Privacy Policy

Last updated and effective: July 22, 2026

Data controller: CleverGames IL, Israel ("CleverGames", "we", "our" or "us"). For privacy questions, requests, or complaints, contact us at support@clevergames.org.

Summary of this update: We added specific disclosures about private messages, images, voice recordings, device permissions, recipients, moderation and reports, storage, retention, deletion, and user choices.

Introduction

CleverGames IL ("CleverGames", "we", "our" or "us") develops, publishes and operates social games for web and mobile environments ("Games"), as well as web and mobile applications (each, an "App") for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).

We also operate the website clevergames.org, its subdomains and its related features ("Site", and together with the Games and App, collectively - the "Services").

CleverGames respects your privacy, and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your personal data, and it applies whenever you visit our Site, install our App and play our Games, interact with us or otherwise access or use any of our Services.

Please read this Policy carefully so that you understand our practices and the choices and rights available to you. This Policy is a notice about our data practices; where we need your consent for a particular activity, we will request it separately.

You are not legally required to provide us with Personal Data. However, some features require certain information to operate and may not be available if you choose not to provide it.

This Privacy Policy should be read together with our Terms of Use.

1. Data Collection

We collect the categories of data described below. Information that identifies, relates to, describes, or can reasonably be linked to a person is referred to in this Policy as "Personal Data".

Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services (as detailed in Sections 4 and 6 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 7 below). Such data consists of connectivity, technical or aggregated usage data, such as IP address, unique advertising ID (e.g. IDFA; you may reset such ID by following the instructions below), non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, and in-App or Game events.We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 4 below.

Data received from you: you may provide Personal Data when you create or update an Account, contact support, make a purchase, participate in a promotion, interact with other users, or choose to connect a third-party account to the Services.

Messages and other content: if you use messaging or other social features, we process the text, images, voice recordings and other content you choose to send or share. We also process related information needed to operate those features, such as the participants, message and media identifiers, timestamps, delivery status and technical information about uploaded files.

Reports, moderation and support information: when you report content, an Account or conduct, or contact support, we process the information you provide together with the relevant content, Account and technical context reasonably needed to review and respond.

Device permissions: features that let you take or select an image or record audio may request access to your camera, microphone or photo library. Access occurs only when you use the relevant feature and grant the permission requested by your device. You can manage these permissions in your device settings.

Data received from Facebook and other third-party account providers: if you choose to sign in with Facebook, we request access to your public profile and email address. Depending on what Facebook makes available under your settings, we may receive your Facebook account identifier, name, email address and profile picture. We do not request your Facebook friends list. If you connect another third-party account, we receive only the information that provider makes available for the connection you authorize. The provider's own terms and privacy policy govern its processing of your information.

Transaction Data: In-Game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.

2. Private Messaging and Safety

Content sent through a private-messaging feature is ordinarily made available to the sender and the selected recipient rather than to the public. "Private" does not mean that a message is confidential or end-to-end encrypted. CleverGames and its Service Providers process and store messages as needed to provide and protect the feature.

Recipients may save, copy, capture, download or reshare content on or outside the Services. CleverGames cannot control copies made by a recipient, so you should consider carefully what you choose to send.

Users can report content and block other users. Reported content and related information may be reviewed by authorized personnel and Service Providers when reasonably necessary for support, safety, security, enforcement or legal compliance. We may preserve report information and relevant content after the original message or Account is deleted when reasonably necessary for those purposes.

3. Data Uses and Legal Bases

We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.

Accordingly, we use Personal Data for the following purposes:

• To facilitate, operate, and provide our Services;
• To deliver, store, synchronize and manage messages and other content as directed through the available controls;
• To authenticate the identity of our players, and allow them access to additional features;
• To provide our users with customer care, assistance and technical support services;
• To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
• To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-Game progress and activity, based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;
• To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Game updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
• To receive and investigate reports, provide support, moderate content, enforce our Terms, protect users and preserve evidence where appropriate;
• To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
• To comply with any applicable laws and regulations.

4. Advertising Uses

Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.

Such data may include your device advertising identifier (for example, IDFA where available), general demographic or interest information, and information about advertising interactions that we or our advertising partners receive in accordance with your choices and applicable law. We do not use the contents of private messages for targeted advertising.

The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.

This Privacy Policy does not apply to the practices of companies that we do not own or control or employees or service providers that we do not manage. Any information you provide to sites, applications or services advertised through our Services will be covered by their applicable privacy policies specified therein. Please be sure to read the privacy policies of any third-party applications, services and sites that you visit or provide permission to access your information. It is those third parties' responsibility to protect any information you give them, so we will not be held liable for their use of your personally identifying information.

How to adjust your preferences regarding interest-based advertising

If you wish to prevent the use of your device's advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the "Privacy" or "Ads" section in your device settings).

If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.yourchoicesonline.com (for European users).

Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see advertisements in our Games, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the Game, or your language preferences. Please note that such actions may result in a less enjoyable user experience.

Aggregated and analytical information

We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service (for further information about cookies, please see the "Cookies" section in this policy).

We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies.

Google Products: Google uses technologies such as cookies in order to track and analyse the use of our Site and/or an SDK to serve ads within our Games. To learn more about how Google processes data, we recommend you review Google's policies located at: https://policies.google.com/technologies/partner-sites. For additional information, please see Google Analytics' opt-out web tool available at: https://tools.google.com/dlpage/gaoptout. For additional information regarding the data which Google SDK processes and stores see: https://support.google.com/admob/answer/7665968

We use anonymous, statistical or aggregated information and may share it with our partners or service providers for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.

5. Storage, International Processing and Retention

Personal Data may be maintained, processed, accessed and stored by CleverGames and authorized Service Providers in Israel and other countries in which they operate. Where applicable law requires a transfer safeguard, we use an available lawful mechanism, such as a recognized adequacy decision or approved contractual safeguards.

While privacy laws may vary between jurisdictions, CleverGames has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.

We retain each category of Personal Data only while it is reasonably necessary for the purpose for which it was collected. Messages and other content are retained while needed to provide the relevant feature and until deleted through an available control, removed by us, or no longer needed to provide the Services. Report evidence, moderation and security records, transaction and accounting records, backups, and information needed for legal obligations or legal claims may be retained for longer while those purposes continue.

Deleting a message or account does not delete copies that another user has saved, captured or reshared, and may not delete content that another participant is legally entitled to retain. When retention is no longer necessary, we delete, de-identify or securely dispose of the information, subject to technical backup cycles and applicable law.

6. Data Sharing

We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates - but only in accordance with this policy:

• Recipients You Choose: We disclose messages, content and related sender information to the users or audiences you select. Those recipients determine what they do with their own copies, subject to our Terms and applicable law.
• Authorized Moderation and Support Access: Authorized personnel and contractors may access content and related records on a need-to-know basis for support, security, report investigation, abuse prevention, Terms enforcement, or legal compliance.
• Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
• Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
• Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook account to a certain Game or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) - so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
• Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of CleverGames, any of our users or any members of the general public.
• CleverGames Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Policy. In addition, should CleverGames or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.

For the removal of doubt, CleverGames may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.

7. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.

A "cookie" is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the user. For example, we may use cookies to store your language preferences or other settings so you do not have to set them up every time you use our Services. Some of the cookies we use are associated with your account (including personal information about you, such as the email address you gave us), and other cookies are not.

While we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, we cannot guarantee that our Services will fully operate should you choose to block cookies. For example, any preferences you may have defined on our Site or App will not be saved.

8. Communications

Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.

Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you wish not to receive such promotional communications, you may notify CleverGames at any time by e-mailing us at support@clevergames.org or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.

9. Data Security

We use technical and organizational measures intended to protect Personal Data, including access controls, security logging and encryption in transit where appropriate. No system is completely secure, and we cannot guarantee that unauthorized access, loss or misuse will never occur. Private messages are not end-to-end encrypted and should not be used as a secure vault for highly sensitive information.

10. Data Subject Rights

Depending on where you live and subject to applicable exceptions, you may have the following rights regarding Personal Data about you:

• To know whether we process your Personal Data and to access a copy;
• To correct Personal Data that is inaccurate, incomplete, unclear or out of date;
• To request erasure or restriction, or object to processing, where applicable;
• To receive certain Personal Data in a portable format where applicable;
• To withdraw consent for future processing where consent is the legal basis; and
• To avoid a decision based solely on automated processing where that decision has a legal or similarly significant effect and applicable law provides that right.

If you exercise one (or more) of the above-mentioned rights in accordance with the provisions of applicable law, or any other right that you may have under applicable law, we will, to the extent required, instruct third parties that hold your personal information, in accordance with this Privacy Policy, to act accordingly.

You may also complain to the data protection authority in your country. To exercise a right, contact us at support@clevergames.org. We may be unable to provide a feature that depends on information you ask us to delete or stop processing, and some rights may be limited by applicable law or the rights of other people.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will then be retained only as reasonably necessary for verification, security, legal obligations or legal claims, in accordance with the retention terms in this Privacy Policy.

If you wish to manage the information we receive about you from a third-party application or platform where you play our Games, such as Facebook, Apple or Google, please follow the third-party application's instructions for updating your information and changing your privacy settings.

11. Minors

Our Services and Games are not available to anyone under the age of sixteen (16). We do not knowingly permit an under-16 user to create or continue using an Account. If we learn that an under-16 user is using the Services, we may block that use and take appropriate steps to delete or otherwise handle the related Personal Data, subject to applicable legal, safety, security and evidence-retention requirements.

If you believe that we might have any such data, please contact us at support@clevergames.org

12. Updates; How to Contact Us

Updates and amendments: We may update this Policy as our Services, practices or legal obligations change. We will publish the new effective date and provide appropriate notice of material changes. Where a related change to our Terms requires agreement, we will ask you to agree to the updated Terms; reviewing or acknowledging this Privacy Policy does not by itself turn every processing activity into consent-based processing.

Questions, Concerns or Complaints: If you have comments or questions about this Privacy Policy, a privacy concern, or a rights request, contact our privacy team at support@clevergames.org.

13. Personal Data Deletion and Closure of Accounts

You may request account deletion through the "Account Deletion" control in the applicable Game. Deletion is irreversible and removes or de-identifies account data under our control through our deletion process, subject to the retention needs and exceptions described above. It does not remove copies held by recipients or third parties, and accepted moderation evidence may be preserved separately. If you maintain Accounts in multiple Games, request closure of each Account.

Please allow reasonable time for the deletion process and backup cycles. We may retain limited information where required or permitted for legal obligations, accounting, fraud and security prevention, report handling, enforcement, disputes, or legal claims. Contact support@clevergames.org with questions.