This Privacy Statement describes how PuzzleData and its affiliates (hereinafter “PuzzleData,” “we,” or “us”) collect and process personal data. It applies if you:

(a) use PuzzleData’s websites;
(b) communicate with PuzzleData (for example, by e-mail or phone);
(c) access PuzzleData’s cloud products or services as an authorized employee of a PuzzleData customer;
(d) participate in PuzzleData’s forums, portals and other events or
(e) are another data subject from whom PuzzleData receives personal data.

This Privacy Statement only applies when PuzzleData processes personal data in its role as a data controller. It does not apply if PuzzleData processes personal data as a processor.

1. Which types of personal data does PuzzleData process?

PuzzleData collects personal data directly from you, your contacts and public sources.

Customers and suppliers may provide personal data to PuzzleData. In this case, the customer or supplier ensures that the personal data is transferred to PuzzleData in accordance with applicable data protection law.
Below you will find a list of the categories of personal data which PuzzleData may collect and process:

(a) Computer Internet Protocol (IP) address, date and time of use, operating system and information on the Internet browser used including installed add-ons, internet address of the website from which the online offer was accessed (so-called origin or referrer URL) (“device data”);
(b) Name, e-mail, telephone & fax number, employer, business address, profession, gender, contact details (“business data”);
(c) Name, username, passwords (“account login data”);
(d) Personal data of employees and other contacts of customers, billing details (“customer data”);
(e) Event registrations and participation, user behavior, service requests, downloads (“marketing data”);
(f) Communication data, documents and materials exchanged in the course of conducting customer business (“conduct data”);
(g) Passports or other identification documents, date of birth (“verification data”).

2. For which purposes do we process data and on what legal basis?

PuzzleData processes personal data for the following purposes and on the following legal bases:

(a) In order to provide services, equipment, business, account login, customer data are necessary to fulfill the contracts concluded with the customers. The legal basis in this case are the legitimate interests of PuzzleData.

(b) In order to perform internal business processes as well as customer and supplier management, business, account login and customer data are required in order to fulfill the contracts concluded with the customers/suppliers. The legal basis in this case are the legitimate interests of PuzzleData.

(c) Marketing, business, account login and device data are processed to provide information about interesting events, products and services, technical and commercial news, customer conferences, forums, portals, other networking opportunities and to be able to answer your requests to us. The legal basis in this case are the legitimate interests of PuzzleData. In some countries, your prior consent to marketing activities is required and will be requested in the appropriate way.

(d) Making PuzzleData’s websites as user-friendly as possible in order to offer and provide products and services that meet your needs requires device data. The legal basis in this case are the legitimate interests of PuzzleData or your consent.

(e) For the secure and stable use of the websites, business, account login and execution data is required in order to be able to detect illegal behavior timely. The legal basis in this case are the legitimate interests of PuzzleData.

(f) To comply with legal requirements, business, verification, account login, execution and device data are needed to comply with PuzzleData’s legal obligations.

(g) In order to enable you to use our portals and forums, account login data is required to perform the services of the portals and forums. The legal basis in this case are the legitimate interests of PuzzleData.

(h) In order to be able to publish your contributions in the forums of PuzzleData, account login data is required, which is within the legitimate interests of PuzzleData or based on your consent. Furthermore, device data is used so that PuzzleData can defend itself against possible publication of illegal content against liability claims.

3. How does PuzzleData process your personal data by using cookies?

Through the use of cookies and related technologies (“cookies”), we process data, which may include personal data, for advertising and analysis purposes, to tailor our website to your interests, to display or send you information about us where necessary with your consent, and to keep you informed about our products and services that may be of interest to you. We also use cookies to understand how our services are used so that we can improve them.

Below you will find general descriptions of the types of cookies used on our websites, including the purposes and legal basis.

Required cookies
Necessary cookies enable navigation and basic functions of the websites, e.g. access to protected areas of the websites. The legal basis for processing information using necessary cookies is our legitimate interest.

Functional cookies
Functional cookies allow us to analyze your use of the website and your defaults on the website (for example, your login name, language or region) so that we can remember these preferences and provide you with a more personalized experience on our websites. These cookies may also be used to remember settings such as font size, font type and other configurations you have made on the websites. The legal basis for processing information through functional cookies is your consent.

Advertising cookies
In some cases, we use third party vendors to track and analyze data about the usage and volume of content used by users of our websites. This may result in cookies being set by the service providers to track the performance of our advertising. In addition, we have agreements with advertising networks. These advertising networks may track your online activity and navigation over time and across multiple websites or other online services by setting cookies. This may result in data about you being processed across multiple browsing devices, such as your PC or laptop, smartphone or tablet. Our third-party service providers use this information to serve advertisements for products and services based on your personal interests. This may result in advertisements being displayed on each of your browsing devices. The advertising cookies and related services help us analyze and monitor the effectiveness of our marketing activities. The legal basis for the processing of information through advertising cookies is your consent.

Cookie settings
You can choose how we use functional and advertising cookies by changing the cookie settings. You can control and restrict the placement of cookies through browser settings. In this context, you can also delete existing cookies. However, this may lead to a restriction of the functionalities of our websites. Required cookies are set automatically and cannot be deselected, as otherwise the website would not function properly.

4. With whom does PuzzleData share information collected?

PuzzleData shares personal data with service providers(s). All recipients only receive personal data from PuzzleData that is required for the performance of the commissioned service or fulfilment of the respective required purpose. Therefore, personal data will only be transferred to:

• Service provider(s) in countries where PuzzleData operates, to the extent the transfer is necessary to provide services in accordance with the purposes set out above;
• PuzzleData’s customers who provide you with access to PuzzleData’s cloud products and services, to the extent the transfer is necessary to resolve suspicious account activity or contract terms;
• Third parties who host or operate the forums/portal, events and other functions. In some countries, your prior consent is required for marketing activities, which you will be asked to provide in the appropriate way. Details can be found there;
• In cases where PuzzleData is legally obliged to do so or where there is a legally binding judgement, as well as in cases where PuzzleData enforces rights or defends itself against claims.
All service providers used are contractually obliged to process personal data only on PuzzleData’s instructions. The service providers do not use personal data for their own purposes.

5. How long do we store your data?

PuzzleData anonymizes or deletes personal data as soon as it is no longer required for purposes set out above unless PuzzleData is legally required to retain it. A different storage period may apply in connection with legal claims that could be made against PuzzleData. In this case, the data will be deleted after the relevant periods have expired or the relevant process has been completed.

If you wish to receive newsletters including notifications about products, services or events, PuzzleData will store the relevant information until you unsubscribe.

If you sign up for an account on the forums and portals of PuzzleData, the data you enter will be stored for as long as you are registered.

If you contact PuzzleData via the contact form, your data will be stored until it is no longer required for the fulfillment of the respective purpose, or until you request PuzzleData to delete it, or until you revoke your consent.

In connection with legal claims that could be made against PuzzleData, the storage period may be different. In this case, the deletion will take place after the hereby related time limits have expired or the hereby related process has ended.

6. What if a child sends PuzzleData her/his personal data?

We do not knowingly collect information about children and do not sell or market our products intentionally to minors. Our products are for business and corporate needs. If a child whom we know to be under 16 sends personal data to us, we will use that data only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal data.

7. To whom can you address your right to object to processing of personal data?

An objection may be lodged at any time against processing that is carried out on the basis of legitimate interest. To request information about how we use or share your personal data, exert any other right under applicable data protection law, or to raise a complaint or ask a general question related to data processing by us, you can contact us at:

Data Protection Officer
Kim Yong Ill
Tel: +82 02-2023-8431
Email: info@puzzledata.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in your country.

8. What other rights do you have?

Data subjects may contact PuzzleData’s Data Protection Officer as addressed above at any time and free of charge in order to exercise their rights as follows:

• to request information about personal data processed by PuzzleData;
• to request the rectification of inaccurate or incomplete personal data held by PuzzleData;
• to request the erasure of their personal data stored by PuzzleData, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims;
• to request the restriction of the processing of their personal data if they contest the accuracy of the data;
• obtaining your personal data provided to PuzzleData in a structured, common and machine-readable format or transferring it to another responsible party;
• revoke your consent to PuzzleData at any time, this means that PuzzleData may no longer process the data based on this consent.

9. Who can you contact if PuzzleData processes your personal data on behalf of a customer?

Your data could be processed as part of the cloud products and services that PuzzleData provides to customers. The customer is responsible for ensuring the continued protection of your data processed in the cloud products and services.

PuzzleData may only provide information about the processed data in accordance with the customer’s instructions. Therefore, you should address your enquiries to the customer directly.

10. How and when does PuzzleData change this Policy?

We reserve the right to change this Privacy Policy from time to time. Any changes to our Privacy Policy will be posted on this page. Where changes to this Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice by notifying you by email or by a pop-up banner on our website as required by applicable law so that you have the opportunity to exercise your rights. By continuing to use our websites and services after a revision takes effect, it is considered that you have read and understood the changes.