Last updated: September 10, 2025
Your privacy is important to us. This policy explains what information we collect, how we use it to run our puzzle game and community, and how you can control your data. We've aimed to make it clear and understandable.
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Application refers to PocketClue, the software program provided by the Company.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to PocketClue, based in Ontario, Canada.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: Ontario, Canada.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual.
- Service refers to the Application or the Website or both.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to PocketClue, accessible from https://www.pocketclue.com
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name (or username/alias)
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (ee.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through Third-party Social Media Services such as Google, Facebook, and others.
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, and your public profile information.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
- Information regarding your location (e.g., for regional leaderboards or content)
You can enable or disable access to this information at any time through Your Device settings.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. This helps us provide essential features (like keeping you logged in) and analyze how our service is used. You can instruct Your browser to refuse all Cookies, but some parts of our Service may not function.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service.
- For the performance of a contract: for services You have purchased or of any other contract with Us through the Service.
- To contact You: by email or other electronic communication regarding updates, features, or security.
- To provide You with news, special offers and general information about other goods, services and events which we offer, unless you have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: In connection with a merger, sale of assets, or acquisition of our business.
- For other purposes: Such as data analysis, identifying usage trends, and to improve our Service and marketing.
We may share Your personal information with Service Providers, Affiliates, business partners, or with your consent.
Information Shared Publicly
When you participate in community features of the Service, your username, any profile picture you upload, and the content you create (such as public clues or comments) will be visible to other users of the Service and may be distributed publicly outside the Service. You are responsible for any Personal Data you voluntarily include in your public User-Generated Content. Please be mindful of the information you share.
Aggregated and Anonymized Data
We may anonymize and aggregate Your Personal Data for statistical analysis, research, and business planning. This anonymized data does not identify you personally and is no longer considered Personal Data. We may use and share this aggregated data for any purpose.
Retention and Transfer of Your Personal Data
We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and to comply with our legal obligations.
Your information, including Personal Data, is processed at the Company''s operating offices and may be transferred to computers located outside of Your jurisdiction where data protection laws may differ. Your consent to this Privacy Policy represents Your agreement to that transfer.
Your Right to Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You may update, amend, or delete Your information at any time by signing in to Your Account and visiting the account settings section.
Disclosure of Your Personal Data
We may disclose Your Personal Data in the event of a Business Transaction (like a merger), if required by law enforcement, or to comply with other legal obligations.
Security of Your Personal Data
The security of Your Personal Data is important to Us, but no method of transmission over the Internet is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
In the event of a data breach that is likely to result in a real risk of significant harm to individuals, we will notify the affected individuals and the appropriate regulatory authorities, such as the Privacy Commissioner of Canada, in accordance with applicable laws.
Detailed Information on the Processing of Your Personal Data
We may use third-party Service Providers to monitor and analyze the use of our Service, process payments, manage email communications, and serve advertisements. These providers have their own privacy policies.
Analytics: We may use services like Google Analytics. You can opt-out of Google Analytics by installing their opt-out browser add-on.
Advertising: We may work with third-party advertising partners to display advertisements within the Service. These partners may use cookies and other tracking technologies to collect information about your activity on our Service and elsewhere online to provide you with personalized advertising. This may include sharing a device's advertising ID with our partners.
Payments: For paid services, we use third-party payment processors like Apple Store In-App Payments, Google Play In-App Payments, and Stripe. We do not store your payment card details.
Your Privacy Rights
Canadian Residents (PIPEDA) If you are a resident of Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) gives you specific rights regarding your personal information. You have the right to:
- Access Your Personal Information: You can request a copy of the personal information we hold about you.
- Correct Your Personal Information: You have the right to request the correction of any inaccurate or incomplete information we hold about you.
- Withdraw Consent: You may withdraw your consent to our collection, use, and disclosure of your personal information at any time, subject to legal or contractual restrictions.
To exercise these rights, please contact us at contact@pocketclue.com.
European Union Residents (GDPR) If you are within the European Union, you have rights under the GDPR, including the right to access, correct, erase, and object to the processing of your Personal Data. The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
Legal Basis for Processing Personal Data under GDPR We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes (e.g., marketing communications).
- Performance of a contract: Provision of Personal Data is necessary for the performance of our agreement with You (i.e., to provide the Service).
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company, such as improving our Service, preventing fraud, and for analytics, except where such interests are overridden by your fundamental rights and freedoms.
California Residents (CCPA/CPRA) If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal data is collected, the right to delete your personal data, and the right to opt-out of the "sale" or "sharing" of your personal data. To exercise these rights, please contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA) Our Service does not respond to Do Track signals. Some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked.
Children's Privacy Our Service is not directed to anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.
Contact Us If you have any questions about this Privacy Policy, You can contact us:
- By email: contact@pocketclue.com