Privacy Policy – Clutch City AppWorks LLC

Last Updated: March 23, 2026

1. Scope of this Policy

This Privacy Policy describes how Clutch City AppWorks LLC ("we," "us," "our") collects, uses, and shares information when you visit our website at clutchcityappworks.com and any related pages that link to this policy (the "Site").

This policy does not cover data collected inside our mobile apps (such as Lotto Ledger), which are subject to their own in‑app privacy notices.

2. Information We Collect via Analytics

When you visit our Site, we use third‑party analytics tools to understand how visitors use our pages and to monitor technical performance. These tools may collect:

• IP address and general location (e.g., city or region).
• Device and browser information (e.g., device type, operating system, browser type, screen resolution).
• Usage information (e.g., pages visited, links clicked, time spent on pages, error codes).
• Basic interaction data (e.g., how quickly pages load and render, whether certain features are used).

Some of this information (such as IP address and certain identifiers) may be considered "personal data" under applicable laws.

We do not combine this analytics information with other data to attempt to identify you as an individual.

3. How We Use This Data

We use the information described above for the following purposes:

• Performance and reliability: To monitor how quickly the Site loads, identify errors, and ensure it functions correctly for visitors.
• Feature planning and improvement: To understand which Site pages, tools, or resources are most used so we can improve them.
• Security and abuse prevention: To help detect and prevent bot traffic, fraud, and other malicious activity.

We do not use website analytics data to show you ads, build cross‑site marketing profiles, or otherwise engage in "targeted advertising" on the Site.

We do not sell personal data collected on the Site.

4. How We Share Information

We may share information collected on the Site in the following limited ways:

• Service providers: With third‑party vendors that provide analytics, performance, hosting, or security services for the Site (currently Google Analytics and Cloudflare). These vendors process data on our behalf and under our instructions.
• Legal and compliance: With law enforcement, regulators, or other parties when we believe disclosure is required by law or reasonably necessary to protect our rights, safety, or property, or that of others.
• Business transfers: In connection with a merger, acquisition, or other corporate transaction involving Clutch City AppWorks LLC, subject to appropriate confidentiality protections.

We do not sell your personal data and do not share personal data from the Site with third parties for targeted advertising.

5. Cookies and Tracking Technologies

How We Use Cookies and Beacons

Clutch City AppWorks LLC does not use cookies on the Site for marketing, advertising, or user profiling. However:

Managing Your Preferences

• Browser settings: Most browsers let you block or delete cookies. Doing so may impact some analytics functionality but should not prevent basic use of the Site.
• Google Analytics opt‑out: You can install the Google Analytics Opt-out Browser Add-on to prevent your information from being used by Google Analytics.

Because we do not sell personal data from the Site or use it for targeted advertising, some state‑law opt‑out mechanisms (such as "Do Not Sell My Personal Information" links) are not applicable to this Site at this time. If we ever begin using cookies or similar technologies for advertising or other non‑analytics purposes, we will update this policy and, where required, provide appropriate consent and opt‑out options.

6. Your Privacy Rights

Depending on where you live, you may have certain privacy rights under U.S. state privacy laws, including those in California, Colorado, Connecticut, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia, and other states with consumer data protection laws.

Rights You May Have

• Right to know and access: Request confirmation of whether we are processing your personal data and access the categories and specific pieces collected about you.
• Right to correction: Request that we correct inaccuracies in your personal data.
• Right to deletion: Request that we delete personal data we have collected about you, subject to certain exceptions.
• Right to data portability: Request a copy of certain personal data you have provided in a portable, readily usable format where technically feasible.
• Right to opt out of certain processing:
  • We do not sell your personal data or process it for targeted advertising on the Site.
  • We do not use personal data on the Site for profiling that produces legal or similarly significant effects for you.
  • If we ever engage in these activities, we will provide clear opt-out mechanisms and honor browser-based opt-out signals (such as Global Privacy Control) as required by law.

How to Exercise Your Rights

To exercise any of these rights, contact us at: [email protected]. Please include enough detail for us to understand and respond to your request (e.g., that it relates to the website, the email or IP address associated with your use, and which right you wish to exercise). We may take reasonable steps to verify your identity before responding.

We aim to respond to verified requests within 45 days. If we need more time (up to an additional 45 days as permitted by law), we will notify you and explain why.

Appeal Process

If we deny your request in whole or in part, you may appeal our decision by replying to our response or emailing us at [email protected] with "Privacy Appeal" in the subject line. We will review your appeal and respond within the time required by applicable law.

7. Data Retention

We retain analytics and performance data collected via the Site only for as long as reasonably necessary for the purposes described in this policy. In general, we rely on our analytics providers' standard retention settings (for example, up to 14 months for Google Analytics data) and may aggregate or anonymize data for longer‑term trend analysis where permitted.

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal data collected through the Site from unauthorized access, use, or disclosure. However, no website or internet transmission is completely secure, and we cannot guarantee absolute security of information transmitted to or from the Site.

9. Children's Privacy

The Site is not directed to children under the age of 13, and we do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data through the Site, please contact us and we will take appropriate steps to delete the information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, provide additional notice. Your continued use of the Site after any changes become effective means you accept the updated Privacy Policy.

11. Contact Us