The purpose of this statement is to explain to you what personal information we collect and how we may use it.
1. About Us
This website (www.puzzler.com) is owned and operated by Puzzler Media Ltd, a company registered in England no 1136669/England, having its registered offices at Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY.
Puzzler Media Ltd is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the data protection legislation in the UK, including the General Data Protection Regulation 2016 and the Data Protection Act 2018 and we are registered on the Data Protection Public Register number Z5734949.
Unless the context otherwise requires, in this agreement the following expressions shall have the meanings set out below:
"Affiliate" means organisations which we partner, work or associate with;
"Group Companies" or "Group Company" means any and all entities controlling or controlled by or under common control with us.
"Control" means ownership, directly or indirectly, of at least fifty percent (50%) of the voting rights in such entity, and "controlling" and "controlled" shall have the corresponding meaning.
3. The Data Protection Officer (DPO)
Due to the type of data we collect and the nature of our business we currently have no legal requirement to have a DPO at Puzzler Media. However, our information security manager will be happy to deal with any queries or requests regarding the data we hold about you. They can be contacted by email at email@example.com or by post to Information Security Manager, Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY.
4. Information we collect about you and how we use it
– information (such as your name, email address, postal address and telephone number) that you provide by completing forms on the site, including if you register as a user of the site;
– in connection with an account sign-in facility, your username, password and other login details;
– details of any transactions made by you through the site;
– credit card details (such as card type, name on the card, long card number, card expiry date and CV2 number) that you provide to enable you to make purchases from the site and that may be updated by you or via your card issuer from time to time;
– communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the site or its content;
– information from surveys that we may, from time to time, run on the site for research purposes, if you choose to respond to them; and
– details of your visits to the site, the resources you access and any data you download.
We do not collect sensitive information (also known as special categories of information) about you.
We do collect some information from cookies and similar software which allows us to understand how you arrive on our websites, and use and navigate round them so we can improve the sites. We obtain some information from Google Analytics and Facebook. The Facebook information provided is limited and only that which you have previously agreed with Facebook that they can share.
5. What we do with your information
We will use your personal information for a number of purposes including:
– To process your orders and provide our services, goods or online content, to provide you with information about them, and to deal with your requests and queries.
– For administration purposes which means we may contact you for reasons related to goods or services ordered or online content you have signed up for, to let you know that a service or online site has been suspended for maintenance, if your subscription is about to expire to ask if you wish to renew it, or if an online account has become dormant to ask if you wish to retain the account before we close it.
– To provide personalised communications.
– We may show you relevant advertising on third party sites. See section 7 (on marketing).
– We use IP addresses and device identifiers to identify the location of users and to establish the number of visits from different countries.
– For analysis and research to improve our services and goods offered.
– We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
6. What if I don’t provide some or all of the information requested?
The impact of this will depend on what information you withhold but the main impacts may be:
– We may not be able to process or fully process your order.
– We may not be able to contact you to let you know of problems regarding your order or the goods/services provided.
– We may not be able to respond fully to requests and queries you may have.
Withholding marketing consent. You are free to do this at any time. It will only stop you receiving marketing. It will not impact any other service/goods we provide you with.
7. Will you be contacted for marketing purposes?
We use your personal information to update you about new products/services by post, email, telephone and SMS text message. We will only contact you with your consent. You will provide this either when you fill in a form to provide your data, by registering on our website, selecting your preferences in your online account or when you call us.
We may personalise the message content based on information you provide us with, purchases you make and your use of Puzzler Media’s website. You are entitled to withhold this consent and opt out from receiving such communications at any time by not giving your consent on the form (paper or web) that collects your details or telling the operator when you call. You can amend your preferences at any time: in your account area at puzzler.com; by telephone to Customer Services, 0800 904 7018; by email, firstname.lastname@example.org; by post to Information Security Manager, Puzzler Media Ltd, Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY. We will always provide you with a way of opting out of receiving future marketing messages from us, each time we send them to you.
8. What grounds (legal basis) are we processing the data under?
There are a number of grounds we process your data under. These are:
– Contractual: we need the information to perform the contract for goods or services you have requested/ordered including payment, delivery etc.
– Legal: should we be legally required to contact you concerning a product, eg a product recall.
– Legitimate interest: this means the processing is in Puzzler Media’s interest. It allows us to manage the customer relationship effectively and efficiently and improve the goods and/or services we provide by better understanding how our services are used and which goods are popular with which groups of individuals.
– Consent: where you have given us consent to market to you.
9. My Account – online account on puzzler.com
This account area allows you to manage your personal information, update your marketing communication preferences, view your online order history, view competition entries made online in the last three months, view and renew your subscriptions, edit or delete addresses within your online Address Book, and update your email and password.
10. Sharing your information with third parties
We may from time to time provide your personal information to third parties for the purposes of providing you with our goods and services. These third party providers include payment processors, providers of card validation services, credit referencing providers, third party sales processor (includes fulfilment services), service providers who assist us with hosting our marketing campaigns, and competition prize suppliers. They do not decide what is done with your data and only process it on our behalf. These third parties may be located outside the European Economic Area; however we only use providers that provide adequate protection for your information at all times.
When transferring any personal information outwith the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
– The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
– The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
– Binding corporate rules: this is where a large company’s own internal processes for international data transfer have been signed off and agreed by the European Commission as safeguarding the data.
– If the data is going to the USA it can be safely transferred to a company that is certified under the EU-US Privacy Shield.
– Appropriate certification schemes.
We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us. You are entitled to withhold this consent and opt out from receiving such third party communications at any time by not giving your consent on the form (paper or web) that collects your details or telling the operator when you call. You can also update these options by logging into your account and adjusting your preferences, contacting us by email at email@example.com or by post to Information Security Manager, Puzzler Media Ltd, Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY.
11. Cookies (and web browser information)
If your settings are set to 'do not track' in your browser then we will not collect analytics data.
12. What if I am aged under 18?
If you are aged 18 or under, please get your parent/guardian's permission before you provide any personal information to Puzzler Media Ltd.
13. How we protect your information
We follow strict security procedures in the storage, use and disclosure of information which you have given us, to prevent unauthorised access to, and loss, misuse or alteration of, your personal information in accordance with the UK data protection legislation. These include access control, firewalls and virus-checking procedures.
You are responsible for keeping any confidential passwords or other login or access details which you select or which we allocate to you secret. Whilst we take steps to ensure the security of your information, there is a risk that any information transmitted over the internet and stored on a computer may be intercepted or accessed by an unauthorised party. If you think that someone has accessed your information held by us without your permission or gained unauthorised access to your login details, you must notify us at firstname.lastname@example.org.
We also recommend that if you use a shared computer or a computer in a public place such as a library that you close your browser when you have finished your session.
14. How long we hold your data for
Some of the information you provide to us is necessary to carry out repeated tasks, such as verifying your identity when signing in to use an account or providing our goods and services to you or you using an online checkout. We will keep this information for as long as you remain a registered user of our sites or an active customer plus a reasonable time, three years beyond this to deal with queries or issues.
Some information may be required for longer periods such as financial information for HMRC purposes, usually a maximum of seven years.
Puzzler Media do not retain your payment card information. It is keyed directly into the payment processor’s system when you provide it.
We may retain anonymised information for analytical purposes.
15. Your rights regarding your personal information
Under the data protection law you have a number of rights with respect to your personal information which are:
Correcting your information
You are entitled to have your personal information updated to ensure it is up-to-date and accurate. This can be done by following the instructions below.
You have the right to withdraw your consent to any processing that is currently being done under your consent eg marketing. Consent can be withdrawn for some processing by updating your preferences in your online account. You can also follow the process below.
Obtaining a copy of your information
You are entitled to receive a copy of the personal information we hold about you.
Deleting your information
You can request that we delete personal information in certain circumstances. These will be specific to each case.
You are entitled to have us transfer to another controller the personal information that you have provided us with.
You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we no longer require to hold your data but you have requested its retention by us to aid you in a legal matter.
Right to object to processing
You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc (also known as profiling).
You can action any of these rights by contacting our Customer Services department or by contacting us by email at email@example.com or by post to Information Security Manager, Puzzler Media Ltd, Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY.
16. Sale of the business
Should all or part of the Puzzler Media business be sold to or taken over by another organisation, your personal information may move to that other organisation as part of the sale or takeover agreement.
17. Right of complaint to the Regulator for Data Protection
The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via:
– The ICO’s website (ico.org.uk/concerns): follow the links or have an online Live Chat.
– Call the ICO helpline on 0303 123 1113.
– Email firstname.lastname@example.org.
– Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
18. Links to third party websites
19. Updates to this policy
We may update this policy at any time without notice. We will tell you that we have updated the policy by emailing you at the email address you have provided to us and/or by posting an announcement on the website. By continuing to use the website after we have emailed you or posted a notice informing you of an update, you accept the changes to this policy.
20. Contacting us
If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us using email@example.com or by post to Information Security Manager, Puzzler Media Ltd, Stonecroft, 69 Station Rd, Redhill, Surrey, RH1 1EY.
Privacy statement updated 22 May 2018