Privacy Policy

Last updated: 21 August 2026

DRAFT — not yet reviewed by counsel. Before publishing, confirm: (1) the legal entity name and address, (2) the exact data your build actually collects, (3) your analytics and SDK vendors, (4) your minimum age gate. Every [BRACKETED] item below must be filled in.

1. Who we are

[LEGAL ENTITY NAME] ("we", "us") operates the Clutch Soccer mini-game on TikTok and this website. You can reach us at privacy@playclutchsoccer.com or by post at [REGISTERED ADDRESS].

2. Information we collect

When you play Clutch Soccer through TikTok, we may receive:

TikTok account basics — your open ID, display name, and avatar image, as provided by TikTok's mini-game platform. We do not receive your TikTok password or email address.
Gameplay data — your club, squad, progress, scores, in-game currency, session length, and actions taken in the game.
Device and technical data — device type, operating system, language, approximate region (derived from IP), and crash or error logs.
Purchase records — if you buy anything in-game, a record of the transaction. Payment card details are handled by the platform, never by us.

We do not collect your precise location, contacts, camera, microphone, or photo library.

3. How we use it

To run the game — save your progress, place you on leaderboards, and match you with opponents.
To keep it working — diagnose crashes, fix bugs, and measure performance.
To keep it fair — detect cheating, botting, and abuse.
To improve it — understand which features are used, in aggregate.
To meet legal obligations and enforce our Terms.

We do not sell your personal information, and we do not use it for cross-context behavioural advertising.

4. Who we share it with

TikTok — as the platform hosting the game, under their own privacy policy.
Service providers — [ANALYTICS VENDOR], and Google Firebase for hosting and data storage, acting on our instructions.
Legal — where required by law, or to protect our rights and users' safety.
Corporate transactions — if the game is sold or merged, subject to this policy.

5. Children

Clutch Soccer is intended for users aged [MINIMUM AGE] and over. We do not knowingly collect personal information from children under 13 (or the equivalent minimum age in your country). If you believe a child has provided us with personal information, contact us at privacy@playclutchsoccer.com and we will delete it.

6. How long we keep it

We keep gameplay data for as long as your account is active, and for [RETENTION PERIOD] after your last session. Crash logs are kept for [LOG RETENTION]. Transaction records are kept as long as tax and accounting law requires.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, or export your data, to object to or restrict processing, and to withdraw consent. If you are in the EEA or UK, you may also complain to your local data protection authority. If you are a California resident, you have rights under the CCPA/CPRA, including the right not to be discriminated against for exercising them.

To exercise any of these, email privacy@playclutchsoccer.com. We respond within 30 days.

8. Security

We use encryption in transit, access controls, and reputable infrastructure providers. No system is perfectly secure, and we cannot guarantee absolute security.

9. International transfers

We are based in [COUNTRY] and our providers may process data in the United States and elsewhere. Where required, we rely on Standard Contractual Clauses or an equivalent safeguard.

10. Changes

We will post any changes on this page and update the date above. Material changes will be announced in the game.

11. Contact

privacy@playclutchsoccer.com