Legal
Privacy Policy
Last updated: 1 September 2026. This policy explains how Clutch collects, uses, and protects your data.
1. Introduction
Welcome to Clutch. The Service is provided by Clutch Technologies Ltd (“Clutch”, “we”, “our”, or “us”), registered in England and Wales (company number 17354677, registered office 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ), which is the data controller responsible for the personal data described in this policy. 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 what personal data we collect, why we collect it, the legal bases we rely on, who we share it with, how long we keep it, and the rights you have over it. It covers our mobile application, our web application for instructors, our marketing website, and related services (collectively, the “Service”).
2. Information We Collect
We collect different types of information depending on whether you are a Learner, an Instructor, or a Parent following a learner.
2.1 Information Collected from All Users
Account Information: Full name, email address, password (encrypted), profile photograph (optional), phone number, date of birth (learners and instructors), account creation date, and account type. If you sign in with Google or Apple, we receive the name and email address associated with that account. We also record when you accepted our Terms of Service and Privacy Policy and which version you accepted.
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 (PostHog) that records how you interact with the app, including session replay of in-app screens. Session replay is paused while you are recording a driving session, and text you type into the app (such as your name, email, or date of birth) is masked in replay recordings.
Purchase and Subscription Information: If you purchase a subscription, we and our subscription management provider (RevenueCat) 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.
Microphone audio is off by default. If you turn on the Record Audio option for a drive, a single audio track from your phone’s microphone is recorded alongside the road-facing video so that clips you export have sound. If you record audio, it may capture the voices of other people in the vehicle, such as your supervising driver or instructor; it is your responsibility to let them know. With the option off, no audio is recorded.
Recorded video is uploaded to our secure cloud storage and analysed by our machine learning systems to assess your driving.
How we analyse the driver-facing video: our systems detect facial landmarks (the positions of facial features such as your eyes and the outline of your face) in each sampled frame to estimate where you are looking, your head direction, and whether your eyes are open. This produces numeric signals such as gaze direction and head angle, which power feedback like mirror-check and observation detection. We do not use facial recognition. We do not identify you or anyone else from your face, we do not create face templates or faceprints, and we cannot match a face across different sessions or users. The stored analysis output consists of numeric measurements only; the facial landmark positions themselves are not retained.
The driver-facing camera may also capture a front-seat passenger, such as your supervising driver or instructor. Our analysis is designed to select the driver and ignore passengers; passenger faces are not analysed beyond that selection and no signals about them are stored.
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.
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. If you connect to Stripe to take payments, Stripe collects identity and bank details from you directly as its own controller.
2.4 Information Collected Before You Have an Account
If you join our waitlist, we collect your email address, signup source, and, where you choose to provide them, your phone number and Instagram handle. If you take part in an Instagram campaign of ours, we process the public comments and handles involved to run the campaign. See Section 5 for where this data is stored.
3. How We Use Your Information and Our Legal Bases
Our Legal Bases
Under UK GDPR we must have a legal basis for each way we use your personal data. Providing the Service, including recording, uploading, and analysing your drives, generating scores and feedback, and the instructor and parent sharing you control, relies on the performance of our contract with you, as do AI-generated summaries, transactional email, and push notifications.
We rely on our legitimate interests for improving our detection models (with an opt-out), for product analytics, session replay, and error reporting (you can object at any time), for fraud prevention and enforcement of our Terms, and for the incidental, dashcam-style capture of other road users that is technically unavoidable when recording a drive, which we minimise as described in Section 2.2.
We rely on your consent for promotional email, a separate opt-in at signup or in settings that you can withdraw at any time. Where the law requires it, we also process data to comply with our legal obligations.
AI and Machine Learning Development
We use derived numeric driving signals (for example gaze direction angles, head pose, event detections, and their human-reviewed verdicts) to improve our detection models. We do not use your face images, video, or audio recordings to train models. You can exclude your data from model improvement at any time with the Keep my data out of AI training switch in Privacy & Security settings, or by emailing privacy@learnwithclutch.com; the exclusion applies to all datasets assembled after you opt out. Coaching on your own drives is unaffected by opting out.
Communication and Safety
We use your contact information to send session summaries, notify you of schedule changes, provide service updates, and respond to support requests. Transactional emails are delivered through a third-party email delivery provider (SendGrid). Promotional communications are sent only with your consent. 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 shows an on-screen recording status with your elapsed time and distance. The app does not give real-time driving alerts or coaching while you drive; the only in-drive alert is a warning if a session approaches the automatic time limit. Recorded data is stored on your device until it is uploaded for analysis, and removed from the device once upload is confirmed.
Cloud-Based Processing
The analysis of your driving takes place on our servers, running in UK and 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. The AI summary service receives aggregated results and road names, never your video, audio, name, or raw coordinates.
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 Parents: If you invite a parent or guardian to follow your progress, they see progress summaries and per-drive digests by default. They can only see full session detail, including video, if you turn on full sharing for that specific parent, and you can turn it off 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.
Clutch staff: A small number of authorised staff can access session data, including video, for support, safety, and to review and improve the accuracy of our detection systems. Staff access is role-restricted, logged, and limited to what the task requires.
Third-Party Service Providers
We share information with the following providers, who are contractually bound to protect your data:
Google Cloud (Firebase): authentication, database, video and file storage, cloud processing (including our machine learning analysis), push notifications, analytics infrastructure, and app integrity checks.
Google Vertex AI: AI-generated coaching feedback and analysis (aggregated session results only).
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).
PostHog (EU-hosted): product analytics, masked session replay of in-app screens, and error reporting.
RevenueCat: subscription status, entitlements, and purchase history (keyed to your account identifier).
Stripe: payments between learners, parents, instructors, and driving schools, and instructor payout accounts.
SendGrid: transactional and service emails.
Expo (EAS): delivery of app updates.
HubSpot (EU-hosted): our customer relationship system, which holds your name, email address, phone number, and date of birth so we can manage support and, with your consent, marketing.
Notion: a workspace tool holding our pre-launch waitlist (email address, signup source, and any phone number or Instagram handle you provided).
Meta (Instagram): if you interact with one of our Instagram campaigns, we process those interactions through Instagram’s APIs.
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 and derived analysis data, 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: You can delete your account in the app (Privacy & Security settings) or by emailing privacy@learnwithclutch.com. Deleting your account permanently removes your profile, your driving sessions including all video and derived analysis data, and your contact record in our customer relationship system. Records we are legally required to keep (see financial records below) and aggregated data that no longer identifies you may be retained.
AI training data: Derived numeric signals included in model-improvement datasets before you opted out or deleted your account may persist in those historic datasets; datasets assembled afterwards exclude you.
Waitlist data: Retained until launch-related campaigns conclude, or deleted on request.
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 (the right to be forgotten), restrict processing, data portability, object to processing (including to our legitimate-interests uses described in Section 3), withdraw consent at any time, and lodge a complaint with the Information Commissioner’s Office (ICO).
Controls in the app: you can export a copy of your data, delete individual sessions, delete your entire account, opt out of leaderboards, opt out of AI training, and turn drive audio recording on or off, all from the app’s settings. To exercise any other right, 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 driving analysis. Microphone is requested only if you turn on audio recording. 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. Access to your recordings and driving data is restricted by security rules to you, the instructor and parents you have connected, and authorised staff.
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 and Young People
The minimum age to use Clutch is 17 (the minimum age to hold a provisional driving licence for a car in the UK), and we check your date of birth at signup to enforce this. We do not knowingly collect personal information from anyone under 17; if you believe a child under 17 has provided us with personal information, please contact us immediately and we will delete it.
Many of our learners are 17, and UK law treats everyone under 18 as a child. We take that seriously: privacy-protective settings are the default, we do not send promotional communications without an explicit opt-in, learners always control what instructors and parents can see, and we apply the standards of the ICO’s Age Appropriate Design Code to how the Service is built.
10. International Data Transfers
Our core infrastructure runs in Google Cloud regions in the UK and Europe, and our analytics and CRM providers are EU-hosted. Some providers named in Section 5 (for example SendGrid, Notion, RevenueCat, Expo, and Meta) may process data in the United States or other countries outside the UK, and some legacy data may be stored in a US cloud region. When data is transferred outside the UK, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses, the UK Extension to the EU-US Data Privacy Framework, or UK adequacy decisions).
11. Cookies and Website Analytics
Our marketing website and instructor web app use an EU-hosted analytics service to understand how they are used. Where consent is required for analytics cookies or similar technologies, we ask for it before they are set, and you can change your choice at any time.
12. 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.
13. 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.
Contact Us
Email: privacy@learnwithclutch.com • Website: www.learnwithclutch.com • Post: Clutch Technologies Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
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.