Privacy Policy for APP users
Clutch Aps

Introduction

  • 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").
  • 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").
  • Clutch is the data controller in relation to your personal data. You can contact Clutch by using the contact information specified in Section 8.

The data we collect, the purpose and the legal basis for processing

  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 badminton match, which you or another user uploads to the App, 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. 
  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). 
  1. 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.
  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).
  1. 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.

How your personal data is collected

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

Disclosure of your personal data

  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. 

Transfer of your personal data to third countries

  • We will not transfer your personal data to recipients outside EU or EEA unless we have ensured compliance with GDPR Chapter V. 
  • 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.  

Your rigts

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

The right of access by the data subject

  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. 
  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.

The right to rectification

  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.

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

  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 personal 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.

The right to restriction of processing

  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.

The right to data portability 

  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.

The right to object

  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.

The right to lodge a complaint

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

Data Retention

  • 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.

Contact information

  • Clutch ApS is the data controller of the personal data, which are collected about you.
  • 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 no.: 42195030
    Rosenvaengets Alle 19, 4tv
    2100 Copenhagen
    Denmark

    info@clutchapp.io
    +45 61666103
    ‍

Changes to this Privacy Policy

  • We may make changes to this Privacy Policy. You will be notified of any changes the next time you use the App.

Versions

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

‍