PRIVACY POLICY FOR APP USERS

CLUTCH APS

1. INTRODUCTION

1.1. This Privacy Policy is intended to provide you with information on how Clutch ApS,

business registration no. 42195030 ("Clutch", "we", "us", "our"), collect and process your

personal data which you have given to us, or we have collected from you when you use

our app ("App").

1.2. We will only process your personal data in accordance with this Privacy Policy and

applicable law to which we are subject, including the General Data Protection Regulation

(EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the

processing of personal data and on the free movement of such data (hereinafter the

"GDPR").

1.3. Clutch is the data controller in relation to your personal data. You can contact Clutch by

using the contact information specified in Section 8.

2. THE DATA WE COLLECT, THE PURPOSE AND THE LEGAL BASIS FOR

PROCESSING

2.1. When you create an account, we will collect information such as your name and email

address. In addition, we may collect and process video recordings of you playing a

sports match from your court's Clutch Cam, as well as any data generated through Clutch’s

AI software in the App related to your game patterns, such as

shot type, match scores, and other match performance data, etc. We also process any

information related to you when users interact with each other through the App’s social

functionality.

2.1.1. The purpose of our processing is to perform the contract we have entered into

with you (Article 6(1) (b) of the GDPR) and/or to pursue our legitimate

interests in providing the services to our users (Article 6(1) (f) of the GDPR).

2.2. When you use the App, we will collect technical data about your device such as device ID,

operating system used as well as how and where the App is used. This may be

information on the country you use the App in or how much you use a specific function.

The information will be aggregated, and we will not use it to identify you.

2.2.1. The purpose of our processing is maintaining, troubleshooting and developing

improvements and functionalities in the App and in general to improve the

services offered by Clutch. The processing of personal data is necessary for us to

pursue these legitimate interests (Article 6(1) (f) of the GDPR).

2.3. If Clutch should wish to process your personal data for purposes other than those for

which the personal data were originally collected, Clutch will provide you with

information on this new purpose prior to any further processing.

3. HOW YOUR PERSONAL DATA IS COLLECTED

3.1. We will collect the personal data about you from the App.

14. DISCLOSURE OF YOUR PERSONAL DATA

4.1. Your personal data may be disclosed to third parties who process personal data on behalf

of Clutch and therefore acts as our data processor(s). We use third parties such as

hosting providers and providers of data annotation platforms. We have entered into data

processing agreements that comply with article 28 of the GDPR with all our data

processors to ensure that such data processors implement appropriate organisational

and technical security measures in such a way that the processing complies with the

requirements of the GDPR and ensures the protection of your rights.

5. TRANSFER OF YOUR PERSONAL DATA TO THIRD COUNTRIES

6. We will not transfer your personal data to recipients outside EU or EEA unless we have

ensured compliance with GDPR Chapter V.

7. Some of our third-party service providers are established outside the EEA so their

processing of your personal data may involve a transfer of data outside the EEA when

providing maintenance, troubleshooting etc. However, to ensure that your personal data

receives an adequate level of protection, we have ascertained that sufficient safety

measures have been implemented to allow for the transfer, including where the

European Commission have deemed the country to provide an adequate level of

protection for personal data; or by use of specific contracts approved by the European

Commission (Standard Contractual Clauses) which give personal data essentially

equivalent protection as it has in Europe.

8. YOUR RIGTS

8.1. Under certain circumstances, you have one or more of the following rights:

8.2. The right of access by the data subject

8.2.1. You have the right to request information from us regarding the personal data

we are processing about you, which purposes the processing serves, what

categories of personal data and recipients of personal data there might be, as

well as information on where the personal data has been obtained.

8.2.2. You have the right to receive a copy of the personal data that we process about

you and to check that we are lawfully processing it. If you want a copy of your

personal data, you must submit a written request to us by using the contact

information specified in Section 8. You may be asked to provide documentation

for proof of identity.

8.3. The right to rectification

8.3.1. You have the right to request correction of your personal data that we hold

about you. If you become aware that the personal data we process is inaccurate,

we encourage you to contact us in writing which will enable you to have any

incomplete or inaccurate information we hold about you corrected.

8.4. The right to erasure ("the right to be forgotten")

8.4.1. You may have the right to request erasure of your personal data. This enables

you to ask us to delete or remove personal data where there is no good reason

for us continuing to process it. To the extent the continued processing of your

2personal data is necessary, for example in order for us to comply with our legal

obligations or for legal requirements to be established, enforced or defended,

we are not required to delete your personal data.

8.5. The right to restriction of processing

8.5.1. You may have the right to request the restriction of processing of your personal

data to consist only of storage. This enables you to ask us to suspend the

processing of personal data about you, for example if you want us to establish

its accuracy or the reason for processing it.

8.6. The right to data portability

8.6.1. You may have the right to obtain personal data that you have provided us with,

in a structured, commonly used, machine-readable format and have the right to

request a transfer of that information to another data controller.

8.7. The right to object

8.7.1. Furthermore, you have the right to object to our processing of your personal

data at any time, for reasons relating to your personal life, where we are relying

on a legitimate interest as legal basis for processing, cf. Section 2.1.

8.8. The right to lodge a complaint

8.8.1. You have the right to complain to your local data protection authority at any

time, if you are dissatisfied with our data protection practices. In Denmark you

can lodge a complaint with Datatilsynet, for example by email

dt@datatilsynet.dk or via phone +45 33 19 32 00.

8.8.2. You can read more about how to lodge a complaint on Datatilsynet’s website

here.

9. DATA RETENTION

9.1. Personal data about your use of the App, cf. section 2.1 and 2.2, will be deleted at the

latest 1 year after you delete your account.

10. CONTACT INFORMATION

10.1. Clutch ApS is the data controller of the personal data, which are collected about you.

10.2. If you have any questions regarding this Privacy Policy or wish to exercise your rights

pursuant to Section 6, please use the contact information set out below:

Clutch ApS

CVR nr.: 42195030

Rosenvaengets Allé 19, 4tv

2100 Copenhagen

Denmark

info@clutchapp.io

+45 61666103

311. CHANGES TO THIS PRIVACY POLICY

11.1. We may make changes to this Privacy Policy. You will be notified of any changes the next

time you use the App.

12. VERSIONS

12.1. This is version 1 of Clutch's Privacy Policy of 4 February 2022.

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