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Clutch Puppy Picks · Legal

Privacy Policy

How Clutch Puppy Picks, operated by LifeHandled LLC (Utah), collects, uses, shares, and protects information about you.

Effective version: 2026-06-07.2

DRAFT legal framework - requires licensed attorney review prior to production use. Not legal advice.

1. Overview

Clutch Puppy Picks, operated by LifeHandled LLC ("we", "us", "our"), respects your privacy. This Policy explains what information we collect, how we use and share it, and the choices you have. This Policy applies to use of the Service from any jurisdiction, including users in California and the European Economic Area.

We do not promise absolute security or absolute privacy. No internet platform can guarantee complete protection against unauthorized access. We use commercially reasonable safeguards as described below.

2. Data Minimization - Information We Collect

We intentionally collect as little personal information as possible. The categories we collect:

  • Account information: email address, chosen username, and a hashed password.
  • Optional profile: display name, avatar URL.
  • Consent records: timestamp, IP address, user agent, version of agreements accepted.
  • Content you create: picks, posts, comments, likes, follows, leaderboard scores.
  • Technical data: IP address, browser/device type, pages viewed, referrer, interactions, performance and error logs.
  • Cookies & similar technologies: as described in our Cookie Policy.

We do not collect real names, home addresses, government IDs, Social Security numbers, or payment information, except where strictly necessary for a feature you explicitly opt into (e.g., merchandise purchases, where payment data is processed by a third-party processor and not stored by us).

3. How We Use Information

  • Operate, maintain, and improve the Service and its features.
  • Authenticate you, secure your account, and prevent abuse, fraud, or scraping.
  • Generate aggregated and anonymized analytics about Service usage, engagement, and model performance.
  • Track engagement behavior (pages, sessions, clicks, retention) to understand and improve the product.
  • Use advertising and attribution technologies to measure marketing performance and, where you consent, to personalize content or ads.
  • Monetize certain non-sensitive aggregated and anonymized engagement and analytics data consistent with this Policy and your cookie choices. We do not sell individually identifying personal information for monetary consideration.
  • Respond to support, legal, or compliance requests.
  • Send transactional emails (account verification, security alerts). We do not send marketing email unless you explicitly opt in.

4. Cookies, Analytics & Tracking Technologies

We and selected third-party providers may use cookies, web beacons, local storage, server logs, SDKs, and similar technologies to operate the Service, remember your preferences, understand usage, measure performance, and serve relevant content. Categories of cookies we may use include:

  • Strictly necessary cookies for authentication and security.
  • Functional cookies that remember your preferences (e.g., cookie choices).
  • Analytics cookies that measure traffic and usage patterns.
  • Advertising cookies that may be used by partners to measure or personalize ads.

You can manage your cookie preferences at any time via the "Cookie preferences" link in the footer or on the Cookie Policy page.

5. Third-Party Service Providers

We share limited information with vendors who help us operate the Service, including hosting and infrastructure providers, authentication providers, analytics providers, advertising and attribution partners, email delivery providers, customer support tools, affiliate networks, and sportsbook odds, weather, and statistics data providers. These providers are contractually limited to using the information to perform services for us.

6. Sharing & Disclosure

Certain user information and behavioral analytics may be shared with service providers, analytics providers, advertising partners, and business partners consistent with this Policy. We may also disclose information:

  • To comply with legal process, lawful requests, or to protect our rights, safety, or property.
  • In connection with a merger, acquisition, financing, or sale of all or part of our business.
  • With your consent or at your direction.

We do not sell your personal information for monetary consideration. Some sharing for cross-context advertising or analytics may qualify as a "sale" or "sharing" under California law; you may opt out as described below.

7. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the right to:

  • Know what personal information we collect, use, disclose, and share.
  • Request access to or a copy of your personal information.
  • Request deletion of your personal information.
  • Correct inaccurate personal information.
  • Opt out of "sale" or "sharing" of personal information for cross-context behavioral advertising.
  • Limit use of sensitive personal information.
  • Not be discriminated against for exercising your rights.

Submit a request from the Account settings page or by emailing legal@clutchpuppypicks.com. We will verify your identity before fulfilling the request.

8. European Economic Area, UK & Swiss Rights (GDPR-style Disclosures)

If you are in the EEA, UK, or Switzerland, you may have the right to:

  • Access your personal data and obtain a copy.
  • Request rectification of inaccurate data.
  • Request erasure ("right to be forgotten") subject to legal exceptions.
  • Restrict or object to processing.
  • Data portability.
  • Withdraw consent at any time where processing is based on consent.
  • Lodge a complaint with your local supervisory authority.

Our legal bases for processing include performance of a contract (account services), legitimate interests (security, abuse prevention, improving the Service), consent (cookies, marketing where applicable), and legal obligations.

9. Data Retention

We retain account information for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. Consent logs are retained for legal-defense purposes for the duration permitted by applicable law. Aggregated and anonymized data may be retained indefinitely. Backups, archives, and logs may persist for additional time per our standard rotation; we do not promise instantaneous deletion from all backups or logs.

10. Account Deletion & Your Choices

You can request account deletion at any time from the Account settings page or by emailing legal@clutchpuppypicks.com. We will process the request within a reasonable period, subject to legal retention requirements. You can also export a copy of your account data from the same page.

11. Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, scoped database access controls, and row-level security on user data. However, no internet platform is completely secure, and we cannot guarantee absolute protection against breaches, hacks, or unauthorized access.

12. International Transfers

We are based in the United States and may process information in the U.S. and other countries where our service providers operate. Where required, we rely on appropriate safeguards for cross-border transfers.

13. Children

The Service is not directed to children under 18. We do not knowingly collect personal information from children. If we learn we have collected such information, we will delete it.

14. Changes

We may update this Policy. Material changes will be reflected by updating the "Effective version" date above. Continued use of the Service constitutes acceptance.

15. Contact

Privacy questions, requests, or complaints? Email legal@clutchpuppypicks.com.