(Last Updated: October 30, 2025)
This Privacy Policy outlines our policies and procedures regarding the collection, use, and disclosure of your information when you use our Service. It also informs you of your privacy rights and how the law protects you.We (Clown's Fortune, our app, hereinafter referred to as "we") use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy was created with the assistance of a Privacy Policy Generator.
1. Interpretation and Definitions
1.1 Interpretation
Words with initial capital letters have specific meanings as defined below. These definitions apply equally whether the words appear in singular or plural form.
1.2 Specific Definitions
For the purposes of this Privacy Policy:
Application: Refers to Clown's Fortune, the software program provided by the Company.
Company: Refers to Clown's Fortune, and may also be referred to as "the Company", "We", "Us", or "Our" in this Agreement.
Device: Any device that can access the Service, such as a computer, cellphone, or digital tablet.
Personal Data: Any information related to an identified or identifiable individual.
Service: Refers to the Application (Clown's Fortune).
Service Provider: A natural or legal person who processes data on behalf of the Company. This includes third-party companies or individuals hired by the Company to facilitate the Service, provide the Service on the Company’s behalf, perform service-related tasks, or assist the Company in analyzing how the Service is used.
Usage Data: Data collected automatically, either generated through the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).
You: The individual accessing or using the Service, or the company/other legal entity on whose behalf such an individual accesses or uses the Service (as applicable).
2. Collection and Use of Information
We collect the following types of information to provide and optimize the Service:
2.1 Game Data Information
We gather various game-related data, including the number of clicks, landing pages you visit, pages you view, apps you open, permission statuses, feature functionality statuses, the number of apps installed on your Device, app package names, app brands, app network status, firebase_device_id, Device model, country associated with your SIM card, system language, and cookies that advertisers may store or access.This data is only shared with authorized third-party statistical platforms, namely Firebase, Facebook Analytics, and our in-house data statistics system (ECS).
2.2 Device Information
To enhance your experience when using our app, we collect details about your Device and network connection. The information collected depends on the context of your interaction with us, your choices (including privacy settings), and the products/features you use. It may include the SDK/API code version, the platform you use, timestamp, application identifier, application version, independent Device identifier, Device manufacturer, Device operating system version, language location, time zone, network status (e.g., Wi-Fi), the app’s publication status on Google Play, ad loading strategy, advertising platform, and ad delivery ID.We store the collected information via the Android ID linked to your Device. This allows us to track your ad-related behavior within the app, and we consider this information as Personal Data.
2.3 Advertising Information
We use your Android Advertising ID to provide you with a personalized advertising experience. This identifier is strictly used for advertising and analytical purposes.It is important to note that the Advertising ID does not contain sensitive user information that could identify you as an individual or your Device. It is not linked to personal identification information, nor to permanent Device identifiers such as SSAID, MAC address, or IMEI.
2.4 Network Information
When you connect to the internet to play our game, we collect information about your network connection type (e.g., Wi-Fi or mobile data) and your IP address. This data is used to ensure a stable network connection for the game.
2.5 Monetization and Analytics Information from Other Sources
Third-party SDKs integrated into our app may access your information, including:
Google AD ID;
Device-related data (e.g., Device type, technical details, and country);
Anti-fraud data (e.g., data related to ad click fraud);
Demographic data (e.g., determining your location via your IP address);
Data used for advertising, marketing, and analytics purposes;
Cookies that advertisers may store or read.
The information collected by these third-party SDKs is managed by their respective providers, and we have no control over these third-party entities. Third-party partners include monetization partners (e.g., Google Admob, Facebook Audience Network, IronSource, AppLovin, Vungle, Unity, Fyber, Amazon, Pangle, Kwai) and analytics tool partners (e.g., Firebase, Facebook Analytics, and our own data analytics system). Links to the privacy policies of these platforms are provided in the "Privacy Policies of Third-Party Partners" section.
3. Legal Basis for Processing Personal Data
As described above, we process Personal Data in line with the purposes stated in this Privacy Policy. The legal bases for our Personal Data processing activities include:
Processing necessary for the performance of the contract we have with you (e.g., delivering the services you requested and verifying your identity);
Processing required to comply with legal obligations (e.g., adhering to applicable accounting regulations and making mandatory disclosures to law enforcement);
Processing for our legitimate interests (e.g., managing our relationship with you, safeguarding the security of our Service, and communicating with you about our products and services);
Processing based on your consent (e.g., placing certain cookies and sharing your information with third parties for advertising purposes).
In some cases, you may need to provide Personal Data to support the above processing activities, ensuring we can provide you with full access to our Service and all features of the app.
4. Methods of Information Collection
4.1 Automatic Collection by the Game
When you run the game, the game system automatically collects the relevant information detailed above. This collection is conducted in compliance with this Privacy Policy and applicable laws and regulations.
4.2 Collection via Third-Party Platforms
If you download and install the game through a third-party platform (e.g., Google Play Store), we may obtain certain information about you from that platform, such as your Device identifier and app download history. This collection adheres to the privacy policies of the third-party platforms and applicable laws and regulations.
5. Retention of Your Personal Data
We will retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specifically, we may retain and use your Personal Data to:
Comply with legal obligations (e.g., retaining data as required by applicable laws);
Resolve disputes;
Enforce our legal agreements and policies.
We also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, unless it is used to enhance Service security, improve Service functionality, or we are legally required to retain it for a longer period.
6. Transfer of Your Personal Data
Your information (including Personal Data) is processed at our operating offices and any other locations where parties involved in the processing are based. This means your information may be transferred to and stored on computers located outside your state, province, country, or other governmental jurisdiction—where data protection laws may differ from those in your jurisdiction.By consenting to this Privacy Policy and submitting your information, you agree to such transfers.We will take all reasonably necessary steps to ensure your data is handled securely and in accordance with this Privacy Policy. No transfer of your Personal Data will occur to an organization or country unless adequate safeguards are in place (including measures to protect the security of your data and other personal information).
7. Deletion of Your Personal Data
You have the right to delete or request our assistance in deleting the Personal Data we have collected about you.Our Service may allow you to delete certain information about yourself directly within the Service.If you have an account, you can update, amend, or delete your information at any time by logging into your account and accessing the account settings section for managing personal information. You may also contact us to request access to, correction of, or deletion of any Personal Data you have provided to us.However, please note that we may need to retain certain information if we have a legal obligation or lawful basis to do so.
8. Disclosure of Your Personal Data
8.1 Business Transactions
If we are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.
8.2 Law Enforcement Requests
Under certain circumstances, we may be required to disclose your Personal Data if mandated by law or in response to valid requests from public authorities (e.g., a court or government agency).
8.3 Other Legal Requirements
We may disclose your Personal Data in good faith if we believe such action is necessary to:
Comply with a legal obligation;
Protect and defend the rights or property of the Company;
Prevent or investigate potential wrongdoing related to the Service;
Protect the personal safety of Service users or the public;
Avoid legal liability.
9. Security of Your Personal Data
We take the security of your Personal Data seriously. However, please note that no method of internet transmission or electronic storage is 100% secure. While we strive to protect your Personal Data using commercially acceptable means, we cannot guarantee its absolute security.
10. California Privacy Rights
The California Consumer Privacy Act (CCPA) grants additional rights to California residents, as detailed below. To exercise these rights, refer to the "Exercising Your California Privacy Rights" section.If you are not a California resident, this section does not apply to you—please refer to our main Privacy Statement.
Right to Know: You have the right to know and access the information we have collected about you in the past 12 months, including:
The types of information collected about you;
The sources from which the information was collected;
The commercial or business purpose for collecting the information;
The specific information we have collected about you.
Right to Erasure: You have the right to request that we delete the information we have collected from you (and direct our Service Providers to do the same). Exceptions apply, including but not limited to situations where we or a third party need the information to:
Provide you with services;
Fix errors in our system;
Comply with the California Electronic Communications Privacy Act (California Penal Code Section 1546 et seq.);
Conduct public or peer-reviewed scientific, historical, or statistical research in the public interest (in compliance with applicable ethical and privacy laws);
Fulfill legal obligations.
Retention Provisions:
We may retain Personal Data for a longer period if you consent to such processing and do not withdraw your consent. Additionally, we may be legally required to extend retention to meet legal obligations or comply with official orders.
Once the game ceases operation, all Personal Data will be deleted.
Response to Requests: We aim to respond to verifiable consumer requests within 45 days. If we need more time (up to 90 days), we will notify you of the reason and extension via email, phone, or other electronic means. We will not charge a fee for processing or responding to your verifiable request, unless the request is excessive, repetitive, or clearly unfounded. If a fee is required, we will inform you of the reasons and provide a cost estimate before fulfilling the request.
Non-Discrimination: We will not discriminate against you for exercising your CCPA rights. Discrimination includes refusing to provide services, charging different prices/rates, or offering different service levels/quality. You should not experience any differences in service pricing, rates, levels, or quality due to exercising your CCPA rights.
Minors’ Data Collection Notice: Our Service is not available to individuals under 13 years of age. We do not knowingly collect personally identifiable information from children under 13. If we become aware that a child under 13 has provided us with Personal Data, we will immediately delete it from our servers. If you are a parent or guardian and know your child has provided such information, please contact us to take appropriate action. Users aged 13–16 have the right to opt in; parents/guardians of users in this age group may also contact us.
11. Rights of EU and UK Residents
If you are a resident of the UK or another EU Member State, you have the following rights under EU data protection legislation:
Confirm whether we process your Personal Data and inquire about the personal information we hold about you;
Modify or verify your data;
Request the deletion of your data;
Request that we stop using some or all of your data if we have no legal right to continue processing it;
Request a copy of the Personal Data you provided to us in a machine-readable format.
To exercise these rights, please send an email to taha98515@gmail.com. We will respond within one month. If you believe we are not complying with data protection laws, you also have the right to file a complaint with your local data protection authority.
12. Third-Party Links
We have provided links to the privacy policies of our third-party partners. These policies are managed independently by the third parties, and we have no control over them. The links contain detailed information on how third parties collect, use, and share user data. We recommend you carefully review these third-party privacy policies. The specific links are as follows:
Adjust: https://www.adjust.com/terms/privacy-policy/
Max/Applovin: https://www.applovin.com/privacy/
Unity: https://unity3d.com/legal/privacy-policy
Pangle: https://www.pangleglobal.com/privacy
Mintegral: https://www.mintegral.com/en/privacy
Vungle: https://vungle.com/privacy/
Bigo: https://www.bigo.tv/privacyPolicy.html
Firebase: https://firebase.google.com/support/privacy
Admob：https://policies.google.com/privacy
13. Children’s Privacy
Our Service is not available to individuals under 13 years of age. We do not knowingly collect personally identifiable information from children under 13. If we become aware that a child under 13 has provided us with Personal Data, we will immediately delete it from our servers. If you are a parent or guardian and know your child has provided such information, please contact us to take appropriate action. Users aged 13–16 have the right to opt in; parents/guardians of users in this age group may also contact us.
14. Updates to This Privacy Policy
We may periodically review and update this Privacy Policy to align with business needs or changes in laws and regulations. The revised policy will be posted within the app, and we will notify you via a reasonable method when appropriate. After receiving the notification, please carefully review the revised Privacy Policy. If you do not agree to the revised terms, you have the right to stop using the game. Continuing to use the game after the update constitutes your acceptance of the revised Privacy Policy.
15. Contact Us
If you have any questions, concerns, or suggestions regarding this Privacy Policy or our handling of your Personal Data, please contact us via:Email: squarenineinternational161@gmail.com