Privacy Policy of ClutchPlay Games LLC

Last updated: October 31, 2025

1. General Information

This privacy policy applies to all of our websites, including but not limited to www.clutchplaygames.com, and the use of our Games “Skullduggery!” and “Little Chomp,” which we will refer to in this document as “games.”

1. Responsible Body & Data Protection Officer

Below we explain to you which personal data is collected and processed by us when using our services and offers.

ClutchPlay Games LLC
815 NE Schuyler St., #12164
Portland, OR 97212
Email: support@clutchplaygames.com

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person, meaning all information that relates to a person.

2. Legal Basis

As far as a legal basis is mentioned in this Privacy Policy, it relates to the General Data Protection Regulation. This went into effect on May 25, 2018. Prior to this, the corresponding provisions of the Federal Data Protection Act apply without naming them.

We collect and process personal data based on the following statutory regulations:

  • Consent according to Article 6 paragraph 1  (a) General Data Protection Regulation (GDPR).
  • Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 (b) GDPR.
  • Processing to fulfill legal obligations under Article 6 para. 1 (c) GDPR.
  • Processing for the protection of legitimate interests in accordance with Article 6 para. 1 (f) GDPR.

3. Rights of Affected

You are entitled to the following rights with regard to the processing of data by us in accordance with the listed articles of the General Data Protection Regulation:

  • Right of access by the data subject to Art. 15 GDPR
  • Right to rectification according to Art. 16 GDPR
  • Right to erasure (“right to be forgotten”) in accordance with Art. 17 GDPR
  • Right to restriction of processing according to Art. 18 GDPR
  • Right to data portability according to Art. 20 GDPR
  • Right to object according to Art. 21 GDPR

You shall have the right to complain to a supervisory authority if you believe that the processing of personal data is violating the GDPR.

4. Data Erasure and Storage Duration

The personal data will be deleted or blocked as soon as the purpose of the storage is deleted. Storage may take place if provided for by regulations to which the processor is subject.

5. Actual Data Processing

1. Visiting the Website clutchplaygames.com

1. Scope of Data Collection

When visiting our website, the following data is collected:

  • Information about the browser type and version used
  • The operating system of the user
  • The IP address of the user
  • Date and time of access

This data is stored in log files and is not stored or processed together with other personal data of the user.

2. Legal Basis

The legal basis for processing the data is Art. 6 para. 1 (f) GDPR.

3. Purpose of Data Processing

The IP address must be kept for the duration of the session to enable delivery of the website.

4. Duration of Storage

The log files will be deleted after seven days at the latest.

5. Objection and Removal Possibility

There is no possibility of objection by the user regarding the collection of data for the provision of the website.

2. Using Our Games

1. Scope of Data Collection

We do not require players to have an account to play our games; therefore, we collect no personal data. Our Android platform games are supported by ads via the Chartboost Ad SDK, and by continuing to play, you consent to collecting and using information for advertising purposes.

2. Legal Basis

The legal basis for processing the data is Art. 6 para. 1 (b) and (c) GDPR.

3. Purpose of Data Processing

The purpose of processing is to enable Chartboost to serve targeted ads, allowing free access to our Android games.

4. Duration of Storage

Data is stored until you ask to have it removed manually.

5. Objection and Removal Possibility

To opt-out, send your device ID to support@clutchplaygames.com.

3. Embedded YouTube Videos

1. Scope of Data Collection

We have embedded YouTube videos which may collect personal data.

2. Legal Basis

The legal basis for the embedding is Art. 6 para. 1 (f) GDPR.

3. Purpose of Data Processing

To inform our customers about our products via video.

4. Duration of Storage

We do not store personal data related to videos.

4. Google Analytics

1. Scope of Data Processing

We use Google Analytics to analyze website usage behavior. It collects data about links, duration on pages, and more, without merging it with other Google data.

2. Legal Basis

The legal basis for processing is Article 6 para. 1 (f) GDPR.

3. Purpose of Data Processing

To analyze website and visitor behavior.

4. Duration of Storage

Data is anonymized immediately after collection.

5. Objection and Removal Possibility

You can prevent cookie storage by modifying your browser settings.