Privacy Policy

1. Introduction

This Privacy Policy describes how Osis AI LLC d/b/a Clutch ("we," "us," or "our") collects, uses, stores, and shares information when you use our website, web application, and mobile messaging service (collectively, the "Service"). By using Clutch, you agree to the collection and use of information as described in this Policy.

We take your privacy seriously. We do not sell your personal data. We collect only what is necessary to provide the Service and handle it responsibly.

2. Information We Collect

We collect the following categories of information:

• Account information: Name, email address, and profile photo if you sign in using a supported authentication provider
• Phone number: Collected and verified when you connect your account to use our text messaging feature
• Birth year: Collected to verify that you meet our minimum age requirement of 13
• Consent records: A timestamped record of your agreement to our Terms of Service and this Policy, including your IP address, browser/device information, and the specific consents you provided
• Study content: Messages, notes, images, and other materials you share while using the Service
• Conversation history: Messages exchanged between you and Clutch, stored to provide personalized context across study sessions
• Usage data: Information about how you interact with the Service, including session frequency and feature usage
• Technical data: IP address, browser type, device type, and operating system, collected automatically when you access the Service
• Payment information: Processed by our third-party payment provider. We do not store your payment card details on our servers.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Clutch study assistant
• Personalize your experience based on your learning history, subjects, and preferences
• Maintain conversation context so Clutch can give you relevant, continuous help across sessions
• Deliver text messages you request, including study responses, verification codes, and optional study reminders
• Process and fulfill subscription purchases and manage your account
• Verify that users meet our minimum age requirement of 13 or older
• Monitor for, detect, and prevent fraud, abuse, and violations of our Terms of Service
• Comply with applicable legal obligations and respond to lawful government requests
• Analyze aggregate usage patterns to understand how the Service is used and improve it over time

4. How We Share Your Information

We do not sell your personal information. We may share your information only in the following circumstances:

• Service providers: We work with carefully selected third-party companies that help us operate the Service, such as authentication providers, AI processing services, messaging infrastructure, payment processors, and database hosting. These providers are bound by contractual obligations to protect your data and use it only as directed by us.
• Legal requirements: We may disclose information if required by law, court order, subpoena, or government authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Clutch, our users, or the public.
• Business transfers: If Clutch undergoes a merger, acquisition, reorganization, or sale of all or substantially all of its assets, your information may be transferred as part of that transaction. We will notify you in advance of your information becoming subject to a different privacy policy.
• With your explicit consent: We may share your information for other purposes with your prior consent.

We do not share your personal information with third parties for advertising or marketing purposes.

5. AI Processing of Your Content

Clutch uses AI language processing to generate responses to your study questions. When you send a message or share content, it is transmitted to our AI processing provider to generate a response. This processing is performed solely for the purpose of operating the Service.

Your conversations are not sold to third parties and are not used for unrelated advertising purposes. We may review conversations in aggregate to improve quality, safety, and accuracy, and we may use anonymized or aggregated data for product development.

We retain conversation history to enable continuity across your study sessions. You may request deletion of your conversation history at any time by contacting us at support@osis.co.

6. Text Messaging

When you use Clutch via text message, your messages are transmitted through a third-party messaging infrastructure provider. Messages are stored in our secure database to maintain conversation context. We access your messages only for the purpose of operating the study assistant and do not use them for any unrelated purpose.

You can opt out of text messaging at any time by replying STOP to any message. After opting out, no further messages will be sent to your number unless you actively re-engage with the Service.

7. Cookies and Similar Technologies

We use cookies and similar technologies to operate, secure, and improve the Service. Specifically:

• Session and authentication cookies: Secure, encrypted cookies that keep you signed in and protect your account
• Consent cookies: Used to record that you have agreed to our Terms and this Policy, so we do not ask again on subsequent visits
• Analytics cookies: We use Google Analytics (GA4) and Microsoft Clarity to understand how users interact with our website. These tools collect anonymized usage data such as pages visited and time on site.
• Advertising pixels: We use Meta Pixel (Facebook), Snapchat Pixel, Google Ads conversion tracking, and RunAds to measure the effectiveness of our advertising campaigns. These pixels may set cookies to track conversions from ads. They do not give us access to your personal social media data.

We display a cookie consent banner on your first visit. You may accept or decline non-essential cookies. You can also manage cookies through your browser settings at any time.

8. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. Conversation history is retained to support continuity across your study sessions. If you request account deletion, we will delete your personal information within a reasonable timeframe, except where retention is required by law or necessary for legitimate business purposes such as fraud prevention, dispute resolution, or tax compliance.

9. Children's Privacy

Clutch is designed for students aged 13 and older in compliance with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13 without verifiable parental consent. If you are a parent or guardian and believe your child under 13 has created an account or provided personal information without your consent, contact us immediately at support@osis.co and we will take prompt action to delete the information.

We do not sell student data. We do not use student data for targeted advertising. We collect from students only what is necessary to provide the educational study service.

10. FERPA Considerations

Clutch is a consumer-facing study tool used directly by students, not a school-provided educational service. As such, student data shared with Clutch is generally not considered an "education record" under the Family Educational Rights and Privacy Act (FERPA). We do not receive data from schools or educational institutions.

However, we are committed to protecting student data with the same care and responsibility expected of educational service providers. We limit data collection, do not sell student data, and provide deletion rights to all users and their parents or guardians.

11. Your Rights and Choices

Depending on where you live, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request that we correct inaccurate or incomplete information
• Deletion: Request that we delete your account and associated personal data
• Opt-out of messaging: Reply STOP to any text message at any time
• Data portability: In certain jurisdictions, request a machine-readable copy of your personal data
• Withdraw consent: Where we process data based on your consent, you may withdraw that consent at any time
• Restriction of processing: In certain circumstances, request that we limit how we use your data

To exercise any of these rights, contact us at support@osis.co. We will respond within a reasonable timeframe and may need to verify your identity before processing your request.

12. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information we collect and how we use it, the right to delete your personal information, the right to correct inaccurate information, and the right to opt out of the sale or sharing of personal information. We do not sell or share personal information as defined by California law. To exercise your rights under California law, contact us at support@osis.co.

13. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information. These include encrypted data transmission (TLS), encrypted storage at rest, strict access controls, and regular security reviews. No method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security. However, we work diligently to protect your information from unauthorized access, disclosure, or loss.

In the event of a data breach that affects your personal information, we will notify you as required by applicable law.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of material changes by posting the updated Policy on our website with a revised "Last updated" date, and where appropriate by sending a notification through the Service. Your continued use of the Service after changes take effect constitutes your acceptance of the revised Policy.

15. Contact Us

Questions, data access requests, or privacy concerns? Reach out at support@osis.co or hello@gotclutched.com. We aim to respond to all inquiries within a reasonable timeframe.

Osis AI LLC
Email: hello@gotclutched.com