Effective Date: March 1, 2020
If you have any questions or concerns about our information practices, please contact us at email@example.com.
2. Information We Collect
Most of the Personal Information we collect is from our customers. This information falls into two (2) general categories:
Passive Data Collection. This refers to data automatically collected from customers when they visit the Website or use the Services.
User-Submitted Information. This refers to information that customers actively submit to us, which may be provided voluntarily or as required to use our Services.
Customers also sometimes provide us with information about other individuals, such as when a customer sends a gift membership or uses our referral services to tell a friend about us. In those cases, we may ask that customer to provide the recipient’s name and email address. (We may also collect Personal Information in any personalized message that is submitted with a gift membership or referral.) We will automatically send the recipient email correspondence with the gift membership or referral, and invite them to visit the Website or otherwise use the Services. If we receive Personal Information for a referral or gift card, we use that information for the sole purpose of sending this email correspondence, and for tracking the use of the gift membership or the success of our referral program.
Passive Data Collection
As a general matter, we automatically collect certain information based on your use of and behavior on the Website and in connection with the Services. We use this information to analyze our customers’ demographics, interests, and behavior to better understand and serve you and our customer base. We also analyze this information for security purposes, to protect the Services and customer information that we hold.
We collect passive data in the following ways:
Like most websites, we automatically receive and record certain information about our customers’ behavior on our Website or App and when using our Services. Our servers automatically gather technical information about our Website or App traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and other clickstream data. We aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, for example to understand customers’ use of the Website and to make inventory and purchasing decisions that will best serve our customer base. Information from log files may also be used to determine general location information such as city, state or geographic area.
Cookies, Web Beacons and Similar Technologies
A cookie is a small text file that is stored on a computer for record-keeping or tracking purposes. Web beacons (also known as pixel tags or clear GIFs), are graphics that can record whether a person has accessed particular content. We use these and other similar technologies on the Website and App and in connection with our Services.
Essential cookies. Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies may make certain features and services unavailable.
Functional cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/analytical cookies. Performance/analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
To find out more information about cookies, including information about how to manage and delete cookies, please visit https://www.allaboutcookies.org/.
We may use web beacons or similar technologies, which help manage content on the Website and in the Services by tracking what content is effective. These technologies may be used to track the online movements of customers, but in contrast to cookies, which are stored on a computer hard drive, these technologies are embedded in the Website or App.
We may also use web beacons in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Third Party Advertisers
As a general matter, we may ask you for information, or retain information, that you provide to us in order to provide our Services to you, and to better serve you and our customer base. This category of information includes information submitted electronically, via phone, and in person through our stores. We may also combine this information with Personal Information to provide you with customized and personalized Services.
We collect User-Submitted Information in the following ways:
In order to use some features of the Website, App and Services, including the rental of Completing the Puzzle’s inventory, you must first create an account with us and agree to the Terms of Service. To create an account, you must provide an email address and create a password. We may also ask you for your birthday. We use the email address you provide to contact you about the products and Services, and to begin to create a tailored experience for you.
If you order a product from us, we request certain Personal Information from you. You must provide contact information (including name, shipping address, telephone number) and a payment method. We use this information for billing purposes, to fill your orders and to communicate with you about your orders. If we have trouble processing an order, we will use this information to contact you.
We record what you order and associate it with your account profile. When you return an item, we may ask you for information about your experience, such as the difficulty of the puzzle and how long it took you to complete. We record that information to better personalize our Services for you and to improve our Services for others.
Surveys or Contests
We may provide you the opportunity to participate in surveys or contests on our Website or in connection with our Services. If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and email address) and demographic information.
We may use this information to notify contest winners and to award prizes, to monitor traffic to our Services, to improve the Services, and to send participants an email newsletter.
Additional information practices (and terms and conditions) may apply to any survey or contest, which will be made available with the survey or contest. Please carefully review any additional information provided.
Public Feedback and Discussion Boards
If you choose to post messages to public message areas or leave feedback for others, that information may become available to anyone. We are not responsible for the use by others of the information you publicly disclose. Additionally, we may, but are not obligated to, collect the information you post in public message areas to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
Please be careful and closely consider disclosing any Personal Information in public message areas.
3. How We Use Your Information
In addition, we may use aggregate, statistical, and deidentified data, which does not specifically identify any individuals, for any purpose.
General Uses of Your Information
We generally use the information we collect, including Personal Information about you, for the following purposes:
To Provide Our Services. We use your Personal Information to provide our Services to you, including:
- To present you with products, information and content through the Services, including personalization of the Services;
- To process transactions, including financial transactions, related to your use of the Services;
- To assist you in finding a location to return an item; and
- To respond to your questions or requests.
For Communications and Marketing. We use your Personal Information to communicate with you and provide you with information about Completing the Puzzle and our marketing partners.
To Develop and Improve Our Services. We may also use your Personal Information as we work to continually improve our Services, our business and our operations. For example, by:
- Analyzing usage or interest in certain features, or identifying items and areas of interest to our customers.
For Compliance, Fraud Prevention and Safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to:
- Protect our, your or others’ rights, privacy, safety or property;
- Enforce the terms and conditions that govern use of our Services, including for legal claims; and
- To prevent, identify, investigate and deter any fraudulent, harmful, unauthorized or illegal activity.
To Comply with Law. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process.
As Described or with Your Consent. We may use your Personal Information for any other purposes that we describe at the time we collect your Personal Information, or otherwise with your consent.
Communications from Us
We use your contact information to communicate with you about Completing the Puzzle and our marketing partners in the following ways:
- To provide newsletters, marketing emails or push notifications with special promotional offers, updates and other relevant marketing content;
- To provide announcements about the Services;
- To communicate with you about the Services and your account, including updates about the status of your orders; and
- To verify your identity and address for your orders and rentals.
We may communicate with you via phone, email, and text messages. Standard call, message and data rates charged by your mobile carrier may apply to text messages or other communications received on your mobile device.
4. How We Disclose Your Information
We may disclose aggregate, statistical, and deidentified data, which does not specifically identify any individuals, for any purpose.
We may also share Personal Information about you, in general:
- As necessary to provide the Services;
- With service providers;
- With our corporate affiliates and business partners; and
- For legal reasons or as required by law.
The purposes and ways that we may share Personal Information about you are described below in more detail.
Completing the Puzzle Partners
Completing the Puzzle engages in marketing and promotional activities with carefully screened brands, or, “Partners,” which we think will appeal to our customer base. From time to time, Partners may also be provided with non-personally-identifying or aggregate information demographic information of customers on our Services and statistical information about buying behavior, and Partners may be given opportunities to market to select segments of our customer base indirectly. When we share aggregate or non-personally identifiable customer data, we do so in a way that we believe cannot reasonably be linked with a customer’s Personal Information.
Corporate Affiliate Parties
As Required by Law
We may disclose Personal Information if we have a good-faith belief that doing so is required under applicable law, for example if we receive a subpoena or other judicial or administrative order or otherwise required by law. This may include responding to legal requests from jurisdictions outside of the United States, where we have a good faith belief that the response is required by law in that jurisdiction.
In Connection with Business Transactions
We may disclose Personal Information in certain corporate transactions, such as in connection with an actual or proposed merger, acquisition, or other sale of or transfer of all or part of our business or assets, including as part of a bankruptcy, liquidation, or other insolvency proceeding.
In the event of a change in ownership of Completing the Puzzle, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all of your Personal Information, including email addresses and other information about you collected by us (in accordance with this policy), to that entity.
To Protect Rights
Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Service or our other agreements; take precautions against liability; protect the rights, property, or safety of Completing the Puzzle, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
5. Third Party Websites
6. Your Choices
Accessing and Requesting Changes to Your Personal Information
If you are a customer of Completing the Puzzle, you may review and change your Personal Information through your customer account.
If you do not have a customer account with Completing the Puzzle, or if you cannot access or change any of your Personal Information through your account, but you still wish to inquire about, access, correct, update or delete Personal Information that we may hold about you, please email us at firstname.lastname@example.org. Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity.
Please also understand that we may not be obligated or able to alter or delete your Personal Information and may retain information to provide you with requested services or fulfill obligations to you, for security reasons, if we are required under applicable law or regulations, for internal business use or for other valid reasons. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual. In some circumstances, we may charge a reasonable fee to fulfill your request.
If you would like to change the types of communications you receive from us or how you receive communications from us, or if you would like to opt out of promotional communications, you may do so at any time by updating the communication preferences provided in your customer account.
If you do not have a customer account, you may also use the unsubscribe links and instructions that will be present in any promotional emails or other communications that we send.
Please understand that, even if you opt out of marketing or promotional communications, we may continue to send non-promotional communications such as confirmations of transactions, changes to the Services or other information about your use of the Services.
“Do Not Track” Settings
Our Website and Services are not at this time configured to read or respond to “do not track” settings or signals in your browser headings.
Tailored Advertisements and Passive Data Collection
To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at https://www.networkadvertising.org/choices/, https://optout.networkadvertising.org/ or https://www.aboutads.info/choices/.
We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it.
Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic data storage is 100% secure, and we cannot guarantee that the information will remain free from unauthorized access, use, disclosure, or alteration. While we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent hackers or other unauthorized persons from illegally accessing or obtaining this information.
8. Children’s Privacy
Completing the Puzzle and the Services are not intended for or directed toward children under 13 years of age, and children should not use the Services for any purpose unless they have the consent of, and are under the supervision of, a parent or guardian. We ask that individuals do not provide Personal Information through our Website or Services, and if we learn that we have collected or received Personal Information from a child under 13 years of age, we will delete that information
Additionally, we may collect Personal Information from teenagers between the ages of 13 and 18, but only if such an individual is of legal age to enter into a binding contract under applicable law, or with the consent and supervision of a parent or legal guardians, as permitted by law.
If you are the parent or legal guardian of a child under 13 years of age who has registered on the Website or App or you believe has otherwise provided Personal Information to Completing the Puzzle, please contact Completing the Puzzle at email@example.com to have the account terminated and information deleted.
If you believe that we may have inadvertently collected any Personal Information about a child aged 13 years or younger, please contact us at firstname.lastname@example.org or as provided in the “Contact Us” section below.
9. Notices to California Residents
If you are a resident of the state of California, California’s “Shine the Light” law permits you to request information regarding the disclosure of your Personal Information by us to a third party for the third party's direct marketing purposes. To make such a request, please send an email to email@example.com
California Residents’ Rights under the CCPA. Under the CCPA, California residents have certain rights regarding their Personal Information. Subject to certain exceptions, California residents have or may exercise the following rights:
Right to Know about Personal Information Collected, Disclosed or Sold. A California resident has the right to be informed about the information practices of a business, and the specific pieces of Personal Information that a business holds about that resident.
Right to Request Deletion of Personal Information. A California resident may request that a business delete their Personal Information.
Right to Opt-Out of the Sale of Personal Information. A California resident has the right to opt-out of the sale of their Personal Information by a business.
Right to Non-Discrimination for Exercise of Consumer Privacy Rights. A California resident has the right not to receive discriminatory treatment by a business for the exercise of privacy rights provided by the CCPA.
To submit requests to Completing the Puzzle to exercise these rights, California residents may email a request to firstname.lastname@example.org.
Please understand that we are only obligated to respond to verifiable consumer requests. If we receive a request for information about you, we need to know that it is actually coming from you, or somebody legally authorized to act for you.
We may implement authentication procedures that are appropriate to the nature of the personal information requested. We may also use any information that we have already collected about you in order to verify your request. Also, if we collect any personal information to verify your request, we will only use that information to verify your request.
Please remember that we are only obligated to respond to a request for access twice within a 12-month period.
11. Contact Us
2901 Barton Skyway #1002 Austin, Texas 78746
Attn: Legal Department