GDPR Compliance
Last updated: December 2024
1. Introduction
CLUTCH LLC is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR). This document outlines how we collect, use, and protect your personal data in accordance with GDPR requirements.
2. Legal Basis for Processing
We process your personal data under the following legal bases:
- Consent: When you provide explicit consent for specific processing activities
- Contract: When processing is necessary for the performance of a contract
- Legal Obligation: When we must comply with legal requirements
- Legitimate Interest: When processing is necessary for our legitimate business interests
3. Your Rights Under GDPR
As a data subject, you have the following rights:
- Right to Access: You can request a copy of your personal data
- Right to Rectification: You can request correction of inaccurate data
- Right to Erasure: You can request deletion of your personal data
- Right to Restrict Processing: You can request limitation of processing
- Right to Data Portability: You can request transfer of your data
- Right to Object: You can object to certain types of processing
- Right to Withdraw Consent: You can withdraw consent at any time
4. Data We Collect
We collect the following types of personal data:
- Identity Data: Name, username, email address
- Contact Data: Email address, phone number, postal address
- Technical Data: IP address, device information, browser type
- Usage Data: Information about how you use our services
- Marketing Data: Your preferences for receiving marketing communications
5. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. When data is no longer needed, we securely delete or anonymize it.
6. Data Security
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, access controls, and regular security assessments.
7. International Data Transfers
If we transfer your personal data outside the European Economic Area (EEA), we ensure adequate protection through appropriate safeguards such as Standard Contractual Clauses or adequacy decisions by the European Commission.
8. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with data protection laws. You can contact our DPO at: dpo@clutchllc.com
9. Cookies and Tracking
We use cookies and similar tracking technologies to improve your experience. You can manage your cookie preferences through your browser settings or our cookie consent banner.
10. Children's Data
We do not knowingly collect or process personal data from children under 16 years of age without parental consent. If you believe we have collected such data, please contact us immediately.
11. Exercising Your Rights
To exercise any of your rights under GDPR, please contact us at:
Email: gdpr@clutchllc.com
Subject: GDPR Request - [Your Request Type]
Include: Your name, email address, and detailed description of your request
We will respond to your request within 30 days of receipt.
12. Complaints
If you have concerns about how we handle your personal data, you have the right to lodge a complaint with your local data protection authority. You can also contact us directly to resolve any issues.
13. Contact Information
For any questions regarding GDPR compliance or data protection, please contact us:
CLUTCH LLC
3831 5TH AVE SW
NAPLES, FL 34117
Email: gdpr@clutchllc.com