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Terms·Privacy

© 2026 Clutch

Privacy Policy

Last updated: November 19, 2025

This Privacy Policy is part of the Clutch Terms of Service. All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of Service are incorporated into this document by reference.

This policy governs the use of the Clutch mobile application and the associated tools and services.

Clutch is a decentralized exchange (DEX) aggregator that aggregates prediction markets from multiple platforms, including Polymarket and KalshiEX LLC. Clutch provides enhanced market information, analytics, and faster access to prediction market opportunities across multiple platforms, enabling users to make more informed trading decisions and react more quickly to market events.

Key Features of the Services

  • Real-time odds tracking: Monitor changes in prediction market odds as they happen, with faster data streaming for live events to ensure you have the most up-to-date information.
  • Livestream integration: View odds movements in real-time while watching livestreams of events, allowing you to track market sentiment as events unfold.
  • Cross-platform analytics: Compare markets across different platforms to identify the best opportunities.
  • Enhanced notifications: Receive alerts about significant market movements and opportunities across all aggregated platforms.

Collectively, the application and the associated tools and services are referred to as the "Services" in these terms. The operator may offer other products and services.

The Services do not include outside websites or platforms which may be linked or interconnected to the Services. Such outside platforms may have their own terms of service, which control for all transactions on such platforms. These outside platforms may include, but are not limited to:

  • The KalshiEX LLC platform and prediction markets at kalshi.com
  • The Polymarket platform and prediction markets at polymarket.com

Slash Workman Inc., a Delaware C-corp, operates the Services. It and its affiliates are referred to in this document as the "operator," "we," or "us."

Third-Party Prediction Market Platforms

Clutch operates as a DEX aggregator, facilitating access to prediction markets from multiple platforms:

KalshiEX LLC

A CFTC-regulated Designated Contract Market (DCM) offering prediction markets on various events. When you use the Services to interact with Kalshi markets, you are subject to KalshiEX LLC's terms of service and regulatory framework.

Polymarket

A decentralized prediction market platform built on blockchain technology. When you use the Services to interact with Polymarket markets, you are subject to Polymarket's terms of service.

All funds used for trading on prediction markets are held in a self-custodial manner. You maintain control over your funds, and the operator does not have custody of or control over your trading capital. Your relationships with KalshiEX LLC and Polymarket, including the custody and management of funds deposited with them, are governed by their respective terms of service and applicable regulations.

The operator provides an aggregation interface and enhanced analytics to facilitate your access to and interaction with prediction markets across multiple platforms. Clutch aggregates market data, provides additional information and insights, and enables faster discovery of and reaction to market opportunities. However, the operator does not operate the underlying trading infrastructure or hold customer funds.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and become aware that your child has shared personal data with our Services, please contact us so that we may remove such data.

Note: We cannot delete information stored by third-party platforms or on public cryptographic blockchains.

Collecting

Things You and Others Do and Provide

Information and content you provide. We collect the content, communications and other information you provide when you use our Services, including when you create an account, initiate the use of the Services, create or share content, and message or communicate with others. This information may include, but is not limited to:

  • Name
  • Address
  • Email
  • Phone Number
  • SSN (or equivalent)
  • Financial Information
  • Date of Birth
  • Citizenship
  • Payment Information

Information used to verify your identity. Identity verification may be required by the underlying prediction market platforms (KalshiEX LLC and/or Polymarket) in accordance with applicable regulations and Know Your Customer (KYC) requirements. KalshiEX LLC may require identity verification in accordance with CFTC regulations. Any identity verification documents you provide to these platforms are subject to their respective privacy policies and regulatory obligations.

Financial information. In order to use prediction market services through the aggregated platforms (KalshiEX LLC and Polymarket), you may need to provide financial information directly to those platforms in accordance with their respective terms of service. Since funds are held in a self-custodial manner, the operator does not collect, store, or process your payment or financial account information for the purpose of holding or transferring funds.

Your usage. We collect information about how you use our Services, such as:

  • The types of content you view or engage with
  • The features you use
  • The actions you take
  • The people or accounts you interact with
  • The time, frequency, and duration of your activities
  • Which markets you view
  • Odds changes you track
  • Livestreams you watch
  • Alerts you receive

Information about transactions made on our Services. If you use our Services for transactions of any kind, we collect information about them. Note that actual transaction execution occurs on the third-party platforms (KalshiEX LLC or Polymarket), not through our Services.

Things others do and information they provide about you. We also receive and analyze content, communications, and information that other people provide when they use our Services.

Cookies

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

Device Information

As described below, we collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.

Information we obtain from these devices includes:

  • Device operations: Information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
  • Identifiers: Unique identifiers, device IDs, and other identifiers.
  • Network and connections: Information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
  • Cookie data: Data from cookies stored on your device, including cookie IDs and settings.
  • Push notification information: If you enable push notifications in our services, we will collect information from your device as may be necessary to enable such notifications.

Information from Partners

See the Third-Party Data Collection section for additional information on third-party collection of data.

When Using the Services

When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.

In our servers, we may store the following data:

  • Your account identifiers
  • Usage and activity logs
  • Device information
  • The Internet protocol address ("IP address")
  • Feature interaction data
  • Aggregated market data from third-party platforms
  • Real-time odds and market movements
  • Livestream viewing data and associated odds tracking
  • User preferences, watchlists, and notification settings
  • Market alerts and user-configured triggers

Note: Transaction and trading data is stored by the respective prediction market platforms (KalshiEX LLC and Polymarket) in accordance with their privacy policies and applicable regulatory requirements, not by the operator.

Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide and support the Services. Here's how:

Provide, Personalize and Improve Our Services

We use the information we have to deliver our Services, including to personalize features and content. This includes:

  • Real-time data streaming: Processing and delivering faster data streams for live events, enabling you to see odds changes as they happen.
  • Livestream integration: Synchronizing odds data with livestream viewing to provide real-time market insights during live events.
  • Personalized alerts: Using your preferences and watchlists to deliver customized notifications about significant market movements.
  • Market analytics: Aggregating data across platforms to provide comparative analytics and identify opportunities.
  • Product research and development: We use the information we have to develop, test and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.

Provide Measurement, Analytics, and Other Business Services

We use the information we have (including your activity on our Services) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.

Promote Safety, Integrity and Security

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.

Communicate with You

We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services don't recognize it for tracking purposes.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the Services to provide content, functionality, or to measure and analyze performance. These third parties include:

KalshiEX LLC

  • Terms: kalshi.com/terms
  • Privacy Policy: kalshi.com/privacy-policy

KalshiEX LLC independently collects and processes data in accordance with CFTC regulations and their own privacy policies for all trading and prediction market activities.

Polymarket

  • Terms: polymarket.com/terms
  • Privacy Policy: polymarket.com/privacy

Polymarket independently collects and processes data in accordance with their own privacy policies for all trading and prediction market activities. Polymarket operates on blockchain technology, and certain transaction data may be publicly visible on the blockchain.

Supabase

  • Terms: supabase.com/terms
  • Privacy Policy: supabase.com/privacy

Google

  • Terms: policies.google.com/terms
  • Privacy Policy: policies.google.com/privacy

You may choose whether to receive certain personalized (also known as targeted) advertising from participating ad networks, audience segment providers, ad serving vendors, other service providers or entities by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance or if you are a user in the European Economic Area, Your Online Choices. We adhere to the Self-Regulatory Principles for Online Behavioral Advertising.

Retention

The Services may keep the information we gather about you an unlimited length of time.

To request that information collected about you be deleted, please contact us at the email provided in this policy. A valid request must include sufficient information to identify your personal data.

Note: We cannot delete information stored by third parties such as KalshiEX LLC (which maintains records in accordance with CFTC regulatory requirements) or Polymarket (which may store data on public blockchains that cannot be deleted).

Sharing

The Services only share information about you with others as follows:

  • We may transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.

  • We will share your information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harm our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your data, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in our Privacy Policy.

  • To operate the Services, we share information about you as needed with our service providers, including financial institutions, accountants, auditors, lawyers, payment processors, information technology consultants, advisors, and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Services. The information is only shared so long as you have an account on the Services.

  • We routinely share information with companies closely related to us – our "affiliates" – for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights under this Privacy Policy and we will be responsible for our affiliates' conduct related thereto.

  • We may share information about you with US, state or international regulators, CFTC, SEC, or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas.

The Services may contain links to third party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with the operator. Third party websites are not under our control, and we are not responsible for any third party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to these websites does not imply an endorsement by the operator, or of the provider of such content or services, or of any third party website. Please be aware that when you enter a third party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.

Opt-Out

If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language), in those communications. You can also contact us at contact@averagetechlab.com to opt out.

Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt-out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Services.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact

If you have comments or questions about the privacy policies of the Services, contact daniel@averagetechlab.com.

Changes

The Services may change their privacy policy at any time. Check this page for the latest.