ClustR privacy policy

1. Who is responsible (data controller)

The controller of your personal data under the GDPR is: Valentin Varadi, private individual / independent developer, Hungary, EU.
Email: hello@marvar.eu

ClustR – Display for Tesla (“ClustR”, “the app”, “I”, “we”) is an iPhone app developed and operated by the controller named above (the “Developer”).

ClustR is an independent product. It is not affiliated with, endorsed by or sponsored by Tesla, Inc. Tesla is a trademark of Tesla, Inc.

2. What the app does with your data

ClustR connects to your car over Bluetooth Low Energy and shows live vehicle information (for example speed, gear, battery, range, tire pressure and charging status) on your iPhone, like an instrument cluster. Vehicle data is processed on the iPhone and is not sent to the Developer. The one exception is the car's model and model year (for example “Model Y, 2024”), which the app reads from the VIN on the phone and includes in the optional usage statistics described in Section 5. The VIN itself, and everything else it encodes, never leaves the phone.

Data	Why	Where it goes
Vehicle data received over Bluetooth (speed, gear, battery, range, tire pressure, charging, etc.)	To display the cluster	Processed on your iPhone. Not sent to the Developer. Only the car's model and model year go into the optional usage statistics (see section 5).
Pairing key (private key)	To pair with your car and talk to it securely	Stored in your iPhone's Keychain, accessible only while the device is unlocked and not transferred to other devices. Not sent to anyone.
Car identifier (VIN)	To recognize your car and to label the key	Stored in a protected file inside the app (encrypted at rest by iOS file protection, excluded from backups). The VIN is also used as the label under which the key is stored in the Keychain. Not sent to the Developer; only the car's model and model year, read from the VIN on your iPhone, go into the optional usage statistics (see section 5).
Location (precise, only while the app is in use)	For the map faces, navigation, route and arrival estimates	Used on your iPhone. To calculate a route, ClustR sends the position of your car and the destination to Apple (Apple Maps / MapKit), and Apple Maps loads map tiles. Apple's privacy policy applies to that. Not sent to the Developer.
Purchase information (subscription status, purchase history, receipts) and a random app user ID	To unlock ClustR Pro, restore purchases and prevent fraud	Processed by Apple and by RevenueCat, Inc., our purchase-management provider. The random user ID is also shared with RevenueCat.
Optional usage statistics and crash reports – off by default	To understand which features are used and to fix crashes	Only if you turn it on in Settings: Google Firebase (Analytics and Crashlytics). See section 5.
Trip and odometer counters	To show trip totals	Stored on your iPhone in the app's settings storage (UserDefaults). This storage can be included in your iPhone backups (iCloud or computer).
Your settings (for example chosen cluster face, colors, units)	To remember your preferences	Stored on your iPhone.

The random user ID. On first launch ClustR creates a random identifier that does not contain your name or any account data. It stays the same on your device across launches and is shared with RevenueCat and, if you enable statistics/crash reports, with Firebase. Because it is persistent and links data about the same installation together, it is a pseudonymous identifier, not an anonymous one.

We do not ask for or collect your name, email address, phone number, contacts or photos. ClustR does not show ads, does not ask for permission to track you across other companies' apps or websites (App Tracking Transparency), and does not sell your data or share it for advertising.

3. Bluetooth and your car

ClustR asks for Bluetooth permission to find and connect to your car. During setup you confirm with your key card, and ClustR enrolls its own phone key on your car with the driver role. This is not a read-only role: a key enrolled on a car is a real key. After that, each time ClustR connects it sends a wake command so the car keeps sending data.

ClustR does not send lock, unlock, start or drive commands. You can remove the ClustR key from your car at any time in the car's own key management screen. Deleting the app removes the data stored by the app on your iPhone. Items kept in the iOS Keychain (the pairing key and the random user ID) may remain on the device after the app is deleted, because iOS does not always remove Keychain items together with an app; removing the key from your car makes any such leftover key useless.

4. Purchases (Apple and RevenueCat)

ClustR offers optional paid features (ClustR Pro). Payments are processed entirely by Apple through the App Store; the Developer never receives your card or payment details.

To manage entitlements, ClustR uses RevenueCat. RevenueCat receives the random app user ID, your purchase receipts and purchase history, your subscription status, and basic device and app information needed to validate purchases. If you have turned on usage statistics, RevenueCat also receives the Firebase app-instance identifier so purchases can be matched with those statistics. RevenueCat acts as our service provider.

5. Optional usage statistics and crash reports (Firebase)

ClustR contains Google Firebase Analytics and Firebase Crashlytics. They are off by default: nothing is collected for them unless you switch on the option in the app (during onboarding or in Settings). You can switch it off again at any time in Settings.

If you switch it on, Google (as our processor) receives:

• crash reports, which can include device model, iOS version, app version and technical stack traces;
• the random app user ID and a Firebase app-instance identifier, and technical data that is transmitted with any internet connection, such as your IP address.

If you turn statistics on, usage events include only feature and screen names and app state. Alongside them, two properties describe your car: its model (Model 3, Model Y, Model S, Model X, Cybertruck or Semi) and its model year, both read from the VIN on your iPhone. They help us see which cars a fault occurs on. The VIN itself, your speed, position, destination, charge and anything else about your driving are never sent. Turning statistics off stops this as well.

We designed the events to exclude vehicle and location data (apart from the car's model and model year described above), but we cannot guarantee that a technical crash trace never contains something unexpected. Google describes its handling of this data in the Firebase privacy information.

Diagnostic logs. ClustR can export a diagnostic log, but only when you choose to. It is not uploaded automatically; it is handed over from the app through a temporary local clipboard entry that expires after 120 seconds, and you decide where it goes. In release builds the VIN and the car's Bluetooth name are redacted, but a log can still contain app events, car state and information about a route you navigated (for example the destination name and coordinates). Please review a log before you send it to anyone, including us. If you send us a log, we use it only to fix the problem you reported.

6. Legal basis (EU/EEA and UK users)

• Performing a contract (GDPR Art. 6(1)(b)): providing the app's functions and your purchases.
• Consent (Art. 6(1)(a)): Firebase Analytics and Crashlytics, including storing and reading information on your device for that purpose. You give this consent by switching the option on in the app. Device permissions (Bluetooth, location) are granted by you in iOS and can be withdrawn there.
• Legitimate interests (Art. 6(1)(f)): keeping the purchase flow secure and preventing fraud.

How to withdraw consent: switch the usage statistics / crash reports option off in the app's Settings, and withdraw Bluetooth or location permission in iOS Settings at any time. Withdrawal does not affect processing that happened before. To have data already collected by Firebase deleted, contact us (see section 8).

7. Recipients, international transfers and retention

Recipients: Apple (App Store, Apple Maps / MapKit), RevenueCat, Inc. (purchases), and Google (Firebase, only if you opt in). The Developer operates no server and does not receive your vehicle data, location or VIN.

International transfers: These providers may process data outside the EU/EEA, including in the United States. Where this happens, they rely on safeguards for international transfers as described in their own privacy and data-processing documentation (see the links above and Apple).

Retention: Data stored on your iPhone is kept until you delete it or remove the app (see the note on the Keychain in section 3). Purchase records at Apple and RevenueCat are kept as long as needed to provide your purchases and to meet legal obligations, according to their policies. Firebase data is kept for the period set in Google's Firebase settings and documentation. We do not keep a separate copy of your data.

8. Your rights

Under the GDPR you have the right to information and access, rectification, erasure, restriction of processing, data portability, and to object to processing based on legitimate interests. You may withdraw consent at any time (section 6). You also have the right to lodge a complaint with a supervisory authority, for example in Hungary the NAIH (Nemzeti Adatvédelmi és Információszabadság Hatóság), or the authority in your own country.

Because most data stays on your device, you can exercise many of these rights by deleting the app. For data held by our providers (for example purchase records, or Firebase data if you opted in), email hello@marvar.eu. Because the data is linked to a random identifier rather than to your name, we may not be able to find your data without that identifier or other information that lets us link it to you; we may ask you for such information. Providing the personal data processed under a contract is necessary to use the paid features; providing statistics and crash reports is entirely voluntary.

9. Children

ClustR is not directed to children. We do not knowingly collect personal data from children under 16 (or the age set by local law). If you believe a child has provided data, contact us at hello@marvar.eu.

10. Terms of use

ClustR is licensed under Apple's standard End User License Agreement (EULA): https://www.apple.com/legal/internet-services/itunes/dev/stdeula/.

11. Safety notice

ClustR is a secondary display. Always follow your car's own displays and local laws, use a secure phone mount that does not block your view, airbags or controls, and set up the app before you drive.

12. Changes

If we change this policy, we will update the date at the top and, for material changes, tell you in the app or in the release notes. If a change would require new consent, we will ask for it.

13. Contact

Questions about privacy? Email hello@marvar.eu.

© 2026 Valentin Varadi. ClustR is not affiliated with Tesla, Inc. Tesla is a trademark of Tesla, Inc.