PRIVACY POLICY

PRIVACY POLICY

Empty Agenda LLC · Effective date: September 14, 2026

1. INFORMATION WE COLLECT

We collect information linked directly to your account to facilitate gameplay, ensure legal compliance, and process wagers:

  • Contact and account information: Your name, email address, user IDs, and account credentials.
  • Gaming identity: Your PlayStation Network ID, Xbox Gamertag, Activision ID, and Epic Account ID and display name to verify player eligibility and match results.
  • Financial information: Wager transaction records, deposit details, payout history, and Stripe-issued payment references. We do not store full payment card numbers, bank account numbers, or CVV codes.
  • Gameplay and user content: Match scores, game statistics, wager history, and leaderboard activity.
  • Precise location data: Geofencing data used strictly to verify physical eligibility for real-money wagers under local state laws.
  • Usage and diagnostics data: Product interaction events, crash logs, device information, and performance metrics to maintain stability and prevent fraud.
  • Identity verification: In limited cases involving disputes or security lockouts, Stripe Identity may process government-issued ID and biometric selfie data under Stripe's privacy policy. We do not retain raw biometric data.

2. HOW WE USE YOUR DATA

  • To manage your CLUTCH PLAY account and process matchmaking wagers.
  • To verify geographic eligibility and legal compliance for skill-gaming wagers.
  • To process deposits, escrow, payouts, and withdrawals through secure payment processors.
  • To verify match outcomes, display player leaderboard standings, authenticate your account on clutchplay.net, maintain platform security, prevent cheating, and combat financial fraud. Epic Account IDs and display names are used solely for match performance verification, leaderboard standings, and account authentication.
  • To send transactional notifications and comply with applicable legal obligations.
  • To improve application performance and resolve technical issues.

3. DATA TRACKING DISCLOSURES

We do not sell your personal data. We do not track users across third-party websites or applications for targeted advertising purposes, and we do not share your personal identity with data brokers.

CLUTCH PLAY uses only necessary session cookies and tokens for authentication and security. We do not use advertising or analytics cookies without your explicit consent.

4. DATA SHARING AND SERVICE PROVIDERS

We share information only with providers necessary to operate the Service, including:

  • Stripe, Inc. — payment processing, escrow management, identity verification, and payout distribution.
  • Epic Games, Activision, PlayStation, and Xbox — gaming identity linking and match result verification through official services.
  • Base44 — application hosting, database, and authentication infrastructure.

These providers are required to protect information and use it only to provide services to us. We may also disclose information when required by law or to protect the security and integrity of the Service.

5. DATA RETENTION

We retain account data while your account remains active. Financial transaction and match records are retained for at least 7 years for financial accountability, legal compliance, and dispute resolution. Following account deletion, personal identifiers are anonymized within 90 days unless retention is required by law or an active dispute.

6. YOUR RIGHTS AND DATA CHOICES

Depending on your jurisdiction, including under the CCPA and applicable GDPR principles, you may have the right to access, correct, delete, or receive a portable copy of your personal data, and to opt out of non-essential processing.

You may request account deletion within CLUTCH PLAY settings or contact us to exercise your rights. We will respond within 30 days, subject to legal retention requirements.

7. SECURITY

We use industry-standard safeguards to protect account information, precise location logs, and financial transactions from unauthorized access. These measures include encryption in transit, cryptographic protection for transaction PINs, Stripe-managed payment tokenization, optional biometric confirmation for withdrawals, and server-to-server match verification.

Although no security system is completely impenetrable, we will notify affected users within 72 hours of discovering a breach involving their personal information.

8. CHILDREN'S PRIVACY

CLUTCH PLAY is not directed to individuals under 17 years of age. We do not knowingly collect personal information from children under 17. If we discover that a user is under 17, we will terminate the account and delete associated data as required by law.

9. CONTACT US

If you have questions about this Privacy Policy, your data, or a privacy request, please contact:

Empty Agenda LLC
Email: support@clutchplay.net
Website: clutchplay.net

© 2026 Empty Agenda LLC. All rights reserved. · Terms of Service · Geographic Restrictions