Legal
Privacy Policy
Last updated: December 2024. 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 real-time 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 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).
Device Information: Device type and model, operating system and version, unique device identifiers, mobile network information, IP address, app version, language and locale settings.
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.
2.2 Information Collected from Learners
Camera and Visual Data
We use your device's camera to provide AI-powered driving coaching. This includes face detection data (head position, rotation angles, facial landmarks for mirror check detection), eye tracking data (drowsiness and attention monitoring), pose detection data (driving position assessment), and video recordings stored on Firebase Storage for review and service improvement.
Important: Face detection processing occurs primarily on your device using Google ML Kit. When you record sessions, video footage is uploaded to Firebase Storage. By using the recording feature, you consent to storage and processing as described in this policy, including for AI model training purposes.
Location and Sensor Data
Location Data: Real-time GPS coordinates during driving sessions, route data, speed measurements, start and end locations, distance travelled, and geographic context for analysis.
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), performance scores and metrics, AI-generated feedback, session conditions, and road/traffic data including speed limit recognition and hazard perception.
2.3 Information Collected from Instructors
Professional Information: Business name, qualifications, instructor license 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 driving in real-time 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 monitoring, 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@clutchdriving.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. 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
The following processing occurs directly on your device using Google ML Kit and does not involve data transmission to our servers: face detection and head pose estimation, drowsiness and attention monitoring, vehicle and pedestrian detection, speed limit sign reading, and body position analysis. This ensures sensitive biometric-type data remains on your device.
Cloud-Based AI Processing
Post-session AI analysis using Google Vertex AI (Gemini) generates detailed feedback and recommendations. Session data aggregation tracks long-term progress, and AI generates personalised improvement suggestions based on your driving history.
5. Data Sharing and Disclosure
Sharing Within the Platform
For Learners: If connected with an instructor, they may access your driving session data, progress reports, and performance metrics. You control which sessions and data are shared. 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: Google Firebase (authentication, database, storage, analytics), Firebase Storage (video and file storage), Google ML Kit (on-device processing only), Google Vertex AI (AI coaching and analysis), and Mapbox (mapping and navigation). These providers are contractually bound to protect your data.
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
Account Information is retained for the duration of your account plus 2 years after deletion. Driving Session Data is kept for 3 years from session date or until account deletion. Video Recordings for user access are retained for 90 days or until manually deleted, while video recordings used for AI training may be retained indefinitely in anonymised/processed form.
Location Data is kept for 3 years from session date or until account deletion. Analytics Data is retained for 2 years in aggregated and anonymised form. Support Communications are kept for 2 years from resolution, and Financial Records are retained for 7 years as required by law.
Upon account deletion, personal information will be deleted or anonymised within 30 days. Aggregated, anonymised data may be retained for analytical purposes. Some information may be retained as required by law.
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, contact privacy@clutchdriving.com. We will respond within 30 days.
App Permissions
You can control permissions through your device settings. Camera is required for driver monitoring and mirror check detection. Location is needed for route tracking and speed compliance. Motion and Fitness sensors enable smoothness analysis. 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 1.3) and at rest (AES-256). We use role-based access controls and authentication requirements, hosted on Google Cloud Platform with enterprise-grade security.
We conduct periodic security assessments and penetration testing, provide regular privacy and security training for staff, and maintain documented procedures for responding to data breaches. We also use Firebase App Check to verify that requests come from our genuine app.
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 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
Your information may be transferred to and processed in countries outside the United Kingdom. When we transfer data outside the UK, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses), only transfer to countries with adequate data protection laws, and work with organisations providing adequate protections. Google Cloud and Firebase comply with international data transfer requirements.
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.