CLUTCH PRIVACY POLICY
August 8 2025
1. INTRODUCTION
This Data Protection and Privacy Policy ("Policy") describes how Clutch ApS ("Clutch", "we", "our") collects and processes personal data relating to the purchase and use of our products, subscriptions, and services, including the Clutch app and Clutch Live platform, as well as general use of our website and ongoing development of our products and services.
This Policy is prepared to comply with the General Data Protection Regulation (2016/679 of 27 April 2016) ("GDPR") and related data protection rules.
Clutch ApS is the sole data controller for the purposes described in this Policy. Any questions, comments, or enquiries regarding Clutch’s processing of personal data should be addressed to Clutch ApS directly (see Section 15).
2. PURPOSES FOR PROCESSING PERSONAL DATA
We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, personal data may be processed for the following purposes:
To deliver products and services to customers and users
To respond to enquiries or complaints
To store personal data in compliance with applicable laws (e.g., Danish Bookkeeping Act, GDPR)
To send service messages and updates about our products and services
To provide customer support
To send newsletters and marketing communications (subject to consent)
To facilitate sales processes
To improve our products, services, website, and user experience
To develop, train, and validate our AI systems and features
To generally administer the use of our website, app, and platform
To advertise and market our services and products
To establish, exercise, or defend legal claims
3. TYPES OF PERSONAL DATA PROCESSED
Depending on the purpose and circumstances, the personal data we process may include:
Name, address, telephone number, email address
Club affiliation and user role
Purchase history, payment details, invoicing and bookkeeping data
Account details (username, password, account status)
Age (if provided)
IP address, location, login details, and device/browser type
Video and audio recordings from matches and training sessions
Match metadata (date, time, location, participants, scores, statistics)
Behavioural data on platform usage
If we need to process more personal data than listed here, we will inform you separately.
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
We only process personal data when we have a legal basis under the GDPR. Depending on the situation, this may include:
Consent (Article 6(1)(a)): For specific activities like marketing emails or using public content for promotional purposes. You can withdraw consent at any time by contacting us.
Contract (Article 6(1)(b)): Processing necessary to perform our agreement with you.
Legal obligation (Article 6(1)(c)): Processing necessary to comply with applicable law.
Legitimate interests (Article 6(1)(f)): Processing necessary for our business interests, such as developing and optimising our products, services, and features, provided these are not overridden by your rights.
5. MARKETING
If you consent to receive direct marketing (via email, phone, or SMS), we will use your personal data to send targeted communications about our products, services, offers, events, and competitions. You may withdraw your marketing consent at any time by following the unsubscribe link in emails or contacting us.
6. DISCLOSURE AND TRANSFER OF PERSONAL DATA
We only share personal data when permitted by law. Recipients may include:
Subprocessors (e.g., AWS for hosting, Stripe for payment processing)
Service providers (e.g., analytics, customer support tools)
Public authorities when required by law
We store and process EU user data in regional data centres (e.g., AWS Frankfurt for EU). Where data is transferred outside the EU/EEA, it is done in accordance with the European Commission’s adequacy decisions or standard contractual clauses.
7. RETENTION OF PERSONAL DATA
We delete or anonymise personal data when it is no longer needed for its original purpose, unless we are required to retain it by law (e.g., accounting records).
8. DATA SUBJECT RIGHTS
You have the right to:
Access your personal data
Correct inaccurate or incomplete data
Request erasure of your personal data (subject to certain conditions)
Restrict processing in certain situations
Object to processing for direct marketing or on legitimate interest grounds
Receive your data in a portable format
Withdraw consent where processing is based on consent
You can exercise your rights by contacting us (Section 15).
9. COOKIES
We use analytics and marketing cookies to improve our website, personalise content, and deliver targeted advertising. Cookies are set based on your consent. You can change your cookie preferences at any time via your browser settings.
10. CHILDREN UNDER 13
The Clutch app is not intended for children under 13. We do not knowingly collect personal data from children under this age. Parents or guardians who believe their child has provided us with personal data should contact us to request deletion.
11. SOCIAL MEDIA PLUGINS
Our website may use plugins from social media platforms such as Facebook, Instagram, and YouTube. When you interact with these plugins, data is sent directly to those platforms. Please refer to their privacy policies for details.
12. RTMP STREAMING
When you use Clutch Live to stream to third-party platforms via RTMP, you are responsible for enabling streaming and ensuring you have the right to process any personal data in that stream. The third-party platform’s privacy policy applies to their processing of data.
13. SECURITY
We apply reasonable technical and organisational measures to protect personal data from unauthorised access, loss, or misuse. However, no internet-based system is 100% secure.
14. CHANGES TO THIS POLICY
We may update this Policy from time to time. The updated version will be posted on our website with a new "Effective Date". Significant changes may be communicated directly to you.
15. CONTACT
Clutch ApS
Rosenvængets Alle 19, Copenhagen, Denmark
Email: info@clutchapp.io
CLUTCH PRIVACY POLICY
August 8 2025
1. INTRODUCTION
This Data Protection and Privacy Policy ("Policy") describes how Clutch ApS ("Clutch", "we", "our") collects and processes personal data relating to the purchase and use of our products, subscriptions, and services, including the Clutch app and Clutch Live platform, as well as general use of our website and ongoing development of our products and services.
This Policy is prepared to comply with the General Data Protection Regulation (2016/679 of 27 April 2016) ("GDPR") and related data protection rules.
Clutch ApS is the sole data controller for the purposes described in this Policy. Any questions, comments, or enquiries regarding Clutch’s processing of personal data should be addressed to Clutch ApS directly (see Section 15).
2. PURPOSES FOR PROCESSING PERSONAL DATA
We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, personal data may be processed for the following purposes:
To deliver products and services to customers and users
To respond to enquiries or complaints
To store personal data in compliance with applicable laws (e.g., Danish Bookkeeping Act, GDPR)
To send service messages and updates about our products and services
To provide customer support
To send newsletters and marketing communications (subject to consent)
To facilitate sales processes
To improve our products, services, website, and user experience
To develop, train, and validate our AI systems and features
To generally administer the use of our website, app, and platform
To advertise and market our services and products
To establish, exercise, or defend legal claims
3. TYPES OF PERSONAL DATA PROCESSED
Depending on the purpose and circumstances, the personal data we process may include:
Name, address, telephone number, email address
Club affiliation and user role
Purchase history, payment details, invoicing and bookkeeping data
Account details (username, password, account status)
Age (if provided)
IP address, location, login details, and device/browser type
Video and audio recordings from matches and training sessions
Match metadata (date, time, location, participants, scores, statistics)
Behavioural data on platform usage
If we need to process more personal data than listed here, we will inform you separately.
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
We only process personal data when we have a legal basis under the GDPR. Depending on the situation, this may include:
Consent (Article 6(1)(a)): For specific activities like marketing emails or using public content for promotional purposes. You can withdraw consent at any time by contacting us.
Contract (Article 6(1)(b)): Processing necessary to perform our agreement with you.
Legal obligation (Article 6(1)(c)): Processing necessary to comply with applicable law.
Legitimate interests (Article 6(1)(f)): Processing necessary for our business interests, such as developing and optimising our products, services, and features, provided these are not overridden by your rights.
5. MARKETING
If you consent to receive direct marketing (via email, phone, or SMS), we will use your personal data to send targeted communications about our products, services, offers, events, and competitions. You may withdraw your marketing consent at any time by following the unsubscribe link in emails or contacting us.
6. DISCLOSURE AND TRANSFER OF PERSONAL DATA
We only share personal data when permitted by law. Recipients may include:
Subprocessors (e.g., AWS for hosting, Stripe for payment processing)
Service providers (e.g., analytics, customer support tools)
Public authorities when required by law
We store and process EU user data in regional data centres (e.g., AWS Frankfurt for EU). Where data is transferred outside the EU/EEA, it is done in accordance with the European Commission’s adequacy decisions or standard contractual clauses.
7. RETENTION OF PERSONAL DATA
We delete or anonymise personal data when it is no longer needed for its original purpose, unless we are required to retain it by law (e.g., accounting records).
8. DATA SUBJECT RIGHTS
You have the right to:
Access your personal data
Correct inaccurate or incomplete data
Request erasure of your personal data (subject to certain conditions)
Restrict processing in certain situations
Object to processing for direct marketing or on legitimate interest grounds
Receive your data in a portable format
Withdraw consent where processing is based on consent
You can exercise your rights by contacting us (Section 15).
9. COOKIES
We use analytics and marketing cookies to improve our website, personalise content, and deliver targeted advertising. Cookies are set based on your consent. You can change your cookie preferences at any time via your browser settings.
10. CHILDREN UNDER 13
The Clutch app is not intended for children under 13. We do not knowingly collect personal data from children under this age. Parents or guardians who believe their child has provided us with personal data should contact us to request deletion.
11. SOCIAL MEDIA PLUGINS
Our website may use plugins from social media platforms such as Facebook, Instagram, and YouTube. When you interact with these plugins, data is sent directly to those platforms. Please refer to their privacy policies for details.
12. RTMP STREAMING
When you use Clutch Live to stream to third-party platforms via RTMP, you are responsible for enabling streaming and ensuring you have the right to process any personal data in that stream. The third-party platform’s privacy policy applies to their processing of data.
13. SECURITY
We apply reasonable technical and organisational measures to protect personal data from unauthorised access, loss, or misuse. However, no internet-based system is 100% secure.
14. CHANGES TO THIS POLICY
We may update this Policy from time to time. The updated version will be posted on our website with a new "Effective Date". Significant changes may be communicated directly to you.
15. CONTACT
Clutch ApS
Rosenvængets Alle 19, Copenhagen, Denmark
Email: info@clutchapp.io