# Privacy Policy — Clutch Data Last updated: 6 November 2026 This policy explains what personal data Clutch Data LLC ("Clutch Data", "we", "us") collects through clutchdata.net, why we collect it, how long we keep it, and what rights you have over it. It covers this website only. Data processed inside a client engagement is governed by the confidentiality and data processing terms of that specific contract. ## 1. Who is responsible for your data The data controller is Clutch Data LLC. We are a distributed team working across Europe and the Americas. For any question about this policy, about how your data is handled, or to request the controller's registered details, write to info@clutchdata.net. ## 2. What we collect ### Information you send us When you submit the contact form on our homepage we receive the fields you fill in: your name, your club or organization, your email address, and the description of the decision you are facing. When you email us directly we receive whatever your message and signature contain. Please do not send confidential player medical data, contract terms, or special-category personal data through the website form. ### Information collected automatically - **Aggregate usage analytics.** Vercel Web Analytics counts page views and referrers. It is cookieless: no tracking cookies, no cross-site profile, no persistent identifier we can tie back to an individual. - **Performance measurement.** Vercel Speed Insights measures how quickly pages load and respond (Core Web Vitals). It records anonymous performance metrics with the page visited and the browser and device type. No cookies, no identifier tied to you. - **Server logs.** Our hosting provider records IP address, timestamp, requested URL and user agent for security and reliability. - **Language preference.** Your site language choice is stored in your browser's local storage under the key `cd_lang`. It never leaves your device and is not a cookie. - **Where your visit started.** The first page you see, the website that sent you here (without any query string) and any `utm_*` campaign tags in our own links are kept in your browser's session storage under the key `cd_entry`. It is erased when you close the tab and reaches us only if you send the contact form, together with your enquiry. We do not use advertising cookies, retargeting pixels, session recording or heat mapping. ## 3. Why we use it, and on what legal basis - **To answer your enquiry and scope possible work** — pre-contractual steps at your request and our legitimate interest in responding to business enquiries (GDPR Art. 6(1)(b) and 6(1)(f)). - **To keep the site secure and available** — legitimate interest (Art. 6(1)(f)). - **To understand which pages are read and how fast they load** — legitimate interest, aggregate cookieless measurement only (Art. 6(1)(f)). We do not sell personal data, do not share it with advertisers, and do not use it to train machine learning models. ## 4. Who processes data on our behalf - **Vercel Inc.** — hosting, content delivery, cookieless analytics, performance measurement. - **Formspree, Inc.** — delivery of contact form submissions to our inbox. - **Slack Technologies, LLC** — notification of new contact form submissions in a private channel of our team. - **Google LLC (Google Fonts)** — the site loads two typefaces from Google's font CDN, so your IP address is visible to Google when the fonts are fetched. - **Our email provider** — receipt and storage of correspondence to info@clutchdata.net. Some providers are established in the United States, so data may be transferred outside the EEA under Standard Contractual Clauses or an equivalent adequacy mechanism. Substack, LinkedIn and X are linked from this site but are separate services with their own privacy policies. ## 5. How long we keep it Contact enquiries are retained while the commercial conversation is live and for up to 24 months afterwards. If an engagement begins, correspondence is retained under that contract. Server logs are held for a short operational period. Aggregate analytics contain no personal data. You can ask us to delete your enquiry sooner at any time. ## 6. Your rights If you are in the EEA or the UK, the GDPR gives you the right to access, correct, erase, restrict, object to and port your data, and to withdraw consent where processing is based on consent. Email info@clutchdata.net to exercise any of these; we respond within 30 days. You may also lodge a complaint with your national data protection supervisory authority. ## 7. Security The site is served exclusively over HTTPS. Access to enquiry correspondence is limited to the senior analysts who need it. Confidentiality is the default posture of the business, not an add-on. ## 8. Children This site is aimed at professional basketball organizations and is not directed at children. We do not knowingly collect personal data from anyone under 16 through this website. Analysis performed inside a client engagement may concern players who are minors; that processing takes place under the club's instructions and the relevant contract, not under this policy. ## 9. Changes to this policy If we change how we handle personal data we will update this page and revise the date at the top. Material changes affecting people who have already contacted us will be communicated by email where we hold a valid address. ## 10. Contact info@clutchdata.net — see also https://www.clutchdata.net/contact