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Privacy Policy

Last updated: 25 August 2026

1. Who we are

JOA Games Inc. ("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 704-228th Ave NE, 3001, Sammamish, WA 98074, USA.

2. Information we collect

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

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

Some of this information comes from TikTok rather than directly from you, as described above. We do not use your data for automated decision-making that produces legal or similarly significant effects about you, and we do not carry out profiling of that kind.

3. How we use it

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

Legal bases (EEA and UK)

If you are in the EEA or the UK, we rely on the following legal bases under the UK/EU GDPR:

4. Who we share it with

5. Children

Clutch Soccer is intended for users aged 13 and over (14 in Florida), matching TikTok's own minimum age. It is not offered through TikTok's Under 13 Experience. We do not knowingly collect personal information from children under 13, or under the higher minimum age that applies 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 player account and progression data for the life of your active account. If an account has no activity for 36 months, we review it for deletion or anonymisation. When an account is deleted, we remove it from active production systems within 30 days.

We may keep data longer where a legal hold, legal obligation, active investigation, or dispute requires it.

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 without undue delay and ordinarily within one month. For complex or numerous requests we may extend by up to two further months, and we will tell you if we do.

8. Security

We encrypt covered data at rest in our production database, object storage, and backups, and require TLS 1.2 or later for data in transit. Access to production systems requires multi-factor authentication, follows least-privilege principles, and is reviewed at least annually. We maintain a vulnerability and patch-management process for production systems.

If a personal data breach occurs, we will notify regulators and affected users where and within the time limits the law requires. No system is perfectly secure, and we cannot guarantee absolute security.

9. International transfers

JOA Games Inc. is incorporated in the United States, with operations in the United Kingdom. Our production systems and backups are hosted in the United States, and authorised personnel in the United Kingdom access those systems remotely.

Because we have an establishment in the United Kingdom, the UK GDPR applies to our processing directly. If you are in the UK, your supervisory authority is the Information Commissioner's Office (ICO), and you may complain to them at ico.org.uk.

Where we transfer personal data from the EEA or the UK, we rely on the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914) and, for UK transfers, the UK International Data Transfer Addendum or another valid UK transfer mechanism.

10. Cookies and similar technologies

This website does not set cookies. Fonts and images are served from our own domain, so loading a page does not send your details to an advertising network.

We use Cloudflare Web Analytics to understand how many people visit the site and which countries they visit from. It is cookieless: it stores nothing on your device, does not fingerprint you and does not track you across other websites. Your IP address is used to determine your country and is not stored or logged. Because no information is stored on your device, no consent is required for it.

Some pages include videos hosted on YouTube. These are not loaded when the page opens. Nothing is sent to YouTube or Google until you choose to press play, at which point YouTube may set cookies on your device and receive your IP address under Google's own privacy policy. If you never press play, no connection to YouTube is made.

Our hosting provider records standard server request logs, including IP address, to deliver the site and protect it from abuse. If you give us your email address to join the early access list, we record it with the country you signed up from, so we know which regions to launch in next. The country is looked up from your IP address at the moment you submit the form and the IP address itself is not stored. We use your email only to contact you about Clutch Soccer and you can ask us to delete it at any time.

The game uses Google Analytics to measure how it is played. This relies on a pseudonymous identifier rather than cookies set by us, and we do not use it for cross-context behavioural advertising. Where your local law requires consent for this kind of measurement, we obtain it through the platform or in-game.

11. Changes

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

12. Contact

privacy@playclutchsoccer.com