Privacy Policy
Last updated 18 October 2026
1. Who we are
Clownd is operated by CODEIUM, a sole proprietorship registered in Croatia ("we", "us"). We are the controller of the personal data described here.
Contact for anything about your data: hello@clowndapp.com
This policy covers the Clownd waitlist at clowndapp.com. When the Clownd app launches, it will have its own privacy policy, and we will tell you before anything changes.
2. What we collect
When you join the waitlist:
- Your email address, to confirm your signup and tell you when Clownd launches.
- Your invite code and who invited you (if you joined through a friend's link), so we can place friends in the same group on launch day.
- The result of the age check: whether you passed, your country (based on your approximate location) and the minimum age that applied. We do not store your birth year.
- When you agreed to join and which version of our terms you saw.
- How you found us: campaign tags in the link you used (for example "tiktok") and the website you came from (the site's address only, not the full page).
- Confirmation details: whether and when you confirmed your email, and when we sent you emails.
Automatically, for security:
- Our hosting, bot-protection and rate-limiting services briefly see your IP address when you visit or sign up, as any website does. We store only a scrambled (hashed) version of your IP address for abuse prevention, and delete it after 30 days. We never store your IP address in readable form.
- Anonymous usage statistics (pages viewed, page speed). These use no cookies, collect no email address or link codes, and cannot identify you.
What we don't collect: no name, no phone number, no contacts, no photos, no payment details, no advertising identifiers. We don't sell your data and we don't use it for advertising.
3. Why we use it, and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Keeping your place on the waitlist, confirming your email, telling you when Clownd launches | Your consent (you can withdraw it at any time) |
| Placing you in your friends' group and showing your inviter how many friends joined (a number only, never who) | Your consent, as part of the waitlist you signed up for |
| Checking you meet the minimum age | Legal obligation and our legitimate interest in not collecting data from children |
| Preventing fake signups, spam and abuse | Our legitimate interest in keeping the service secure |
| Understanding which videos and links bring people to Clownd | Our legitimate interest in improving how we reach people, using minimal data |
We only send emails about your waitlist place: the confirmation email and the launch announcement. No newsletters or marketing emails.
4. Who we share it with
We use trusted service providers who process data only on our instructions:
| Provider | What they do |
|---|---|
| Vercel | Hosts the website; anonymous usage and speed statistics; firewall |
| Supabase | Stores the waitlist database |
| Resend | Sends our emails (keeps a copy of each email it sends, including your address) |
| Cloudflare | Domain and email forwarding for hello@clowndapp.com; bot protection (Turnstile) on the signup form |
| Upstash | Short-lived counters that stop people from spamming the form (stores only scrambled values) |
We may also disclose data if required by law, or to a buyer if Clownd is ever sold, in which case this policy would continue to protect your data.
5. International transfers
Some of these providers process data outside the European Economic Area, mainly in the United States. Where they do, we rely on recognised safeguards, such as the EU–US Data Privacy Framework (where the provider is certified) or the European Commission's Standard Contractual Clauses.
6. How long we keep it
- Unconfirmed signups are deleted 30 days after signing up.
- Confirmed signups are kept until 90 days after the Clownd app launches (so we can tell you it's live and set up your group), then deleted. If you sign up for the app, its own privacy policy applies from then on.
- Scrambled IP addresses are deleted after 30 days.
- Anti-spam counters expire on their own within about a day.
- Copies held by our providers (such as Resend's email logs and hosting logs) are kept for the limited time each provider sets.
- If you remove yourself, your signup is deleted immediately.
7. Cookies and similar technology
We don't use advertising or tracking cookies.
- Session storage: if you arrive through an invite or campaign link, your browser remembers the invite code and campaign tag until you close the tab, so they're included when you sign up.
cl_youngcookie: only if you don't pass the age check, a cookie keeps the form closed for 24 hours.- Bot protection: Cloudflare Turnstile runs a check in its own frame on the signup form to tell people from bots.
- The anonymous statistics use no cookies.
8. Your rights
You have the right to:
- access the data we hold about you, and get a copy (portability),
- correct it,
- delete it: use the "remove me" link in any of our emails, or email us,
- withdraw your consent at any time (this doesn't affect anything done before),
- object to or restrict how we use it.
Email hello@clowndapp.com to use any of these rights. We reply within one month and may ask you to confirm the request from the email address you signed up with.
You can also complain to the Croatian data protection authority, AZOP (Agencija za zaštitu osobnih podataka, azop.hr), or to the data protection authority in the country where you live.
9. Children
The waitlist is not for children. You must be at least 13 to join, or older where the law in your country requires it (up to 16; if we can't tell your country, the minimum is 16). We don't knowingly collect data from anyone under that age. If you believe a child has joined, email us and we'll delete it.
10. Security
We protect your data with encryption in transit, strict access controls, a database that only our server can reach, and regular security reviews. No system is perfectly secure, but we work hard to keep your data safe and to collect as little as possible.
11. Changes to this policy
We may update this policy. If we make important changes, we'll tell you by email or on this page before they take effect. The date at the top shows the latest version.