Privacy Policy

Last updated: October 20, 2026

This Privacy Policy explains how Clearhaven (“we,” “us,” or “our”) collects, uses, shares and protects information when you visit clearhaven.link (the “Site”) or contact us. It also describes the rights available to you under major data protection laws, including the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), the Brazilian General Data Protection Law (LGPD) (Lei nº 13.709/2018), and the Personal Information Protection Law of the People’s Republic of China (PIPL), which applies because we operate from the People’s Republic of China.

By using the Site you acknowledge this Privacy Policy. If you do not agree, please discontinue use of the Site. This Policy should be read together with our Terms of Service.

1. Who Controls Your Data

The data controller is Clearhaven, operator of clearhaven.link. Privacy requests: [email protected]. We have not appointed a statutory Data Protection Officer (not required for our scale under the GDPR), but we handle all privacy requests at that address.

2. Information We Collect

2.1 Information you provide voluntarily. When you use the contact form or email us, you may provide your name, email address, chosen topic and the content of your message. On game pages, you may type a display name and comment text, and use like / favourite buttons.

2.2 Information stored on your device (not our servers). To keep the Site functional without accounts, certain features use your browser’s localStorage. Specifically:

• Comments on game pages (keys like cm:*) — display name, comment text, date;
• Likes and favourites (keys like like:*, fav:*);
• Contact form drafts (key clearhaven:contact) — your name, email, topic and message, retained in your browser as a local record of what you sent us.

This data stays in your browser on your device. We do not receive it on our servers unless you separately send it to us (for example, by email). You can delete it at any time by clearing site data for clearhaven.link in your browser settings.

2.3 Information collected automatically. Like virtually all websites, our hosting infrastructure may automatically process technical data such as IP address, browser type and version, device type, operating system, referring URL, pages viewed, and timestamps, primarily for delivery, security and aggregate traffic statistics. This data is used at the infrastructure level and is not linked to an identified person by us.

2.4 Embedded third-party games. Our catalog embeds browser games hosted by GamePix (play.gamepix.com). When a game loads, your browser connects directly to GamePix’s servers, which necessarily process your IP address and standard technical data under GamePix’s own terms and privacy policy. We do not control what GamePix collects inside the game iframe.

3. How and Why We Process Your Data (Legal Bases)

The GDPR requires a legal basis for each processing operation. The table below details every category of processing on the Site:

• Serving pages and embedded games — data: IP address, request metadata. Purpose: delivering the Site you requested. Legal basis: legitimate interests (GDPR Art. 6(1)(f); LGPD Art. 7(VI); PIPL necessity for handling your request).
• Security, abuse prevention and debugging — data: IP address, request patterns, error logs. Purpose: detecting attacks, spam and malfunctions. Legal basis: legitimate interests in keeping the Site secure.
• Responding to contact-form emails — data: your name, email, message. Purpose: answering your inquiry. Legal basis: steps prior to a contract and legitimate interests (GDPR Art. 6(1)(b), (f)).
• Local features (comments, likes, favourites) — data: stored only in your browser. Purpose: remember your preferences on your device. Legal basis: not applicable to us as controller (data never reaches our servers); processing happens on your device for your convenience.
• Compliance with legal obligations — data: whatever is strictly necessary. Purpose: responding to lawful requests from competent authorities. Legal basis: legal obligation (GDPR Art. 6(1)(c); LGPD Art. 7(II)).
• Personalized advertising (if and when displayed) — data: cookie/identifier-based interests. Purpose: showing and measuring ads. Legal basis: consent where required (GDPR Art. 6(1)(a); LGPD Art. 7(I)); you can withdraw consent at any time using the opt-out links in Section 6.

Retention. Contact emails are kept only as long as needed to resolve your request and for up to 12 months afterward for correspondence context. Server logs are kept for up to 90 days. Local browser data remains until you clear it or it expires per your browser’s policy.

4. How We Share Information

We do not sell your personal information. We share data only in these limited ways:

• Service providers that host the Site or deliver email (acting as processors under GDPR Art. 28 terms);
• Third-party game platforms (currently GamePix) — data flows to them directly when you load a game, as explained in Section 2.4;
• Advertising partners (if ads are enabled) — limited identifiers may be shared for ad delivery and measurement, subject to your consent and the opt-out rights in Section 6;
• Legal disclosures — when required by law, court order, or to protect the rights, safety and property of Clearhaven, our users, or the public;
• Business transfers — in connection with a merger, acquisition or sale of assets, subject to this Policy or an equivalent notice.

5. Cookies and Local Storage

The Site itself functions without tracking cookies: core features (browsing, rankings, guides) use no cookies at all. We rely on localStorage for the local features described in Section 2.2. Third parties embedded in the Site (game providers and, if enabled, advertising partners) may set their own cookies or use similar technologies under their own policies. You can control or delete cookies and site data through your browser settings (for example, “Clear browsing data,” “Site settings,” or private-browsing mode). Blocking technologies may affect embedded games but not the rest of the Site.

6. Personalized Advertising & Opt-Out Links

If personalized or interest-based advertising is displayed on the Site (including Google personalized ads served across the web), you can opt out at any time using the official controls below:

• Turn off Google ad personalization for your Google Account: https://myadcenter.google.com/personalizationoff
• Learn how Google uses data when you or our partners use its services (ad measurement, partner sites): https://policies.google.com/technologies/partner-sites
• Google Ads Settings (classic control): https://adssettings.google.com/
• Industry-wide opt-outs (US, Europe, other regions): https://optout.aboutads.info/ and https://www.youronlinechoices.com/

Opting out of ad personalization does not stop ads from being shown; it stops them from being tailored to your interests. Browser-level controls such as Global Privacy Control (GPC) and “Do Not Track” signals are respected where legally required.

7. Your Data Protection Rights

Depending on your location, you may have some or all of the following rights:

• GDPR (EU/EEA/UK users): right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection to processing based on legitimate interests (Art. 21), and the right to withdraw consent at any time. You may also lodge a complaint with your national supervisory authority.
• LGPD (Brazilian users): right to confirmation and access, correction, anonymization/blocking/deletion of unnecessary or excessive data, portability, information about sharing, the right to revoke consent, and the right to complain to the Autoridade Nacional de Proteção de Dados (ANPD) — LGPD Art. 18.
• PIPL (users in the PRC): right to know, decide, restrict or refuse processing, right to copy/port your personal information, right to request correction or deletion, and the right to request an explanation of the rules — PIPL Arts. 44–50.

Because most Site data (comments, likes, favourites, contact drafts) never leaves your device, you can exercise many of these rights instantly by clearing site data in your browser. For anything held by us (such as email correspondence), write to [email protected]. We respond within 30 days, or sooner where local law requires.

8. International Transfers

Clearhaven operates from the People’s Republic of China; data may therefore be processed in the PRC and in any country where our hosting or email providers operate. Where personal data of EU residents is transferred outside the EEA, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions, in line with GDPR Chapter V. Where Brazilian or Chinese users’ data is transferred abroad, we apply the transfer conditions required by the LGPD and PIPL respectively.

9. Children’s Privacy

The Site is not directed at children under 13, and we do not knowingly collect personal information from children. Under the GDPR, a higher digital age of consent (up to 16) may apply in your member state — if you are below the applicable age, please use the Site only with parental or guardian permission. If you believe a child has provided us personal data, contact us and we will delete it.

10. Data Security

We take reasonable technical and organizational measures appropriate to the risk — including HTTPS transport, access controls on our infrastructure, and minimizing what we collect in the first place (privacy by design: most features run entirely in your browser). No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Third-Party Links and Embedded Services

The Site links to and embeds third-party services (for example GamePix games and the advertising services referenced in Section 6). Their privacy practices are governed by their own policies, not ours. We encourage you to review them. We are not responsible for the content or practices of any third-party service.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top shows when it was most recently revised. For material changes, we will provide prominent notice on the Site at least 30 days before they take effect, where required. Continued use of the Site after the effective date means you accept the updated Policy.

13. Contact

Questions or requests about this Privacy Policy or your data: [email protected], or via the Contact page. EU users may also contact their local supervisory authority.