Privacy Policy

Effective Date: March 13, 2026
Last Updated: March 13, 2026

Clutio ("the Extension", "we", "us", or "our") is a Chrome browser extension that provides AI-powered translation and vocabulary building. This Privacy Policy describes how we handle information when you use the Extension.

Our core principle: Your data stays on your device. We do not operate any servers, do not collect personal data, and do not track your activity.

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1. Information We Process

1.1 Information You Provide

1.2 Information Generated During Use

1.3 Information We Do NOT Collect

• Names, email addresses, phone numbers, or other personally identifiable information
• Browsing history or URLs of pages you visit
• Location data
• Device identifiers (IMEI, MAC address, etc.)
• Cookies or tracking data
• Payment or financial information
• Analytics or telemetry of any kind

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2. How We Use Information

All data processing occurs locally on your device. We use the information solely to:

1. Provide AI translation: Send your selected text and surrounding context to the AI service you have chosen, using the API key you have provided, to generate translations.
2. Manage your vocabulary: Store translated words and related information locally for study material and quiz generation.
3. Maintain your preferences: Store your language and model settings locally.

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3. Third-Party Data Sharing

We do not sell, rent, or share your personal information with any third party. However, when you use the translation feature, data is transmitted to third-party AI services solely at your direction:

Important:

• Data transmission occurs only when you actively request a translation by selecting text and triggering the translate action.
• You provide your own API key — we do not supply API keys or have access to your keys.
• All communications with AI APIs use HTTPS encryption.
• We have no access to the data transmitted between your browser and these AI services.
• For information on how these services handle data, please refer to their privacy policies:
  • Anthropic: https://www.anthropic.com/privacy
  • OpenAI: https://openai.com/privacy
  • Google: https://policies.google.com/privacy

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4. Data Storage and Retention

4.1 Local-Only Storage

All data is stored exclusively on your device using the browser's built-in storage mechanisms (IndexedDB and chrome.storage). No data is transmitted to or stored on any server operated by us.

4.2 Retention Periods

4.3 No Server-Side Storage

We do not operate any servers. There is no server-side data storage, no database, no cloud backup, and no data warehouse associated with this Extension.

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5. Data Deletion

You have full control over all your data:

No request to us is necessary to delete your data, as we never have access to it.

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6. Your Rights

6.1 For Users in the European Economic Area (EEA) — GDPR

Under the General Data Protection Regulation, you have the right to:

• Access: View all your stored data directly in the Extension interface.
• Rectification: Edit or correct your data through the Extension.
• Erasure ("Right to be Forgotten"): Delete any or all data through the Extension, or uninstall it entirely.
• Restriction of Processing: Disable the Extension to stop all processing.
• Data Portability: Export your vocabulary data using the built-in study file generation feature.
• Object: Stop using specific AI services by not selecting them.
• Withdraw Consent: Uninstall the Extension at any time.
• Lodge a Complaint: Contact your local Data Protection Authority.

Legal Basis for Processing:

• Consent: You consent to data processing by installing and using the Extension, and by actively triggering translations.
• Legitimate Interest: Local storage of your vocabulary data to provide the service you requested.

Since all data is stored locally on your device and we have no access to it, you can exercise all rights directly without contacting us.

6.2 For Users in California — CCPA/CPRA

Under the California Consumer Privacy Act and the California Privacy Rights Act:

• Right to Know: This Privacy Policy discloses all information we process.
• Right to Delete: You can delete all data directly through the Extension.
• Right to Opt-Out: We do not sell or share your personal information.
• Right to Non-Discrimination: We do not discriminate against users who exercise their privacy rights.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

6.3 For Users in Japan — APPI

Under the Act on the Protection of Personal Information:

• Right to Access: View your data directly in the Extension.
• Right to Correction: Edit your data through the Extension.
• Right to Deletion: Delete your data through the Extension.
• Right to Suspend Use: Disable or uninstall the Extension.
• Cross-Border Transfer Notice: When you use translation features, your selected text is transferred to AI service providers located in the United States. These transfers occur via HTTPS encryption and only at your direct request.

6.4 For Users in China — PIPL

Under the Personal Information Protection Law:

• Right to Know and Decide: This policy fully discloses all data handling practices.
• Right to Access and Copy: You can view and export all your data.
• Right to Correct: Edit your data through the Extension.
• Right to Delete: Delete your data through the Extension.
• Right to Withdraw Consent: Uninstall the Extension at any time.
• Cross-Border Transfer Notice: Selected text may be transferred to AI providers (Anthropic, OpenAI, Google) in the United States for translation processing, only when you actively request a translation.

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7. Security Measures

1. Local-First Architecture: All data remains on your device. We operate no servers.
2. Encrypted Communication: All communication with AI APIs uses HTTPS (TLS) encryption.
3. Minimal Data Transmission: Only the selected word, surrounding context, and target language are sent to AI services — no browsing history, URLs, or personal identifiers.
4. No Tracking: We use no analytics tools, no cookies, no web beacons, no pixel trackers. Zero telemetry.
5. API Key Security: Your API keys are stored locally in your browser and are transmitted only to the respective AI service for authentication.

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8. Children's Privacy

The Extension is not directed at children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly process data of children. If you believe a child has used the Extension, all data can be deleted by uninstalling the Extension.

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9. Chrome Extension Permissions

The Extension requests the following browser permissions:

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10. International Data Transfers

When you request a translation, your selected text and context are transmitted to AI service providers located in the United States:

• Anthropic, Inc. — San Francisco, CA, USA
• OpenAI, Inc. — San Francisco, CA, USA
• Google LLC — Mountain View, CA, USA

These transfers:

• Occur only when you actively request a translation
• Use HTTPS encryption in transit
• Are initiated using your own API key (we have no access to the data)
• Can be avoided by choosing not to use a particular AI service

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11. Changes to This Policy

We may update this Privacy Policy to reflect changes in the Extension or applicable laws. We will notify users through Extension updates and on our website (clutio.com).

• Current Version: 1.0
• Effective Date: March 13, 2026

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12. Contact Us

If you have questions or concerns about this Privacy Policy or your data:

• Developer: Jaebeom You
• Email: contact@clutio.com
• Website: https://clutio.com

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13. Supervisory Authorities

If you wish to lodge a complaint regarding data protection:

• EU/EEA: Contact your local Data Protection Authority — list of DPAs
• South Korea: Personal Information Protection Commission (PIPC) — https://www.pipc.go.kr
• Japan: Personal Information Protection Commission — https://www.ppc.go.jp
• USA (California): California Privacy Protection Agency — https://cppa.ca.gov