Privacy & Biometrics Notice
Last updated: 6 July 2026 · Prepared under Rule 3 of the NZ Biometric Processing Privacy Code 2025
If you appear in footage that was processed by ClipMine and want to know what data was held about you, the answer is most likely: nothing. Facial recognition templates are deleted the moment processing is finished. If you have a question or want to confirm, email team.clipmine@gmail.com.
Who we are
| Field | Detail |
|---|---|
| Organisation | ClipMine |
| Operator | Tony Xia, Hamilton, New Zealand |
| Service | AI-powered footage organisation at clip-mine.com |
| Contact | team.clipmine@gmail.com |
| Regulator (NZ) | Office of the Privacy Commissioner — privacy.org.nz |
Who this notice is for
This notice is for anyone whose face appears in video footage uploaded to ClipMine — not just people who hold a ClipMine account. If you attended an event, played in a match, or appeared in footage that a videographer later processed with ClipMine, this notice describes what ClipMine did with data about you and what rights you have.
What ClipMine collects
When footage is uploaded to ClipMine for processing, the following data is derived from the video:
- Facial recognition templates — a numeric vector derived from the position and proportions of facial features in each detected face. This is biometric data.
- Detection metadata — timestamps and frame positions where a face was detected, used to cut clips.
ClipMine does not collect names, contact details, gender, ethnicity, or any other identifying information from individuals appearing in footage. If you are a ClipMine account holder, see the section below for what we collect about you as a registered user.
What we collect from account holders
When you create a ClipMine account, we collect the following data about you as a registered user — separate from any biometric processing of footage you upload:
| Data | Source | Purpose | Retention |
|---|---|---|---|
| Email address | Signup | Account management, verification, service notices | Until account deletion |
| IP address + device info | Automatic | Security, abuse prevention | 12 months rolling |
| Usage analytics (page views, events) | Vercel Analytics | Product improvement — aggregated, not linked to individuals | Per Vercel retention policy |
| Error logs (user ID + context) | Application | Debugging, support | 12 months rolling |
| Billing records (Stripe customer ID, plan, payment status) | Stripe | Billing and subscription management | 7 years (NZ Inland Revenue requirements) |
Legal basis (GDPR Art. 6): performance of contract for account management and billing; legitimate interests for security, analytics, and debugging.
Why we collect it
ClipMine processes facial recognition templates for one purpose: to cluster video clips by person, so the videographer who uploaded the footage can find and download clips of specific individuals without manually scrubbing the source recording.
We have assessed this purpose as necessary and proportionate under Rule 1 of the NZ Biometric Processing Privacy Code 2025. The assessment considers: the purpose is specific and limited; no reasonably effective lower-risk alternative achieves the same outcome at scale; safeguards include immediate deletion, access controls, and processing only by authorised infrastructure.
ClipMine does not use facial recognition outputs to infer emotional state, intent, mental health, political views, or any other sensitive characteristics. Outputs are limited to temporal and spatial clustering of footage by detected identity.
How long we keep it
Short answer: facial templates are deleted immediately. ClipMine deletes all facial recognition templates as soon as the clip-cutting job is complete — typically within minutes of processing finishing. There is no standing biometric database. After processing, ClipMine holds your clip files (the video segments themselves) but not the biometric data that was used to create them.
| Data type | Retention |
|---|---|
| Facial recognition templates | Deleted immediately on job completion |
| Clip files (video segments) | Retained until the videographer deletes the project |
| Processing logs | Retained for 12 months (rolling) for security and audit purposes |
| Account data (email, IP, analytics, error logs) | Retained until account deletion |
| Billing records (Stripe) | Retained for 7 years (NZ Inland Revenue requirements) |
Non-biometric alternative
If you are a videographer who prefers not to use facial recognition, ClipMine can provide manual organisation assistance upon written request at no extra charge. Contact team.clipmine@gmail.com.
Who has access to processed data
- The videographer who uploaded the footage — can access clip files grouped by person identity. They cannot access raw facial recognition templates.
- ClipMine's processing infrastructure — cloud GPU processing via Modal (United States). Facial templates exist only during the processing job. No human operator routinely accesses templates during processing; access is limited to emergency incident response and is logged.
- ClipMine personnel — may access processing logs and metadata for security and billing purposes. No access to biometric templates.
Third-party service providers (processors): ClipMine uses the following processors who may handle data as part of service delivery:
- Vercel (United States) — hosting and serverless compute. Processes request logs and aggregated analytics.
- Supabase (United States) — database. Stores account data, project metadata, and processing records.
- Cloudflare R2 (United States) — object storage. Stores uploaded video files and clip outputs.
- Modal (United States) — GPU compute. Receives footage for biometric processing; no data is retained after job completion.
- Stripe (United States) — payment processing. Stores billing information for subscribed accounts.
ClipMine does not sell, share, or license biometric data to any third party.
Your rights
Under the NZ Privacy Act 2020 and the Biometric Processing Privacy Code 2025, you have the right to:
| Right | Detail |
|---|---|
| Access | Request a description of any personal or biometric data ClipMine holds about you. (In most cases, the answer will be: facial templates already deleted; clip files remain in the videographer's account.) |
| Deletion | Request deletion of any data ClipMine holds. For biometric data, our deletion policy means there is typically nothing to delete. For clip files, deletion requests are directed to the videographer who uploaded the footage, as they are the data controller. |
| Correction | Request correction of any inaccurate personal data ClipMine holds about you. |
| Complaint | Lodge a complaint with ClipMine directly, or escalate to the relevant regulator (see below). |
How to make a request or complaint
Step 1 — Contact ClipMine: Email team.clipmine@gmail.com with a description of your request. We aim to respond within 5 working days. For deletion requests, please include a description of the event or footage you appeared in so we can identify the relevant project.
Step 2 — Escalate to a regulator: If we do not resolve your complaint to your satisfaction, you can contact:
- New Zealand: Office of the Privacy Commissioner — privacy.org.nz | 0800 803 909
- Australia: Office of the Australian Information Commissioner — oaic.gov.au | 1300 363 992
- Other jurisdictions: Contact your local data protection authority.
Regional applicability
| Jurisdiction | Position |
|---|---|
| New Zealand | This notice is designed to meet the notification requirements of Rule 3 of the NZ Biometric Processing Privacy Code 2025. |
| Australia | This notice provides a baseline disclosure under the Privacy Act 1988 (Cth). Additional consent obligations may apply depending on the context of processing. |
| European Union / UK | ClipMine is not currently available in the EU or UK. GDPR Article 9 requires explicit consent from biometric data subjects before processing. Our current service does not meet that requirement. Users visiting from these regions are shown a region restriction page. We are working on a compliant version for these jurisdictions. |
| Illinois / Texas / Washington (US) | ClipMine is not currently available in Illinois, Texas, or Washington. State biometric privacy laws (Illinois BIPA, Texas CUBI, Washington My Health My Data Act) require prior written or electronic consent from biometric data subjects before collection. Users visiting from these states are shown a region restriction page. We are working on a compliant version for these jurisdictions. |
| California (US) | California residents have rights under the California Consumer Privacy Act (CPRA / CCPA). Biometric data is Sensitive Personal Information (SPI) under CPRA §1798.121. You have the right to: (a) know what personal data is collected about you; (b) request correction of inaccurate data; (c) request deletion of your data; (d) limit our use and disclosure of your SPI to purposes reasonably necessary to provide the service; and (e) non-discrimination for exercising your rights. ClipMine does not sell or share personal data. To exercise CPRA rights, email team.clipmine@gmail.com. |
| Rest of world | This notice provides a general disclosure baseline. Specific rights may vary by jurisdiction. |
Changes to this notice
We will update this notice if our processing practices change materially. The date at the top of this page reflects the most recent revision. Continued use of ClipMine after an updated notice is published constitutes acceptance of the changes.
Related documents
- Terms of Service — includes the full data handling schedule and prohibited use restrictions.
- NZ Office of the Privacy Commissioner — Biometric Processing Privacy Code 2025: privacy.org.nz