Privacy Policy

This policy describes how Puzzle Pack Studio (“we”, “us”), the operator of Puzzle Pack Studio at puzzlepackstudio.com (the “Service”), collects, uses, discloses and retains personal data. It forms part of our Terms of Service.

1. Data we collect

• Email address. Collected at registration and used to authenticate the account. Where a third-party identity provider is used to sign in, we receive the email address, name and profile image associated with that provider account, and retain the email address.
• Subscription data. The plan applicable to the account and, where a subscription exists, the identifiers assigned by our payment processor to the customer and subscription records, the status of that subscription, its billing interval, and the date on which the current period ends.
• Usage records. For each file generated: the date and time, and the number of puzzles contained. These records are the basis on which plan limits are applied.
• Saved configurations. Where a user elects to save layout and typography settings, those settings and the name assigned to them.
• Aggregate page view data. For each page viewed: the date and time, the address of the page, the referring address, the approximate location derived from the network connection (country, region and city), and the operating system, browser and device type reported by the browser. This data is not associated with an account and is described further in section 5.

2. Data we do not collect or retain

• Generated files. PDF output is generated in memory in response to a request, transmitted to the requesting browser, and not written to persistent storage.
• Word lists. Word lists submitted by a user are processed for the duration of the request and are not retained.
• Payment card data. Payment is completed on infrastructure operated by our payment processor. Card details are not transmitted to, received by, or accessible to us.
• Passwords. The Service does not use passwords.

3. Purposes and legal basis

Email address and subscription data are processed in order to provide the Service requested, and usage records in order to apply the limits applicable to the relevant plan. In each case the processing is necessary for performance of the contract between you and us, and none of it is optional to the operation of the Service.

Aggregate page view data is processed in our legitimate interest in understanding how the Service is used and how it may be improved. That interest is not overridden by the interests or rights of visitors, because the data is not associated with any account, carries no persistent identifier, and cannot be used to identify an individual, as described in section 5.

We do not rely on consent as a basis for any processing described in this policy.

4. Disclosure to third parties

Personal data is disclosed only to service providers engaged in the operation of the Service, and only to the extent required for the function each performs. These comprise:

• hosting and database providers, which store account data and operate the Service;
• our payment processor, which processes payments and holds billing and card data not held by us;
• our email delivery provider, which transmits authentication messages;
• a third-party identity provider, where and only where a user elects to authenticate using that provider;
• our hosting provider’s analytics service, which records the aggregate page view data described in section 5.

We do not sell personal data, do not disclose it for advertising purposes, and operate no advertising tracking on the Service. The identity of the specific providers engaged is available on request to hello@puzzlepackstudio.com.

We may disclose personal data where required to do so by law or by binding order of a competent authority.

5. Analytics and cookies

We record aggregate page view statistics in order to understand how the Service is used. The analytics service we use for this purpose does not set cookies and does not assign persistent identifiers. Repeat visits within a single day are counted using a hash derived from the incoming request, which is discarded after 24 hours and is not stored against any record. It is not possible for us, or for the provider, to reconstruct an individual’s browsing activity, to identify an individual from this data, or to follow a visitor to any other website.

No page of the Service includes personal data in its address, so no personal data is transmitted to the analytics service by way of the recorded page address.

Cookies are set for the sole purpose of maintaining an authenticated session. Additional cookies may be set by our payment processor on its own checkout pages for fraud prevention purposes. No advertising or analytics cookies are used, and no consent banner is therefore presented.

6. Retention

Account data and usage records are retained for the lifetime of the account. Transaction records are retained by our payment processor for the period required by applicable tax and accounting law, which is typically several years and is not within our control to shorten. Aggregate page view data is retained by the analytics provider in aggregate form; the identifier used to count repeat visits is discarded after 24 hours.

7. International transfers

We are established in the United States and the service providers referred to in section 4 operate in the United States or globally. Personal data of users outside the United States is therefore transferred to and processed in the United States.

8. Your rights

You may request access to the personal data we hold about you, request its correction, or request its erasure together with deletion of your account, by email to hello@puzzlepackstudio.com. Deletion of an account removes the account record, associated usage records and any saved configurations. Files previously downloaded reside on the user’s own device and are not within our control.

Depending on your place of residence you may hold additional rights, including rights to object to or restrict processing, to data portability, and to lodge a complaint with a supervisory authority. No adverse consequence follows from exercising any such right.

9. Children

The Service is intended for use by adults. Material generated using the Service is frequently intended for children, but the account holder must be an adult. We do not knowingly collect personal data from children under 13.

10. Amendment

This policy may be amended from time to time. Where an amendment materially affects the processing of your personal data, notice will be given by email to subscribers before it takes effect. The date shown at the head of this page indicates the version in force.

11. Contact and identity of the controller

The controller in respect of personal data processed through the Service is Puzzle Pack Studio, established in the United States, contactable at hello@puzzlepackstudio.com. See also our Terms of Service and Refund Policy.