(Last updated December, 2019)
Our websites, located at uniform resource locators www.clutch.com, www.blog.clutch.com, www.portal.clutch.com and www.vt.clutch.com (the “Site”), are provided by Clutch Holdings, LLC (“Company,” “we,” “our,” or “us”) to the person accessing the Site (“you,” or “your”).
1. You Agree to These Terms by Using the Site
2. Permitted Use of the Site
The information and materials on the Site are provided for general informational purposes. You may use the site solely for the purpose of learning about and/or purchasing Company services or products. You may not use, reproduce or distribute the text, graphics, downloads, tools or any other content on the Site for any other purpose.
3. User Submitted Content
The Site may, from time to time offer interactive features that allow users to submit content to the Site. Company does not and cannot review all such content, and is not responsible for such content.
You acknowledge that by providing the ability to view and distribute your user-generated content on the Site, Company is merely acting as a passive conduit for such distribution and is not undertaking any obligation or liability related thereto. However, Company reserves the right to block or remove communications or materials that it determines to be unacceptable to Company in its sole discretion.
Harassment in any manner or form on the site, including via e-mail, chat, or by use of obscene or abusive language, is strictly forbidden. Impersonation of others, including a Company employee, host, or representative, as well as other members or visitors on the site is prohibited. You may not upload to, distribute, or otherwise publish through the site any content which is libelous, defamatory, obscene, threatening, invasive of privacy or publicity rights, abusive, illegal, or otherwise objectionable which may constitute or encourage a criminal offense, violate the rights of any party or which may otherwise give rise to liability or violate any law.
4. Notice: Electronic Communications
When you visit the site or send e-mails to Company, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on the site. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.
6. Typographical Errors
In the event that a service or product is mistakenly listed at an incorrect price or with incorrect specifications, Company reserves the right to refuse or cancel any orders placed for product or service listed incorrectly, whether or not the order has been confirmed and whether or not you have been charged for such product or service. If your credit card has already been charged for the purchase and your order is cancelled, Company shall issue you a credit (to your credit card account or otherwise) in the amount of the incorrect price.
7. Disclaimer – Warranty
The Site, its content, materials, SERVICES and products on thE site are provided “as is.” To the fullest extent permissible pursuant to applicable law, COMPANY HEREBY disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose and non-infringement.
Company does not represent or warrant that the functions contained in the Site will be uninterrupted or error-free, that the defects will be corrected, or that the Site or the server that makes the Site available are free of viruses or other harmful components. Company does not make any warranties or representations regarding the use of the materials in the Site in terms of their correctness, accuracy, adequacy, usefulness, timeliness, reliability or otherwise. Company does not make any warranties or representations regarding the security of your personal information. Some states do not permit limitations or exclusions on warranties, so the above limitations may not apply to you.
9. Limitations of Liability
YOUR USE OF THE SITE IS AT YOUR OWN RISK. NEITHER COMPANY, NOR ANY OF ITS SUBSIDIARIES, AFFILIATES, OFFICERS OR DIRECTORS, NOR ANY OF ITS AGENTS OR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING, OR DELIVERING THE SITE OR ITS CONTENT, ARE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OF THE SITE WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF ANY SUCH DAMAGES. Some states do not permit limitations or exclusions on warranties, so the above limitations may not apply to you.
10. Third-Party Links
In an attempt to provide increased value to our visitors, Company may link to sites operated by third parties. However, even if the third party is affiliated with Company, Company has no control over these linked sites, all of which may have separate privacy and data collection practices, independent of Company. These linked sites are only for your convenience and therefore you access them at your own risk. Without limiting the foregoing, Company specifically disclaims any responsibility if such sites: infringe any third party’s intellectual property rights; are inaccurate, incomplete or misleading; are not merchantable or fit for a particular purpose; do not provide adequate security; contain viruses or other items of a destructive nature; or are libelous or defamatory.
Company does not endorse the content, or any products or services available, on such sites. Nonetheless, Company seeks to protect the integrity of its web site and the links placed upon it and therefore requests any feedback on not only its own site, but for sites it links to as well (including if a specific link does not work).
The following trademarks are our property: Clutch, Clutch Holdings, Clutch Connect. These marks may not be used without our consent on any product or service, except our own.
Copyright © 2019, Clutch Holdings, LLC. ALL RIGHTS RESERVED.
All content included on the Site, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of Company or its content suppliers and protected by United States and international copyright laws. The compilation of all content on the Site is the exclusive property of Company and protected by United States and international copyright laws. All software used on the Site is the property of Company or its software suppliers and protected by United States and international copyright laws. You agree not to change or delete any proprietary notices from materials printed or downloaded from the site.
13. Copyright Complaints
Company respects the intellectual property of others. If you believe that your work has been copied in a way that constitutes copyright infringement, please contact us at (267-419-6400).
14. Export Control
Software and other materials downloaded or otherwise made available from the Site may be subject to United States Export Control. The United States Export Control laws prohibit the export of certain technical data and software to certain territories. No software from the Site may be downloaded or exported: into (or to a national or resident of) Cuba, Iraq, Libya, North Korea, Iran, Sudan, Syria, or any other country to which the United States has embargoed goods; or anyone on the United States Treasury Department’s list of Specially Designated Nationals or the United States Commerce Department’s Table of Deny Orders.
Company does not authorize the downloading or exportation of any software or technical data from the Site to any jurisdiction prohibited by the United States Export Control Laws.
15. Law and Jurisdiction
17. Questions and Feedback
We welcome your questions, comments, and concerns about the Site. Please send us any and all feedback pertaining to the Site to [email protected]
(Last updated December 2019)
At Clutch Holdings LLC (“Clutch”), our core mission is to transform the way businesses identify,
understand and motivate their customers; and we provide a guarantee that you will know more about your customers than ever before, and you’ll be able to drive intelligent connections, profitable engagements and lifetime customers. A necessary part of that mission is to set a high standard for protecting the privacy of your information. We want to be clear about how we collect, use, protect, and share your information, including your personal information (“Personal Information”), and the rights and choices you have about the ways in which you can help us protect your privacy.
This Privacy Statement explains:
- What information we collect and why we collect it
- How we use that information and when we disclose it
- Your rights regarding that information, including how to access and update your information
- The steps we take to protect your information
Scope: This Privacy Statement applies to the information that we obtain through your use of Clutch products and services, including our website (www.clutch.com), our Portal, Virtual Terminal, Hosted Sites, social media, communications, and web-based tools (collectively, our “Services”). For a current list of the vendors covered by this Privacy Statement, see our Subvendor Directory, below.
This Privacy Statement does not apply to Personal Information arising from Clutch employment-related activities. Except to the extent that a third party provides services on our behalf (such as a SaaS vendor), this Privacy Statement also does not apply to the practices of third parties to which we may link or otherwise refer you, such as consultants, pen testing firms, audit firms, and other vendors.
Geography: Clutch is a U.S.-based company that offers its Services to domestic and international business customers. As a result, information that we collect, your Personal InformationI may be transferred to our U.S. offices to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may provide information to third-party service providers in the U.S. and in other countries to the extent necessary to support Clutch’s business activities, and we may access personal information collected by our customers to support the Services that we provide to our customers. Thus, Personal Information may be transferred to and stored on servers located in the United States and in countries different from the country in which that information was initially collected. Similarly, the information we collect may be accessed by Clutch and our third-party service providers and business partners from countries other than the ones in which the information is stored. Please review Clutch notice to EU residents for more information about how we handle EU resident’s personal data.
If you have any questions or concerns about this Privacy Statement or about our privacy or data security practices, please contact us at [email protected].
What We Mean by Personal Information
For purposes of this Privacy Statement, “Personal Information” means information from or about you that identifies you directly and information that is associated with you and thus could potentially identify you, including when combined with other information from or about you.
“Sensitive Personal Information” includes data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union memberships, genetic and biometric data when used for identification purposes, and data about health, sex life, and sexual orientation.
Types of Personal Information that We Collect
- Physical address
- Email addresses
- Telephone numbers
- Business contact information, including names, email addresses, business addresses, telephone numbers, company name or business affiliation, and title.
- User IDs and passwords
- Personal information that you choose to share within our user communities
- Payment card and financial account information
- Identifiers of devices used to access our Services
Information that We Collect from and About You
Information that You Provide to Us Voluntarily
Content: We collect and store content that you create, input, submit, post, upload, transmit, or store while using our Services. Such content may include any personal or other sensitive information submitted using our Services, such as HIPAA protected health information, EU personal data, and other information such as source code or regulatory compliance materials.
Other submissions: We collect other data that you may submit to our Services or to us directly, such as when you request customer support or communicate with us via email or social media sites.
Information that We Collect Automatically When You Use Our Services
Web Logs and Analytics Information: We record certain information and store it in log files when you interact with our Services. This information may include Internet protocol (IP) or other device addresses or ID numbers as well as browser type, Internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information that you search for, your locale and language preferences, your mobile carrier, and system configuration information. We and our analytics providers (see our Subvendor Directory), also collect and store analytics information when you use our Services to help us improve our Services.
Information that We Collect from Other Sources
Information from Third Parties: We may obtain information, including Personal Information, from our business partners and service providers. This information includes, but is not limited to, information that we receive from our direct marketing providers, product referrals, and other interactions. We also may combine information we receive from third parties with other information we collect from you through our Services as described in this Privacy Statement. If we use this information to provide you with opportunities that we think may be of interest to you, you will have the ability to inform us that you do not wish to receive such offers, and you may unsubscribe from our marketing and other email communications by clicking on the link in the email, sending an email to [email protected], or accessing your user account and changing your distribution preferences.
Information Provided by Other Individuals: While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including Personal Information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of Personal Information as described in this Privacy Statement. Please contact us immediately at [email protected] if you become aware of an individual providing us with Personal Information about another individual without being authorized to do so, and we will act consistently with this Privacy Statement.
Information that We Receive About You from Our Customers
Our customers and their designated users use our Services to develop, establish, implement, and maintain secure application and database deployment environments for processing sensitive data, including Personal Information and sensitive Personal Information. While using our Services, our customers may create, input, submit, post, upload, transmit, or store Personal Information that they have collected from individuals. During the course of our business relationship, we may need to access a customer’s account and the information it contains to provide support for our Services.
Our customers and prospective customers are responsible for complying with all applicable federal, state, local, and international laws and regulations regarding notice, disclosure, consent, and transfer of Personal Information, prior to providing that Personal Information to Clutch.
In addition, our customers and prospective customers are also responsible for identifying, in the Services agreement or in a related document (such as a HIPAA Business Associate Agreement or GDPR agreement), any additional requirements for protecting, accessing, and handling Personal Information in a particular matter that exceeds the reasonable, risk-based administrative, technical, and physical safeguards that Clutch would otherwise routinely implement, or that are inconsistent with the collection and use practices identified in this Privacy Statement.
Unlike the other collections of information described in this section, our agreements with customers include specific protections and limitations regarding our access to and use of Personal Information collected by customers, and we do not access, use, copy, retain, or aggregate that customer data except as stated in those agreements.
Why We Collect Information from and About You
We will not use your Personal Information for anything other than the following lawful purposes:
To establish and maintain contractual relationships with our customers:
- To establish relationships with new customers
- To fulfill our obligations to current customers
- To contact customers regarding account-related issues and business communications relating to the Services, including technical notices, updates, security alerts, and administrative messages
- To enable our customers to access and use our Services
To comply with our legal obligations:
- To comply with legal obligations, including but not limited to complying with tax and financial reporting requirements
- To demonstrate compliance with applicable privacy and data security laws and regulations, such as HIPAA and GDPR
- To comply with incident monitoring, reporting, assessment, and notification requirements
- To comply with other applicable criminal and civil law and regulatory requirements under federal, state, and international law
To provide services and information that you request and consent to receive:
- To provide customer service and support
- To communicate with you, including responding to your comments, questions, and requests regarding our Services
- To process and complete transactions, and send you related information, including purchase confirmations and invoices
- To provide direct marketing, email, and other distributed information distribution
To conduct business operations necessary for the continued operation of our business:
- To administer, operate, maintain, and secure our website and Services
- To monitor and analyze trends, usage, and activities in connection with our Services
- To investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities
- To verify compliance with our internal policies and procedures
- For accounting, recordkeeping, backup, and administrative purposes
- To customize and improve the content of our communications, websites, and social media accounts
- To educate and train our workforce in data protection and customer support
- To provide, operate, maintain, improve, personalize, and promote our Services
- To develop new products, services, features, and functionality
- To market our products and services (first-party marketing only; we do not provide Personal Information for use in marketing any non-Clutch, third-party goods or services)
When possible, we will use anonymized data for these purposes, but if we do not, or if we combine it with Personal Information we will treat it in accordance with this Privacy Statement.
When and Why We Share or Disclose Personal Information
Except to the extent necessary to fulfill our business obligations, to accomplish one of the lawful purposes described in this Privacy Statement, or pursuant to your express instructions, we do not sell, transfer, or otherwise disclose Personal Information that we collect from or about you.
We may share your information in the following ways:
With Your Express Consent: We will share your Personal Information with companies, organizations, or individuals outside of Clutch when we have your consent to do so.
When You Choose to Directly Share Your Information While Using Our Services: When you use our Services, certain features allow you to make some of your content accessible to the public or other users of the Services. We urge you to consider the sensitivity of any information prior to sharing it publicly or with other users.
When Your Account Is Accessed by Your Organization’s Designated Clutch Administrator: Your Clutch account owners and administrators may be able to:
- Access information in and about your Clutch account;
- Disclose, restrict, or access information that you have provided or that is made available to you when using your Clutch account, including your content; and
- Control how your Clutch account may be configured, accessed, or deleted.
With our vendors and business partners, to accomplish our business purposes: We may share your information with our service providers and other third parties who perform services on our behalf, listed in our Subvendor Directory. We provide your payment information to our service providers for payment processing and verification. Service providers such as analytics providers may collect information about your online activities over time and across different online services when you use our Services. We also work with third-party service providers to provide the cloud-based tools that our customers use to create their secure storage containers and securely store their sensitive information, including Personal Information.
When Necessary to Comply with Laws and Law Enforcement Requests, or Otherwise to Protect Our Rights or Those of Individuals: We may disclose your information (including your Personal Information) to a third party if:
- We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request
- To enforce our agreements, policies and terms of service
- To protect the security or integrity of Clutch’s products and services
- To respond to an incident involving personal data for which Clutch has direct or indirect responsibility
- To protect the property, rights, and safety of Clutch, our customers or the public from harm or illegal activities
- To respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person
- To investigate and defend ourselves against any third-party claims or allegations.
As the result of a business transition: We may share or transfer your information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will take reasonable steps to assure that any other entity involved continues to comply with the terms of this Privacy Statement. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
Sharing aggregated, anonymized, de-identified, or otherwise non-personal data: We may share aggregated, anonymized, de-identified, or otherwise non-Personal Information that does not directly or indirectly identify you and that cannot with reasonable effort, be used to re-identify you in order to improve the overall experience of our Services. Such aggregated, anonymized, de-identified, or otherwise not re-identifiable information is not Personal Information within the scope of this Privacy Statement.
NOTE: Clutch does not sell your Personal Information
Your Control Over Your Personal Information
You maintain control over the data you share with us, as described below.
- You may decline to share certain Personal Information with us, in which case we may not be able to provide to you (or our customers) some of the features and functionality of our Services or fulfill your requests. For example, we need your email address to authenticate you and perform account services such as password resets, or to provide you with customer support.
- You may decline to accept cookies, but that decision may affect the functionality and performance of our Services.
- You may update or correct your Personal Information at any time by accessing the account settings page on the website or within our platform.
- You may opt out of receiving promotional communications from Clutch by using the unsubscribe link within each email. Note that, as long as you maintain an account with us, you will continue to receive administrative messages from us regarding the Services.
- You may request information about, and access to, the personal data that we collect from you.
- You may ask questions or make complaints about our privacy and data security practices with regard to your personal data.
- You may request that we delete information that we have collected about you.
- You may ask us for a copy of the information that we collect from you.
To exercise any of these options, or for additional information about our privacy and data security practices, contact us at [email protected].
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. That said, we certainly try very hard, employing a variety of organizational, technical and administrative measures to provide a level of security appropriate to the risk associated with the Personal Information you trust us with.
To that end, we manage our data protection program consistent with ISO 27001 (https://www.iso.org/isoiec-27001-information-security.html). Please see our Security Policy for more details.
Clutch protects Personal Information under its control, and requires its service providers (see our Subvendor Directory) to also protect against, accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, personal data transmitted, stored, or otherwise processed.
If you have concerns about the security of your information with Clutch, please contact us immediately at [email protected] to report an issue.
We retain your Personal Information only as long as necessary to accomplish the business purpose for which it was collected or to comply with our legal and contractual obligations, and then securely dispose of that information.
Our Services are not directed to individuals under 16. We do not knowingly collect Personal Information from children under 16. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact us at [email protected].
Notice to Residents of the European Union
We store and process the information that we collect in the United States in accordance with this Privacy Statement (our sub-processors may store and process data outside the United States). However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries have.
We provide a high standard of privacy protection — as described in this Privacy Statement — to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business, working with our Data Protection Officer as part of a cross-functional team that oversees our privacy compliance efforts. Additionally, if our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.
- Clutch provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal information using consent as a basis.
- We collect only the minimum amount of personal information necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
- We offer you simple methods of accessing, correcting, or deleting the User Personal Information we have collected.
- We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement. These are the EU-US Privacy Shield Principles, but they are also just good practices.
Cross-border data transfers
Clutch complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of User Personal Information transferred from the European Union, the UK, and Switzerland to the United States. Clutch has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, visit the Privacy Shield website.
How we respond to compelled disclosure
Clutch may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.
In complying with court orders and similar legal processes, Clutch strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
How we, and others, communicate with you
We will use your email address to communicate with you, if you’ve said that it is okay, and only for the reasons you’ve said that’s okay. For example, if you contact our Support team with a request, we will respond to you via email. You have a lot of control over how your email address is used and shared on and through Clutch. You may manage your communication preferences in your user profile.
Depending on your email settings, Clutch may occasionally send notification emails about changes in a repository you’re watching, new features, requests for feedback, important policy changes, or offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. We have provided an unsubscribe link located at the bottom of each of the marketing emails we send you. Please note that you can not opt out of receiving important communications from us, such as emails from our support team or system emails, but you can configure your notifications settings in your profile.
Our emails may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email.
If you have concerns about the way Clutch is handling your User Personal Information, please let us know immediately. We want to help. You may email us directly at [email protected] with the subject line “Privacy Concerns.” We will respond promptly — within 45 days, which complies with the regulation.
You may also contact our Data Protection Officer directly–see “Contact Information” below.
Dispute resolution process
For residents of the EU and those in which GDPR applies, in the unlikely event that a dispute arises between you and Clutch regarding our handling of your Personal Information, we will do our best to resolve the matter with you. If we cannot, we have selected to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, and with the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. Please contact us if you’d like us to direct you to your data protection authority contacts.
Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.
Under certain limited circumstances, EU, EEA, Swiss, and UK individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please read more about Privacy Shield. Arbitration is not mandatory; it is a tool you can use if you choose to.
As Clutch is an American company, we are subject to the jurisdiction of the U.S. Federal Trade Commission (FTC).
Notice to California Residents
The California Consumer Privacy Act of 2018, (Cal. Civ. Code §1798.100 et seq., as amended, “CCPA”) gives California residents rights and control over their personal information. Clutch provides this statement to those residents (“you”) in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their personal information. This is Clutch’s California-specific description of consumers’ privacy rights under the CCPA.
We Do Not Sell Your Personal Information
Under the CCPA, a business that sells California residents’ personal information to others:
1) must give notice to California residents before selling their personal information to others; and 2) must provide the right to opt out of the sale of their personal information.
Clutch does not sell personal information, including Personal Information of anyone under 16 years old, without consent.
Your Rights Under the CCPA
1. Right to know what personal information is being collected, for what purposes and with whom it is shared
California residents have the right to request from a business disclosure of the categories and specific pieces of personal information it has collected from them in the preceding 12 months, the categories of sources from which such personal information is collected, the business or commercial purpose for collecting or selling such personal information, and the categories of third parties with whom the business shares personal information.
If you request that a business disclose categories and specific pieces of personal information collected about you, you have the right to receive that information, free of charge, twice a year. The information may be delivered by mail or electronically and, if provided electronically, shall be in a portable and, to the extent technically feasible, readily usable format that allows the California resident to relatively easily transmit this information to another entity.
2. Right to know whether your personal information is sold or disclosed for a business purpose and to whom
California residents have the right to request from a business that sells or discloses personal information for a business purpose separate lists of the categories of personal information collected, sold or disclosed for a business purpose in the preceding 12 months, including the categories of third parties to whom the personal information was sold or disclosed for a business purpose.
3. Right to say no to the sale of your personal information
As explained above, the CCPA requires businesses that sell personal information to allow residents the ability to opt out of the selling of their information.
Again, Clutch does not sell personal information.
4. Right to non-discrimination of service or price if you exercise your privacy rights
The CCPA prohibits businesses from discriminating against a California resident for exercising any of their rights under the CCPA, including by:
- denying goods or services to the resident;
- charging different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
- providing a different level or quality of goods or services; or
- suggesting that the person exercising their rights will receive a different price or rate for goods or services or a different level or quality of goods or services.
5. Right to deletion
California residents have the right to request that a business delete any of their personal information that the business collected from them, subject to the exceptions in CCPA §1798.105.
To Exercise Your CCPA Rights
Contact us at 1(888)-541-6789
Clutch will verify your request within seven (7) days and complete the request within 45 days from receipt of the request, as required by law.
If you have any questions specifically about CCPA, you may reach out to us at [email protected].
Changes to this Privacy Statement
We may change this Privacy Statement from time to time. If we make any changes, we will update the version and date at the top of this Privacy Statement and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to the log-in screen or sending you an email notification). We are not required to notify you directly.
Your continued use of our Services after the revised Statement has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Statement.
Please contact us with any questions or comments about this Privacy Statement, your Personal Information, our use and disclosure practices, or your consent choices by email at [email protected].
Our Data Protection Officer (DPO) is:
Clutch is not established in the EU, however we do maintain a designated EU representative under Article 27 of GDPR:
VeraSafe has been appointed as Clutch’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Brian Bettencourt, Clutch’s DPO, only on matters related to the processing of personal data.
To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27- representative or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Netherlands BV
Keizersgracht 391 A 1016 EJ
Clutch’s Subvendor Directory
(Last updated: December 27, 2019)
Clutch shares information with service providers and other third parties who perform services on our behalf.
This page provides a list of vendors with whom we share Personal Information as well as describes where each is located and what services these vendors provide for us.
|Subvendor||Service Provided||Headquarters Location|
|Google Analytics||Analytics||United States|
|AWS||Cloud infrastructure||United States|
|AppCues||Product Growth||United States|
|Marketo||Client Marketing||United States|
|Google G-Suite||Communication and Daily Management||United States|
|Atlassian||Task Management & Documentation||Australia|
|Sharefile||Internal and External Secure File Share||United States|
|Dropbox||Internal File Storage||United States|
(Last updated December 2019)
- To personalize your Site experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To allow us to better service you in responding to your customer service requests.
- To quickly process transactions.
- To administer a promotion, survey or other Site feature.
(Last updated December 2019)
- To personalize your Site experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To allow us to better service you in responding to your customer service requests.
- To quickly process transactions.
- To administer a promotion, survey or other Site feature.
The Company acknowledges that individuals have the right to access the personal information/data that we maintain about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct your query to [email protected] or (267-419-6400). If requested to remove date, the Company will respond within a reasonable timeframe.We may contract with third-party service providers to assist us in better understanding our Site visitors. These firms may aggregate site traffic in terms of industry, corporation size and geography. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.Please be aware that the Company may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.The Company complies with the CASN, which went into effect on July 1, 2014. The Company has certified that it adheres to the CASN. The purpose of the CASN is to promote the efficiency of the Canadian economy by regulating commercial conduct that discourages the use of email to carry out commercial means The purpose of the CASN is to promote the efficiency and adaptability of the Canadian economy by regulating commercial conduct that discourages the use of electronic means to carry out commercial activities, because that conduct:(a) impairs the availability, reliability, efficiency and optimal use of electronic means to carry out commercial activities;
(b) imposes additional costs on businesses and consumers;
(c) compromises privacy and the security of confidential information; and