PRIVACY POLICY

Last Updated: March 14, 2025

1. INTRODUCTION

This Privacy Policy explains how Sunden Group AB, doing business as Clutch Group ("we," "us," or "our"), collects, uses, and shares information about you when you use our website (clutch.game), Discord bots and applications, and all other services provided by Clutch Group (collectively, the "Services"). We respect your privacy and are committed to protecting your personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation ("GDPR").

2. DATA CONTROLLER

Sunden Group AB is the data controller responsible for your personal data. We are a company registered in Sweden.

Contact Details:

  • Email: bot@clutch.game
  • Company: Sunden Group AB (d/b/a Clutch Group)
  • Location: Stockholm, Sweden

3. INFORMATION WE COLLECT

3.1 Information You Provide

When using our Services, we may collect the following types of information:

For Website Users:

  • Account information (name, email address, username, password)
  • Profile information (profile picture, biography)
  • Contact information
  • Billing and payment information
  • Communication preferences
  • Any other information you choose to provide

For Discord Bot and Application Users:

  • Discord User ID
  • Discord Username
  • Discord Server ID
  • User commands and interactions with our applications
  • User preferences and settings
  • Configuration data and selections

3.2 Information Collected Automatically

When you interact with our Services, we automatically collect certain information, including:

  • Log data (such as IP address, browser type, pages visited, time spent)
  • Device information (such as device type, operating system)
  • Usage statistics and analytics
  • Cookies and similar tracking technologies
  • Error reports

4. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

  • To provide, maintain, and improve our Services
  • To process and complete transactions
  • To respond to your comments, questions, and requests
  • To send technical notices, updates, security alerts, and support messages
  • To communicate with you about products, services, offers, and events
  • To monitor and analyze trends, usage, and activities in connection with our Services
  • To detect, prevent, and address technical issues
  • To personalize and improve your experience
  • To develop new products and services
  • For billing and administrative purposes

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process your personal data under the following legal bases:

  • Performance of Contract: Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
  • Legitimate Interests: Processing is necessary for our legitimate interests, such as to improve our Services and provide a better experience, as long as these interests are not overridden by your rights.
  • Consent: Where required by law, we process your personal data based on your consent.
  • Legal Obligation: Processing is necessary to comply with a legal obligation to which we are subject.

6. DATA RETENTION

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Different types of data may be retained for different periods:

  • Account data: For the duration of your account plus a reasonable period thereafter
  • Transaction data: As required by tax and accounting regulations
  • Communication data: As long as necessary to respond to inquiries and provide support
  • Usage data: For analytical purposes, typically anonymized after a certain period

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Cookies

We use cookies and similar tracking technologies to track activity on our website and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier.

7.2 Types of Cookies We Use

  • Essential Cookies: Necessary for the functioning of our website
  • Analytical/Performance Cookies: Help us understand how visitors interact with our website
  • Functionality Cookies: Enable us to remember choices you make
  • Targeting Cookies: Record your visit to our website, pages visited, and links followed

7.3 Your Choices Regarding Cookies

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

8. DATA SHARING AND DISCLOSURE

We do not sell, trade, or otherwise transfer your personal information to outside parties except in the following circumstances:

  • Service Providers: We may share your information with third-party service providers who help us operate our Services, conduct our business, or serve our users. These third parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • Partners: With your consent, we may share your information with our partners to offer you certain products, services, or promotions.
  • Legal Requirements: We may disclose your information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement.
  • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
  • With Your Consent: We may disclose your personal information for any other purpose with your consent.

9. YOUR DATA PROTECTION RIGHTS

Under the GDPR and other applicable data protection laws, you have certain rights regarding your personal data:

  • Right to Access: You have the right to request copies of your personal data.
  • Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • Right to Erasure: You have the right to request that we erase your personal data under certain conditions.
  • Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
  • Right to Object to Processing: You have the right to object to our processing of your personal data under certain conditions.
  • Right to Data Portability: You have the right to request that we transfer the data we have collected to another organization or directly to you under certain conditions.

If you wish to exercise any of these rights, please contact us at bot@clutch.game. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

10. INTERNATIONAL TRANSFERS

Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of Sweden and choose to provide information to us, please note that we transfer the data to Sweden and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

11. SECURITY

We implement appropriate technical and organizational measures to protect the security of your personal data. These measures include:

  • Encryption of sensitive data
  • Regular security assessments
  • Access controls and authentication measures
  • Staff training on data security
  • Physical security measures for our facilities

However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

12. USER RESPONSIBILITY

You are responsible for ensuring that your use of our Services complies with all applicable laws and regulations in your jurisdiction. We recommend that parents and guardians supervise the online activities of their wards and consider the use of parental control tools available from online services and software manufacturers to help provide a child-friendly online environment.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website and, where appropriate, via email. You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page. The date of the most recent revision will appear at the top of the page.

14. CONTACT US

If you have any questions about this Privacy Policy, please contact us at:

Email: bot@clutch.game

Sunden Group AB (Clutch Group)
Stockholm, Sweden

15. SUPERVISORY AUTHORITY

If you are a resident of the European Economic Area (EEA) and you believe we are processing your personal data unlawfully, you have the right to lodge a complaint with your local data protection supervisory authority. In Sweden, this is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten).

Published by Silverfox