Clutch Privacy Policy

Effective Date: June 9, 2026

This Privacy Policy explains how Clutch (“we,” “us,” or “our”) collects, uses, stores, and shares information when you use the Clutch mobile application and related services (the “App”).

By using the App, you acknowledge the practices described in this Privacy Policy.

1. Overview

Clutch is designed primarily as a local-device mobile game experience. Depending on the features you use, the App may process gameplay data, locally stored preferences, device sensor input, advertising-related data, and content you choose to share.

The App is not intended for children.

2. Information We Collect

A. Information Stored Locally on Your Device

The App may store game-related information locally on your device, such as:

• tournament progress;

• selected sport and gameplay settings;

• language and haptics preferences;

• team, club, roster, trophies, finances, and simulation state;

• other app state needed to resume your experience.

This information is generally stored on-device to support gameplay continuity and user preferences.

B. Device and Usage Information

Depending on your device, platform, and enabled SDKs, the App or its third-party service providers may collect limited technical information such as:

• device type and operating system;

• app version;

• general diagnostic or crash information;

• advertising identifiers or similar device identifiers, where permitted;

• approximate interaction data related to ad delivery, performance, fraud prevention, or service reliability.

This information may be collected automatically by the App, the operating system, app stores, or integrated SDK providers.

C. Sensor Data

The App may access motion-related device sensor information, such as accelerometer input, to support gameplay or celebration effects. This sensor data is used for in-app functionality and is not intended to identify you personally.

D. Shared Content

If you use the App’s share features, the App may generate screenshots or other shareable content on your device. Sharing occurs only when you choose to initiate it through your device’s native sharing tools.

E. Information from Third Parties

Third-party advertising, platform, or sharing tools integrated into the App may collect information in accordance with their own privacy policies.

F. Information Sent for AI-Powered World Cup Predictions

If you use the App’s OpenAI-powered World Cup prediction feature, the App may send limited scenario data to OpenAI, such as:

• match identifiers;

• team names and group information;

• tournament structure and prediction instructions;

• a pseudonymous app installation identifier used for service integrity and abuse prevention.

This feature is used only when you actively invoke the applicable World Cup simulation AI function. It is not required for ordinary gameplay.

3. How We Use Information

We may use information to:

• provide and operate the App;

• save your progress and preferences;

• enable gameplay systems, simulations, and event prediction features;

• support in-app sharing features;

• generate AI-powered World Cup simulation results and explanations when you request them;

• display and manage advertisements;

• maintain security, detect abuse, and prevent fraud;

• improve performance, stability, and user experience;

• comply with legal obligations and enforce our terms.

4. How We Share Information

Download the Medium App We do not sell your personal information in the ordinary sense of directly exchanging it for money. However, we may share information in the following circumstances:

• with service providers and SDK partners that support ads, analytics, sharing, diagnostics, or app functionality;

• with platform providers such as Apple or Google where necessary for app distribution or operation;

• when required by law, regulation, legal process, or government request;

• to protect rights, safety, security, users, or the public;

• in connection with a merger, acquisition, restructuring, financing, or sale of assets.

5. Advertising

The App may use third-party advertising services, including Google AdMob. Consistent with the capabilities of such services, advertising providers may use device information, advertising identifiers, IP address, approximate location derived from IP, app interaction signals, and related technical data to:

• deliver and display ads;

• limit ad frequency;

• measure ad performance and campaign effectiveness;

• detect invalid traffic, abuse, or fraud;

• provide contextual or, where permitted, personalized advertising.

Where required by applicable law or platform requirements, personalized advertising depends on applicable permissions, consent signals, or device settings. Even when personalized advertising is disabled or unavailable, advertising providers may still process certain technical data for basic ad delivery, security, frequency capping, aggregated reporting, and legal compliance.

Your device or platform may allow you to limit ad tracking, reset advertising identifiers, deny app tracking permission, or opt out of certain forms of personalized advertising.

On iOS, the App may request permission under Apple’s App Tracking Transparency framework before enabling tracking-related advertising functionality where applicable.

At this time, any personalized advertising is intended to be shown only where a user has provided any required consent or permission.

6. AI Usage Limits

To protect service stability and manage misuse, certain AI-powered features may be subject to usage limits. For example, the OpenAI-powered World Cup simulation feature may be limited per device per day.

7. Data Retention

Locally stored gameplay and preference data may remain on your device until you delete the App, clear app data, or use in-app reset or deletion features, if available.

Retention periods for third-party service providers are governed by their own policies unless we specify otherwise.

8. Children’s Privacy

The App is not directed to children under the age at which personal data processing requires parental consent under applicable law, unless expressly stated otherwise. If we learn that we have collected personal information from a child in a manner inconsistent with applicable law, we will take reasonable steps to delete or limit that information as appropriate.

If you believe a child has provided personal information in violation of applicable law, please contact us so we can review the issue.

9. International Use

If you use the App in a jurisdiction different from where the App provider or its service providers operate, your information may be processed in other countries, subject to applicable legal safeguards where required.

10. Your Rights and Choices

Depending on your jurisdiction, you may have rights regarding personal information, including rights to:

• access;

• correct;

• delete;

• restrict certain processing;

• object to certain processing;

• withdraw consent where processing is based on consent;

• lodge a complaint with an appropriate authority.

You may also be able to control certain data practices through your device settings, such as language preferences, motion permissions, ad tracking settings, or app deletion.

11. Security

We use reasonable measures designed to protect information processed through the App. However, no method of storage, transmission, or electronic processing is completely secure, and we cannot guarantee absolute security.

12. Third-Party Services

The App may link to or rely on third-party services, SDKs, tools, or websites. Their privacy practices are governed by their own policies, not this Privacy Policy. We encourage you to review the privacy policies of those third parties, including:

• Google AdMob / Google Privacy Policy

• OpenAI Privacy Policy

• Apple App Store and iOS platform privacy information

• Google Play and Android platform privacy information

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the App, a website, or app store materials. Your continued use of the App after an updated Privacy Policy becomes effective means you acknowledge the revised policy.

14. Contact

If you have questions, requests, or concerns about this Privacy Policy, you may contact us at:

Email: ground171717@gmail.com

Business Name: Ground17