Privacy Policy

1. Introduction

This Privacy Policy describes how CloutCall LLC (“we,” “us,” “our,” “Company”), a Delaware limited liability company, collects, uses, stores, shares, and protects your information when you use the CloutCall application and website (“the Service”). This policy applies to all users of the Service, including the website at cloutcall.com and any associated mobile applications.

By using the Service, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use the Service.

2. Information We Collect

2.1 Information You Provide

When you create an account and use the Service, we may collect the following information that you voluntarily provide:

• Account Information: Username, display name, email address, and password.
• Profile Information: Profile picture, bio, and any other information you choose to add to your profile.
• User Content: Comments, chat messages, predictions, and other content you submit through the Service.
• Payment Information: If you subscribe to Pro, payment is processed by third-party payment processors (Apple App Store, Google Play Store, or Stripe). We do not directly collect or store your credit card number, bank account details, or other financial account information. We may receive confirmation of payment status and subscription details from these processors.
• Communications: If you contact us for support or feedback, we collect the content of your communications.

2.2 Information Collected Automatically

When you use the Service, we automatically collect certain information:

• Usage Data: Pages viewed, features used, actions taken (swipes, predictions, comments, follows, likes), time spent on features, search queries, and interaction patterns.
• Device Information: Device type, operating system, browser type, screen resolution, device identifiers, and app version.
• Log Data: IP address, access times, referring URLs, and error logs.
• Location Information: Approximate location based on IP address (city/country level). We do not collect precise GPS location.
• Performance Data: App crashes, load times, and other diagnostic information.

2.3 Information from Third Parties

We may receive information from third-party services including:

• Authentication Providers: If you sign in using a third-party service (e.g., Apple Sign-In, Google Sign-In), we may receive your name, email address, and profile picture from that provider.
• App Store Platforms: Subscription status and purchase confirmation from Apple App Store or Google Play Store.
• Analytics Providers: Aggregated and anonymized usage statistics.

2.4 Information We Do NOT Collect

• Cryptocurrency Wallet Addresses: The Service does not require wallet connections. We do not collect, store, or have access to your private keys, seed phrases, wallet addresses, or on-chain transaction history.
• Financial Information: We do not directly process payments or store payment card details.
• Precise Location: We do not collect GPS coordinates or precise geolocation data.
• Biometric Data: We do not collect fingerprints, facial recognition data, or other biometric identifiers.

3. How We Use Your Information

3.1 Providing the Service

• Creating and maintaining your account.
• Processing your predictions, swipes, comments, and other in-app actions.
• Managing the Diamond economy, follow credit system, and leaderboard rankings.
• Personalizing your explore feed and content discovery experience.
• Displaying trending collections and community activity.
• Processing Pro subscription purchases and managing subscription status.

3.2 Improving the Service

• Understanding how users interact with the Service to improve features and design.
• Analyzing engagement patterns to optimize the prediction game, discovery engine, and social features.
• Identifying and fixing bugs, errors, and performance issues.
• Conducting internal research and analytics.

3.3 Personalization

• Tailoring the explore feed based on your engagement history (collections liked, viewed, comments posted, predictions made).
• Generating heat scores and trending signals from aggregated user activity.
• Recommending collections and content based on your interaction patterns.
• Adjusting content ranking based on your implicit signals (view duration, tap patterns).

3.4 Communication

• Sending you notifications about your predictions, rank changes, follower activity, and other in-app events.
• Responding to your support requests and inquiries.
• Sending important service announcements (Terms updates, security alerts, maintenance notices).
• With your consent, sending promotional communications about new features or updates. You may opt out of promotional communications at any time.

3.5 Safety and Security

• Detecting, preventing, and addressing fraud, abuse, and violations of our Terms of Service.
• Identifying multi-account abuse, bot activity, and manipulation of game mechanics.
• Enforcing our Terms of Service and protecting the rights and safety of our users.
• Complying with legal obligations and responding to lawful requests.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Public Information

Certain information is visible to other users of the Service by design:

• Your username and profile picture.
• Your comments and chat messages.
• Your prediction history and accuracy (on leaderboards).
• Your follower and following counts (following count visible to all; follower count visible only to Pro users).
• Your tier, level, and leaderboard ranking.
• Your Pro status badge.

4.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Hosting and Infrastructure: Cloud hosting providers (server infrastructure, database hosting).
• Analytics: Usage analytics and crash reporting services.
• Payment Processing: App store platforms and payment processors for Pro subscriptions.
• Content Delivery: Content delivery networks for serving media and static assets.

These providers are contractually obligated to use your information only for the purposes of providing services to us and are required to protect your information.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal requests, including:

• Court orders, subpoenas, or other legal process.
• Requests from law enforcement or government agencies.
• To protect the rights, property, or safety of CloutCall LLC, our users, or the public.
• To enforce our Terms of Service.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

4.5 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

5. Data Storage and Security

5.1 Where We Store Data

Your information is stored on servers located in the United States. If you are accessing the Service from outside the United States, you consent to the transfer of your information to the United States, where data protection laws may differ from those in your jurisdiction.

5.2 How We Protect Data

We implement reasonable technical and organizational measures to protect your information, including:

• Encryption of data in transit using TLS/SSL.
• Encryption of sensitive data at rest.
• Access controls limiting employee access to personal information on a need-to-know basis.
• Regular security assessments and monitoring.
• Secure authentication mechanisms.

5.3 No Guarantee

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee the absolute security of your information.

6. Data Retention

6.1 Account Data

We retain your account information and User Content for as long as your account is active. If you delete your account, we will delete or anonymize your personal information within 30 days, except where retention is required by law or for legitimate business purposes (such as resolving disputes or enforcing our Terms).

6.2 Usage and Analytics Data

Aggregated and anonymized usage data may be retained indefinitely for analytical and improvement purposes. This data cannot be used to identify individual users.

6.3 Activity Data

In-app activity data (swipes, predictions, comments) used for real-time trending and personalization is retained for 30 days in our search and analytics systems, after which it is automatically deleted. Permanent records of predictions and their outcomes are retained in the primary database for as long as your account is active.

6.4 Legal Requirements

We may retain certain information for longer periods as required by applicable law, regulation, or legal process.

7. Your Rights and Choices

7.1 Access and Portability

You may request access to the personal information we hold about you. Where technically feasible, we will provide your data in a structured, commonly used, machine-readable format.

7.2 Correction

You may update or correct your account information at any time through the Service settings. For other corrections, contact us at the address below.

7.3 Deletion

You may request deletion of your account and associated personal information. Account deletion is permanent and results in the loss of all Diamonds, follow credits, predictions, comments, and other account data. To delete your account, use the in-app account deletion feature or contact us.

7.4 Opt-Out of Communications

You may opt out of promotional communications by following the unsubscribe instructions in any promotional message or by adjusting your notification settings within the Service. You cannot opt out of essential service communications (such as security alerts or Terms updates).

7.5 Do Not Track

The Service does not currently respond to “Do Not Track” browser signals. However, you may adjust your device and browser settings to limit certain tracking.

8. Children’s Privacy

The Service is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child under 18 has provided us with personal information, please contact us immediately.

9. Cookies and Similar Technologies

9.1 What We Use

When you access the Service through a web browser, we may use cookies and similar technologies to:

• Maintain your login session.
• Remember your preferences and settings.
• Understand how you interact with the Service.
• Analyze traffic and usage patterns.

9.2 Types of Cookies

• Essential Cookies: Required for the Service to function (authentication, session management). These cannot be disabled.
• Analytics Cookies: Help us understand usage patterns and improve the Service. You may opt out of these.
• Preference Cookies: Store your settings and preferences for a better experience.

9.3 Your Cookie Choices

Most web browsers allow you to control cookies through their settings. You may block or delete cookies, but this may affect your ability to use certain features of the Service.

10. Third-Party Links and Services

The Service may contain links to third-party websites, marketplaces, blockchain explorers, or other external services. We are not responsible for the privacy practices or content of these third-party services. We encourage you to review the privacy policies of any third-party service before providing them with your information.

11. International Users

The Service is operated from the United States. If you are located outside the United States, your information will be transferred to and processed in the United States. By using the Service, you consent to this transfer.

11.1 European Economic Area (EEA) and United Kingdom (UK)

If you are in the EEA or UK, you may have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the right to:

• Access your personal data.
• Rectify inaccurate personal data.
• Erase your personal data (“right to be forgotten”).
• Restrict or object to processing of your personal data.
• Data portability.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with a supervisory authority.

Our legal basis for processing your personal data includes: performance of a contract (providing the Service), legitimate interests (improving and securing the Service), consent (where applicable), and compliance with legal obligations.

To exercise these rights, contact us at the address below.

11.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of your personal information.
• Right to Opt-Out of Sale: We do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at the address below. We will respond to verifiable requests within 45 days.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last Updated” date. If we make material changes, we will notify you through the Service or by email. Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

CloutCall LLC
Email: privacy@cloutcall.com
Website: https://cloutcall.com

For data protection inquiries from the EEA or UK:
Email: privacy@cloutcall.com
Subject Line: “GDPR Request” or “UK GDPR Request”

For California privacy rights requests:
Email: privacy@cloutcall.com
Subject Line: “CCPA Request”

By using CloutCall, you acknowledge that you have read, understood, and agree to this Privacy Policy.