Clutch Privacy Policy

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 data controller for the purposes described in this Policy, except where Clutch processes personal data on behalf of a customer as a data processor under an applicable Data Processing Agreement. Any questions, comments, or enquiries regarding Clutch's processing of personal data should be addressed to Clutch ApS directly (see Section 15).

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

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) • Booking and participant information received from clubs or supported booking integrations • Behavioural data on platform usage

If we need to process more personal data than listed here, we will inform you separately.

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.

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.

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 use infrastructure and service providers in the EU/EEA and other countries. Certain processing may take place outside the EU/EEA, including in the United States. Where required by applicable data protection law, appropriate safeguards are used for international transfers.

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).

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 • Lodge a complaint with the relevant data protection supervisory authority

You can exercise your rights by contacting us (Section 15).

We use strictly necessary cookies to run the website, plus analytics and marketing cookies (Google Analytics, Google Ads, Meta Pixel and PostHog) to improve our website, personalise content, and measure advertising.

If you visit us from the EEA, the UK or Switzerland, analytics and marketing cookies are only set after you accept them in our cookie banner. Declining leaves only the strictly necessary cookies in place, and the website continues to work normally.

You can change or withdraw your choice at any time using the "Cookie preferences" link in the website footer, or by clearing cookies via your browser settings.

The Clutch app is not intended for account registration by children under 13. Because Clutch cameras are used at sports venues, recordings may include minors. Where another organisation acts as controller for a recording, that organisation is responsible for satisfying applicable requirements relating to that processing.

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.

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.

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.

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.

Clutch ApS, Rosenvængets Alle 19, Copenhagen, Denmark. Email: info@clutchapp.io