Legal

Privacy Policy

Version 1.2 Effective 13 August 2026 Zachary Stephens trading as ClutchUp

Effective date: 13 August 2026 · Version: 1.2

1. Who we are

ClutchUp is operated by Zachary Stephens trading as ClutchUp, a sole trader based in the United Kingdom ("we", "us", "our"). We are the data controller for the personal data described in this policy.

If you are unhappy with how we handle your data, please contact us first so we can try to put it right. You also have the right to complain to the UK Information Commissioner's Office (ICO) at any time: ico.org.uk, or by phone on 0303 123 1113.

2. What this policy covers

This policy explains what personal data the ClutchUp mobile app collects, why we collect it, the legal bases we rely on under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, who we share it with, how long we keep it, and the rights you have.

3. The data we collect

Account data

  • Email address, password (stored only as a secure hash by our authentication provider — we never see your password), and your sign-in method.
  • If you sign in with Google (or Apple, where offered), we receive your name, email address, and account identifier from that provider.
  • Profile details you choose to add: your name, date of birth, learning stage, theory/practical test dates.
  • Your unique share code — a randomly generated code shown in your Settings that a driving instructor can use to send you a connection request (see section 7). The code identifies your account for that purpose only; on its own it gives no one any access to your data.

Onboarding personalisation answers

When you first set up the app we ask a few optional questions: roughly when your driving test is (e.g. booked and coming up, or not booked yet), how you are learning (instructor lessons, private practice, or both), and which areas of driving you most want to work on (e.g. observation, speed control, nerves). These are stored on your profile and used to personalise the app — the framing of your feedback, your onboarding plan, and which tips you see. Your stated focus areas are also included when we generate your drive debrief so the feedback connects to your goals (see section 5).

Drive telemetry (recorded only while you are actively recording a drive)

  • GPS location trace (latitude/longitude, speed, heading, accuracy).
  • Motion-sensor readings (accelerometer and gyroscope).
  • Timestamps and derived metrics (distance, duration, detected driving events such as harsh braking).
  • On guided routes, if mirror-check detection is enabled: derived mirror-check results — numbers, timestamps and labels only, never images (see section 6).

Road-facing camera images (optional — see section 6)

  • A pre-drive "road check" still image, used to confirm the phone is mounted facing the road.
  • During a drive, a small number of still images ("keyframes") captured at detected driving events. Continuous video is not recorded or uploaded: frames are held briefly on your device and discarded unless they are linked to a detected event.

Front-camera (driver-facing) processing (optional — see section 6)

  • Used only when you choose the "Telemetry + road + face view" analysis mode, for mirror-check detection. No facial images are ever uploaded or transmitted — analysis happens on your device and only derived results (numbers, timestamps and labels) leave it.
  • Where a result is uncertain, a short video clip may be stored temporarily on your device only, so you can review the moment yourself. It is never uploaded, and it is deleted after you review it or within 48 hours, whichever comes first.

Voice memos (optional, where available)

  • Short audio clips you deliberately record during a drive to flag a moment for your debrief.

Instructor account data (instructor accounts only)

  • If you create an instructor account we collect your name and email address. Your name and email are shown to any student you send a connection request to, so they can recognise you before deciding whether to accept.

Payment data

  • Payments are handled by Stripe through a secure web checkout. We never see or store your card details. We store your subscription status, plan, and a Stripe customer reference.

Diagnostics and usage

  • Crash reports and error logs (via Sentry) including device model, OS version, and the technical state of the app when a fault occurred.
  • Basic usage records needed to run the service (e.g. how many analysed drives you have used on the free tier).

We do not collect your home address. We do not use advertising SDKs and we do not sell personal data.

Under UK GDPR we must have a legal basis for each use:

  • Providing the service (contract): recording your drives, generating your AI debrief, showing your history and progress, managing your account, and providing customer support.
  • Personalising the app (contract & legitimate interests): using your onboarding answers to tailor your plan, tips, and the framing of your feedback.
  • Billing (contract & legal obligation): managing subscriptions through Stripe and keeping the records we are required to keep for tax and accounting purposes.
  • Camera, microphone, and precise location (consent): these are collected only after you grant the relevant device permission, and you can withdraw that permission at any time in your device settings (see section 6).
  • Mirror-check detection (consent): front-camera processing runs only if you have granted camera permission and leave the feature enabled. We explain it before your first guided drive, and you can turn it off at any time in Settings (see section 6).
  • Sharing with your driving instructor (consent): we share your data with a connected instructor only after you explicitly accept their request, and you can withdraw that consent at any time by disconnecting them (see section 7).
  • Safety, security and fraud prevention (legitimate interests): keeping the service secure, enforcing our free-tier limits, and preventing misuse.
  • Improving the app (legitimate interests): using diagnostics and crash reports to fix faults and understand how features perform. Where we rely on legitimate interests we balance them against your rights, and you may object (section 11).

5. AI processing of your drive data

To generate your examiner-style debrief, we send your drive telemetry (and, if the camera feature was used, the event-linked keyframes and the road-check image) to our AI provider, Anthropic (the Claude API), which processes it on our behalf to produce the analysis. The analysis request also includes your derived mirror-check results (numbers only — see section 6) and the focus areas you told us about during onboarding, so the feedback can connect to your goals; the debrief text may therefore refer to those focus areas. We send what is needed to produce the debrief and nothing more; your email address and account identity are not included in the analysis request.

AI-generated feedback can be wrong or incomplete. It is provided for learning purposes and is not driving instruction (see the Terms & Conditions).

Improving ClutchUp: we may use drive telemetry and images that have been de-identified (stripped of account identifiers) to evaluate and improve ClutchUp's analysis quality. We do not permit our AI provider to train its models on your data. You can opt out at any time by emailing clutchup.support@gmail.com, and opting out does not affect your use of the app.

6. Camera, location and microphone — a special note

These are the most privacy-sensitive things the app touches, so to be explicit:

  • Rear camera (road-facing). If you enable it, the rear camera acts as a road-facing dashcam view. Images may incidentally capture the road scene around you — other vehicles, number plates, and passers-by. Only the pre-drive road-check image and a capped number of event-linked keyframes are uploaded; everything else is discarded on the device. You are responsible for mounting and using the camera lawfully and for any passengers' awareness of it. The camera is optional: you can decline the permission or choose "telemetry only" before any drive and still use ClutchUp.
  • Front camera (mirror-check detection). Only in the "Telemetry + road + face view" analysis mode, which you choose before each drive (see "Analysis modes" below). On guided routes the app opens a short window as you approach a planned manoeuvre; on free drives it does the same as you approach a junction detected from map data. Each window lasts around 20 seconds at most, and there is a limit of 15 per drive. Snapshots are analysed entirely on your device using Apple's on-device Vision framework to measure head movement. No facial images are ever uploaded or transmitted. Only derived results are uploaded with your drive data: whether a check was detected, head-turn angle summaries, timestamps, the turn's location, and a per-turn outcome. If you approach a junction but drive straight on, the window is discarded entirely — no result is kept and any frames are deleted immediately.
  • Pre-drive face check. In this mode, before the drive starts the app takes a few front-camera snapshots to confirm the camera can actually see you, and tells you how to adjust the mount if not. These are analysed in memory and immediately discarded — neither the images nor the result are stored or uploaded. If it cannot see you, you can still drive in a lower mode.
  • Review clips (on your device only). When a mirror check is uncertain, the app keeps a short clip of that moment (about 6 seconds before and 2 after) in private storage on your phone so you can judge it yourself. These clips are never uploaded, never sent to any AI service, never included in your drive analysis, and never added to your photo library. They are deleted as soon as you review them, or automatically after 48 hours, whichever comes first — and also when you delete the drive or your account, or change analysis mode. Connected instructors can never see them. Only your yes/no answers and the numeric results are stored.
  • Analysis modes. You choose before each drive how much the app analyses, and camera use is entirely optional: Telemetry only (sensors and GPS; no camera is opened at all), Telemetry + road view (adds the rear camera), or Telemetry + road + face view (adds the front-camera mirror checks described above). Your choice is shown during the drive and stated on your debrief, so a missing section is always explained.
  • Location. GPS is recorded only while a drive is being recorded, including in the background during that drive so your route is complete. Your current coordinates are also used, live, to display the map and the road's speed limit. Location has no purpose in the app outside recording and planning drives.
  • Microphone. Used only if you deliberately record a voice memo.

You can withdraw any of these permissions in your device settings at any time; the related features will stop working but the rest of the app remains usable.

7. Sharing with your driving instructor (optional)

ClutchUp lets you connect with a driving instructor so they can follow your practice and support your learning. This is entirely optional and controlled by you:

  • Your share code sends requests, not data. Every account has a unique share code (shown in Settings). Giving it to an instructor lets them send you a connection request — the code alone gives them no access to any of your data. Only give your code to an instructor you know and trust.
  • Nothing is shared until you accept. A request appears in your Settings showing the instructor's name and email. Your data is shared only if you explicitly accept; declining shares nothing.
  • What a connected instructor can see (read-only — they cannot change or delete anything):
    • your full drive history — including drives recorded before you connected — with each drive's date, time, route, distance and duration, and the recorded GPS route trace;
    • detected driving events and your drive telemetry;
    • your AI analyses and debriefs — scores, verdicts, fault breakdowns and examiner commentary, including derived mirror-check results where that feature was used (and, where your debrief references them, your stated focus areas);
    • your name and share code.
  • What they can never see: your voice memos or any audio you record; camera images (road-check image or keyframes); on-device review clips (these never leave your phone); your email address, date of birth or other profile details; your payment or subscription details; and nothing belonging to any other student.
  • You can disconnect at any time in Settings. Revoking the connection ends the instructor's access immediately. (It does not retroactively undo what they saw while connected.)
  • Purpose and lawful basis: the sharing exists so your instructor can see your progress and tailor your lessons. The lawful basis is your explicit consent, given when you accept the request and withdrawable at any time by disconnecting.
  • Instructors' obligations: our Terms & Conditions require instructors to use your data only to support your learning and not to share it with anyone else. Misuse can lead to their account being terminated.

8. Who we share data with (processors and third parties)

Beyond the instructor sharing you control (section 7), we share personal data only with the service providers we need to run ClutchUp, acting under contracts that restrict what they can do with it:

  • Supabase — hosts our database, authentication, and file storage (your account, drives, telemetry, keyframes, voice memos, consent records).
  • Anthropic (Claude API) — receives drive telemetry summaries and event-linked images to generate your debrief (see section 5).
  • Stripe — processes payments and manages subscriptions. Stripe collects your card details directly; we never see them. Stripe acts as an independent controller for its own fraud-prevention processing.
  • Google — sign-in (if you use Google sign-in) and the Google Maps SDK, which receives your device's map viewport/location to draw the map.
  • Apple — sign-in (where offered) and standard iOS services. Mirror-check head-pose analysis uses Apple's Vision framework on your device — no image is sent to Apple or anyone else.
  • Sentry — receives crash and error reports (device/OS details and technical state; not your drive content).
  • OpenStreetMap Overpass API — receives your approximate coordinates (only) during a drive to look up the road's speed limit. No account information is sent.

We may also disclose data where the law requires it (for example, to comply with a court order), or as part of a genuine business transfer, in which case this policy would continue to apply.

9. International transfers

Our primary data store (Supabase — your account, drives, telemetry, images, and consent records) is hosted in the United Kingdom (London). Some of our other providers process data outside the UK/EEA — for example Anthropic, Stripe, Google, and Sentry operate from the United States. Where personal data leaves the UK we rely on UK adequacy regulations or the UK International Data Transfer Agreement / Addendum (IDTA) incorporated in each provider's data processing agreement.

10. How long we keep your data

  • Drives, telemetry (including derived mirror-check results), keyframes, voice memos: kept so you can review your history, until you delete the drive or your account, or after 24 months of account inactivity, whichever is sooner.
  • Non-event camera frames: never uploaded; discarded on-device within minutes. Front-camera mirror-check snapshots: never uploaded; discarded immediately after on-device analysis. Review clips: stored only on your device and deleted after you review them or within 48 hours, whichever is sooner.
  • Account data (including onboarding personalisation answers): kept while your account exists, then deleted or anonymised within 30 days of your deletion request.
  • Instructor connection records (requests, acceptances, declines, revocations): kept while your account exists as a record of your sharing choices, then deleted with your account.
  • Consent records: kept for 6 years after account deletion, as evidence of compliance.
  • Payment/subscription records: kept for 6 years as required by UK tax law.
  • Crash logs (Sentry): retained for 90 days, then deleted automatically.

11. Your rights

Under UK GDPR you have the right to:

  • Access a copy of your personal data.
  • Rectify inaccurate data.
  • Erase your data ("right to be forgotten").
  • Port the data you provided to us, in a machine-readable format.
  • Object to processing based on legitimate interests.
  • Restrict processing in certain circumstances.
  • Withdraw consent at any time (e.g. by turning off camera, microphone, or location permissions, turning off mirror-check detection, or disconnecting an instructor) — this does not affect processing that happened before you withdrew.

To exercise any of these, email clutchup.support@gmail.com from the address on your account. We will respond within one month. Deleting a drive in the app removes its telemetry and images; deleting your account removes your personal data subject to the retention periods in section 10.

12. Security

We take reasonable technical and organisational measures to protect your data: encryption in transit (HTTPS/TLS) for all traffic, per-user row-level security on our database so accounts can only read their own data (with instructor access granted only through an accepted, revocable connection), access controls and secrets management on our infrastructure, and payment handling delegated entirely to Stripe. No system is 100% secure, and we cannot guarantee absolute security, but we work to protect your data proportionately to its sensitivity and will notify you and the ICO of any breach where the law requires it.

13. Children and age

ClutchUp is designed for learner drivers. You must be at least 16 years old to create an account, and hold (or be eligible to hold) a UK provisional licence to use the driving features. Users aged under 18 should involve a parent or guardian, and a parent or guardian should review this policy with them. We do not knowingly collect data from children below our minimum age; if you believe we have, contact us and we will delete it.

14. Cookies and similar technologies

The ClutchUp app itself does not use advertising cookies or tracking SDKs. The Stripe web checkout (opened in your browser) uses cookies necessary for secure payment processing — see Stripe's own privacy policy. Our crash-reporting SDK (Sentry) uses a device-generated identifier to group error reports.

15. Changes to this policy

If we make material changes we will bump the version, update the effective date, and ask you to review and accept the new policy in the app before you continue. Minor clarifications may be made without re-acceptance, but the current version is always available in the app under Profile → Legal.

16. Contact

Zachary Stephens trading as ClutchUp · clutchup.support@gmail.com

This is the current published version of the Privacy Policy — version 1.2, effective 13 August 2026 — and it matches the document shown in the ClutchUp app under Profile → Legal. See also the Terms & Conditions, or email clutchup.support@gmail.com with any question about it.