Legal

Privacy Policy

Last updated: August 2026

Privacy Policy for the “Clutch Darts” app

Scope of the Privacy Policy

This Privacy Policy applies to the app for mobile operating systems and devices referred to in the heading (hereinafter the “App”). This Policy explains the nature, purpose and scope of data collection in connection with the use of the App.

Please note that when you download our App from the Apple App Store, you must register with or identify yourself to the operator, Apple (using an Apple ID). When downloading the App, various personal data, such as your email address, username, the customer number of your App Store account, your unique device identifier, the time of download and, where applicable, payment information, may be processed by the App Store operator. Apple’s privacy policy and terms of use apply in this regard, which may differ from the data protection laws of the European Union. We have no influence over these terms.

We reserve the right to amend this privacy policy at any time, in accordance with legal requirements.

Data Controller

The data controller for the data processing described in this privacy policy is Element 2.0158 UG (limited liability) & Co. KG, Gohlstraße 1, 70597 Stuttgart, Germany, email: hey@clutchdarts.com. Further details can be found in our Imprint.

Purpose and legal basis of data processing

Unless otherwise specified in this privacy policy, we process your personal data in connection with your use of the App in order to provide the App’s functionalities, to ensure the App’s security or – where necessary and legally permitted – to contact you. The legal basis is Article 6(1)(b) of the GDPR (performance of a contract) and our legitimate interest in providing a fully functional App (Article 6(1)(f) of the GDPR). Where consent has been sought, processing takes place exclusively on the basis of Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG; consent may be withdrawn at any time.

Categories of data processed

When you use this App, the following personal data relating to you is processed:

  • Anonymised subscriber ID
  • Device type
  • End device operating system
  • User and game data (e.g. darts scores entered, game scores, statistics, settings)

The processing of the aforementioned data is carried out for the purpose of fulfilling the user agreement between us and the App users (Article 6(1)(b) of the GDPR). With regard to voluntary information provided, data processing is also carried out on the basis of Article 6(1)(f) of the GDPR.

Notifications

The App may display local notifications on your device (e.g. reminders for matches or training sessions). These notifications are generated locally on your device; they are not sent via external push services. You can disable notifications at any time in your device’s system settings.

App access permissions

In order to provide our services, the App requests the access permissions listed below, which enable us to access certain functions on your device:

  • Notifications (for local reminders)

The access permissions granted are used exclusively to provide the associated App functionalities. The legal basis for this access is, on the one hand, Article 6(1)(b) of the GDPR (contract) and, on the other hand, your consent (Article 6(1)(a) of the GDPR). You can change the App’s access permissions at any time in the system settings and thereby withdraw your consent. However, in this case, the App or certain App features may no longer function properly.

In-app purchases

Within the App, you have the option to purchase paid services (in-app purchases), e.g. subscriptions or – where offered – a one-off (lifetime) purchase. Purchases are made exclusively via the Apple App Store, through which you obtained the App. For further details, please refer to Apple’s privacy policy:

Apple App Store: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA, https://www.apple.com/de/ios/app-store/. The privacy policy can be found at: https://www.apple.com/legal/privacy/de-ww/.

Recipients of personal data

Personal data is generally only transferred to external recipients within the scope of the services and functions described below:

  • Apple Inc.: The App is made available via the Apple App Store. Apple’s privacy policy applies.
  • RevenueCat: For the management and analysis of in-app purchases and subscriptions.

Where data is transferred to recipients in the USA (including Apple and RevenueCat), the transfer is based on the Standard Contractual Clauses adopted by the European Commission or – where applicable – on certification under the EU-US Data Privacy Framework.

Use of RevenueCat (subscription management)

Our App uses the RevenueCat service (RevenueCat, Inc., USA) to manage and analyse in-app purchases and subscriptions. In doing so, RevenueCat processes technical data relating to the use of the App, information on purchases/trial periods, and pseudonymous identifiers (e.g. an anonymised subscriber ID).

This processing is carried out on the basis of Article 6(1)(b) of the GDPR (performance of a contract to provide the in-app purchases ordered) and our legitimate interest under Article 6(1)(f) of the GDPR in the proper processing and management of our subscriptions.

RevenueCat may transfer data to the USA. The transfer is carried out on the basis of the Standard Contractual Clauses adopted by the European Commission. Further information can be found at: https://www.revenuecat.com/privacy.

Use of Google Analytics (Web Analytics)

If you have granted your consent, our website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Scope and Categories of Data Processed: Google Analytics uses technologies (such as cookies or device identifiers) that enable an analysis of your use of our website. The information generated about your use of the website includes aggregated usage metrics, such as pages viewed, duration of visit, operating system/browser info, and interaction patterns.

Privacy Safeguards (IP Anonymization): We have activated IP anonymization on our website. Your IP address is automatically truncated (shortened) by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area prior to transmission or processing.

Purpose of Processing and Access Restriction: Data collection and analysis are conducted strictly for our own internal optimization, performance measurement, and website improvement purposes. We do not pass this data to unauthorized third parties, nor do we permit Google to merge or utilize this data for its own advertising or cross-tracking activities.

Legal Basis: Storage of information on your terminal equipment and access to information already stored in your terminal equipment is carried out on the basis of Section 25(1) TDDDG. The subsequent processing of your personal data is carried out on the basis of your explicit consent pursuant to Article 6(1)(a) GDPR.

Third-Country Transfers: Data processed by Google may be transferred to Google LLC in the United States. Where personal data is transferred to the USA, such transfer is based on the EU-U.S. Data Privacy Framework or the Standard Contractual Clauses issued by the European Commission.

Withdrawal of Consent: You may withdraw your consent at any time with future effect by modifying your settings in our cookie consent banner or by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Website forms and hosting

Waitlist

On our launch page you can join the waitlist for the App. We process only the email address you enter, together with the date on which it was submitted. We use it solely to notify you when the App becomes available. The legal basis is your consent (Article 6(1)(a) of the GDPR), given by submitting the form. You may withdraw your consent at any time with future effect by emailing hey@clutchdarts.com; we will then delete your address. Otherwise your address is deleted once the launch notification has been sent or once the waitlist is discontinued.

Contact form

If you contact us via the form on our contact page, we process the subject, your email address and the content of your message. We use this data solely to process and respond to your enquiry. Your message is stored in our database and additionally forwarded to our own support mailbox by email. The legal basis is Article 6(1)(b) of the GDPR where your enquiry relates to a contract, and otherwise our legitimate interest in answering enquiries addressed to us (Article 6(1)(f) of the GDPR). We delete enquiries once they have been dealt with conclusively, unless statutory retention periods under tax or commercial law require longer storage.

Hosting and technical service providers

Our website is hosted by Vercel Inc. (USA), and the data submitted via the forms described above is stored in a database operated by Neon Inc. (USA). Outgoing emails are sent via our email service provider. These providers act as processors on our behalf under Article 28 of the GDPR. Where personal data is transferred to the USA, the transfer is based on the Standard Contractual Clauses adopted by the European Commission or on certification under the EU-U.S. Data Privacy Framework.

When our website is accessed, our hosting provider processes technical connection data (in particular IP address, date and time of access, the page requested, referring URL, browser and operating system). This processing is necessary to deliver the website and to ensure its stability and security, and is based on our legitimate interest under Article 6(1)(f) of the GDPR.

Retention period

Unless a more specific retention period is stated within this privacy policy, we will retain your personal data until the purpose for which it is processed no longer applies. The purpose generally ceases to apply when you uninstall the App or no longer use the relevant function. Data stored locally on your device will be deleted when you uninstall the App.

If you submit a valid request for erasure or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these grounds no longer apply.

Automated decision-making

No automated decision-making with legal effect or similarly significant adverse impact within the meaning of Article 22 of the GDPR takes place.

Your rights

You are entitled to the following data protection rights under the provisions of the GDPR:

  • Right of access (Article 15 GDPR): You have the right to request information about the personal data we hold about you.
  • Right to rectification (Article 16 GDPR): You have the right to request the rectification of inaccurate personal data concerning you. Taking into account the purpose of the processing, you also have the right to request the completion of incomplete personal data.
  • Right to erasure (Article 17 GDPR): You have the right to request the erasure of your personal data.
  • Right to restriction of processing (Article 18 GDPR): You have the right to request the restriction of the processing of your personal data.
  • Right to data portability (Article 20 GDPR): You have the right to have personal data that we process by automated means, on the basis of your consent or in fulfilment of a contract, provided to you or to another controller in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place to the extent that it is technically feasible.
  • Right to withdraw your consent (Article 7(3) GDPR): If you have given your consent to the processing of your data, you have the right to withdraw this consent at any time with future effect.
  • Right to lodge a complaint (Article 77 GDPR): If you believe that we are not complying with data protection regulations when processing your personal data, you have the right to lodge a complaint with a data protection authority.

In cases where data processing is carried out on the basis of Article 6(1), first sentence, points (e) or (f) of the GDPR, you have the right to object to the processing of your data on grounds relating to your particular situation (right to object under Article 21 of the GDPR).

Last updated: August 2026