Legal
Privacy Policy
Last updated: 11 July 2026. This policy explains how Clutch collects, uses, and protects your data.
1. Introduction
Welcome to Clutch ("we," "our," or "us"). Clutch is an AI-powered driving instruction platform that uses smartphone sensors and computer vision to provide coaching, assessment, and progress tracking for learner drivers and driving instructors.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, our web application for instructors, and related services (collectively, the "Service"). Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
We collect different types of information depending on whether you are a Learner or an Instructor.
2.1 Information Collected from All Users
Account Information: Full name, email address, password (encrypted), profile photograph (optional), phone number (optional), date of birth, account creation date, and account type (Learner or Instructor). If you sign in with Google or Apple, we receive the name and email address associated with that account.
Device Information: Device type and model, operating system and version, unique device identifiers, mobile network information, IP address, app version, language and locale settings, and push notification tokens (used to deliver notifications to your device).
Usage Information: Features accessed and frequency of use, session duration and timing, in-app interactions and navigation patterns, preferences and settings choices, error logs and crash reports. We use an EU-hosted product analytics service that records how you interact with the app, including session replay of in-app screens and interactions. Session replay is paused while you are recording a driving session, so your drives are not captured by it.
Purchase and Subscription Information: If you purchase a subscription, we and our subscription management provider process your subscription status, entitlements, purchase history, and transaction identifiers. Payment card details are handled by Apple or Google through their app stores and never reach our systems.
2.2 Information Collected from Learners
Camera and Visual Data
During a recorded driving session, the app records video from two cameras: the front (driver-facing) camera and the rear (road-facing) camera. No audio is recorded.
Recorded video is uploaded to our secure cloud storage and analysed by our machine learning systems to assess your driving. This includes analysing the driver-facing footage to understand where you are looking (for example, mirror checks and observation) and the road-facing footage to understand the driving environment around you.
Please note: the road-facing camera may capture other road users, pedestrians, vehicles, and registration plates in the vicinity of your vehicle, in the same way a dashcam does. This footage is used only to analyse your driving and is protected under the same safeguards as the rest of your session data.
By using the recording feature, you consent to the upload, storage, and processing of this footage as described in this policy, including for AI model training purposes (see Section 3).
Location and Sensor Data
Location Data: GPS coordinates during driving sessions, route data, speed measurements, start and end locations, distance travelled, and geographic context for analysis. If you grant background location permission, location recording continues while your phone is locked or the app is in the background during an active session only. Location is not collected outside of driving sessions.
Sensor Data: Accelerometer data (braking smoothness, acceleration patterns), gyroscope data (steering smoothness, lane positioning), compass data (orientation), and barometer data where available.
Driving Session Data
Session timing and duration, driving events detected (mirror checks, braking events, speed compliance, lane deviations, manoeuvres such as junctions and roundabouts), performance scores and metrics, AI-generated feedback, session conditions, and road context such as speed limits and road layout derived from mapping services.
2.3 Information Collected from Instructors
Professional Information: Business name, qualifications, instructor licence number, years of experience, teaching specialisations, service area, and vehicle information.
Student Management: Associated students list, student progress records and assessments, session notes and annotations, teaching plans and curriculum assignments.
Business Data: Availability schedules, lesson bookings, cancellation records, calendar integrations, payment preferences, transaction history, and business analytics.
3. How We Use Your Information
Core Service Delivery
We use your information to provide AI driving coaching by analysing your recorded driving sessions using camera, sensor, and location data. We track your progress over time, generate insights including post-session summaries and personalised recommendations using AI (powered by Google Vertex AI), enable session review for you and your instructor, and facilitate instructor-learner connections.
AI and Machine Learning Development
We reserve the right to use data collected through the Service to train, improve, and develop our AI and machine learning models. This includes video recordings for computer vision model training (driver observation, mirror check detection, hazard perception), sensor data for smoothness analysis algorithms, and aggregated patterns for service improvement. You may opt out of AI training by contacting privacy@learnwithclutch.com.
Communication and Safety
We use your contact information to send session summaries, notify you of schedule changes, provide service updates, respond to support requests, and send promotional communications with your consent. Transactional emails (such as verification and password reset emails) are delivered through a third-party email delivery provider. We also use information to detect fraud, enforce our Terms of Service, and comply with legal obligations.
4. Data Processing and AI
On-Device Processing
Your phone records video, location, and motion sensor data during a session and provides real-time information such as spoken prompts and session status. Recorded data is stored on your device until it is uploaded for analysis.
Cloud-Based Processing
The analysis of your driving takes place on our servers, running in European cloud regions. Our systems analyse your uploaded footage to assess observation and awareness, and match your route against mapping services to determine the roads you drove on, applicable speed limits, and manoeuvres such as junctions and roundabouts. Route coordinates are shared with our mapping providers for this purpose. We then use AI (Google Vertex AI) to generate feedback, personalised recommendations, and long-term progress insights from your session results.
5. Data Sharing and Disclosure
Sharing Within the Platform
For Learners: If you are connected with an instructor, they can see your driving session summaries, progress reports, scores, and detected events. Access to your session video recordings is separate: your instructor can only view a session's video if you approve it for that session. You can grant or withdraw video access per session at any time.
For Instructors: Your students' driving data is shared with you to enable effective instruction. Your professional profile may be visible to potential students if you opt into discovery features.
Third-Party Service Providers
We share information with the following providers, who are contractually bound to protect your data:
Google Cloud: authentication, database, video and file storage, cloud processing (including our machine learning analysis), push notifications, and app integrity checks.
Google Vertex AI: AI-generated coaching feedback and analysis.
Google Maps (Street View): static street imagery used in lesson planning tools (receives the coordinates of the locations viewed).
Mapbox and other mapping providers: mapping, route matching, speed limits, and road data (receive route coordinates from your sessions).
A product analytics provider (EU-hosted): product analytics, session replay of in-app screens, and error reporting.
A subscription management provider: subscription status, entitlements, and purchase history.
An email delivery provider: transactional and service emails.
An app build and update service: delivery of app updates.
A workspace tool used to manage our waitlist: email address and signup source collected before account creation.
Legal Requirements
We may disclose information if required by law, to comply with legal obligations, protect our rights, prevent wrongdoing, protect user safety, or in connection with business transfers such as mergers or acquisitions.
6. Data Retention
We retain your personal data for as long as your account is active, so that you and your instructor can review your driving history and track progress over time.
Deleted sessions: When you delete a driving session, it is archived immediately (no longer visible in the app) and permanently erased, including its video recordings, 30 days later. During the 30-day window an archived session can be restored on request.
Video exports: Shareable video clips you create expire and are deleted 30 days after they are generated.
Account deletion: When your account is deleted, your personal information is deleted or anonymised within 30 days. Aggregated, anonymised data may be retained for analytical purposes, and some information may be retained where required by law.
AI training data: Video and sensor data used to train our models may be retained in anonymised or processed form for as long as it remains useful for model development, even after the original recording is deleted, unless you have opted out of AI training.
Financial records: Retained for 7 years as required by law.
Support communications: Retained for up to 2 years from resolution.
7. Your Rights and Choices
Your Rights Under UK GDPR
You have the right to: access your personal data, request correction of inaccurate data, request erasure ("right to be forgotten"), restrict processing, data portability, object to processing, withdraw consent at any time, and lodge a complaint with the Information Commissioner's Office (ICO).
To exercise these rights, including requesting deletion of your account and data, contact privacy@learnwithclutch.com. We will respond within 30 days.
App Permissions
You can control permissions through your device settings. Camera is required for session recording and driver observation analysis. Location (including background location during sessions) is needed for route tracking and speed compliance. Motion and Fitness sensors enable smoothness analysis. Notifications are optional and used for session and lesson updates. Disabling these permissions will affect the corresponding features.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data. All data is encrypted in transit (TLS) and at rest (AES-256), hosted on Google Cloud Platform with enterprise-grade security. We use role-based access controls and authentication requirements, and security rules that restrict every user's data access to what this policy describes.
We also use Firebase App Check to help verify that requests come from our genuine app, and we maintain documented procedures for responding to data breaches.
9. Children's Privacy
The Service is not intended for use by individuals under the age of 17 (the minimum age to hold a provisional driving licence for a car in the UK). We do not knowingly collect personal information from children under 17. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.
10. International Data Transfers
Our core infrastructure runs in Google Cloud regions in the UK and Europe, and our analytics provider is hosted in the EU. Some data may nonetheless be transferred to and processed in countries outside the United Kingdom, for example by Google, Mapbox, or the other service providers described in Section 5, or where legacy data is stored in a US region. When data is transferred outside the UK, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses or UK adequacy decisions) and work with organisations providing adequate protections.
11. Instructor-Specific Terms
When using the Service to manage students, instructors act as independent data controllers for student data they process. Instructors must comply with applicable data protection laws, obtain necessary consents from students, maintain appropriate security measures, use student data only for legitimate instructional purposes, and respect students' privacy preferences.
12. Changes and Contact
We may update this Privacy Policy from time to time. We will notify you of changes by posting the new policy in the app, updating the "Last Updated" date, and sending a notification for material changes. Your continued use indicates acceptance of the updated policy.
Contact Us
Email: privacy@learnwithclutch.com • Website: www.learnwithclutch.com
If you are not satisfied with our response, you may lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk or by telephone at 0303 123 1113.