Privacy Policy

Welcome to Cluever. This Privacy Policy explains how Cluever ("we", "us", or "our") collects, uses, shares, and protects your personal information when you use the Cluever mobile application and any associated services (collectively, the "Service"). Cluever is a US-based company and acts as the data controller for personal information processed through the Service.

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Service.

1. Information We Collect

1.1 Information You Provide

The only personal information we collect directly from you is your email address, used to create and identify your account and to deliver a One-Time Passcode (OTP) each time you log in. We do not collect your name, date of birth, phone number, or any other personal identifiers.

1.2 Passwordless Authentication (OTP)

Cluever uses a passwordless login system. Each time you sign in, we send a One-Time Passcode to your email address. The OTP is single-use and expires shortly after being issued. OTP emails are transmitted via Resend, a third-party email delivery provider (see Section 5). We do not send marketing, promotional, or any other emails. Login OTPs are the only emails you will ever receive from us.

1.3 Gameplay and App Usage Data

We collect data about how you interact with the Service, including:

• Puzzle progress, stage completions, and coin balances
• In-app activity such as coin transactions, word and phrase reveals, sponsored briefing views, and feature usage
• Subscription and purchase status (Cluever Pro, Cluever+)
• Invitation history (up to 3 per month per account)
• App preferences (notifications, sound effects, haptic feedback)
• App session information

1.4 Technical and Device Data

We may automatically collect certain technical information to maintain security and stability:

• Device type, operating system, and app version
• Crash logs and diagnostic data
• General network information (e.g. connection type)

This data does not personally identify you and is used solely for technical operations.

2. How We Use Your Information

2.1 Purposes of Processing

• Account Management: To create and maintain your account, associate gameplay data with your email, and authenticate you via OTP.
• Service Operation: To deliver puzzles, manage coin balances, process reveals, serve ads (where applicable), and handle in-app purchases.
• Service Improvement: To analyze usage patterns and technical performance in order to fix bugs, improve features, and ensure reliability.
• Security and Fraud Prevention: To detect, prevent, and address abuse, fake accounts, or fraudulent coin activity.
• Legal Compliance: To meet obligations under applicable law, including responding to lawful requests from authorities.

We do not use your personal information for behavioral advertising, profiling, or automated decision-making that produces legal or similarly significant effects.

2.2 Legal Basis for Processing (GDPR — EU/UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following lawful bases:

3. Advertising

Cluever may display advertisements in the free tier of the app. All ads are non-personalized. We do not use your personal data or behavioral profiles to target advertisements. Ad delivery is based solely on general, non-identifiable contextual information.

Users who purchase Cluever+ (one-time) or subscribe to Cluever Pro will have ads removed entirely. You may also watch optional "Sponsored Briefing" ads to earn coins; these are always opt-in.

Third-party ad delivery infrastructure may collect limited technical data (such as device type or IP address) as required for serving ads. We configure such services to operate in non-personalized mode.

4. In-App Purchases

All purchases — including coin packs, Cluever+ (one-time, ad-free), and Cluever Pro (annual subscription) — are processed exclusively through the Apple App Store or Google Play Store. We do not collect, store, or process your payment card or billing information. We receive only a transaction confirmation and entitlement status from the relevant platform. All payment transactions are governed by Apple's and Google's respective privacy policies.

5. Third-Party Service Providers

We engage a limited number of third-party providers. These providers access your data only to the extent necessary to perform their function and are contractually prohibited from using it for any other purpose.

5.1 Email Delivery — Resend

We use Resend (resend.com) to deliver login OTP emails. Resend receives your email address and the OTP content solely for transmitting the authentication message. No other data is shared with Resend. See resend.com/legal/privacy-policy.

5.2 App Store Payment Processors

Apple Inc. and Google LLC process all in-app payments. Please refer to their respective privacy policies for details on how they handle your payment information.

5.3 Analytics and Crash Reporting

We may use analytics or crash reporting tools to monitor app performance. Any such tools are configured to process data in a privacy-preserving manner, limited to technical and aggregated usage information.

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to any third party.

We may disclose your information only in the following limited circumstances:

• To service providers as described in Section 5, subject to data processing agreements.
• If required by applicable law, regulation, court order, or lawful governmental request.
• To protect the rights, property, or safety of Cluever, our users, or the public.
• In connection with a merger, acquisition, or sale of our business, provided the successor is bound by equivalent privacy obligations.

7. International Data Transfers (GDPR)

Cluever is based in the United States and our servers are located in the United States. If you are in the EEA or United Kingdom, your personal data may be transferred to and processed in the United States. Where such transfers occur, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission. You may request a copy of the applicable safeguards by contacting us at contact@cluever.app.

8. Data Retention

• Account data (email, gameplay, preferences): Retained for the duration of your active account, and deleted or anonymized within 30 days of an account deletion request.
• OTP tokens: Automatically expire and are purged within minutes of issuance.
• Technical / diagnostic logs: Retained for up to 90 days, then automatically deleted.
• Aggregated or de-identified data: May be retained indefinitely as it cannot be used to identify you.

9. Your Privacy Rights

9.1 Rights for All Users

You may contact us at any time to access, correct, or request deletion of your account and associated data. Email us at contact@cluever.app.

9.2 EU / UK Users — GDPR Rights

If you are in the EEA or United Kingdom, you have the following rights under the GDPR / UK GDPR:

• Right of access — request a copy of your personal data (Art. 15)
• Right to rectification — request correction of inaccurate data (Art. 16)
• Right to erasure — request deletion in certain circumstances (Art. 17)
• Right to restriction of processing — request we limit how we use your data (Art. 18)
• Right to data portability — receive your data in a structured, machine-readable format (Art. 20)
• Right to object — object to processing based on legitimate interests (Art. 21)
• Right to lodge a complaint — contact your local Data Protection Authority. In the EU: edpb.europa.eu. In the UK: ico.org.uk.

We will respond to GDPR requests within 30 days of receipt (extendable by 60 days for complex requests, with notice).

9.3 California Users — CCPA / CPRA Rights

If you are a California resident, the following categories of personal information are collected:

• Identifiers: email address
• Internet or network activity: gameplay data, app usage, session data
• Commercial information: purchase and subscription status (as reported by Apple/Google)
• Inferences: none drawn

Your California rights include: Right to Know, Right to Delete, Right to Correct, and Right to Non-Discrimination. We do not sell or share personal information for cross-context behavioral advertising — no opt-out mechanism is required, but we state this explicitly. To submit a CCPA request, email contact@cluever.app. We will respond within 45 days.

10. Children's Privacy

Cluever is not directed to children under 13 (or 16 where applicable under local law), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information without parental consent, please contact us at contact@cluever.app and we will promptly delete the information.

11. Data Security

We implement industry-standard technical and organizational measures to protect your personal information, including encrypted data transmission and access controls on stored data. No method of internet transmission is completely secure. We encourage you to keep your email account secure, as it is the primary credential used to access Cluever.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page. Continued use of the Service after any update constitutes acceptance of the revised policy.

13. Contact Us