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
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.
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.
4
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
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.
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.
4