Legal

CardTray - Privacy Policy

Effective date: October 6, 2026 Product: CardTray Provider: Clearware, LLC, a Delaware limited liability company ("Clearware," "we," "us," or "our") Contact: [email protected] | https://cardtray.io

The short version (plain-language summary)

This summary highlights the key points. The full policy below controls.

CardTray runs on your device. Every game you play - the deals, every move, your replays, scores, streaks, achievements and solver answers - is stored in a database on your computer. We don't upload it.
We never receive your deals or your moves. Our crash and usage reporting is built around a code-level allow-list. It can say which game was played and roughly how it went, as a public game name and coarse ranges, but it never carries a deal's seed, a move log, your exact score or time, or any file name or path.
How CardTray is funded - bandwidth sharing. While CardTray is installed, it shares a slice of your idle internet bandwidth when it can through a bundled partner network (Massive) to relay other parties' traffic. Only one Clearware app shares on a device at a time, so this may not run at all if another Clearware product already holds the slot. When it is running, it runs in the background and keeps sharing even after you close CardTray, until you uninstall. It does not read or upload your data. See Section 3. This is disclosed in the EULA and shown by an always-visible status indicator in the app and by Massive's own system-tray icon.
To operate the network, Massive processes some device data (such as your IP address, an anonymous device identifier, city-level location, device specifications, and bandwidth statistics). Massive is an independent data controller for that processing under its own privacy policy. See Section 3.
What we do collect is limited and carries no name or contact details: crash reports and usage events, which you can turn off, and install and uninstall signals keyed to a random install id. See Section 4 for exactly which of these you can switch off.
We don't sell your personal information.
You have rights to access, delete, and control your data - see Sections 12-13.

1. Who we are

Clearware, LLC develops and distributes CardTray, a free Windows desktop card-game app. This policy explains what information the Software and our related services handle, how, and your choices. It applies to the CardTray application and the cardtray.io website's interactions with it. It is incorporated into the End User License Agreement.

2. Our core principle: local-first

CardTray is designed to keep your data on your device:

Your games are stored on-device. Every game you start, every move you make, your replays, personal bests, streaks, achievements and the answers the solver gives are stored in a local database in CardTray's own folder on your computer. We don't have a copy, and nothing in that database is uploaded.
The game runs on-device. Dealing, play, the Daily Challenge pick, checking a finished game and the solver all run inside the app on your computer. The Daily Challenge is computed locally, not fetched. Share on a Daily result copies a one-line summary to your clipboard and sends nothing anywhere. The optional Daily reminders are created on your computer.
Your settings are local. Preferences, including your card deck, table and sound choices, are stored on your device via a local settings store.
No account required. CardTray does not require you to create an account or give us your name, email, or other identifying details to work. There are no online leaderboards and no multiplayer.

3. The bandwidth exchange (how the app is funded)

CardTray is free because, while it is installed, it shares a slice of your device's idle, unused internet bandwidth when it can through a bundled third-party network operated by Massive and/or its partners (the "Exchange"). Your connection relays third-party internet traffic. This is how we generate revenue instead of charging you or showing ads.

Only one Clearware app shares on a device at a time. The Exchange currently allows a single connected client per machine. If you have more than one Clearware application installed, only one shares bandwidth at any moment; a sibling app that does not currently hold the slot keeps retrying and takes over automatically once it frees up. On a device where a sibling app already holds the slot, CardTray may share nothing for as long as that lasts.

The Exchange runs in the background, including after you close CardTray. The Massive agent starts with your Windows user session and keeps sharing while you are logged in, even after you close or quit CardTray, until you turn sharing off or uninstall. It shares only for the logged-in Windows user; it is not a system-wide service and does not run for other users of the device or at the Windows sign-in screen.

The Exchange does not access your data. Specifically, it does not read, upload, or share your files, your games, saves, replays or records, your browsing or search history, the sites you visit, your credentials, cookies, keystrokes, or screen contents. It relays other parties' traffic - not yours.

What Massive processes to operate the network. To route traffic, Massive processes a limited set of device data: your IP address (during active sessions), an anonymous device identifier, city-level location, device specifications, and connection and bandwidth statistics. Massive retains this data on a capped schedule (currently up to 60 days) and is an independent data controller for it, governed by Massive's own terms and privacy policy, not ours. See:

Massive license: https://www.joinmassive.com/en/terms
Massive privacy policy: https://www.joinmassive.com/en/privacy
Massive SDK privacy policy: https://www.joinmassive.com/en/monetization-sdk-privacy-policy
Massive FAQ: https://www.joinmassive.com/faq

Resource use. Sharing uses network bandwidth and a small amount of CPU. CardTray does not itself instruct the Massive agent to keep your computer awake; depending on your system and the agent's own default behavior, participating may keep your device awake or reduce how often it sleeps while sharing is active, and otherwise defers to your operating system's normal power and sleep settings.

Your control. You can turn sharing off at any time from CardTray's Settings, CardTray's tray menu, or Massive's own system-tray icon; a stop from Massive's icon is honored and the app will not restart sharing behind you. Note: CardTray's games do not run while sharing is off (see the EULA Section 4). You cannot start or continue a game, and a game in progress is paused. It is already saved, so nothing is lost, and it resumes at the same move when sharing is back on. Your saved games, stats, records and replays stay readable while sharing is off. To end participation permanently, uninstall the app, which stops and removes the Massive agent.

4. Information the Software collects

Nothing below carries your name, email address, URLs, file names, or the content of your games. The table says which items you can switch off.

Data	What it is	Purpose	Default	Third party
Crash reports	Anonymized error type and stack trace with URLs, file paths, filenames, and local variables scrubbed out before sending. A solver result that disagrees with the game's own rules check is reported as the error class `solver_verifier_disagree` with the game's public name only	Diagnose and fix crashes and rules bugs	On (opt-out)	Sentry
Usage analytics	A small, fixed set of events: app launched, a game tile opened, a solve started/finished, a game started or finished, a Daily Challenge played, an achievement unlocked, fullscreen toggled, a replay opened, the bandwidth exchange changing state, and the app-update lifecycle (update available/downloaded/applied/failed). The only details attached are: the module id; the game's public catalog name (e.g. `klondike`); the card theme; whether the game is Verified or Beta; yes/no flags for whether it was a Daily, a retry of the same deal, a replay branch, fullscreen, or a solve from the original deal; the result (won/lost); coarse ranges for duration, moves, undos, streak length and solver effort, never exact values; an achievement id; the bandwidth exchange's status and which of its two connection methods is in use; a coarse error category; the update channel (stable/beta); and a public version number. These events are sent to Aptabase and also to Clearware's own usage service, which receives them together with the random install id described in the next row, plus one "app active today" signal per day	Understand which games and features are used, how reliably, and whether updates are being adopted	On (opt-out)	Aptabase; Clearware (cardtray.io)
Install-attribution signal	A first-launch ping containing a random install identifier created by the installer (a UUID) and the app version - no name or email	Measure how many downloads become active installs	On (opt-out)	Clearware (cardtray.io)
Install and uninstall signals	When the installer starts - before its agreement pages - it sends the same random install id, the app version, the operating system, a coarse screen-size range, and your computer's Windows machine identifier (MachineGuid). As you move through the installer it reports which step you reached. When CardTray is uninstalled, the uninstaller sends the install id, the app version and the machine identifier. The machine identifier is the same one the Massive agent reports, so we can match bandwidth-sharing activity to the download that produced it	Count installs and uninstalls, see where installs stop, and attribute sharing activity to the channel that delivered the install	Always sent; the in-app switches do not control it	Clearware (cardtray.io)
Update checks	A request to our update server to see whether a newer version exists	Deliver security and functionality updates	On (needed to update)	Clearware / update host

How the "no PII" design is enforced. In the Software, every analytics event passes through an allow-list that permits only the fixed event names and the non-identifying properties above; anything else is dropped, and any value that looks like a URL, a file path or a filename is dropped too. Durations, move counts, undo counts, streaks and solver effort leave the app only as range labels, never as numbers. Every crash report passes through a scrubbing step that removes user/identity fields and redacts URLs, Windows and Unix file paths, and filenames from the text before transmission. This is a design safeguard, not an absolute guarantee.

Nothing about a specific deal is reported. The game's name is a public catalog name, not something you wrote. No field anywhere in the telemetry allow-list can carry a deal's seed, a move, a move log, a game id, an exact score or an exact time. So an event can say "a Klondike game was won in a few minutes"; it cannot say which deal it was, what moves you made, or your exact score or time. That is a property of the event schema, not a filter applied afterwards.

5. Information we do NOT collect

We do not collect, and the Software is built not to transmit:

the seed (deal number) of any game you play, or the moves you make in it;
your game history, replays, exact scores or times, streak dates, or the contents of the game database;
the solutions the solver finds;
the names or contents of any file on your disk;
your browsing history or the websites you visit;
your name, email address, passwords, payment details, or precise location;
persistent cross-site advertising identifiers.

6. How we use information

We use the limited information we do collect only to:

keep the Software stable (diagnose crashes and errors, including rules bugs in a game);
understand which games and features are used and how reliably, to prioritize improvements;
measure install activation, retention and uninstalls in aggregate, and attribute installs and bandwidth-sharing activity to the channel that delivered them;
deliver updates.

We do not use it to build advertising profiles or to identify you.

7. Cookies and tracking

The CardTray desktop application does not use advertising cookies or cross-site trackers. The website does, and rather than describe that in the abstract, here is the exact list of what runs on cardtray.io and why:

What	Who runs it	What it does	How long it lasts
Google Analytics 4	Google, as our analytics provider	Counts page views and navigation so we can see which pages lead to a download	Per Google's retention settings (Google privacy policy)
Microsoft UET tag	Microsoft Advertising	A conversion-tracking tag — an advertising cookie — that tells Microsoft when a visitor who clicked one of our Microsoft/Bing ads reached the site	Per Microsoft's retention schedule (Microsoft privacy statement)
Microsoft click id (`msclkid`)	Us, first-party	When you arrive from one of our Microsoft ads, the ad's landing URL carries a click id. We store it in your browser (local storage plus a first-party cookie) so a download you make later can be matched back to the ad that produced it	90 days from your most recent ad click, then it expires. A newer click replaces an older one
Google click id (`gclid`)	Us, first-party	When you arrive from one of our Google ads, the ad's landing URL carries a click id. We store it the same way, for the same reason	90 days from your most recent ad click, then it expires. A newer click replaces an older one
Asterra click id (`asterra`)	Us, first-party	When you arrive through one of our Asterra advertising links, the landing URL carries a click id. We store it in your browser (local storage plus a first-party cookie) so that a first launch of the app can be matched back to the link that produced it	30 days from your most recent Asterra click, then it expires. A newer click replaces an older one
Affiliate link parameters (`st_ap`)	Us, first-party	When you arrive through a partner's link marked `?aff=`, we store the partner's name and the other parameters on that link (such as the partner's own click id) in your browser (local storage plus a first-party cookie), so that a later download or install can be reported back to that partner	30 days from your most recent partner-link arrival, then it expires. A newer one replaces an older one
Anonymous install id (`st_iid`)	Us, first-party	A random identifier (a UUID) with no name, email, or device profile attached, used to join "visited the site → downloaded → installed" into one count	The cookie lasts 180 days and is refreshed each time you visit; the copy kept in your browser's local storage stays until you clear this site's data

What we send to the ad platforms, and what we do not. When a download or install happens, our server reports that conversion to Microsoft Advertising and to Google Ads. The Microsoft report contains exactly: the Microsoft click id, the random install id, your browser's user-agent string, the name of the event (for example download, install, or first_open), and a number we assign to weight how meaningful that event is. The Google report contains the Google click id, which conversion it counts as, when it happened, a value, and a transaction id built from the random install id so the same event is never counted twice. Neither contains your IP address, your email address, your phone number, or any hashed version of them. That is not an accident of implementation — we never store a full IP address anywhere in this measurement chain (only a truncated prefix), and we deliberately declined to start collecting any of those in order to improve ad matching.

What we send to Asterra, and what we do not. Some of our advertising runs through Asterra, whose links carry their own click id. If you arrive through one and later install and open the app for the first time, our server tells Asterra so by requesting its conversion address with that click id. The request carries the click id and nothing else: no install id, no IP address of yours, no email address, no device details. A visitor who declined in the cookie notice never has the click id stored or forwarded, so nothing is sent.

What we send to other partners. When a download or install arrives through a partner's ?aff= link, our server reports it back to that partner using the parameters the partner put on its own link, so that partner can count the conversion. It does not add your IP address, your email address or device details. A visitor who declined in the cookie notice never has the parameters stored or forwarded.

This is measurement, not targeting. These identifiers exist to count conversions from ads we already paid for. We do not use them to build advertising audiences, we do not run remarketing or dynamic remarketing, and the consent signal we send Google explicitly withholds permission to personalise ads from these conversions. If we ever adopt any of that, this policy changes before it is switched on, not after.

Your controls. The site and the download work with all of this blocked. Your browser's cookie and tracking-protection settings, or any ad/tracker blocker, will stop the Google and Microsoft tags loading and prevent any click id being stored — nothing on cardtray.io depends on them. You can also use Google's and Microsoft's own opt-outs, linked in their policies above.

The cookie notice. Where consent is required — the EEA, the UK and Switzerland — cardtray.io asks before any of this runs. Until you answer, the Google and Microsoft tags are held in a no-storage mode in which they neither read nor write cookies, and the click ids, partner parameters and install id described above are not stored at all. Choosing Decline keeps it that way, and a download you make afterwards is counted only against the campaign, with no identifier attached and nothing reported to Microsoft Advertising or Google Ads about you. Your answer is remembered in your browser and travels with you; declining here stays in force even if you later visit from elsewhere. You can reopen the notice at any time from Cookie settings in the site footer.

Changing your mind later. If you accepted and then decline — from Cookie settings at any time — we do two things, not one. Your browser's copies of the click ids, the partner parameters, the install id and the stored campaign record are erased, and we also tell our own server to stop reporting you, because a click id recorded while you were consenting would otherwise still be sitting there. From that point no further conversion of yours is sent to Microsoft Advertising or Google Ads. Reports already delivered to those platforms are subject to their retention schedules, not ours.

8. Legal bases for processing (EEA/UK users)

Where the GDPR or UK GDPR applies, we rely on these legal bases:

Legitimate interests - for crash and usage reporting and install and uninstall measurement, to keep the Software secure, stable, and improving, balanced against your privacy (and, for crash reports, usage analytics and the first-launch signal, you can opt out).
Consent - where required, including your acceptance of the bandwidth exchange at install; you may withdraw consent by disabling the relevant option or uninstalling.
Performance of a contract - to provide the Software and deliver updates under the EULA.

9. How information is shared

We share information only as follows:

Service providers (sub-processors): Sentry (crash reporting) and Aptabase (privacy-friendly analytics) process the limited data described above on our behalf.
The Exchange operator: Massive and/or its partners operate the bandwidth-sharing network as an independent data controller, subject to their own terms and privacy practices. Massive is not our service provider or processor for that activity.
Update and website hosting providers deliver updates and run cardtray.io.
Legal and safety: we may disclose information if required by law, or to protect the rights, safety, or property of Clearware, our users, or others.
Business transfers: if Clearware is involved in a merger, acquisition, or asset sale, information may transfer as part of that transaction, subject to this policy.

We do not authorize these providers to use the data for their own unrelated purposes.

10. We do not sell your personal information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA) and similar U.S. state laws. Because the Software is built to avoid collecting personal identifiers in the first place, there is very little personal information involved at all.

11. Data retention

On your device: your games, replays, records, achievements, solver answers and settings remain in CardTray's folder until you delete them. Uninstalling does not delete them - the folder is kept on purpose so that reinstalling picks up where you left off. Deleting CardTray's folder under %APPDATA% removes all of it.
Crash and usage data: retained by our providers, and by Clearware's usage service, for a limited period consistent with diagnosing issues and understanding trends, then deleted or aggregated.
Install-attribution, install and uninstall signals: retained in aggregate/measurement form; the random install id is not linked to your identity.
Microsoft click id (msclkid) and Google click id (gclid): each stored in your browser for 90 days from your most recent ad click, then it expires; a newer click replaces an older one. Where one has been used to report a conversion, the platform's own copy is subject to its retention schedule, not ours.
Asterra click id (asterra): stored in your browser for 30 days from your most recent Asterra click, then it expires; a newer click replaces an older one. Where it has been used to report a first launch, Asterra's own copy is subject to Asterra's retention schedule, not ours.
Affiliate link parameters (st_ap): stored in your browser for 30 days from your most recent partner-link arrival, then they expire; a newer arrival replaces them. Where they have been used to report a conversion, the partner's own copy is subject to its retention schedule, not ours.
Consent withdrawal: if you decline after having accepted, we keep a minimal record that you withdrew — the anonymous install id and the date — because that record is what stops any further conversion being reported for you. It contains nothing else.
Exchange data processed by Massive: governed by Massive's own retention schedule (currently capped at up to 60 days), under Massive's privacy policy.

12. Your privacy rights

Depending on where you live, you may have rights to:

access the personal information we hold about you;
correct inaccurate information;
delete your information;
object to or restrict certain processing, and withdraw consent;
portability of information you provided;
non-discrimination for exercising your rights.

Because CardTray is local-first and largely anonymous, the fastest way to exercise most of these rights is directly in the app - turn off telemetry, turn off bandwidth sharing, delete your local data, or uninstall. To make a formal request, or if you're in the EEA/UK, California, or another region with statutory rights, email [email protected] and we will respond as required by law. You may also have the right to lodge a complaint with your local data-protection authority.

For rights relating to the data Massive processes to operate the Exchange, contact Massive through the privacy policy linked in Section 3.

13. Your choices and controls

You are in control of the optional data flows:

Control	Where	Effect
Crash reporting	Settings → Privacy & diagnostics	Turn off to stop sending any crash reports
Usage analytics	Settings → Privacy & diagnostics	Turn off to stop sending usage events, to Aptabase and to Clearware
Install-attribution	Settings → Privacy & diagnostics (Reinstall / Uninstall analytics)	Turn off to suppress the first-launch signal. It does not stop the installer's and uninstaller's own signals, which run outside the app (Section 4)
Bandwidth sharing on/off	CardTray Settings, CardTray tray menu, or Massive's tray icon	Stops sharing immediately. While off, you cannot start or continue a game; a game in progress is paused and saved, and your saved games, stats and replays stay readable (see EULA Section 4)
End sharing permanently	Uninstall	Uninstalling stops and removes the Massive agent and ends participation

This policy does not claim automatic pausing on metered connections or during active use, and does not claim a bandwidth cap. Those controls are not part of the shipped build. In particular, sharing is not paused while you are playing a game.

14. Security

We design the Software to minimize the data at stake: processing is local, the renderer runs sandboxed and isolated from system APIs, and privileged work is confined to the app's main process behind a typed bridge. Every finished game is checked by replaying its saved moves in the main process before it counts toward your records, so a corrupt save or a display bug cannot write a false result, and the solver runs in a separate background process. CardTray downloads no add-ons, models or helper programs after install; everything it uses is inside the signed installer. No method of transmission or storage is completely secure, but we take reasonable measures to protect the limited information we handle.

15. Children's privacy

CardTray is not directed to children under 13 (or the minimum age required in your jurisdiction), and we do not knowingly collect personal information from them. If you believe a child has provided us personal information, contact [email protected] and we will address it.

16. International data transfers

We are based in the United States, and our service providers may process data in the U.S. and other countries. Where required, we use appropriate safeguards (such as standard contractual clauses) for transfers of personal data out of the EEA, UK, or other regions with transfer restrictions.

17. Changes to this policy

We may update this Privacy Policy to reflect changes to the Software, our practices, or the law. When changes are material, we will update the effective date and provide reasonable notice (for example, in-app or on cardtray.io). Your continued use of the Software after an update takes effect constitutes acceptance of the updated policy.

18. Contact us

Clearware, LLC Email: [email protected] Web: https://cardtray.io

For privacy requests, please put "Privacy Request" in the subject line so we can route it quickly.