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 and support data: order IDs, invoice or receipt references, payment status, subscription status, refund or chargeback status, limited payment provider references, support messages, billing questions, safety reports, and privacy request correspondence. ClueHop should not receive full card numbers.

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 and uses cloud providers that may process data in the EU/EEA and other countries. When personal data is transferred outside the EU/EEA, ClueHop aims to use appropriate safeguards such as EU Standard Contractual Clauses, adequacy decisions, and provider security and compliance commitments where applicable.

Retention

We keep personal data only as long as needed for service operation, account administration, Game Session delivery, security, support, billing, accounting, tax, dispute, fraud-prevention, legal, and compliance purposes.

Admin account records are generally kept while the account or customer relationship is active and for a reasonable period after closure where needed for legal, tax, accounting, dispute, or security reasons.

Game Session, team, Game Organizer, and player records are kept for service operation, support, audit, abuse prevention, and customer administration, then deleted or anonymized according to operational retention rules, customer agreements, or legal requirements.

Optional analytics retention depends on the analytics provider configuration and is used only after opt-in. Local consent choices remain in the visitor's browser until changed or cleared.

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. ClueHop does not currently describe direct marketing as a core public-site analytics purpose, but any future marketing use must follow applicable consent and opt-out rules.

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.