Privacy Policy

Privacy Policy of ClutchPlay Games LLC

Last updated: June 12, 2024

  1. General Information

This privacy policy applies to all of our websites, including but not limited to, and the use of our Games “Skullduggery!” and “Little Chomp,” which will 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


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

  1. Legal Basis

As far as a legal basis is mentioned in this Privacy Policy, they relate to the General Data Protection Regulation. This comes into effect from May 25, 2018. Prior to this, the corresponding provisions of the Federal Data Protection Act apply without us 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). Consent is any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, which indicates that the data subject consents to the processing of his personal data.
  • Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 (b) GDPR, this means that the data is required so that we can fulfill the contractual obligations to you or we need the data to prepare a contract closure with you.
  • Processing to fulfill legal obligations under Article 6 para. 1 (c) GDPR, this means that a processing of the data is required by law or other regulations.
  • Processing for the protection of legitimate interests in accordance with Article 6 para. 1 (f) GDPR, this means that processing is necessary to safeguard legitimate interests on our part or by third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail.

  1. Rights of affected

You are entitled to the following rights with regard to the processing of data by us in accordance with the respectively 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

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating the GDPR.

  1. Data Erasure and Storage Duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage is deleted. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the processor is subject. Blocking or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

  1. Actual data processing

  1. Visiting the Website
  1. Scope of Data Collection

When visiting our website, the following data is collected and stored by our web server:

  • 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

The data is stored in the log files of of our hosting provider. This data is not stored or processed together with other personal data of the user. Our hosting provider is DreamHost based in the United States.

  1. Legal basis

The legal basis for processing the data is Art. 6 para. 1 (f) GDPR. The legal basis for the data processing by our hosting provider is Art. 28 para 3 GDPR.

The legitimate interest within the meaning of Art. 6 para. 1 (f) GDPR therefore lies in the functionality of our website and its availability.

  1. Purpose of data processing

The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user’s IP address must be kept for the duration of the session.

The data is stored in order to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

  1. Duration of storage

The logfiles will be deleted after seven days at the latest, unless there is a need to keep the data for the aforementioned purpose due to specific events.

  1. Objection and removal possibility

The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no possibility of objection by the user.

  1. Visiting the Website

When visiting our website we do not collect personal data.

  1. Using our Games

  1. Scope of Data Collection

Because we do not require that our players have an account to play our games, we collect no personal data.

Our games on the iOS platform are considered “premium” in that they must be purchased outright before they can be played.  Therefore, we collect no personal data related to those games.  Our games that have been released on the Android platform are supported by ads, so we have integrated the Chartboost Ad SDK.  By accepting this Privacy Policy and downloading or continuing to play our games or using our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.

When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.

Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.

You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. Our current advertising partner is Chartboost Inc ( You can refuse or withdraw your consent to such use at any time as outlined in the section below.

  1. Legal basis

The legal basis for processing the data is Art. 6 para. 1 (b) and (c) GDPR in connection with the respective tax law. The legal basis for the data processing by our advertising  provider is Art. 28 para 3 GDPR. The data exchange with Chartboost Inc. is based upon Art. 6 para 1 (c) GDPR. Chartboost is an independent processor.

  1. Purpose of data processing

The purpose of the processing is to enable Chartboost to serve up targeted ads which enables us to allow you to play our games on the Android platform without having to purchase them outright.

(d)        Duration of storage

The data is stored until you ask to have it removed manually.

  1. Objection and removal possibility

To remove your device identifier from the Chartboost system, please send your device ID to and we will manually remove it from the Chartboost system.  You will receive email confirmation upon successful removal of our device ID.

  1. Embedded YouTube videos
  1. Scope of Data Collection

On our websites we have embedded videos of our game which are hosted by YouTube LLC.

In order to display the video on our website we have used programming provided by YouTube which enables YouTube to place cookies and collect personal data by as an independent controller. You can find YouTube’s data protection policies here: 

We have used YouTube’s “privacy-enhanced mode” while embedding the video.

  1. Legal Basis

The legal basis for the embedding of the video is Art. 6 para. 1 (f) GDPR. The presentation of our own videos and products directly on our website is legitimate Interest.

  1. Purpose of the Data Processing

The purpose is to directly embed a video in our website in order to inform our customers about our products. Regarding the processing by YouTube we advise you to consult

  1. Duration of storage

We do not store any personal data. Regarding the storage time for YouTube please consult

  1. Objection and removal possibility

The processing of the data is required to embed and display the videos. There is no option for objection.

  1. Google Analytics
  1. Scope of data processing

The websites use Google Analytics, a web analytics service provided by Google Inc. (“Google”). This software collects information about how you use the website and compiles various statistics. The increased usage data include in particular the concrete selection of links, the length of stay on individual pages and the order of use of the website, the frequency of the page request. This data is collected together with your IP address. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by cookies about your use of this website is usually transmitted to a Google server in the USA and stored there.

We have activated a so-called IP anonymization on our website, this means that the IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area prior to retransmission to the USA.

Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google itself describes here its data processing activity.

  1. Legal basis

The legal basis for the processing of data when using the website is Article 6 para. 1 (f) GDPR.

The legitimate interest within the meaning of Art. 6 para. 1 (f) GDPR is a customer-oriented design of the website, which meets the requirements of the users and takes their user preferences into account.

The legal basis for the transfer of data to Google are Article 28 para. 3, and Article 45 para. 3 GDPR. The service provider is certified under the Privacy Shield Framework and is therefore subject to the EU Commission’s decision on adequacy (Implementing Decision 2016/1250), this means that the data protection level of the service provider is recognized as being equivalent to the GDPR, although it is based in the USA.

  1. Purpose of data processing

The purpose of the processing is to analyse this website and the usage behaviour of its visitors.

  1. Duration of storage

The data is already anonymized directly after the survey. Personal data is therefore collected only in the context of the transfer and not permanently stored.

  1. Objection and removal possibility

You can prevent the storage of cookies, including the generation and transmission of data to Google, by restricting or prohibiting the use of cookies in your browser software. This may result in the deactivation of non-Google-related cookies as well as the inability to use all functions of this website to the full extent.

You can prevent the collection of the data generated by the cookie and your use (including your IP address) and their transmission to Google as well as the processing of this data by Google by downloading the browser plugin available under the following link and to install: