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We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we may be subject to various laws in the United States and/or the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and, if applicable, we are responsible as “controller” of that personal information for the purposes of those laws.

  1. Who We Are. For purposes of this policy, the terms “we”, “us” or “our” refers to MyPuzzle LLC, an Indiana limited liability company located at 4775 Dale Drive, Lafayette, IN 47904. Our telephone number is (765) 588 9140. Email: support@mypuzzle.com
  2. Personal Information We Collect. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
  • Geolocation data

This personal information is required to provide our products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing our products and services to you.

  1. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email. However, we may also collect information:
  • From publicly accessible sources (e.g., property records);
  • Directly from a third party;
  • From cookies on the Site including third-party cookies and plugins;
  • From Borlabs Cookie;
  • From Google and its affiliates including YouTube, Google Maps, Google ReCAPTCHA, Google Analytics, Google Analytics Remarketing in combination with the functions of Google Ads and Google DoubleClick, which work on all devices;
  • From Facebook Pixel;
  • From Adobe Systems Incorporated; and
  • From other third parties, with your consent.

To learn more information about your privacy with respect to any third parties, please visit the following sites:

 

Additional Information About Cookies

We use “cookies” on the Site. Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or when they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

We use cookies for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website. We have a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the Site. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained and this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Privacy Policy and, if applicable, ask for your consent.

  1. How and Why We Use Your Personal Information. Under applicable data protection laws, we can only use your personal information if we have a proper reason for doing so. For example, we may use your personal information for the following purposes:
  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for

Our reasons

To provide products and services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, to minimize fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity

 

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, including policies covering security and internet use

For our legitimate interests or those of a third party, including to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests and to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests related to protecting trade secrets and other commercially valuable information

 

Statistical analysis to help us manage our business

To be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

To prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and creating customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

To make sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

 

Marketing our services to:

¾   existing and former customers;

¾   third parties who have previously expressed an interest in our services;

¾   third parties with whom we have had no previous dealings.

To promote our business to existing and former customers

 

  1. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at support@mypuzzle.com; or
  • Using the “unsubscribe” link in emails or “STOP” number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

  1. Persons With Whom We Share Your Personal Information. We routinely share personal information with:
  • Our affiliates, including companies and affiliates within our group of businesses;
  • Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts; and
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

  1. Sale of Personal Information. In the preceding 12 months, we have not sold personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  2. Where Your Personal Information is Held. Information may be held at our offices and those of our affiliates, third-party agencies, service providers, representatives and agents as described above (see above: “Persons With Whom We Share Your Personal Information”).

If your use is subject to the GDPR, please note that some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

  1. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

  1. Transferring Your Personal Information Out of the EEA. If your use of the Site is subject to the GDPR, note that it is sometimes necessary for us to receive or share your personal information outside the European Economic Area (EEA), e.g.:
  • With our offices outside the EEA;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or
  • Where there is an international dimension to the services we are providing to you.

If applicable, these transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information, please contact us (see “How To Contact Us” below).

  1. Rights of Users Subject to the GDPR. To the extent applicable, this section governs your rights under the GDPR.

 

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

•   at any time to your personal information being processed for direct marketing (including profiling);

•   in certain other situations to our continued processing of your personal information, including processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information on each of those rights, including the circumstances in which they apply, please review the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

  1. Your Rights Under the CCPA. If applicable, you may have rights under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

Disclosure of Personal Information We Collect About You

You have the right to know:

·      The categories of personal information we have collected about you;

·      The categories of sources from which the personal information is collected;

·      Our business or commercial purpose for collecting or selling personal information;

·      The categories of third parties with whom we share personal information, if any; and

·      The specific pieces of personal information we have collected about you.

·      Please note that we are not required to:

·      Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

·      Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

·      Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, please contact us.

 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

·      Delete your personal information from our records; and

·      Direct any service providers to delete your personal information from their records.

·      Please note that we may not delete your personal information if it is necessary to:

·      Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

·      Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

·      Debug to identify and repair errors that impair existing intended functionality;

·      Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

·      Comply with the California Electronic Communications Privacy Act;

·      Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

·      Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

·      Comply with an existing legal obligation; or

·      Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

·      Deny goods or services to you;

·      Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

·      Provide a different level or quality of goods or services to you; or

·      Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

 

  1. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
  2. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:
  • Complete a data subject request form available on our website at www.mypuzzle.com;
  • Call us, toll-free, at (765) 588 9140; or
  • Email us at support@mypuzzle.com.

Please note that, if applicable, you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email, you will need to provide us with:

  • Enough information to identify you;
  • Proof of your identity and address; and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

  1. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

When applicable, the General Data Protection Regulation also gives certain persons a right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

  1. Changes to This Privacy Notice. This privacy notice was published on 08/31/2021 and last updated on 08/31/2021.

We may change this privacy notice from time to time–when we do, we will inform you via email.

  1. How to Contact Us. Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

MyPuzzle, LLC

Attn: Data Privacy Department

4775 Dale Drive, Lafayette, IN 47905

Phone: (765) 588 9140

E-mail: support@mypuzzle.com

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