Momentum / cinemaOS
Privacy

Privacy / 24 September 2026

Privacy notice.

Version privacy-2026-09-24, published 24 September 2026. Earlier notices remain available in our legal archive. This notice does not reduce your GDPR rights.

1. Controller

Julien Kerknawi, trading as Momentum Studios, Belgian sole trader, enterprise number 0648.946.826, VAT BE0648946826, is controller for the Momentum account and cinemaOS service. Registered establishment: Jules Van Biesbroeckstraat 156, 9050 Gent, Belgium. Privacy contact: privacy@mntm-studios.com.

Momentum is established in the EEA and does not require an Article 27 representative. Its core activities do not involve large-scale special-category processing or large-scale regular and systematic monitoring, so no data protection officer is appointed. Privacy requests are handled directly by the controller.

2. Local processing and data we do not receive

cinemaOS projects, footage, audio, frames, transcripts, prompts, embeddings and bundled AI output stay on your Mac. Momentum does not receive them for product operation, analytics or model training. There is no advertising SDK, third-party analytics SDK or automatic crash-reporting SDK in the app.

3. Account and security data

We process email address, normalized email, password verifier, account and plan state, accepted legal versions and timestamps, referral records, education decision metadata, device public-key material, entitlement and session records, IP-derived security events and audit records. One-time tokens are stored as keyed hashes. We never store your password in readable form.

Purpose and legal basis: perform the account and licence contract; take requested pre-contract steps; protect the service and prevent fraud under legitimate interests; and meet tax, accounting, consumer and security obligations.

4. Billing and tax

Stripe processes card data, billing address, VAT number, payment, subscription, invoice and tax-calculation information. Momentum receives Stripe customer and subscription identifiers, plan, payment status, period end and event records, but not full card numbers. Processing is necessary for the contract and legal accounting and tax duties. Stripe may also act as an independent controller for its regulated payment and compliance activities.

5. Account and optional email

Resend processes destination address, sender, subject, message content, delivery events and technical logs for verification, password reset, security, billing and service notices. These account messages are necessary to operate the service and arrive whether or not you choose marketing email. Email delivery is configured through Resend’s Ireland sending region, while Resend states that account, email metadata, logs and API records may be stored in the United States.

If you separately opt in to “news, tips and the occasional offer”, we use your email address, first name, selected mail language and trial end date to send occasional cinemaOS news and offers. The legal basis is your consent. The sign-up choice starts unticked; an earlier “product news” choice does not count as permission to send offers. We record your choice, its time, the exact notice version and the privacy version shown to you. You can withdraw at any time through the unsubscribe link in every marketing email or under Privacy & data in your account. Withdrawal does not affect messages about your account, billing or support.

Offer mail is sent through a separate Resend marketing account and verified news.mntm-studios.com sender domain. We do not use marketing opens or clicks for tracking. We use a campaign queue, delivery status, suppression records and a tokenised one-click unsubscribe to honour your choice, avoid repeated sends and handle delivery problems. A discount card inside your signed-in account may still appear when you are eligible, regardless of your email choice.

6. Optional crash reports

Crash upload is currently disabled. If enabled later, it will require a separate explicit opt-in and send only the displayed, scrubbed diagnostic envelope to a private EU-jurisdiction bucket for no more than 30 days. Raw local reports can contain paths or exception text and will not be uploaded. Declining has no effect on account access.

7. Education applications and referrals

Education review may process institution, role, eligibility period and evidence chosen by the applicant. A human makes the material decision. Raw evidence is limited to authorized reviewers and deleted 30 days after decision, or after 90 days if incomplete; decision metadata is retained for the account lifetime plus 24 months. Referral codes and reward events are processed to operate the requested program and detect duplicate or fraudulent use.

8. Website, application and support

The account portal uses strictly necessary security and session mechanisms, including Cloudflare Turnstile. Cloudflare processes request, network and security data at its edge. We do not use advertising cookies. The app stores preferences and update state locally. If you contact support, we process your message, contact details and any files you deliberately provide to answer and document the request.

9. Processors, locations and safeguards

  • Cloudflare hosts the portal, Worker, EU-jurisdiction D1 account database, private EU-jurisdiction crash bucket and update distribution. Edge security and delivery can involve processing outside the EEA. See Cloudflare’s customer DPA and subprocessor disclosures.
  • Stripe Payments Europe Ltd provides payments, subscriptions, invoicing and Stripe Tax. See Stripe’s DPA and its incorporated subprocessor information.
  • Resend provides account email and, through a separate marketing team, optional news and offers. See Resend’s DPA and subprocessor list.

Transfers outside the EEA use applicable adequacy decisions, the EU–US Data Privacy Framework where valid and applicable, or European Commission Standard Contractual Clauses with supplementary measures. We may disclose data to authorities where legally required and to professional advisers bound by confidentiality.

10. Retention

  • verification links: 30 minutes; password-reset links: 15 minutes;
  • access sessions: 15 minutes; rotating refresh sessions: 30 days;
  • security, webhook and audit records: only as long as reasonably needed for integrity, fraud defence and legal claims, then pruned or anonymized;
  • optional scrubbed crash reports, if enabled: 30 days;
  • education data: as stated in section 7;
  • billing, invoice and tax records: the period required by Belgian law;
  • marketing consent and unsubscribe receipts: for the account lifetime, removed when the account is erased subject to legal retention;
  • offer mail recipient address and first name in the delivery log: cleared seven days after a final delivery status; campaign delivery rows: folded into campaign totals and removed twelve months after the campaign cutoff; staff test-send rows: ninety days;
  • marketing suppression records: kept while needed to prevent another unwanted send, and removed with account erasure where applicable;
  • other account data: deleted or irreversibly anonymized within 30 days of a valid deletion request, subject to legal retention and fraud-defence needs.

11. Security

Controls include salted and peppered password derivation, hashed bearer and one-time tokens, P-256 device proof, signed offline entitlements, encrypted transport, least-privilege secrets, rate limits, human verification, isolated beta and production databases, and signed application updates. Email links place one-time secrets in browser fragments to keep them out of portal request logs. No system is risk-free; confirmed incidents are assessed and notified as required.

12. Your rights

Subject to GDPR conditions, you may request access, correction, deletion, restriction or portability, object to legitimate-interest processing, and withdraw consent without affecting earlier lawful processing. Email privacy@mntm-studios.com. We may verify identity and normally respond within one month, extendable where permitted.

You may complain to the Belgian Data Protection Authority at dataprotectionauthority.be or to the supervisory authority where you live or work.

13. Automated decisions, marketing and children

Device, rate-limit and entitlement rules can automatically reject an action, but material education and abuse decisions receive human review. We do not conduct profiling that produces legal or similarly significant effects. Optional news and offer email requires separate affirmative consent, with an unsubscribe route in every such message. We do not sell your email address or use marketing opens or clicks for tracking. cinemaOS is not directed to children and account holders must be at least 18.

14. Changes and contact

Changes are published under a new immutable identifier and presented again where consent or notice is required. Questions and rights requests: privacy@mntm-studios.com. Support: support@mntm-studios.com. The corresponding terms are terms-2026-09-24-v2.