Puzzable – Privacy Statement
We are Brainwave Games LLC (“Puzzable”, “we”, “us” and “our”). We provide a service for the creation, sharing and playing of puzzles made from photographs, artwork and other images (the “Services”) through our website at Puzzable.org (the “Site”), mobile applications (the “Software”), electronic mail, texts, and other forms of electronic communications.
Each person or entity who uses our Services is referred to as a “user” or “you” or “your”. If you subscribe to any of our Services, we will refer to you as a “registered user”. If you don’t register with us, we will refer to you as an “unregistered user”.
This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, personal health information, personal financial information, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Data.
Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data includes information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).
Among other services, Puzzable connects users with other companies in the industry (collectively, “Partners”). This Privacy Statement does not apply to any Partners or to any other websites, mobile applications, individuals, businesses or organizations. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services.
By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Data, as described in this Privacy Statement.
- Information We Collect
As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Data that we use to contact you and our Partners, and which is necessary to provide the Services. Other Content we collect from you includes Behavioral Data and other Non-Personal Data that we aggregate, share, and use to improve our Services, the services of our Partners, and others in the industry.
We collect many different types of information from you, both directly and indirectly.
Information you provide us directly
- Registration information. When you create or modify an account, or subscribe to our Services, you provide Personal Data to us, such as your user name, age or age-range (to confirm the user as an adult), password, telephone number (for SMS/texts and phone calls), postal address and email address.
- Payment information. We use a third-party payment processor (“Processor”) to process your payments, so we do not store your credit card numbers or other payment information. Please note that our Processor does store and process your credit card numbers and other payment information in accordance with the Processor’s privacy policies and privacy statement, and subject to applicable law.
- Profile information. You may provide us with additional profile information that you choose to make public or share with other users. You may also provide information to customize your account, such as a telephone number for the delivery of short message system (“SMS”) or text messages. Each individual user may connect with other users and third parties to share their puzzles and other Personal Data and Content. Similarly, Partners and other third parties may provide their Personal Data and Content to the Services to attract and communicate with users, share puzzles and other Content. We may use your contact information and other Personal Data to send you information about our Services, or to market to you. You may use your account settings to customize notifications from us. If you email us, we may keep your message, email address and contact information to respond to your request.
- Location Information. We may ask for your postal address or your geographic location information, especially if you place an order for Services with us. When you post User Content to our website or to social media, you may provide your location information, including global positioning system (“GPS”) data or other location information embedded in or accompanying the User Content (e.g., in tags or captions) or embedded in the User Content.
- Communications between you and Puzzable. We may send you emails, SMS or text messages, and other electronic communications for sales and delivery, account verification, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.
Information we gather from your use of our Services
- We collect and may save private emails sent to us by users, and we may share your emails with any third parties or other users. Any public posts on Services may be viewed by any user and is public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit to any public forums is not confidential or private, and Puzzable does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users and by other third parties, and could be used to send you unsolicited messages and for other purposes.
- We use third-party analytics tools (currently, Google Analytics) to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user.
- Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. Puzzable may collect and store metadata, including about each user’s public posts on the Services.
- Puzzable may keep track of how you interact with links across our Services, including our email notifications and third-party Services by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant local data, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
- Device Identifiers. We may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your computer, phone or other device, which uniquely identifies your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Puzzable. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports or personalized Content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
- Log Data. Our servers automatically record information (“log data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. Puzzable uses log data to review how we provide our Services and to measure, customize, and improve the Services.
- How We Store Your Information
- We currently provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers located inside the United States.
- In the future, we may store Personal Data and other User Content on servers located outside the United States.
- Certain types of User Content you submit to us might reveal your gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data or sensitive information about you or others.
- By using our Services, or by submitting your Personal Data to us, you consent to the collection, storage, processing and onward transfer of your Personal Data as stated in the current version of this Privacy Statement and the current version of our other online documents, including the Terms of Service.
- How We Use Your Information
We share and use your Personal Data in the following circumstances:
- Opt-in with Your Consent. We may ask for your permission to share your Personal Data with other people and organizations outside of Puzzable, including to help conduct studies or provide you with other services. As with any opt-in procedure, you are under no duty to agree to a request that you opt-in.
- Partners and Affiliates of Puzzable. We may share your Personal Data with Partners and with our Puzzable affiliates (meaning entities controlled by, controlling or under common control with Puzzable) as necessary to sell and provide the Services. However, any Personal Data stored in one country or jurisdiction would not be forwarded to another country or jurisdiction, except in compliance with applicable laws and regulations.
- Opt-out Email or Postal Address. If you supply us with your postal or email address you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not want to receive such mailings, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes.
- Service Providers. We employ third party companies and individuals to facilitate our Services (e.g., payment processing, maintenance, analysis, audit, marketing and development). These third parties may have limited access to your Personal Data only to perform these tasks on our behalf and are obligated to Puzzable not to disclose or use your Personal Data for other purposes.
- Required by Law. We may access, preserve and share your Personal Data in response to a legal request (such as a search warrant, court order or subpoena). We may also access, preserve and share Personal Data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
- National Security and Intelligence Activities. We may release your Personal Data to authorized federal officials for intelligence, counterintelligence and other national security activities when required by law. For example, under current law in the United States, certain federal officials may require that we provide Personal Data and other Content in response to a national security letter, subpoena, demand, or court order. In some cases, we would be required not to tell you that we complied with that letter, subpoena, demand, or court order. Where permitted by applicable law, we reserve the right to comply with, or to fight or quash, any such letter, subpoena, demand, or court order.
- Change of Control. If we sell or otherwise transfer part or the whole of Puzzable or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or transferred. You will continue to own your User Content, but the license you grant to us in the Terms may be transferred to others.
- Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.
- In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that we receive to:
- help you efficiently access your information after you sign in.
- remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
- provide personalized Content and information to you and others, which, in the future, could include online ads or other forms of marketing.
- provide, improve, test, and monitor the effectiveness of our Services.
- develop and test new products and features.
- monitor metrics such as total number of visitors, traffic, and demographic patterns.
- diagnose or fix technology problems.
- Your Right to Review, Request Changes, and Disclose Personal Data
Subject to applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Data as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by Puzzable, and we will comply with the outcome of the review.
Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.
Any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Data or your User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data or your User Content with other people, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.
Our Services are not directed to persons under age 13. If you are the parent or guardian of a person under 18, and you become aware that your young person has provided us with Personal Data or User Content without your express consent, please contact us at Info@Puzzable.org and we will remove the information or User Content, and we will terminate the young person’s account. You may then establish an account that you manage for your child or guardian.
- Changes to this Privacy Statement
We may modify our Privacy Statement from time to time on prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective when posted on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us.
- Different Locations, Different Laws
The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:
- Location or residence of the user.
- Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
- Location or residence of the person or organization that employs or contracts with the Data Subject.
- Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to.
- Location of the relevant office of Puzzable.
Several of the Laws that concern unregistered users, registered users, and Puzzable are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.
7.1 United States Federal Laws
Several of the federal Laws in the United States may apply to the Personal Data collected by us.
Currently, all Personal Data of users resident in the United States is stored on servers and other machines physically located within the United States.
7.1.1 Health Insurance Portability and Accountability Act (“HIPAA”)
Currently, HIPAA does not apply to the Services as we are neither a covered entity nor a business associate (as those terms are used in HIPAA).
7.1.2 Children’s Online Privacy Protection Act (“COPPA”)
Currently, COPPA does not apply to the Services. Each registered user and other user must be 13 years of age or older. As noted in this Privacy Statement, if we learn of any registered user is under the age of 18, or if any parent or guardian of a user under the age of 18 contacts us, we will close that user’s account and remove all information provided by the individual from our Services.
7.2 State Laws in the United States
Individual states in the United States have passed and enforce information privacy and security laws.
– 7.2.1 Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to Info@Puzzable.org, or send us postal mail at:
Attn: Privacy, Brainwave Games LLC, 8302 Old York Road, Suite C200, Elkins Park, PA 19027, USA.
Pursuant to California Civil Code Section 1798.83(c)(2), we do not currently share users’ Personal Data with affiliate companies or others outside Puzzable for those parties’ direct marketing use, unless a user elects that we do so.
If you are a California resident under the age of 18, and a subscriber of any site where this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to Info@Puzzable.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.
By submitting any Personal Data or other User Content to us, or placing any order with us, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us in the United States.
- Use of Email Addresses and Other Contact Information
We collect the email addresses of those who voluntarily provide them to us, including unregistered users and registered users. You may receive subscription, editorial and other messages from the Services or from us. If you do not want to receive email from us in the future, please let us know at Info@Puzzable.org .
- Contact Us
If you have questions or concerns about this Privacy Statement, please contact us online at Info@Puzzable.org, or by postal mail addressed to:
Attn: Privacy, Brainwave Games LLC, 8302 Old York Road, Suite C200, Elkins Park, PA 19027, USA.
- Revision Date and History
These Terms were last revised: July 18, 2018.
Prior versions of this Privacy Statement are listed below: