that MJP is the controller of all personal data relating to persons appearing in a Clip. MJP’s role depends on the actual purposes and means of the relevant processing. Sharing a Clip beyond a personal or household context may also affect the legal position of the person sharing it.

Accordingly, within the same customer relationship, MJP may act as controller of Account, operational and support data while also acting as a processor of personal data contained in a customer’s Clips. Where applicable, processing on a customer’s behalf is governed by the relevant data processing terms, including the provisions of the Terms of Service or a separate data processing agreement (“DPA”).

4. Personal Data We Collect and Where It Comes From

4.1 Accounts, Identity and Membership

We process first and last names, email addresses, Account identifiers, login and authentication information, Organisation and Workspace memberships, roles, invitations and permissions. WorkOS provides authentication and business identity-management features, including single sign-on (“SSO”) and the System for Cross-domain Identity Management (“SCIM”). MJP does not store Account passwords. We obtain this information from the user, an Organisation administrator or the identity provider selected by the Organisation.

4.2 Subscriptions and Customer Communications

We process information about the selected plan, Subscription status, the number of paid Seats and billing events needed to manage access to the service. Creem sells Subscriptions and processes payments in its own name as merchant of record. When a user starts a purchase, we send Creem the user’s email address (or the existing Creem customer identifier), the Organisation identifier and the number of Seats. From Creem we receive and store in our own database only: the Creem customer identifier, the Subscription and Subscription item identifiers, the plan, the Subscription status, the number of paid Seats and the end date of the current billing period. We use this information to operate the service, manage Subscriptions and communications, and meet applicable legal obligations or pursue legitimate interests. We do not receive or store payment-card numbers or other payment-card details, and we do not store billing addresses or tax identifiers; Creem holds those as seller. We also process communications and contact information supplied in support requests, including requests for video files or bulk data exports.

4.3 Clips and Other Content

Depending on how the service is used, Tellclip servers may store screen recordings, video and audio, thumbnails, titles, transcripts, captions, speaker identifiers and names, chapters, AI-generated summaries, comments, reactions, sharing settings, branding settings and other user-submitted information. This content may include personal data about people who do not have an Account, confidential information, or special categories of personal data if a user includes them in a recording or other content. The type of information processed generally depends on the decisions of the party arranging the recording and sharing.

4.4 Product Usage and Clip Views

When people use our website, applications or shared Clips, we may record IP addresses, browser and device information, application version, operating system, feature-use events, operating-system permissions granted to the application, session identifiers and diagnostic information. For Clip views, we record information such as device type, operating system, country and an identifier used to distinguish anonymous visits. Views by signed-in Organisation members may be associated with their Accounts. We do not identify visitors who watch a Clip without signing in by their name merely as a result of viewing the Clip.

4.5 Integrations and Other Sources

When an Organisation enables an import from Fireflies, we may receive a meeting recording and a transcript already prepared by Fireflies, including speaker labels. Where a user enables Slack, we send notifications through that integration that may include a Clip title and link. We may also receive personal data from Organisation administrators, people sending invitations, Clip creators, commenters, identity providers and persons reporting misuse.

5. Purposes and Legal Bases When MJP Is a Controller

When we act as a controller, we process personal data for the following purposes and on the following legal bases:

• Creating and operating an Account for a user who is a party to our contract, providing access to features and responding to that user’s contractual requests: Article 6(1)(b) GDPR (performance of a contract or steps taken before entering into a contract).
• Managing Accounts and permissions for individuals acting on behalf of business customers, communicating with customer representatives and administering business relationships: Article 6(1)(f) GDPR (our and our customers’ legitimate interests in providing the service and managing business relationships).
• Maintaining service and login security, detecting abuse, investigating events and outages, preventing unauthorised access and protecting infrastructure: Article 6(1)(f) GDPR (our legitimate interest in maintaining the security, integrity and reliability of the service) and, where a legal obligation applies, Article 6(1)(c) GDPR.
• Providing technical support, handling correspondence, complaints, data-related requests and reports of illegal content: Article 6(1)(b) GDPR where necessary to perform a contract with the individual concerned; otherwise Article 6(1)(f) GDPR (our legitimate interest in responding to users, customers and reports), or Article 6(1)(c) GDPR where we must respond by law.
• Keeping necessary records, handling transaction information and copies of documents received from Creem, and meeting our own legal and accounting obligations: Article 6(1)(c) GDPR where processing is legally required, or Article 6(1)(f) GDPR (our legitimate interests in record-keeping, administering Subscriptions and protecting legal claims). Creem separately determines the purposes and legal bases of its own activities as seller.
• Analysing feature use, service quality and the operation of Tellclip, and improving the product: Article 6(1)(f) GDPR (our legitimate interest in improving the service and its security), insofar as the particular activity does not require consent. Where non-essential identifiers, cookies or session-replay technologies are used and consent is required, Article 6(1)(a) GDPR applies to the associated personal-data processing. The use of technologies accessing or storing information on a device is also subject to the applicable rules on terminal-equipment access.
• Establishing, pursuing and defending legal claims and documenting lawful provision of the service: Article 6(1)(f) GDPR (our legitimate interest in protecting our rights and the rights of others).

Where processing is based on legitimate interests, you may object as provided by the GDPR. We send newsletters and marketing communications only with the consent required under Article 6(1)(a) GDPR and applicable electronic-communications laws. Consent can be withdrawn at any time, including using an unsubscribe link where one is provided or by contacting [email protected]. Withdrawal does not affect the lawfulness of processing performed before it.

Providing the information required to create an Account or identify an individual is necessary to use features that require sign-in. Other information is generally optional, although we may be unable to fulfil a request without information needed to handle it. We do not ask users to provide payment-card details directly to MJP.

6. Processing on Your Device

In standard recording mode, the user starts the recording of the screen, camera video or audio in the macOS application, and the recording project is initially created locally. In Instant sharing mode, data may be uploaded to the service while recording is in progress. The application does not start recording automatically without user action. Transcription of recordings made in the macOS application takes place locally on the user’s device and does not require the recorded audio to be sent to an external transcription provider. Content imported from Fireflies may include a transcript previously created by Fireflies.

7. Artificial Intelligence Features and Agents

We use Google’s paid Gemini application programming interface (“Gemini API”) to generate titles, descriptions, summaries, chapters and other AI outputs, to suggest the Workspace a Clip belongs in, and to power Clip search. For these purposes, we may send Google transcripts, including speaker labels and names, and the names of the Organisation’s Workspaces; where a recording contains little or no speech, a single video frame from the Clip; and, for Clip search, Clip titles and summaries and the search queries users enter. These transfers are made to provide the relevant feature. MJP does not use User Content to train its own AI models. Under the terms applicable to the paid Gemini API service we use, Google does not use prompts or responses submitted through that service to improve its products, including to train its models. Under those terms, Google processes prompts and responses in accordance with its Data Processing Addendum for Products Where Google is a Data Processor.

Google may process the data submitted to fulfil a request to the extent and for the periods set out in the applicable Gemini API terms and documentation. Under Google’s Gemini API usage policies, Google retains prompts, contextual information and outputs for 55 days to detect and prevent violations of its Prohibited Use Policy and for any required legal or regulatory disclosures. We limit the data submitted to what is needed for the requested feature. Information about processing and retention by Google is available in the terms and privacy documentation for the relevant Gemini API service. Our use of Google does not exclude MJP’s responsibility for its own processing operations or for engaging processors where required by law.

If a user connects an external Agent through the Model Context Protocol (“MCP”) server, that Agent operates within the permissions of the signed-in user and the operations made available by Tellclip. The data and actions accessible to an Agent depend on the tool used and its permissions. Organisation API keys are used to upload Clips. Information disclosed to an external Agent or its model provider may be processed independently by that provider under its own terms. Users should review those terms before connecting an Agent.

8. Analytics, Cookies and Session Replay

We use PostHog in its European Union region (data hosted in Frankfurt, Germany) to analyse the use of our website and applications. Analytics data may include information about features used, pages visited, device information, application version and events associated with registration or a Subscription. PostHog is configured to discard IP addresses rather than store them with analytics events. We do not submit Clip video files or Clip transcripts to PostHog as analytics content.

Session replay creates a technical reconstruction of interactions with the interface, such as clicks, scrolling and page layout. It runs only on our website and web application, not in the macOS application. In the web application, text, form fields and media are masked; elements of public marketing and legal pages may remain visible. Masking is intended to reduce the information recorded, but it does not mean that session data necessarily contains no personal data.

We use cookies and comparable technologies that are necessary for sign-in and basic service functionality; these do not require consent. On our website and web application, PostHog analytics and session replay, together with the cookies and similar identifiers they use, run only after you give consent in the cookie banner. If you decline, or until you choose, they do not run. You can change or withdraw your consent at any time through the “Cookie settings” link in the website footer. Withdrawal does not affect processing carried out before it. Information about the technologies used and their purposes is provided in the cookie banner and cookie settings. We do not use advertising or cross-site tracking cookies.

The macOS application sends usage events to PostHog to help us improve it. You can turn this off at any time in the application under Settings → Advanced → “Share usage analytics”; once turned off, the application stops sending these events and deletes the identifier it stored for them.

Independently of the cookie banner, our servers record a limited set of product events without storing anything on your device: sign-ins, app downloads, views of shared Clips and similar service events. Events of a signed-in user are linked to their Account identifier; other events carry a random identifier that is not linked to a person. We process these events on the basis of our legitimate interest in operating, securing and improving Tellclip (Article 6(1)(f) GDPR), store them in PostHog for the period stated in section 11, and you may object to this processing by contacting [email protected].

9. Service Providers, Recipients and Transfers Outside the EEA

We share personal data only as appropriate for the purposes described in this Privacy Policy and the settings selected by the user. A provider’s legal role depends on the processing activity: the same provider may act as our processor in respect of data for which MJP is a controller, or as a subprocessor in respect of personal data that a customer has entrusted to MJP. Not every provider is our subprocessor.

• Amazon Web Services EMEA SARL (Luxembourg), as part of Amazon Web Services (AWS): application infrastructure, database services, Account and Organisation information, Clip metadata, transcripts and comments, application logs, and sending of service emails through Amazon Simple Email Service (SES). Location: AWS US East (N. Virginia) region, United States. Transfer mechanism: SCCs under the AWS GDPR Data Processing Addendum; Amazon.com, Inc., including Amazon Web Services, Inc., is also certified under the DPF.
• Cloudflare, Inc. (United States): storage of video files, thumbnails and certain transcripts in Cloudflare R2, and network proxying and content delivery. Location: R2 storage with an Eastern Europe location hint; network traffic is handled in Cloudflare’s global network, including outside the EEA. Transfer mechanism: DPF, with SCCs under the Cloudflare Data Processing Addendum as a fallback.
• WorkOS, Inc. (United States): authentication, identity management, SSO and SCIM features. Location: United States. Transfer mechanism: SCCs under the WorkOS Data Processing Addendum.
• Google Cloud Poland Sp. z o.o. (Warsaw, Poland), as the Google entity providing the paid Gemini API: processing required to provide AI features, limited to data submitted when the relevant feature is invoked. Location: Google processes Gemini API data in the United States and other countries where Google or its subprocessors operate. Transfer mechanism: DPF (Google LLC), with SCCs under Google’s Data Processing Addendum as a fallback.
• PostHog, Inc. (United States): website and product analytics and session replay. Location: PostHog EU Cloud, hosted in Frankfurt, Germany. Transfer mechanism, to the extent PostHog, Inc. accesses data from outside the EEA: DPF and SCCs under the PostHog Data Processing Agreement.
• Functional Software, Inc. d/b/a Sentry (United States): identification and diagnosis of errors in the website and applications. Location: Sentry’s EU data region (Germany). Transfer mechanism, to the extent Sentry accesses data from outside the EEA: DPF, with SCCs under the Sentry Data Processing Addendum as a fallback.
• Armitage Labs OÜ (Tallinn, Estonia), operating Creem: an independent seller of Subscriptions and a separate controller of data processed for sales, payments, taxes, invoicing and transaction-related enquiries. Location: EEA; we do not transfer data to Creem outside the EEA.
• Slack Technologies Limited (Dublin, Ireland): an optional user-enabled integration that receives information needed for requested notifications, including Clip titles and links. Location: Slack may process data in the United States and other countries. Transfer mechanism: Slack’s onward transfers are governed by the Salesforce Data Processing Addendum (binding corporate rules, SCCs and the DPF).
• Google LLC (United States), through Google Fonts: delivery of web fonts used on our website. When a page loads, your browser requests the font files from Google’s servers, which receive your IP address and browser information. Location: United States and other countries where Google operates. Transfer mechanism: DPF.
• Google Cloud Poland Sp. z o.o. (Warsaw, Poland), as the Google entity providing Google Workspace: email, including messages sent to [email protected], and internal documents. Location: Google data centres in the EEA, the United States and other countries. Transfer mechanism: DPF (Google LLC), with SCCs under the Cloud Data Processing Addendum as a fallback.
• Mintlify, Inc. (United States): hosting of our help documentation at tellclip.com/docs, which receives the IP address and browser information of visitors to those pages. Location: United States. Transfer mechanism: SCCs under the Mintlify Data Processing Addendum.
• Fireflies.ai Corp. (United States): an external service from which we import recordings and previously prepared transcripts at an Organisation’s request. The initial processing by Fireflies is governed by that Organisation’s relationship with Fireflies. Location: United States. Transfer mechanism, to the extent our requests transfer personal data to Fireflies: DPF, with SCCs as a fallback.

In connection with our infrastructure and third-party services, some personal data may be stored or accessed outside the European Economic Area (“EEA”), including in the United States. Transfers of personal data outside the EEA are subject to the requirements of Chapter V of the GDPR. For each recipient listed above, we state the transfer mechanism we rely on: an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework (“DPF”) for recipients certified under it) or standard contractual clauses adopted by the European Commission (“SCCs”), together with supplementary safeguards where required. You may contact [email protected] to request information about the safeguards applicable to a particular transfer and how to obtain a copy of them.

10. Clip Sharing and Visibility

New Clips have access through a public Share Link enabled by default. Anyone who has an active Share Link can watch the recording and access the accompanying material made available with it, such as transcripts, summaries and comments, even without an Account. Users can restrict access to Organisation members or disable the Share Link through the service settings. Excluding a Clip from a sitemap or providing technical instructions to search engines does not guarantee that the Clip cannot be discovered or redistributed after the link has been disclosed.

Watching a Clip does not require sign-in. To comment or react, a person must sign in to an Account, including as a guest. Their name or account name and guest status may be visible alongside their comment. The comment author, Clip owner and authorised Organisation administrator can remove comments in accordance with their permissions. Organisation administrators may have access to content stored within their Organisation after its creator is no longer a member. Having a work email address alone does not allow an employer to take control of a separate personal Organisation.

Third parties to whom a user shares a Share Link, or to whom information is disclosed through an enabled integration or Agent, may process that information independently. Where an Organisation controls the personal data in a Clip, it is generally responsible for the lawfulness of recording and for determining the scope and legal basis of sharing.

11. Retention and Deletion

We retain Clips, transcripts, comments and other User Content within an active Organisation until an authorised user deletes them or the Organisation is deleted, subject to the rules below. Deleting a Clip removes its records and files from the live production environment. There is no recycle bin or standard way to restore a deleted Clip. Database backups are retained for seven days and removed through backup rotation. Video files are not covered by separate backups.

If a seven-day Trial ends without a Subscription purchase, or a paid Subscription ends, the Organisation enters Read-Only Mode. The end of a Trial or Subscription does not, by itself, cause the Organisation or its data to be deleted. Tellclip deletes an Organisation that has no active Subscription after 180 days without activity. Activity means creating a Clip or a comment in the Organisation, or a member of the Organisation signing in to or using Tellclip, including watching a Clip while signed in. After 150 days without activity, we notify the Organisation’s owner and administrators by email at least 30 days before the deletion date; any activity during that period cancels the deletion. Deletion removes the Organisation’s Clips, files and related records from the live production environment and cannot be reversed. Organisations whose membership is managed by an identity provider through SCIM are not deleted under this rule.

In Read-Only Mode, users can play existing Clips, use active Share Links, download transcripts and delete Clips. They cannot create new recordings or use the API or MCP. Video files and bulk exports are provided on request through support after verification of the requester’s authority, provided the data are still available.

We retain Account information, membership records, copies of transaction data received from Creem, support correspondence and security logs for as long as necessary to provide the service and manage customer relationships, and thereafter where justified by statutory retention requirements or applicable limitation periods. Contact information used for consent-based newsletters and marketing is retained until consent is withdrawn or the purpose ends earlier, subject to retaining limited evidence of consent where necessary. Data sent to Google through the Gemini API are retained by Google as described in section 7; we limit the information provided to what is necessary for the requested feature.

Other data are retained for the following periods:

• PostHog analytics events: 1 year from collection.
• PostHog session replays: 30 days from recording.
• Sentry error and diagnostic events: 30 days from collection.
• Application and network-tunnel logs on AWS (which may contain IP addresses and request details): 30 days.
• Database backups: 7 days.

12. Data Security

We use measures intended to protect personal data against unauthorised or unlawful disclosure, access or loss. These include encryption of data in transit using Transport Layer Security (“TLS”), encryption of the database, restricted administrative access to the production database through a secured tunnel, and storage of secrets in encrypted infrastructure configuration. Database backups are retained for seven days. Tellclip personnel do not routinely access Clip content. Access may occur to the extent necessary, for example in response to a verified support or export request, to investigate reported misuse, or to comply with a legal obligation.

13. Your Rights

Where MJP is the controller of your personal data, and subject to the conditions under the GDPR, you may request access to and a copy of your data, rectification, erasure, restriction of processing and data portability; object to processing based on legitimate interests; and withdraw consent where processing is based on consent. You may also lodge a complaint with a competent supervisory authority, in particular the President of the Polish Personal Data Protection Office (“UODO”).

Please send requests to [email protected]. We respond without undue delay and generally no later than one month after receiving a request, subject to the extensions permitted by the GDPR. Where we have reasonable doubts, we may request information necessary to verify your identity or authority to access the data.

If your request concerns your appearance or personal data in a Clip created by another person or Organisation, and MJP acts as processor for that content, the relevant controller, such as the organisation or employer that arranged the recording, is responsible for responding. You may contact that controller directly. If you provide the Clip URL and sufficient information to identify the issue, we may forward your request to the relevant controller or assist it, within the limits of applicable law, our contract and available technical means. MJP may not be able to identify every person appearing in a recording on its own.

MJP does not use personal data for which it is a controller to make decisions based solely on automated processing that produce legal effects concerning an individual or similarly significantly affect them. AI features generate content and support users’ own activities rather than making such decisions on MJP’s behalf.

14. Children

Tellclip is not intended for people under the age of 18. People under that age must not create Accounts or use the service.

15. Changes to This Privacy Policy

We may update this Privacy Policy, including to reflect changes in laws, service providers, safeguards or how the service operates. The current version is published at tellclip.com/privacy with its latest update date. Where significant changes affect the processing of personal data, we will provide any additional information required by law. Continued use of Tellclip does not replace consent where the law requires fresh consent for a new processing purpose.