Three Danish child welfare and consumer groups have filed a complaint with the country’s data authority over CapCut, the wildly popular video editing app that topped Denmark’s App Store charts this week. The organizations warn that the app’s opaque terms let its Chinese-British owner ByteDance harvest user data, including children’s photos and videos, to train AI systems with minimal oversight.
Red Barnet, Børns Vilkår, and Forbrugerrådet Tænk say they filed the complaint after hearing from worried parents about the app, which shares an owner with TikTok and ranks as the most downloaded tool in the photo and video category on iOS. CapCut offers free editing features that fit seamlessly with social platforms like TikTok and Instagram, making it a magnet for young users. But according to the complaint, the app’s terms of service give ByteDance sweeping permission to use uploaded content for purposes ranging from algorithm training to marketing partnerships, all buried in pages of legal language that even adults struggle to parse.
Sørine Vesth Rasmussen, a tech policy advisor at Børns Vilkår, told Danish broadcaster DR that children and teens who use the app have no realistic way to understand what they’re agreeing to when they hit accept. The terms state that user information will be used to improve algorithms and machine learning, a clause that Peter Grønlund Holm, a consumer lawyer at Forbrugerrådet Tænk, says opens the door to serious risks. He argues that with the right prompt, someone could potentially use CapCut’s AI to recreate real images the system was trained on, putting children’s photos at risk of extraction by predators or misuse in voice cloning scams.
A Free App With a Hidden Price
The complaint focuses on four main violations of European data protection law. The groups argue that CapCut’s data practices are opaque, that the company collects far more information than necessary, that it lacks a legitimate interest in using personal data for AI training, and that users cannot easily withdraw consent once given. Amalie Bang, a child rights lawyer at Red Barnet, said even she struggled to trace where the undefined volumes of data mentioned in the terms actually end up.
GDPR rules treat children as especially vulnerable, but CapCut’s age gate sits at just 13 years old and relies on self-reported birth dates that a seven year old could easily fake. The organizations say this puts Danish kids squarely in the crosshairs of a data harvesting operation disguised as a creative tool. Bang told DR that the alarm bells rang so loudly during their review that they needed a formal assessment from Datatilsynet, Denmark’s data protection watchdog, to determine whether ByteDance is breaking the law.
CapCut did not provide a direct comment to DR, instead directing inquiries to its website, which claims the company uses encryption, secure servers, and regular audits to protect user data and complies with all applicable laws. The complaint acknowledges that it will likely be forwarded to Ireland’s data protection commission, since ByteDance’s European headquarters sits in Dublin.
Part of a Broader Pattern
This is not the first time Danish authorities and advocacy groups have raised concerns about apps popular with young people and their data practices. The CapCut case lands amid heightened scrutiny of how tech companies, particularly those with ties to China, handle European user information. Denmark has already seen probes into AI systems accessing patient records and a sharp rise in chatbot use that experts caution could carry privacy risks.
The complaint also underscores a tension I’ve observed repeatedly while covering Denmark: parents and regulators struggle to keep pace with apps that evolve faster than oversight frameworks. CapCut’s integration with TikTok makes it nearly unavoidable for teens who want to participate in online culture, but the price of entry is agreeing to terms written by lawyers for lawyers, not 13 year olds scrolling on their phones.
Whether Datatilsynet will find grounds for enforcement action remains to be seen. But the fact that three major organizations felt compelled to file a joint complaint signals that this is more than a marginal concern. The app’s popularity shows no sign of waning, and ByteDance has so far offered only boilerplate reassurances. For now, Danish kids keep editing their videos, and their data keeps flowing to servers whose ultimate use remains, as the complaint puts it, more or less whatever ByteDance feels like.
Sources and References
The Danish Dream: Meta Ad Ban Hits Danish NGOs Fundraising Efforts
The Danish Dream: Denmark Probes AI Use of Patient Records
The Danish Dream: Use of AI Chatbots in Denmark Skyrockets Experts Caution
The Danish Dream: Mental Health in Denmark for Foreigners
DR: Børneorganisationer og forbrugerråd advarer mod populær app









