Clutch Inc. Privacy Policy

Modified: August 9, 2018

Clutch Inc. was founded to help protect people; that includes protecting the privacy of those who use our products and services.  When we gather any of your information, we are focused on using it to improve our services to enhance your ability to protect yourself and others.  We are not just the makers, marketers, and maintainers of our services.  We are also users.
-The Clutch Team  

Your privacy, and the privacy of all users of Clutch software, websites, and services (collectively, the “Services”) is important to us.

Information for Parents or Legal Guardians  

Clutch does not encourage the use of our Service by children under the age of thirteen.  We encourage parents and guardians to actively protect their children’s online privacy.  To learn how you can protect your child’s online privacy and about US guidelines around protecting child privacy online, please visit OnGuard Online.

In your use of the Services, we may ask for and collect various amounts and kinds of information such as that more fully described below.  This policy (“Privacy Policy”) describes our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:
+On our websites
+In e-mail, text and other electronic messages between you and Clutch.
+Through mobile, desktop, or any other applications you download from our Website, which provide dedicated non-browser-based interaction between you and this Website or our other services.
+When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this website.
+On our applications, mobile or otherwise, you may download from third party distributors.
+How we use and with whom we may share that information.
+How and why we collect that information
+Your ability to update and access that information
+The choices you can make about how we collect, use, and share your information.

It does not apply to information collected by:
+Clutch Inc. offline or through any other means, including on any other website operated by Clutch or any third party (including our affiliates and subsidiaries); or
+Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website or applications.

This Privacy Policy does not apply to the practices of third parties we do not own or control, including third party websites, services and applications (collectively, “Third Party Services”) that you may elect to access through the Service or to individuals that we don’t manage or employ. Please read this Privacy Policy carefully, and contact us at privacy@ClutchSOS.com if you have questions.  Our Privacy Policy is incorporated into and is a part of the Clutch Terms of Service (“Clutch Term of Service”).  Any terms not defined in our Privacy Policy can be found in the our Terms of Service.

If you decline to submit any information through the Service, we may not be able to provide you our Service.

1) INFORMATION WE COLLECT

PERSONAL INFORMATION

We collect personally identifiable information (“Personal Information”) about you and your use of the Service, as described in more detail below:

Registration Information

When you create an account to use the Service (an “Account”), you must provide information including:

+Birth date
+Profile picture
+First name (given name) and last name (surname)
+Mobile phone number
+Email address
+Password

Other User Information

Additional personal information we may request and collect in connection with use of the Service, includes but is not limited to the following:

+Profile information, such as gender, height, weight, hair color, and personal relationships
+Medical conditions or other conditions
+Your belief about how society is likely to perceive your ethnicity
+Audio, image and video recordingsBilling information
+Any information you provide to us through information pages, feedback pages, help tickets, email correspondence, dispute resolution, or any information shared by you via third party applications, services, or websites.

Geospatial Information
We collect unique user identifier and location information through GPS, Wi-Fi, or via wireless network triangulation to identify your location as a part of providing our Service.  If your location services are turned off for the app we may be unable to locate you and the Service may not work properly.  We may collect location information whenever location services are available to the app.  We use this information to share your location with others using the Service to improve your safety.

Messages and User Generated Content  

For purposes of customer service and provision of Service, we may retain correspondences or copies of messages you send us.  We also gather information whenever you send content to other Users via our Service.

Your Information Generated by Other Users

We may receive information about you from other users of the Service, such as when they invite you to join their network.

Information You Provide About Your Third Party Accounts

You may be able to link your Account to certain Third Party Services via you username on those Third Party Services. This includes cases in which you use an authorization process with those Third Party Services.  In the case of these authorizations, we may receive one or more tokens allowing us access to some portion of information regarding those accounts.  We never receive nor do we store the passwords used for Third Party Service accounts.

Information Obtained Via Third Party Services  

We may receive information about you, including but not limited to geospatial data and demographic data, from third parties as permitted by law.  We may use that information to personalize and enhance the Service.

Security Methods

No security methods are perfect and unbeatable.  No security measures are absolute and impenetrable. Users with whom you choose to share your information are outside of our control, and we cannot prevent any misdeeds they may commit. The security of your personal information and the data you generate in using Service, and protecting it is important to us.  We use various precautions and safeguards including physical, administrative, and technological safeguards to preserve the integrity and security of any information we collect and any information we may share with our service providers. Again, no security system is perfect or unbeatable.  No security measures are absolute or impenetrable.  We cannot and do not guarantee perfect and impenetrable security. We cannot and do not guarantee that unauthorized persons won’t find a way to access your data. However, if we ever learn of a breach of security or that User information has been compromised in any way, we will take reasonable steps to ascertain the situation.  When appropriate, we will notify those Users who have had their information compromised.  Further, in accordance with applicable laws and regulations we will prosecute unauthorized actors to the fullest extent of the law.  To be clear, Clutch employees also use Services and view any attack on your data as an attack on their data.  We will not tolerate misuse of the information Users provide Clutch.  Please do not hesitate to report any violations of Service terms to privacy@ClutchSOS.com. ADDITIONAL INFORMATION WE COLLECT We gather, non-personally identifiable information about you and your use of the Service, as described in more detail below, including by using “cookies,” web beacons, local shared objects, or other types of tracking technology (collectively “Non Personal Information”).

Log Data

Our servers may automatically record log data information (“Log Data”) from anyone who uses the Service.  Log Data may contain details such as your IP address, browser type, browser language, the address of a web page you visited before you found to the App, the date and time of your requests and cookies helping us recognize your browser. Other actions, such as interactions with our Service, may also be included in the Log Data.  Such data helps us determine for which browsers we should optimize our site and Service, for instance.

Your Device’ Information

We also gather information about the device through which you’re using the Service, including the type of device, the operating system being used, device settings and unique device identifiers.  This information may help us determine for which device models we should optimize or support the Service, for instance.

KEY WAYS WE USE INFORMATION WE COLLECT

We may use both Personal Information and Non-Personal Information collected from you in any one or more of the following ways:

+Register your Account;
+Service your Account;
+Administer the Service;
+Improve the Service;Resolve disputes;
+Troubleshoot problems;
+Pre-empt, prevent, discover, detect, investigate, and eradicate potentially prohibited or illegal activities, as well as enforce our Service terms;
+Compare information for accuracy,Verify it with third parties;
+Maintain internal records, for tracking and business purposes;
+To contact you to respond to your questions or requests or to provide you with technical support;
+To provide you with information regarding changes to the Service which may affect your Account, your use of the Service, and/or the products and services available through the Service;
+To customize the user experience of the Service;
+To analyze trends, track user movement and gather statistical information for aggregate use; and
+To promote the Service or customize advertising that may be visible to you in connection with the Service.

HOW WE SHARE OR DISCLOSE INFORMATION COLLECTED FROM YOU

We do not rent, lease, or sell your Personal Information to third parties outside of Clutch Inc. and its subsidiaries and affiliates (collectively “Company”) without your consent, except as noted below.

Your information may be shared as follows:

Other Users  

We may share your Personal Information, including name, location, email, and other information with Users of the Service in connection with a Clutch Alert as defined below.

Safety, Security and Legal Compliance

We may disclose any information, including Personal Information, to first responders, safety personnel, law enforcement, governmental agencies, or authorized third-parties, in response to: (1) an alert notification message sent by, or initiated in connection with, the Service (a “Clutch Alert”); or (2) a request relating to one or more criminal investigations, including investigations of any illegal activity, fraud, or any activities that may expose us, you, or any other User or person to physical harm or legal liability.

In any such events, we may disclose any information we may deem relevant to the emergency response or investigation.  Without limiting the above, we respect your privacy and strive to keep the Clutch community respectful, legally compliant, and free from any bad actors, so we will not otherwise disclose your personal information to government officials, law enforcement agents, private detectives, or other third parties after a Clutch Alert unless we’re served with a subpoena or similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to protect the rights, property, or safety of our Users, our Company or others.

Business Transfers

We may, at any time sell or divest the Company, as well as any combination of the assets, products, and services, of the company and its subsidiaries. Personal Information such as the types listed above (user name, email, etc.) and other user information related to the Service may be one of the items transferred in such transactions. Such information may also be transferred or assigned, in the case of such transactions and proceedings such as corporate acquisitions, bankruptcies, dissolutions, divestitures, mergers, or the like.

To Service Providers Performing On Our Behalf

We may contract with third party companies to perform services for us or on our behalf.  Such services include, but are not limited to accounting, customer service, data analysis, hosting, managerial, marketing, messaging, or various operations.

Testimonials

We may post your user testimonials.  These may contain some Personal Information.  If you would like to request that your testimonial be removed, please don’t hesitate to email us. at privacy@ClutchSOS.com.

UPDATE YOUR PERSONAL INFORMATION

You may review and change some of your Personal Information and Non-Personal Information by logging into your Account and updating your Account profile.

If you want to delete your account, or if your child has accidentally signed up for Clutch and entered Personal Information, you may contact us in writing at accounts@ClutchSOS.com with the subject “Please Delete My ClutchSOS Account.”

In any your correspondence with Clutch Inc., please include your name and email address.  If corresponding on behalf of your child, please include your child’s name, email address and your  name, email address and telephone number.  To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any user’s personal information.

Deleting your Account may not remove all content from our systems immediately, copies, caches, backups, and other references to your Account may persist for some period of time and not be removed immediately.  However, we reserve the right, at our discretion, to anonymize, compile, delete, destroy, purge, sanitize, and reconfigure any and all information collected by our Service.

GENERAL TERMS

Links to Third Party Apps, Websites and Services.  

We are not responsible for the practices employed by third party websites or other applications or services linked to or from the Service nor the information or content contained therein.  When you navigate away from the Service to another application or website, our Privacy Policy is no longer in effect.

Changes to This Policy.  

It is our policy to post any changes we make to our privacy policy on this page. If we make major changes to how we treat our users’ personal information, we will notify you by e-mail. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

California Statutory Rights.  

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail at privacy@ClutchSOS.com.

Clutch will provide notice of the categories of information shared together with list of any third parties with which we have shared such data.  If you choose to opt-out or would like a copy of this notice, please submit a written request to the following address: Clutch Inc., California Resident Privacy Request, c/o Clutch Privacy Department 40 South 7th Street, Suite 212-149, Minneapolis, MN 55402.  Please allow 45 business days for a response.

Clutch will to take reasonable steps to protect your Personal Information from alteration, destruction, disclosure, loss, misuse, and unauthorized access. While Clutch has taken appropriate electronic, managerial, and physical procedures to safeguard and secure Personal Information, Clutch cannot guarantee the security of Personal Information on or transmitted via the Internet.

Clutch holds a periodic self-assessment of its approach to privacy and continued compliance with this Privacy Policy and that it is accurate.