Privacy Notice

Controller and scope

CogniWolf AB, registration number 559587-2580, is the controller for ClueHop account, support, website, billing, security, and service data where ClueHop decides why and how the data is processed.

Business customers, venues, employers, schools, hotels, or private organizers may be independent controllers for participant lists, invitations, venue operations, employee or guest communications, and other processing they conduct outside ClueHop.

This notice covers ClueHop public pages, admin accounts, accountless Game Organizer and player flows, support interactions, and service operations. It does not cover third-party websites, payment provider pages, customer systems, or Venues that are not controlled by ClueHop.

People covered by this notice

Admins and customer representatives: people who create or use admin accounts, manage route workspaces, buy Game Passes or memberships, configure routes, or communicate with ClueHop for an organization.

Game Organizers: people who use Game Organizer Codes, organizer links, or organizer QR flows to create or manage Game Session teams without creating a ClueHop account.

Players and participants: people who join a team through a team QR/link or team URL, provide a display name, and use the browser game flow.

Website visitors and support contacts: people who visit public pages, manage analytics choices, send support messages, or ask billing, legal, safety, or privacy questions.

Personal data we collect

Admin account data: name, email address, authentication identifiers, admin role, account status, route workspace permissions, membership status, account settings, language preference, and legal acknowledgement metadata.

Customer, route, and Game Session data: managed location details, route setup details, Game Organizer Code status, purchase references, membership or subscription details, Game Session state, team setup, route progress, stop validation settings, timestamps, and operational notes entered into approved fields.

Game Organizer and player data: organizer flow state, team names, player display names, team membership, player/member tokens, game progress, clue responses, marker-code attempts, GPS validation attempts where enabled, QR validation attempts where enabled, timestamps, and Game Session access status.

Location data: when GPS validation is enabled for a stop and a player starts that validation, the browser may send GPS coordinates, accuracy, and capture time to check proximity to the configured stop. ClueHop does not require continuous background tracking.

Camera and QR data: when QR validation is enabled and a player starts QR scanning, the browser may request camera access to read the QR code. ClueHop does not need to store camera images for normal QR validation, but it may process the decoded QR token and validation result.

Technical and security data: IP-derived request data, browser and device information, language and storage choices, authentication/session state, rate-limit records, security logs, diagnostics, error reports, and abuse-prevention signals.

Payment data: order IDs, invoice or receipt references, payment status, subscription status, refund or chargeback status, and limited payment provider references. ClueHop should not receive full card numbers.

When you contact Support, we process your email address, any name and purchase reference you provide, your messages, screenshots you choose to upload, case-management records and information needed to secure access to your cases. Sensitive case fields and correspondence are stored encrypted. Screenshots are processed and stored privately. Authorized support staff use this information to investigate, respond and carry out permitted support actions. Please redact passwords, access links, payment-card details and unrelated personal information before submitting material.

We use email addresses, language preferences, marketing choices and records of changes to those choices to manage ClueHop promotional emails. Player offers are optional and requested separately from result emails. Account holders can manage account offers in their preferences. You can unsubscribe using the link in a promotional email. We retain limited suppression information to respect an unsubscribe request. Requested results, receipts, account-access and other service emails are handled separately from promotional emails.

We process custom-story text, translations and uploaded images to provide the custom-content feature and review compliance with the Custom Content Policy. When automated moderation is enabled, specialist providers of text and image moderation process the relevant content on our behalf. We record moderation results and review decisions. Authorized ClueHop personnel may also review content.

Optional analytics data: if optional analytics are accepted, ClueHop may collect public page views and basic product interactions through Google Analytics or Google Tag Manager. Analytics is configured not to intentionally send Game Organizer Codes, Player Join Codes, team tokens, organizer tokens, marker codes, QR validation tokens, emails, or GPS coordinates.

Sources of personal data

We collect data directly from admins, Game Organizers, players, visitors, and support contacts when they use ClueHop or communicate with us.

We may receive data from business customers, route owners, payment providers, authentication providers, hosting providers, analytics providers after opt-in, email providers, security tools, and support workflows.

If a customer or Game Organizer shares Game Session links or invites participants, ClueHop may process participant data because the participant joins the ClueHop Game Session flow, while the customer or Game Organizer remains responsible for its own invitation and participant communications outside ClueHop.

Purposes and legal bases

Provide the service: account creation, authentication, route setup, Game Organizer Code delivery, organizer/team flows, marker-code validation, optional GPS/QR validation, game progress, and support. Legal bases may include contract performance, steps before contract, and legitimate interests in operating the service.

Admin, billing, and subscription operations: payments, invoices, receipts, taxes, accounting, subscription status, order history, chargebacks, and customer administration. Legal bases may include contract performance, legal obligations, and legitimate interests.

Safety, security, and abuse prevention: rate limits, token validation, access controls, security logs, fraud prevention, incident response, and enforcement. Legal bases may include legitimate interests and legal obligations.

Privacy, legal, and compliance requests: responding to data subject requests, legal notices, disputes, and regulator inquiries. Legal bases may include legal obligations and legitimate interests.

Optional analytics: measuring public page performance and basic account/signup funnel events after opt-in. The legal basis is consent where required for analytics storage and related processing.

Browser permission prompts for location or camera are technical browser permissions. They are separate from legal consent for optional analytics and do not mean ClueHop will use location or camera data for unrelated purposes.

How we share personal data

Service providers and processors: ClueHop may use providers for hosting, database, authentication, email, payments, analytics after opt-in, DNS, security, logging, deployment, support, and operations. Current launch architecture includes Cloudflare, Render, Supabase, Paddle for payment processing, Resend when app email is enabled, and Google analytics services only after opt-in.

Customers and Game Organizers: Game Session data may be visible to the admin, route owner, Game Organizer, or customer that arranged the real-world activity, depending on the product surface and permissions.

Payment providers: payment status and transaction references are shared with Paddle for Paddle-processed purchases. Paddle acts as merchant of record and may be an independent controller for payment activities under its own terms and notices.

Legal, safety, and business reasons: we may disclose information where required by law, to protect rights and safety, to respond to legal process, to investigate misuse, to enforce terms, to complete a merger or similar business transaction, or with your direction.

We do not sell personal data. We do not use player GPS coordinates to rank teams, create competition features, build native app tracking, or sell location data.

International transfers

ClueHop is operated from Sweden. Our cloud providers process personal data in the EU/EEA and in other countries. Transfers outside the EU/EEA must be covered by an applicable adequacy decision or appropriate safeguards under the GDPR, including the European Commission’s Standard Contractual Clauses where required. Provider security statements alone do not replace those safeguards.

Contact support@cluehop.com for information about the countries and transfer safeguards relevant to your personal data, or to request a copy of the applicable safeguards.

Retention

We retain personal data for the periods and purposes below. A specific legal obligation, unresolved dispute, security investigation or documented retention hold can extend the period for the affected records. Such an extension does not apply to unrelated personal data.

Account profiles and customer content are kept while the account provides access to the service. An account-deletion request is processed after the existing paid membership period and active Game Sessions have ended. Unresolved payment or authorization matters require review before processing. At final deletion, ordinary profile data is minimized, account-owned content is removed and login access is revoked, subject to specific retention holds.

If a membership remains unpaid, customer-authored stories, quizzes and related route content are archived after 90 days without payment. Recovery after that point is not guaranteed. Renew within the 90-day period to protect that content. Deleting an account is a separate process and does not use this renewal period.

Detailed Game Session result snapshots use a 24-hour retention period from creation. Pending result-email delivery or an unresolved processing requirement can delay cleanup. Cleanup removes or minimizes player names, access credentials, precise validation locations and detailed gameplay payloads while retaining the limited purchase and usage evidence described below.

Limited purchase and gameplay evidence is retained for 365 days from purchase completion, then archived for 30 days before deletion. A restricted lookup linking a deleted account to retained purchase evidence is kept for 365 days from final account deletion, then archived for 30 days before deletion. A retention hold delays the applicable cleanup and the archive period starts when archival actually occurs.

Support case content is deleted or minimized 24 months after resolution. Support screenshots are deleted 90 days after resolution, and spam is deleted after 30 days. An active retention hold delays the affected cleanup.

Accounting records are retained through the seventh year after the end of the calendar year in which the relevant financial year ended, as required by Swedish bookkeeping law. Records needed for a specific refund, payment dispute, legal claim or investigation are retained until that matter is resolved and the applicable legal preservation requirement ends. Paddle retains its own payment records under its separate obligations.

Marketing preferences are retained while they control permitted promotional messages. Limited suppression records are retained while needed to prevent further marketing to an address that has unsubscribed. Service-email delivery records are kept separately from marketing consent.

The Cookie Notice states how long browser storage and optional analytics cookies last. Local language and consent choices remain in your browser until changed or cleared. You can withdraw optional analytics consent through the footer control and clear browser storage at any time.

Your rights

Depending on applicable law, you may have rights to access, correct, delete, restrict, object to, or receive a copy of personal data, and to withdraw consent where processing is based on consent.

You always have the right to object to direct marketing.

To make a privacy request, contact support@cluehop.com. We may need to verify your identity and may retain limited information where required for legal, security, tax, accounting, dispute, or anti-fraud reasons.

If you believe your personal data has been processed incorrectly, you may lodge a complaint with the Swedish Authority for Privacy Protection (IMY) or another competent supervisory authority.

Children and supervision

ClueHop is intended to be arranged by adults, businesses, Venues, schools, hotels, or private organizers. Route owners and Game Organizers are responsible for supervision where participants need it.

Players should not enter unnecessary personal information into display names, team names, clue answers, or support messages. Game Organizers should provide privacy-appropriate instructions for their group.

Automated decisions

ClueHop uses automated validation logic to check marker codes and optional GPS/QR proof during gameplay. These product checks control game progress but are not intended to make legal or similarly significant decisions about a person.

Changes

We may update this Privacy Notice as ClueHop changes. Material updates will use a new effective date or version and may require renewed acknowledgement for admin account creation or continued admin use.