Privacy Policy

Introduction and Scope

Clutr Labs LLC ("Company," "we," "our," or "us"), a Wyoming limited liability company, is committed to protecting the privacy and personal information of users of the Clutr mobile application ("Application") and the website located at clutrlabs.com ("Site"). This Privacy Policy ("Policy") sets forth the legal basis on which we collect, process, use, disclose, retain, and protect personal data in connection with the Application and Site.

This Policy applies to all individuals who access or use the Application or Site, regardless of location ("Users" or "you"). By accessing or using the Application or Site, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. If you do not agree with this Policy, you must discontinue use of the Application and Site immediately.

This Policy is incorporated by reference into our Terms of Service and forms part of the legal agreement between you and Clutr Labs LLC.

Data Controller Information

Clutr Labs LLC is the data controller responsible for your personal information collected through the Application and Site. Our contact details are as follows:

Information We Collect

We collect personal information only to the extent necessary to provide the Application's core functionality. The categories of personal data we collect are as follows:

• Account credentials: email address or phone number, collected during registration and used solely for identity verification and authentication
• Third party authentication data: if you elect to register or sign in using a third party identity provider (including Google, Apple, Facebook, or Microsoft), we receive limited profile information, such as your name and email address, as permitted by your settings with that provider
• User generated content: calendar events, tasks with deadlines, and to do list items that you create within the Application
• Group membership data: information regarding which shared groups you belong to within the Application, including group membership and assigned tasks
• Device identifiers: push notification tokens used solely to deliver in-Application notifications to your device
• Technical data: device type, operating system version, and Application version, collected only as necessary to provide support or diagnose technical issues

Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: processing required to perform our agreement with you and to provide the Application's core features
• Consent: where you have provided explicit consent, including consent to receive push notifications or to use optional features
• Legitimate interests: processing necessary for our legitimate business interests, including fraud prevention, security, and service improvement, provided such interests are not overridden by your rights
• Legal obligation: processing required to comply with applicable laws and regulations

How We Use Your Information

We use personal information collected from you solely for the following purposes:

• To create, authenticate, and maintain your user account
• To provide, operate, and maintain the Application's core features, including shared calendars, tasks, and to do lists
• To deliver transactional communications, including account verification codes, security alerts, and critical account notifications
• To send push notifications for task reminders, calendar alerts, and group activity updates, where you have granted permission
• To respond to support inquiries and resolve technical issues
• To monitor and improve the security and integrity of our systems
• To fulfill our obligations under applicable law and enforce our Terms of Service

We do not use personal data for advertising, behavioral profiling, or any purpose not expressly stated in this Policy.

Sharing of Information Within Groups

The Application is designed to facilitate shared coordination among members of a group. Calendar events, tasks, and to do list items that you create within a shared group are visible to all other members of that group. This sharing constitutes the core functionality of the Application and is performed with your knowledge and consent upon joining or creating a group.

Upon leaving or being removed from a group, you will no longer have access to that group's shared content. Content you previously contributed to a shared group may remain visible to remaining members until it is deleted by those members or the group is dissolved.

Disclosure to Third Parties

We engage a limited number of third party service providers to assist in the operation of the Application. These providers are contractually prohibited from using your personal information for any purpose other than the specific services they provide to us. Our current third party processors include:

• Postmark (Wildbit LLC): transactional email delivery, including account verification and security notifications
• Twilio Inc.: SMS delivery for account verification codes
• Google LLC (Google Workspace): business email communications received at admin@clutrlabs.com
• Apple Inc. and Google LLC: push notification delivery through their respective platform notification services

Beyond the above, we may disclose personal information: (i) to comply with applicable law, regulation, legal process, or governmental request; (ii) to enforce our Terms of Service or investigate potential violations; (iii) to protect the rights, property, or safety of Clutr Labs LLC, our users, or the public; or (iv) in connection with a merger, acquisition, or sale of substantially all of our assets, in which case the acquiring entity will be bound by this Policy or provide notice of any material changes.

We do not share personal information with data brokers, advertising networks, analytics providers, or any third party for commercial, marketing, or advertising purposes.

Data Security

We implement industry standard technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of all data in transit using Transport Layer Security (TLS/HTTPS)
• Encryption of personal data at rest within our storage systems
• Strict access controls limiting access to personal data to authorized personnel with a demonstrable operational need
• Regular security monitoring and review of our systems and practices

Notwithstanding the foregoing, no method of electronic transmission or storage provides absolute security. We cannot guarantee the security of information transmitted to or through the Application and Site, and any such transmission is at your own risk. In the event of a data breach affecting your personal information, we will notify you and applicable regulatory authorities in accordance with applicable law.

Data Retention

We retain your personal information for as long as your account remains active and as reasonably necessary to fulfill the purposes described in this Policy. Upon deletion of your account, we will permanently delete your personal information and associated user generated content within thirty (30) days of receiving your deletion request.

Certain data may be retained beyond this period where required or permitted by applicable law, including for legal compliance, fraud prevention, dispute resolution, or enforcement of our agreements. Where data is retained for such purposes, we will limit further processing to only what is strictly necessary.

Account and Data Deletion

You may request deletion of your account and all associated personal data at any time through the following channels:

• In-Application: navigate to Settings and select Delete Account, then confirm the deletion when prompted
• Web request: submit a deletion request at clutrlabs.com/delete-account
• Email: send a written request to admin@clutrlabs.com with the subject line "Account Deletion Request"

Deletion requests will be processed within thirty (30) days of receipt. You will receive confirmation upon completion.

Cookies and Website Analytics

Our Site may employ cookies and similar tracking technologies to collect aggregate, non-personally identifiable information regarding how visitors interact with the Site, such as pages visited and navigation patterns. This information is used solely to improve the functionality and user experience of the Site and is not linked to any individual's personal identity.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Disabling cookies may affect certain functionality of the Site. Where required by applicable law, we will obtain your consent prior to placing non-essential cookies on your device.

Children's Privacy

The Application and Site are not directed to children under the age of 13, and we do not knowingly collect personal information from individuals under the age of 13. If we become aware that personal information has been collected from a child under 13 without verifiable parental consent, we will take immediate steps to delete such information from our systems. If you believe we have inadvertently collected such information, please contact us at admin@clutrlabs.com.

Your Privacy Rights

Depending on your jurisdiction, you may have rights in relation to your personal information, including the right to:

• Access: obtain a copy of the personal information we hold about you
• Rectification: request correction of inaccurate or incomplete personal information
• Erasure: request deletion of your personal information, subject to legal retention obligations
• Portability: receive your personal information in a structured, machine-readable format
• Restriction: request that we limit processing of your personal information in certain circumstances
• Objection: object to processing of your personal information based on legitimate interests
• Withdrawal of consent: withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing

To exercise any of the above rights, please submit a written request to admin@clutrlabs.com. We will respond within a reasonable timeframe and in accordance with applicable law.

Jurisdiction Specific Provisions

Canada (PIPEDA): We collect, use, and disclose personal information in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA"). We collect personal data only for identified purposes, with your knowledge and consent. You have the right to access your personal information and challenge its accuracy. To exercise these rights or to contact our designated privacy officer, please write to admin@clutrlabs.com.

Mexico (LFPDPPP): This Policy serves as our Aviso de Privacidad under the Federal Law on Protection of Personal Data Held by Private Parties. The data controller is Clutr Labs LLC. You have the right to access, rectify, cancel, or oppose the processing of your personal data (derechos ARCO) by contacting admin@clutrlabs.com.

European Union and United Kingdom (GDPR / UK GDPR): Where the GDPR or UK GDPR applies, you have additional rights, including the right to lodge a complaint with your applicable supervisory authority. Our legal basis for processing personal data is set out in the "Legal Basis for Processing" section above. For data transfers outside the European Economic Area, we take appropriate safeguards to ensure your data receives an equivalent level of protection.

International Data Transfers

Clutr Labs LLC operates globally and your personal information may be transferred to, stored, and processed in the United States and other countries where our service providers are located. We take appropriate steps to ensure that any such cross-border transfers of personal information comply with applicable data protection laws and that your information is afforded a level of protection consistent with this Policy.

Changes to This Policy

We reserve the right to modify this Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated Policy on this page with a revised effective date. Where required by applicable law, we will provide additional notice of material changes. Your continued use of the Application or Site following the posting of any changes constitutes your acceptance of those changes.

Contact Us

For any questions, concerns, or requests regarding this Policy or our data handling practices, please contact us at: