Legal

Privacy Policy

Version 1.6 Effective 4 October 2026 Zachary Stephens trading as ClutchUp

Effective date: 4 October 2026 · Version: 1.6

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 — currently available on iPhone only — 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.

Your test date (optional)

When you first set up the app you can optionally tell us when your practical driving test is (or that it is not booked yet). This is stored on your profile and used to frame your progress against your test. Older versions of the app asked further personalisation questions (how you are learning, and which areas of driving you wanted to work on); those questions no longer exist, and any answers given to older versions remain stored on your profile, unused, until you delete your account.

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).
  • The speed limit shown for the road you were on, recorded alongside your route so the drive can be assessed against it.
  • 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. It is the only image the rear camera ever produces: once the drive starts the rear camera is not used at all, and no road imagery is captured, uploaded or stored during a drive.

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

  • Used only when you choose the "Sensors + mirror checks" 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 (about 7 seconds, and always without sound) 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.

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.

Past payment records

  • ClutchUp is free, so we collect no payment data. If you bought (or tested) a subscription in an earlier version of the app, we still hold the record of it — the plan, its status and the identifiers Apple or, before August 2026, Stripe gave us — until you delete your account (see section 10).

Diagnostics and usage

  • Error logs written when something goes wrong, including device model, OS version and the technical state of the app or server at the time. These stay in our own infrastructure logs — we do not currently send crash reports to any third-party crash-reporting service.
  • Basic usage records needed to run the service and protect it from misuse, such as the counters we use to apply rate limits.

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 optional test date to frame your progress.
  • Past purchase records (legal obligation): keeping the records of any earlier subscription for as long as tax and accounting law requires.
  • Camera 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 only on drives where you choose the "Sensors + mirror checks" analysis mode. You pick the mode before every drive, and choosing a lower mode means the front camera is never opened (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, applying rate limits, and preventing misuse.
  • Improving the app (legitimate interests): using diagnostics and error logs 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 to our AI provider, Anthropic (the Claude API), which processes it on our behalf to produce the analysis. No images are sent with it. (The pre-drive road-check still is sent separately, at that moment, only to confirm the phone is facing the road.) The analysis request also includes your derived mirror-check results (numbers only — see section 6). 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.

The pre-drive road check is a separate, real-time call to the same provider: the single mount-check image is sent so the app can tell you whether the phone is aimed at the road before you set off.

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 and location — a special note

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

  • Rear camera (road-facing). Used ONCE, before a drive starts, for the road check: a single still confirms the phone is mounted facing the road. That image may incidentally capture the road scene ahead — other vehicles, number plates, and passers-by. It is checked automatically and is not kept as part of your drive record. Once the drive starts the rear camera is never used again: no road stills, no video, nothing. 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 "Sensors only" before any drive and still use ClutchUp.
  • Front camera (mirror-check detection). Only in the "Sensors + mirror checks" 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. Those junctions are worked out on your device from the same OpenStreetMap road tiles the app already fetches to show the speed limit (see section 8). Each window lasts around 20 seconds at most, and there is a limit of 30 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 7 seconds around the turn, extended only as far as needed to include the movement being asked about, and never longer than the check window — in private storage on your phone so you can judge it yourself. Review clips contain no audio: audio is never recorded. The cameras run without a microphone, so a clip is video only — there is no sound to mute, because none is ever captured. These clips are never uploaded, never sent to any AI service, never included in your drive analysis, and never added to your photo library. Each is deleted the moment you answer it, and any left over are deleted when you leave the review screen and swept again next time you open the app; nothing survives past 48 hours. They are also removed when you delete your account and when you switch to an analysis mode that does not use the camera. 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: Sensors only (motion sensors and GPS; no camera is opened at all) or Sensors + mirror checks (adds the pre-drive road check and 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, with the drive screen open — the app does not record your location in the background. 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. 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 written commentary, including derived mirror-check results where that feature was used;
    • your own answers to the mirror review — the yes / no / not-sure you gave when judging an uncertain check — which are shown alongside the detection so the report is honest about which is which;
    • where the drive used the road camera, the written descriptions the AI produced from those photos (never the photos themselves);
    • any guided routes you have planned, including their start point and waypoints — these are built from your live position at the time, so treat them as location data;
    • your name and share code.
  • What they can never see: the road-check image; on-device review clips (these never leave your phone); your email address, date of birth or other profile 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, planned routes, consent records).
  • Anthropic (Claude API) — receives drive telemetry summaries to generate your debrief, and the pre-drive road-check still to verify the mount (see section 5).
  • Stripe — our former payment provider (until August 2026). It takes no payments for us; we keep historic billing records only, for the period tax law requires.
  • 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.
  • OpenStreetMap Overpass servers (overpass-api.de and overpass.kumi.systems, each used as a fallback for the other) — receive your coordinates during a drive to look up the road's speed limit. Coordinates only: no account information is sent.
  • OSRM (project-osrm.org) — when you ask the app to plan a guided route, the start point and the route's waypoints are sent to this public OpenStreetMap routing service so it can work out a driveable route. Coordinates only: no account information, and nothing that identifies you.

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, Apple and Google operate from the United States, and the OSRM and Overpass servers are operated by European volunteer and community projects. 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 and telemetry (including derived mirror-check results): kept so you can review your history, until you delete your account. We do not currently run an automatic purge of dormant accounts, so your history stays until you remove it.
  • Planned guided routes and their waypoints: kept until you delete your account.
  • 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, deleted as you answer them and swept when you leave the review screen or next open the app, and never kept beyond 48 hours.
  • Account data (including any answers given to older versions' setup questions): 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 while your account exists and deleted with it. We keep no per-user consent record after deletion.
  • Records of past purchases: deleted with your account. Apple (and, for purchases before August 2026, Stripe) keeps its own record of any sale under its own terms.
  • Images and voice notes from older app versions: drives recorded with versions of the app before 7 September 2026 could upload road photos taken around detected events, and much earlier versions could record short voice notes. The current app does neither, but any such photos or voice notes already on your account remain stored (and visible to you in those drives' debriefs as written descriptions) until you delete your account, when they are deleted with everything else.
  • Error logs: our infrastructure logs are 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 — by turning off camera or location permissions in iOS Settings, by choosing a lower analysis mode before a drive so the cameras are never opened, or by disconnecting an instructor. This does not affect processing that happened before you withdrew.

You can delete your account yourself in the app at any time — Profile, then Delete account — which erases your personal data subject to the retention periods in section 10. There is currently no way to delete a single drive on its own — deleting your account removes everything. To exercise any of the other rights above, email clutchup.support@gmail.com from the address on your account and we will respond within one month.

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), and access controls and secrets management on our infrastructure. 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 does not use advertising cookies or tracking SDKs, and it takes no payments, so there is no checkout and no payment cookie. We do not use any third-party analytics or crash-reporting SDK that would place an identifier on your device.

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 1.6, effective 4 October 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.