Privacy Policy

Last updated: 1 July 2025

Entity
Clutch Track Pty Ltd (ACN 678 762 564 / ABN 27 678 762 564)
Trading as
Clutch
Effective date
1 July 2025
Version
1.0
Applies to
The Clutch mobile app (iOS and Android), the Clutch web platform, and related services

1. Introduction

Clutch Track Pty Ltd (we, us, our) operates Clutch, a reinforcement scheduling, delivery-tracking and cost-control platform used by construction businesses. This Privacy Policy explains how we collect, hold, use, disclose and protect personal information when you use the Clutch mobile application, the Clutch web platform and related services (together, the Platform).

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) set out in that Act. This policy also addresses the privacy disclosure requirements of the Apple App Store and Google Play.

By downloading, installing or using Clutch, you acknowledge that your personal information will be handled as described in this policy. If you do not agree, please do not use the Platform.

1.1 How Clutch is used

Clutch is business-to-business software. In most cases you access Clutch because your employer, principal contractor or another organisation (your Account Organisation) has subscribed to the Platform and issued you a user account. Where we handle personal information on behalf of an Account Organisation, we act largely as a service provider to that organisation, and its own privacy policy may also apply to information it enters into or extracts from Clutch.

2. Information we collect

We only collect personal information that is reasonably necessary for the functions and activities of the Platform.

2.1 Information you provide to us

CategoryExamples
Account and identity informationFull name, work email address, password or federated login credentials, employer or company name, job title or site role, and the projects you are assigned to.
Contact informationWork phone number and work email address, including the contact details of project team members, site personnel, suppliers and subcontractors that you or your Account Organisation enter into the Platform.
Content you submitPhotographs and images captured with your device camera or selected from your photo library — for example photos of reinforcement deliveries, bar marks, delivery dockets, and damaged or missing items — together with comments, notes, delivery mark-offs, issue flags and other entries you make.
Project documentsReinforcement schedules, delivery dockets, invoices, progress claims and similar documents you upload or that are supplied to us for processing, which may incidentally contain personal information such as names and signatures.
Support and correspondenceInformation you provide when you contact us for support, report a fault, or give feedback.

2.2 Information we collect automatically

CategoryExamples
Device and technical dataDevice model, operating system and version, app version, language and region settings, and a device or installation identifier.
Push notification tokensA token issued by Apple Push Notification service or Firebase Cloud Messaging so we can deliver notifications to your device.
Usage and analytics dataFeatures accessed, screens viewed, actions taken within the Platform, session dates and times, and aggregated usage patterns.
Diagnostics and crash dataCrash reports, error logs, performance data and stack traces.
Log dataIP address, access timestamps and API request metadata generated when your device communicates with our servers.

2.3 What we do not collect

  • We do not collect precise or background location data. Clutch does not request or use GPS location permissions.
  • We do not collect sensitive information as defined in the Privacy Act — such as health information, racial or ethnic origin, religious beliefs, or union membership — and we ask that you do not submit it through the Platform.
  • We do not collect payment card details through the mobile app. Subscription billing is arranged directly with the Account Organisation.
  • We do not sell personal information, and we do not use personal information for third-party advertising or cross-app tracking.

2.4 Anonymity and pseudonymity

Because Clutch is an access-controlled project platform in which every action must be attributable to an identified user, it is not practicable for you to deal with us anonymously or under a pseudonym when using the Platform. You may, however, make a general enquiry or complaint to us anonymously, though this may limit our ability to respond.

3. Device permissions

The Clutch mobile app requests the permissions below. You may decline or later revoke any of them in your device settings. Where a permission is declined the related feature will not function, but the rest of the app will continue to work.

PermissionWhy we request itIf you decline
CameraTo photograph deliveries, bar marks, dockets, and damaged or missing items directly from site.You can still upload images from your photo library, or use the app without photos.
Photo libraryTo attach existing images from your device to a delivery, schedule item or issue report.You can still capture new photos with the camera, or proceed without images.
NotificationsTo alert you to deliveries, variances, missing items, approvals and other project events.You will need to open the app to check for updates.
Contacts (optional)Where offered, to let you add a project team member without typing their details manually.You can enter team member details manually.

Photos you capture are uploaded to your Account Organisation’s Clutch workspace and are visible to other authorised users of that workspace. We do not access your camera roll in the background, and we do not scan images unrelated to the item you attach them to.

4. How we use personal information

PurposeWhat this involves
Providing the PlatformCreating and authenticating your account, assigning you to projects, displaying schedules and registers, recording deliveries and installation status, and processing documents.
Document processingClassifying and extracting data from reinforcement schedules, delivery dockets and invoices using optical character recognition and automated classification, so the information can be reconciled against budgets and claims.
Notifications and coordinationSending operational notifications about deliveries, variances, missing or incorrect items, approvals and other project events.
Support and troubleshootingResponding to your enquiries, investigating faults, and diagnosing crashes and performance issues.
Security and integrityVerifying access rights, maintaining audit logs, detecting duplicate claims and discrepancies, and preventing unauthorised or fraudulent use.
Improving ClutchAnalysing aggregated and de-identified usage data to improve features, reliability and estimating accuracy.
Legal and complianceMeeting our legal, regulatory, contractual, insurance and record-keeping obligations, and establishing or defending legal claims.

We will not use your personal information for an unrelated purpose unless you would reasonably expect it, you have consented, or the use is otherwise permitted or required by law.

4.1 Automated processing

Clutch uses automated classification and data-extraction techniques on uploaded project documents. These processes operate on document content — bar marks, quantities, rates — rather than on individuals, and we do not use automated decision-making that produces legal or similarly significant effects on individuals.

4.2 Direct marketing

We may occasionally send you information about Clutch product updates, new features or related services. Every marketing message includes a clear unsubscribe function, consistent with APP 7 and the Spam Act 2003 (Cth). Operational and transactional messages about your projects are not marketing and cannot be unsubscribed from while your account remains active, though you can disable push notifications at any time.

5. When we disclose personal information

We disclose personal information only as described below. We do not sell, rent or trade personal information.

  • Your Account Organisation and other authorised users. Entries you make in Clutch — including your name, the time of the action, and any photos or comments you attach — are visible to other authorised users of the same project workspace, including your employer, the principal contractor, and where relevant the reinforcement supplier.
  • Service providers. Third parties that host, secure, process or support the Platform on our behalf, under contractual obligations of confidentiality and security. These are listed in section 6.
  • Professional advisers. Our lawyers, accountants, auditors and insurers where reasonably required.
  • Corporate transactions. A prospective purchaser or successor in the event of a sale, merger or restructure of our business, subject to confidentiality undertakings.
  • Legal requirements. Courts, regulators, law enforcement or other authorities where required or authorised by Australian law, or where reasonably necessary to prevent a serious threat to life, health or safety.

6. Service providers and data location

6.1 Where your data is stored

Clutch data is hosted in Australian data centre regions. Our primary application, database and document storage are located in Australia.

6.2 Third-party service providers

We rely on the following providers. Each is engaged under terms that limit their use of the data to providing services to us.

Provider / categoryPurposeData handled
Auth0 (Okta)User authentication, role-based access control and permission management.Name, email address, credentials, login metadata.
Amazon Web ServicesApplication hosting, database and document storage (Australian region).All Platform data, including uploaded documents and photos.
Microsoft Azure – Document IntelligenceOptical character recognition and structured data extraction from project documents.Uploaded schedules, dockets and invoices.
Microsoft Outlook / Microsoft 365Monitoring a dedicated Clutch mailbox for inbound supplier documents.Email metadata and PDF attachments sent to that mailbox.
Apple Push Notification service; Firebase Cloud Messaging (Google)Delivery of push notifications to your device.Push token, notification content.
Analytics and crash reportingDiagnosing faults and understanding feature usage.Device data, usage events, crash logs.
Cloud file storage integrationsWhere enabled by your Account Organisation, retrieving project documents from its own file storage.Documents in the folders you connect.

6.3 Overseas disclosure (APP 8)

Although our hosting is located in Australia, several of the providers above are incorporated overseas — principally in the United States — and their support, security and engineering personnel may be able to access data from outside Australia in the course of maintaining their services. Some support and diagnostic functions may also be performed from other countries in which those providers operate.

Before disclosing personal information to an overseas recipient we take steps that are reasonable in the circumstances to ensure the recipient does not breach the Australian Privacy Principles, including through contractual data protection terms. By using Clutch you acknowledge that these overseas disclosures may occur.

A current list of our service providers and their locations is available on request.

7. Security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, as required by APP 11. Our measures include:

  • Encryption of data in transit using TLS, and encryption of stored documents and database contents at rest.
  • Authentication and role-based access control, with administrative functions restricted to users holding administrator roles.
  • Access to production systems limited to personnel who need it, on a least-privilege basis.
  • Audit logging of significant actions within the Platform.
  • Regular patching, backups and review of our security controls.

No method of transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential and for notifying us promptly if you suspect unauthorised use of your account.

7.1 Data breaches

We maintain a data breach response plan. If we suffer an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act, and we will notify the relevant Account Organisation.

8. Retention and deletion

We retain personal information for as long as it is needed for the purposes described in this policy, and for as long as the relevant Account Organisation maintains its Clutch subscription. Project records, delivery evidence and document data are commonly retained for the life of the project and for a further period to support progress claims, contract administration, warranty periods and dispute resolution.

After that, we will destroy or de-identify personal information, unless we are required to retain it by law — for example under taxation, corporations, or building and construction record-keeping obligations — or it is reasonably necessary to retain it in connection with an actual or anticipated legal claim.

8.1 Deleting your account

You can request deletion of your Clutch account and associated personal information at any time, in any of the following ways:

Once a deletion request is verified, we will delete your account credentials, profile and personal usage data within 30 days, and from backups within a further 90 days.

Please note: project records created through your use of Clutch — delivery mark-offs, issue reports, uploaded documents and photographs — belong to your Account Organisation and form part of its project record. These may be retained by that organisation after your individual account is deleted. Where technically feasible and lawful, we will disassociate them from your personal identifiers, or refer your request to the Account Organisation as data controller. We will tell you which applies when we respond to your request.

9. Accessing and correcting your information

Under APP 12 and APP 13 you may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Much of this information is available directly in the app through your profile settings.

To make a request, contact our Privacy Officer using the details in section 13. We will need to verify your identity. We will respond within a reasonable period, ordinarily within 30 days. Access is provided free of charge, though we may charge a reasonable cost-recovery fee for a request requiring substantial effort; we will tell you before any fee is incurred.

In limited circumstances we may refuse access or correction — for example where it would unreasonably affect the privacy of others, where the information relates to a commercially sensitive decision-making process, or where refusal is required or authorised by law. If we refuse, we will give you written reasons and explain how to complain.

10. App Store and Google Play disclosures

This policy is the privacy policy referred to in our App Store privacy details (“Privacy Nutrition Labels”) and our Google Play Data safety section. The data types disclosed on those store listings correspond to the categories described in section 2.

In summary: Clutch collects contact information, user content (photos and documents), identifiers, app activity and diagnostics; data is encrypted in transit; data is not sold or shared for advertising or cross-app tracking; and users can request deletion of their data as described in section 8.

The Clutch app does not use the Advertising Identifier (IDFA) or the Google Advertising ID, and does not perform tracking as defined by Apple’s App Tracking Transparency framework.

11. Cookies and similar technologies

The Clutch website and web platform use cookies and similar technologies (such as local storage and pixels). A cookie is a small text file placed on your device that allows a site to recognise your browser.

11.1 Categories we use

CategoryWhat it doesCan you disable it?
Strictly necessaryKeeps you signed in, maintains your session, secures form submissions, and remembers your cookie preferences. The Platform cannot function without these.No — these are essential to delivering the service you have requested.
Functional / preferenceRemembers settings such as your selected project, filters and display preferences.Yes — the Platform will still work, but will not remember your preferences.
Analytics / performanceHelps us understand which pages and features are used, and diagnose errors, so we can improve the Platform. Reporting is aggregated.Yes.
MarketingMeasures the effectiveness of our marketing on the public clutchtrack.ai website. We do not use marketing cookies inside the authenticated Clutch platform.Yes.

11.2 Managing cookies

Where required, we ask for your consent before setting non-essential cookies, and you can change your choice at any time using the cookie preferences control on our website. You can also block or delete cookies through your browser settings — see your browser’s help documentation. Blocking strictly necessary cookies may prevent parts of the Platform from working.

11.3 Do Not Track

There is no consistent industry standard for responding to browser “Do Not Track” signals, so our website does not currently respond to them. We do not track users across third-party websites for advertising purposes.

11.4 Mobile app

The Clutch mobile app does not use browser cookies. It stores an authentication token and your app preferences locally on your device, which are cleared when you sign out or uninstall the app.

12. Children

Clutch is a workplace tool intended for use by construction industry professionals. It is not directed at, and we do not knowingly collect personal information from, anyone under 16 years of age. Where a user is a lawfully employed apprentice or trainee under 18, their account is created and administered by their Account Organisation. If you believe we have collected information from a child in error, please contact us and we will delete it.

13. Complaints and contact

If you have a question about this policy, or wish to complain about how we have handled your personal information, please contact us:

Privacy Officer
Clutch Track Pty Ltd
Registered address
Suite 2, 1 Transvaal Avenue, Double Bay NSW 2028, Australia

We will acknowledge your complaint promptly, ordinarily within 5 business days, and aim to provide a substantive response within 30 days. We may need to ask you for further information in order to investigate.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au, by phone on 1300 363 992, or by post to GPO Box 5218, Sydney NSW 2001.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our practices, the Platform, or the law. The current version is always available at https://www.clutchtrack.ai/privacy-policy and within the app. Where a change is material, we will give notice in the app or by email before it takes effect. The effective date at the top of this page indicates when the current version came into force.

Clutch Track Pty Ltd complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Last updated 1 July 2025.

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