Privacy Policy.
This policy explains what Clunite ("we," "us") collects when you visit clunite.com, how we use it, who we share it with, and the rights you have over your information. We follow the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA / CPRA), regardless of where you live.
1. Who we are
Clunite is operated by Clunite Editorial, with its principal place of business at Akasaka Ito Building 6F, 7-10-9 Akasaka, Minato-ku, Tokyo 107-0052, Japan. You can contact us about privacy at info@formtalker.com.
2. What we collect
Information you give us
We do not require an account to take a quiz. If you contact us by email, we receive whatever you choose to send (your email address, the body of the message, any attachments). We do not currently operate a newsletter or user account system.
Information collected automatically
- Usage data: pages visited, time on page, referring URL, approximate location (country and region only), device type, browser version, operating system, screen size.
- Quiz responses: the answers you select are stored anonymously and aggregated to improve quiz accuracy. Individual responses are not tied to a personal identifier.
- Cookies and similar technologies: see Section 4.
3. Why we collect it (legal bases under GDPR)
- Legitimate interests: measuring traffic, fixing bugs, improving quiz design, fraud prevention.
- Consent: non-essential cookies (advertising, analytics beyond first-party measurement). You can withdraw consent at any time through the cookie preferences link in the footer.
- Legal obligation: responding to lawful requests from law enforcement.
4. Cookies, GTM, Analytics, and AdSense
We use Google Tag Manager (GTM) to load measurement and advertising tags. The third-party services delivered through GTM include:
- Google Analytics 4 — aggregate traffic measurement. IP addresses are anonymized at collection.
- Google AdSense — contextual advertising. Google may use cookies to serve ads based on visits to clunite.com or other sites. You can opt out of personalized advertising at google.com/settings/ads.
- Functional cookies — remembering your language preference and cookie consent status.
Essential cookies (functional + security) load by default. Non-essential cookies (analytics, advertising) require your consent in the EEA, UK, and California, and you can change your preferences at any time using the link in our footer.
5. Sharing your information (CCPA / CPRA opt-out)
We do not sell personal information for money. We share information only with:
- Google LLC — for analytics and advertising as described above. Google's privacy policy applies.
- Hosting and email providers — to operate the site and respond to your messages.
- Law enforcement — when required by valid legal process.
Under California's CCPA / CPRA, the use of advertising cookies may be considered a "sale" or "sharing" of personal information. California residents can opt out using the Do Not Sell My Information link in the footer.
6. Data retention
Aggregated quiz responses are retained indefinitely for research and quiz refinement. Server logs containing IP addresses are retained for 30 days, then deleted. Email correspondence is retained for two years from your last message, then deleted unless an active issue requires longer retention.
7. International transfers
Our hosting infrastructure and our advertising partner Google operate in the United States and globally. Where we transfer personal data out of the EEA or UK, we rely on Google's Standard Contractual Clauses or comparable safeguards.
8. Your rights
Depending on where you live, you have some or all of the following rights over your personal data:
- Right to know what data we hold about you
- Right to access a copy of that data
- Right to correct inaccurate data
- Right to delete your data ("right to be forgotten")
- Right to restrict or object to certain processing
- Right to data portability
- Right to opt out of "sale" or "sharing" (CCPA / CPRA)
- Right to withdraw consent at any time
- Right to lodge a complaint with your local data protection authority
To exercise any of these rights, email info@formtalker.com with the subject line "Data Subject Request." We will respond within 30 days (45 days under CCPA / CPRA).
9. Children under 13
Clunite is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has submitted information through our site, contact us and we will delete it promptly. Users between 13 and 18 should review this policy with a parent or guardian.
Certain features on Clunite — including the World Cup Winner Prediction Ticket — require signing in with a Google account. Google's Terms of Service require users to be at least 13 years of age (or the minimum age required in their country) to create a Google account. By using Google Sign-In on Clunite, you represent that you meet this age requirement. We do not knowingly collect personal information from users who do not meet this requirement.
10. Security
We use HTTPS site-wide, encrypt data in transit, and limit access to personal data to staff who need it. No system is completely secure, and we cannot guarantee that unauthorized access will never occur.
11. Changes to this policy
We may update this policy. When we do, we'll change the "Last updated" date at the top and, if changes are material, post a notice on the homepage for at least 30 days.
12. Contact for data subject rights
For any privacy question, email info@formtalker.com. EU residents may also contact our EU representative through the same address.