PRIVACY POLICY

Clutch The Close

Effective Date: May 24th, 2025 | Last Updated: May 25th, 2025

1. INTRODUCTION

Clutch The Close ("Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who interact with our business — including website visitors, prospective clients, active clients, and former clients.

This Privacy Policy ("Policy") explains how we collect, use, store, share, and protect your personal information when you:

• Visit our website(s), landing pages, or funnels (including but not limited to clutchtheclose.com and sales.clutchtheclose.com).

• Schedule or attend a discovery call, strategy call, or any other consultation with our team.

• Purchase and engage with our consulting, done-for-you, or advisory services.

• Interact with us through email, WhatsApp, Slack, Zoom, social media, or any other communication channel.

• Submit forms, questionnaires, intake documents, or any other information to us.

This Policy is governed by the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable Indian data protection laws. Where our clients are based outside India, we also adhere to internationally recognized data protection principles.

By engaging with us in any capacity, you consent to the collection and use of your information as described in this Policy.

2. INFORMATION WE COLLECT

2.1 — Information You Provide Directly

When you interact with us, you may provide the following categories of information:

• Personal Identification Information: Full name, email address(es), phone number(s), WhatsApp number, business name, business address, city, state, country, and GST/tax identification numbers.

• Business & Financial Information: Monthly revenue, profit margins, pricing structure, number of employees/team members, business model details, client acquisition methods, ad spend figures, tools and platforms used, and any financial data shared during intake questionnaires or strategy calls.

• Professional Background: Work history, areas of expertise, industry experience, certifications, past client names (where voluntarily disclosed), portfolio links, and LinkedIn profile information.

• Intake & Questionnaire Responses: Answers to our onboarding questionnaires, Hero's Journey document, SOP intake forms, and any other structured documents we ask you to complete.

• Communication Content: Messages, files, documents, voice notes, and any other content shared via Slack, email, WhatsApp, Zoom chat, or any other communication channel during the engagement.

• Payment Information: Payment method, transaction IDs, bank account details (for invoice processing), and payment history. We do not store full credit/debit card numbers on our systems.

2.2 — Information We Collect Automatically

When you visit our website(s) or interact with our digital properties, we may automatically collect:

• Device & Browser Information: IP address, browser type and version, operating system, device type, screen resolution, and language preferences.

• Usage Data: Pages visited, time spent on pages, click patterns, scroll depth, referral source (e.g., which ad or link brought you to us), and navigation paths.

• Cookie & Tracking Data: Information collected through cookies, pixels, and similar tracking technologies (see Section 7 for details).

• Ad Platform Data: If you arrived through a paid advertisement (e.g., Meta, LinkedIn, Google), we may receive data from the ad platform including your ad interaction history, demographic category, and interest segments.

2.3 — Information Collected During Calls

• Call Recordings: All discovery calls, sales calls, onboarding calls, strategy calls, and review calls may be recorded using third-party tools (e.g., Fathom, Zoom recording). You will be informed at the start of each recorded call.

• Call Transcripts: Recorded calls may be transcribed automatically or manually for documentation, quality assurance, and training purposes.

• Screen Shares: If you share your screen during a call, any information visible on your screen may be captured in the recording.

2.4 — Information From Third Parties

We may receive information about you from:

• Referral Partners: If someone refers you to us, they may share your name, contact details, and basic business information.

• Publicly Available Sources: LinkedIn profiles, company websites, business directories, and other publicly accessible information.

• Ad Platforms & Analytics Tools: Meta (Facebook/Instagram), Google Analytics, LinkedIn, and other platforms that provide aggregated or individual-level data about users who interact with our ads or content.

• Payment Processors: Transaction confirmations, payment status, and related financial data from our payment processing partners.

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 — Service Delivery

• To onboard you as a client and set up your engagement.

• To conduct audience research, market analysis, and competitor analysis specific to your business.

• To create custom deliverables including offer architectures, sales pitches, VSL scripts, lead generation strategies, funnel blueprints, and related work products.

• To provide ongoing consulting, strategy calls, and advisory support throughout your engagement.

• To track deliverable progress and engagement milestones.

3.2 — Communication

• To respond to your inquiries, messages, and support requests.

• To send engagement-related updates, deliverable notifications, and scheduling information.

• To coordinate with you and your team via Slack, email, WhatsApp, Zoom, or other agreed channels.

3.3 — Business Operations

• To process payments, generate invoices, and maintain financial records.

• To maintain internal records of client engagements, deliverables, and outcomes.

• To improve our services based on client feedback and engagement data.

• To train our team using anonymized or aggregated engagement data.

3.4 — Legal & Dispute Resolution

• To document the scope, delivery, and timeline of all work performed — including through call recordings, Slack logs, and deliverable records.

• To reference recorded calls and communication logs in the event of a dispute, refund request, or legal proceeding.

• To comply with applicable laws, regulations, court orders, or legal processes.

• To enforce our Service Agreement, Refund & Cancellation Policy, and other contractual terms.

3.5 — Marketing & Growth (Only With Your Consent)

• To send you updates about new services, events, or resources that may be relevant to you (you may opt out at any time).

• To use anonymized case study data (e.g., industry, revenue growth percentage) in our marketing materials — only with your explicit written consent and without identifying you by name unless separately agreed.

• To create testimonials or success stories — only with your explicit written consent.

4. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, or trade your personal information to any third party. Period.

We may share your information only in the following limited circumstances:

4.1 — With Our Internal Team

Your information is shared with relevant members of the Clutch The Close team (including co-founders, consultants, trainers, and support staff) on a need-to-know basis to deliver services to you.

4.2 — With Service Providers & Tools

We use third-party tools and platforms to deliver our services. These may include:

• Communication: Slack, Zoom, WhatsApp, Google Workspace (Gmail, Google Docs, Google Drive).

• Call Recording & Transcription: Fathom, Zoom Recording.

• CRM & Funnels: GoHighLevel.

• Payment Processing: Razorpay, bank transfer systems.

• Analytics: Google Analytics, Meta Pixel, LinkedIn Insight Tag.

• Advertising: Meta Ads Manager, LinkedIn Campaign Manager.

• Project Management: Internal tracking tools and spreadsheets.

These service providers process your data on our behalf and are bound by their own privacy policies and data protection obligations. We do not authorize them to use your data for any purpose other than providing services to us.

4.3 — For Legal Compliance

We may disclose your information if required by law, regulation, court order, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

4.4 — In Dispute Resolution

If a dispute arises between you and the Company, we may share relevant documentation — including call recordings, Slack logs, deliverable records, and signed agreements — with legal advisors, mediators, arbitrators, or courts as necessary to resolve the dispute.

4.5 — With Your Consent

We may share your information with third parties if you have given explicit, informed consent for a specific purpose (e.g., publishing a case study with your name, introducing you to a partner or vendor).

5. DATA STORAGE & SECURITY

5.1 — Where Your Data Is Stored

Your data is stored across the following locations:

• Cloud Platforms: Google Workspace (Google Drive, Gmail, Google Docs), Slack, GoHighLevel — all hosted on secure, internationally recognized cloud infrastructure.

• Call Recordings: Fathom and/or Zoom cloud storage.

• Payment Records: Maintained by our payment processors (Razorpay) and in our internal financial records.

• Internal Systems: Project trackers, CRM records, and engagement documentation maintained on secure, access-controlled systems.

5.2 — Security Measures

We implement reasonable security practices and procedures consistent with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, including:

• Access controls — only authorized team members can access client data, based on their role and need.

• Secure communication channels — all client communication occurs through established, encrypted platforms.

• Regular review of access permissions — team member access is reviewed and updated periodically.

• Secure password practices — all team accounts use strong, unique passwords.

5.3 — Data Retention

• Active Clients: Your data is retained for the duration of the engagement plus 36 months after the engagement ends, for reference, legal compliance, and potential future collaboration.

• Prospective Clients (Non-Purchasers): Data collected during discovery or sales calls is retained for 12 months, after which it is deleted unless you engage with us again.

• Call Recordings: Retained for a minimum of 24 months from the date of recording, or longer if required for legal or dispute resolution purposes.

• Financial Records: Retained for a minimum of 8 years in compliance with Indian tax and accounting regulations.

• Marketing Data: Retained until you unsubscribe or request deletion.

You may request earlier deletion of your data (subject to legal retention requirements) by emailing [email protected].

6. YOUR RIGHTS

Depending on your location and applicable laws, you may have the following rights regarding your personal data:

6.1 — Right to Access

You have the right to request a copy of the personal information we hold about you. We will respond to such requests within 30 business days.

6.2 — Right to Correction

If any personal information we hold is inaccurate or incomplete, you have the right to request correction. Please notify us at [email protected].

6.3 — Right to Deletion

You may request deletion of your personal data, subject to the following exceptions:

• Data required for legal compliance (e.g., financial records, tax documentation).

• Data required for dispute resolution or enforcement of contractual terms.

• Call recordings and communication logs that form part of the engagement record.

We will process deletion requests within 30 business days and confirm what data has been deleted and what data has been retained (with reasons).

6.4 — Right to Withdraw Consent

Where we process your data based on consent (e.g., marketing communications), you may withdraw your consent at any time by emailing [email protected] or clicking "unsubscribe" in any marketing email. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6.5 — Right to Data Portability

You may request that we provide your personal data in a structured, commonly used, machine-readable format. This applies to data you have provided to us directly (e.g., questionnaire responses, intake forms).

6.6 — Right to Object

You may object to the processing of your personal data for direct marketing purposes at any time.

7. COOKIES & TRACKING TECHNOLOGIES

7.1 — What We Use

Our website(s) and landing pages may use the following tracking technologies:

• Essential Cookies: Required for basic website functionality (e.g., session management, form submissions). These cannot be disabled.

• Analytics Cookies: Used to understand how visitors interact with our site (e.g., Google Analytics). These collect anonymized usage data.

• Advertising Cookies/Pixels: Used to track ad performance and enable retargeting (e.g., Meta Pixel, LinkedIn Insight Tag). These may collect data about your browsing behavior across sites.

7.2 — Managing Cookies

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect website functionality. Specific instructions vary by browser:

• Chrome: Settings → Privacy and Security → Cookies • Firefox: Settings → Privacy & Security → Cookies • Safari: Preferences → Privacy → Cookies

7.3 — Do Not Track

Some browsers offer a "Do Not Track" (DNT) setting. We currently do not respond to DNT signals, but you may use the cookie management options above to control tracking.

8. THIRD-PARTY LINKS & SERVICES

Our website, emails, or communications may contain links to third-party websites, platforms, or tools (e.g., Calendly for scheduling, YouTube for video content, LinkedIn for profiles). We are not responsible for the privacy practices, content, or security of any third-party sites or services. We encourage you to review their privacy policies before providing any personal information.

9. CHILDREN'S PRIVACY

Our services are designed for business professionals and are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly.

10. INTERNATIONAL CLIENTS

If you are located outside India, please be aware that your information will be transferred to and processed in India, where our team and primary systems are based. By engaging with us, you consent to this transfer. We take reasonable steps to ensure that your data is treated securely and in accordance with this Policy, regardless of where it is processed.

For clients in the European Union (EU) or European Economic Area (EEA), we process data based on contractual necessity (to deliver services you've purchased), legitimate interest (to operate and improve our business), and consent (where specifically obtained, e.g., for marketing). You may exercise your rights under the GDPR by contacting us at [email protected].

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable laws. When we make material changes:

• The "Last Updated" date at the top of this Policy will be revised.

• Active clients will be notified via email or Slack of any significant changes.

• Continued use of our services after notification constitutes acceptance of the updated Policy.

We encourage you to review this Policy periodically.

12. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the contact details of the Grievance Officer are as follows:

Name: Atul Anand Designation: Founder & CEO Email: [email protected] Address: Jaipur, Rajasthan, India

The Grievance Officer shall address any complaints or concerns regarding the processing of personal data within 30 days of receiving the complaint.

13. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or how your data is handled, please contact us:

Email: [email protected] Website: clutchtheclose.com Address: Jaipur, Rajasthan, India