Privacy Policy

Puzzitive is provided by [[PUBLISHER_LEGAL_NAME]], an individual entrepreneur registered in Poland (jednoosobowa działalność gospodarcza, entered in the CEIDG register).

• Business address: [[PUBLISHER_POSTAL_ADDRESS]]
• Tax identification number (NIP): [[PUBLISHER_NIP]] · EU VAT: [[PUBLISHER_VAT_EU]]
• REGON: [[PUBLISHER_REGON]]
• Email: draw.without.borders@gmail.com

We are the data controller for the personal data described in this policy. The same address and email are our point of contact for users, for authorities, and for anything in this policy. You can write to us in English or Polish.

This policy explains what personal data we collect when you use the Puzzitive mobile app and the puzzitive.com website, why we collect it, who else sees it, how long we keep it, and what you can ask us to do about it.

Puzzitive is a jigsaw puzzle app. You can play puzzles made from our own picture library, or create a picture from a text description or your own photo using artificial intelligence, and then play that.

The app is for people aged 13 and over. It is not designed for or directed at children.

Some of the data below is needed for the app to work at all: the key and account number that make up your account, and the connection details every request carries. You are not obliged to give us anything else. Signing in with a provider, uploading a reference photo, choosing to receive emails and writing to us are all your choice, and declining one only means that feature is not available to you.

Two things are worth knowing up front, because they surprise people:

• You can use the app without giving us your name or email. Tapping "Continue as a Guest" creates an account that is tied to a cryptographic key stored on your device, not to an identity.
• AI generation is the one feature that leaves your device. The picture you describe or upload is sent to our image-generation provider to produce the result. Playing puzzles and your progress do not require that. The section "Creating pictures with AI" explains it in full.

Your account

What	Where it comes from	Why we have it	Legal basis
A device identifier and the public half of a cryptographic key created on your device	Created by the app when you first open it	This is your guest account: it is how the app proves it is you without a password	Performance of our contract with you
Your name, email address and profile picture	Google, Facebook or Apple, if you choose to sign in	To keep your purchases, balance and saved pictures when you change or reset your device	Performance of our contract with you
An internal account number we generate	Us	Ties your balance, images and purchases together	Performance of our contract with you
The country your request came from	Worked out from your connection and stored on your account	To work out how many credits watching a reward ad earns you where you are. Prices and currencies are set by the App Store and Google Play, not by us	Performance of our contract with you
Your language, app version, device model and operating-system version	The app	To send the right content and to diagnose problems	Legitimate interest in a working app
A record of which version of this policy and of the Terms you accepted, and when	The app	Legal obligation to be able to show that you were informed	Legal obligation

If you sign in with Apple and choose to hide your email address, we only ever see Apple's relay address.

What you create

What	Why we have it	Legal basis
The text you type to describe a picture	To generate the picture you asked for	Performance of our contract
Photos you choose as a reference for generation (up to three per request)	Same	Performance of our contract
The pictures the AI produces, and the ones you save to your collection	To show them to you, let you play and re-download them	Performance of our contract
Names you give your pictures and albums	Same	Performance of our contract

We can see this too. Our own administration tools show recent generations account by account, each with the description that produced it, and let us open the picture. We look at them to answer a support request or a report about a picture, to work out why a generation failed or was refused, and to check that the service and its safety filters are working — and for no other reason. Legal basis: our legitimate interest in running the service and keeping it safe.

Puzzles you play, pieces you place and your progress stay on your device. We do not upload them, so signing in does not carry puzzle progress over to another device.

Purchases

Records of your in-app purchases and subscription: what was bought, when, the store's transaction identifier, and your balance of coins, gems and clues. Apple and Google handle the payment; we never see your card details. Legal basis: performance of our contract, and a legal obligation to keep tax and accounting records.

Advertising

If you watch an optional ad to earn credits, we pass your account number to Google's ad service so it can confirm you actually watched it before we credit you. Ads themselves are served by Google AdMob, which may use your device's advertising identifier and an approximate location derived from your network connection. What happens here depends on where you are and on the choices you make, described under "Advertising and your choices". Legal basis: for personalised advertising, your consent in the European Economic Area, the United Kingdom, Switzerland and Canada, and our legitimate interest in funding a free app elsewhere; for checking that a reward was earned, performance of our contract with you.

Usage and diagnostics

• Analytics (screens opened, features used, purchases made). We use Google Analytics for Firebase. It records what you did, not what you wrote: your descriptions, your pictures, your searches, your album names and anything you send to support are never included. It keeps its records under an identifier it stores on your device. What else happens depends on where you are:
  • In the European Economic Area, the United Kingdom and Switzerland, nothing is collected until you agree in the consent form, and agreeing also links the records to your account number. Legal basis: consent.
  • Everywhere else, meaning outside the European Economic Area, the United Kingdom, Switzerland and Canada, these usage records are always collected, because they are how we find out whether the app works. What you control is whether they are linked to your account number: that link is on unless you switch it off in Settings → Manage Privacy Choices. Switching it off also replaces the identifier on your device, so earlier activity cannot be joined back to your account. Legal basis: our legitimate interest in running and improving the app.
  • In Canada the usage records are collected in the same way, but the link to your account starts off. The app asks on first launch whether to switch it on, and it stays off unless you do. Legal basis for the link: your consent.
• Crash reports and error diagnostics: always on, because an app that crashes silently cannot be fixed. Reports from the app carry your account number only while analytics is linked to your account, as described above; otherwise a crash is recorded without being tied to you. They never carry your prompts, pictures or email address. Errors recorded by our own servers carry your account number when the request that failed came from your signed-in app, because that is how we find it; a request that fails before you are signed in, such as a sign-in or a store notification, is recorded without one. Legal basis: legitimate interest in a stable and secure app.
• Server logs, which record the internet address your request came from and, once you are signed in, your account number, kept for 14 days for security and troubleshooting. Legal basis: legitimate interest in security.

When you contact us

The email address you give us, the subject you pick, and what you write, including anything you report through the report button on a generated picture. Legal basis: performance of our contract and our legitimate interest in answering you and in keeping the service safe.

You can also write to us through the form at puzzitive.com/support. If you are signed in, the message joins your account like one sent from the app. If you are not, we keep the email address you give, your name if you add one, the subject and your message, and we answer at that address without sending an automatic copy. To stop the form being used to flood us, we count how many messages arrive from each internet address and each email address, using a one-way code of each rather than the address itself, and each count covers at most a day, after which it stops being used and is deleted automatically, usually within a few days. Before the form sends, your browser solves a short calculation that shows it is not an automated script; it runs entirely on your device, stores nothing, and talks only to us. Legal basis: our legitimate interest in answering you and in keeping the form usable and safe.

Emails

Whether you want emails from us beyond service messages. Today the only such email is a welcome message, sent when you first sign in with, or when you link, a Google, Facebook or Apple account that has an email address. The setting is on when your account is created, and you can switch it off at any time with the Email notifications checkbox on your account page in the app (Settings → your name); the message also carries an unsubscribe link. Service messages, such as confirmation that we received your support request and our answer to it, do not depend on the setting. Purchase receipts come from Apple or Google, not from us. Legal basis: our legitimate interest in welcoming you, for the welcome message; performance of our contract, for service messages.

This is the only part of the app that sends your content to another company, so it is worth describing precisely.

What we send. When you ask for a picture, we send the text of your description, and, if you chose one, your reference photo. The photo is not attached to the request: we generate a link to it that stops working after 120 seconds, and the provider fetches it through that link. We do not send your name or email address. The link to a reference photo contains only internal identifiers: your internal account number, the photo's own reference, and the reference of the creation it belongs to, because that is where the photo is stored.

Who processes it. Our generation provider is fal.ai, which runs the image models on our behalf. Your picture is made in two steps. First it is drawn by Google's Gemini image model, which fal runs for us on Google's paid service. Then fal enlarges it with a second model that fal runs itself. fal.ai works for us: the data protection terms built into our contract with it allow it to use your content only to produce the picture you asked for, on our instructions. Google runs the image model for fal rather than for us — fal brings Google in as its own sub-contractor and has to hold it to the same protections.

Training. We never use your descriptions, photos or generated pictures to train any model, and we do not sell them. Google's paid service does not use prompts or responses to improve Google's products. Our provider may use anonymised and aggregated usage data — data from which you cannot be identified — for its own purposes. Its terms say those include running and improving its service and developing its own products and models. That is data about how the service is used, not your descriptions or pictures. We tell you this rather than promise more than we can deliver.

How long it stays there. We ask the provider to delete the generated files 24 hours after they are made, and we download your picture into our own storage within seconds of it being ready. Your reference photo is never stored at the provider at all: the request carries only the 120-second link described above, and because we also instruct the provider to keep no record of the request, the link itself is not kept either. We also instruct the provider not to keep its own record of the request, so the text of your description is not held in its request history. Google keeps a short-lived log of requests, which it uses to detect abuse of its own rules and to meet any legal requirement to disclose.

Marking pictures as AI-made. Every picture we produce carries a small piece of technical information in the file saying that it was made with AI. It says only that. It carries no identifier for you, your account or your device, and we keep no separate record of individual pictures that would let us recognise them later.

People in photos. Nothing in this process identifies who is in a photo. We do not use face recognition, and no record of faces or other biometric data is created for us.

Where it happens. The provider and the models run in the United States. See "Sending data outside your country".

Safety filtering. Requests pass through our own checks and the provider's safety systems. A request that appears to ask for prohibited content is refused, and no picture is produced. See "Automated decisions".

Their documents. Our providers publish their own privacy policies and terms: fal.ai, its acceptable use policy, and Google's Gemini API terms. We link them so you can read them, but this policy is our own description of what we do, and it is the one that binds us.

Puzzitive is free to play. Ads and optional purchases pay for it, and an optional subscription removes the ads we show you. The ads you can choose to watch for a reward stay available to subscribers as well.

Ads come from Google AdMob. To show them, AdMob may use your device's advertising identifier and an approximate location derived from your network connection, and it acts as an independent controller for that.

AdMob does not always fill an ad itself. It can pass the request to another network it works with, which today means Unity Ads. When that happens Unity receives your advertising identifier and the same connection-derived information, and it acts as an independent controller for it in the same way AdMob does. Your choice about personalised ads applies to it too: if you refuse them or switch them off, that is passed on and we request non-personalised ads.

• In the European Economic Area, the United Kingdom and Switzerland, we ask for your consent through Google's consent tool before any personalised advertising, and we honour a refusal by requesting non-personalised ads instead. Your answer is recorded in the standard industry format that the mediated network reads as well.
• In Canada personalised ads are off until you turn them on. On first launch the app asks you, with nothing pre-selected, and declining is as easy as agreeing.
• Everywhere else — outside the European Economic Area, the United Kingdom, Switzerland and Canada — we do not ask first: ads are personalised unless you turn that off. No law there requires permission up front, and the switch is always one tap away. You see the same number of ads either way — the difference is whether they are chosen using an advertising profile.
• On iOS, we also ask for permission through Apple's App Tracking Transparency prompt, and only where personalised ads are actually switched on, because there is no point asking for an identifier we would not use. If you decline, ads are non-personalised.
• You can change your mind at any time in Settings → Manage Privacy Choices, wherever you live, and you can reset or delete your advertising identifier in your device settings.
• If you signed in with Facebook, Meta's software in the app also records app events and, where allowed, your advertising identifier while personalised ads are on. Meta uses that for its own advertising measurement. In the European Economic Area and the United Kingdom, Meta's own terms make Meta and us jointly responsible for that collection; everywhere else Meta acts on its own account. Switching personalised ads off stops it, and on iOS declining the tracking prompt stops the identifier.
• Ad content is limited to a rating suitable for a teen audience.

Usage analytics is a separate question. In the European Economic Area, the United Kingdom and Switzerland it waits for your consent, just as personalised ads do. Everywhere else basic usage records are always collected, and what the Manage Privacy Choices screen lets you change is whether they are linked to your account — a link that starts off in Canada and on elsewhere. "Usage and diagnostics" above has the details.

Sharing your advertising identifier with an ad network counts as a "sale" or "share" under some United States privacy laws. The same Manage Privacy Choices control is how you opt out. We do not sell personal data in the ordinary meaning of the word, and we never sell your pictures, prompts or messages.

Our website stores nothing until you sign in. If you only read puzzitive.com, no cookie is written and nothing is stored in your browser: no local storage, no session storage, no tracking identifier of any kind, and nothing that survives you closing the tab. We do not show a cookie banner, because nothing is stored for a visitor who has not signed in, and the way we count visits, described next, is limited to anonymous audience measurement that is never used to profile you or show you advertising.

We do count visits to the website. We use Umami, a simple analytics service, on the European Union (Germany) servers of Umami Software, Inc., acting as our processor. It counts pages, not people: the page you looked at, the site that linked you, your browser and operating system, your screen size, your language, your approximate location, and how quickly the page loaded. It works without cookies and without storing anything in your browser. It runs only on the website, has nothing to do with the app, and is never connected to a Puzzitive account. To tell one visit from another it turns your network address and browser description into a one-way code that cannot be turned back into the address. If your browser sends a "Do Not Track" signal, we count nothing. Our legal basis is our legitimate interest in knowing whether the site works and which pages people read.

The typefaces are served from our own site rather than from a font service, and there is no advertising pixel, tag manager or embedded content of any kind. The robot check on the support form is part of our own site code rather than a third-party service, and it stores nothing in your browser either.

Signing in is the only thing that stores anything, and everything it stores is needed to keep you signed in:

Name	What it is for	How long it lasts
pzv_auth	A marker in your browser's local storage saying you are signed in, so the page knows to load your profile. It contains no identifier.	Until you sign out
pkce_verifier	A security check that ties the sign-in you started to the answer that comes back	10 minutes
accessToken	Your session	5 minutes
refreshToken	Renews the session while you are using the site	10 minutes
webDeviceId	A random value that lets a repeat sign-in from this browser reuse one session record instead of creating a new one every time	30 days

The cookies are removed when you sign out and when you delete your account. None of them is used to build a profile of you, follow you to other sites, or show you advertising.

In the app, the same idea applies to identifiers rather than cookies. Analytics relies on an identifier stored on your device: in the European Economic Area, the United Kingdom and Switzerland it is switched on only if you agree, and elsewhere it is always on, while its link to your account can be switched off — and in Canada starts off. Personalised advertising relies on your advertising identifier: in the European Economic Area, the United Kingdom, Switzerland and Canada it waits for your consent, and elsewhere it is on until you turn it off. Your session is kept using a key created on your device, which is what signs you in and cannot be turned off without signing out.

Who	What they do for us	What they get
fal.ai	Runs image generation on our instructions	Your description and reference photo
Google	The image model behind generation; sign-in; analytics and crash reporting; advertising; app store billing	Depends on the service: see the sections above
Amazon Web Services	Hosting, storage, sending our emails	Everything we store, as our infrastructure provider
Sentry	Error and crash diagnostics	Diagnostic reports, which carry your account number when you are signed in and can also carry technical identifiers such as your device's identifier, the identifier your sign-in provider uses for you, and store purchase identifiers
Apple	Sign in with Apple; App Store billing	Sign-in and purchase data; and, if you ask Apple for a refund, information about the purchase — how long your account has existed, whether what you bought was delivered and used, and what we think the answer to your request should be. Apple decides; our view is only one input
Meta	Facebook login, if you choose it; for those users, advertising measurement while personalised ads are on	Your Facebook sign-in data; and, while personalised ads are on, app events and, where allowed, your advertising identifier
Unity	Fills some of the ad requests Google's mediation passes on	Your advertising identifier, the internet address your request came from, and basic device and app information
Umami	Counts visits to our website only, without cookies	The page address, the referring site, your browser, screen size, language and approximate location. Never linked to an account

Some of these companies act on our behalf: fal.ai, Amazon Web Services, Sentry and Umami, and Google when it runs analytics and crash reporting for us. Google appears in more than one role: it also runs the image model behind generation, but there it works for fal.ai as fal's own sub-contractor, and it acts on its own account for sign-in, advertising and store billing. Each of them is bound by terms that limit them to our instructions and require them to protect the data at least as well as this policy does. The others act on their own account for what they receive: Google for sign-in, advertising and billing, Apple, Meta and Unity. They receive only what is described above, and their own privacy policies explain how they protect and use it: Google, Apple, Meta and Unity.

We also disclose data if the law requires it, to establish or defend legal claims, or to prevent fraud and abuse.

We are based in Poland. Our servers are in the United States, and that is where the providers who handle your data on our behalf process it. The one exception is our website visit statistics, which are processed in Germany and stay inside the European Union. When personal data leaves the European Economic Area, the United Kingdom or Switzerland, the safeguard depends on who receives it. Where a provider handles data on our behalf — our hosting, our generation provider, our analytics and crash-reporting provider, our diagnostics provider and our website analytics — the safeguard is written into the data protection terms of our contract with that provider: either the European Commission's standard contractual clauses, with their United Kingdom and Swiss equivalents, or the data protection framework the European Commission recognises for certified United States companies. Those terms come together with the technical protections described under "How we protect your data". Companies that act on their own account — the app stores, the sign-in providers and the advertising networks — make their own transfer arrangements, which their own privacy policies describe. You can ask us for details of the safeguards that apply to a specific provider.

Our website visit statistics are the exception: they are stored and processed on servers in the European Union, in Germany. The company that runs them for us is a United States company, so if it needs to reach them from there, the same terms described above cover that.

What	How long
Your account and profile	Until you delete your account
Pictures you saved to your collection	Until you delete them, or until you delete your account
Work-in-progress generations you did not save	30 days
Files at our generation provider	We instruct deletion after 24 hours
Records of your requests at our generation provider	We instruct the provider not to keep them
Your balance and purchase history	While your account exists; accounting records for as long as tax law requires
Support conversations	Until you delete your account, and in any case no more than 24 months. A message sent through the website without signing in has no account behind it, so it is kept for the 24 months
Message counts that protect the website support form	At most a day, then deleted automatically, usually within a few days
Usage records at Google Analytics for Firebase	Held by Google for the period set on our analytics property, which cannot be longer than 14 months. After that only counts that identify nobody remain
Our own record of what you generated	A mark for each day you asked for a picture, for 35 days; your running totals until you delete your account
Website visit statistics	Held by our analytics provider on its European servers for as long as our account there exists, and deleted with it. They describe visits to the website, not people, and are never joined to an account
Crash and error diagnostics	Up to 90 days at our diagnostics provider
Records of failed generations, which carry your account number	30 days, including after you delete your account
Server logs, including internet addresses and your account number	14 days, including after you delete your account
Messages in our internal processing queues, including ones that could not be processed	Up to 14 days, including after you delete your account
A record that an App Store purchase was claimed by your account	About a week, including after you delete your account
Records of store purchase notifications	180 days, to investigate fraud and billing disputes
The marker on a subscription whose account was deleted, which keeps that account number	For as long as the store could present the same subscription again, so without a fixed end
Revoked sign-in tokens	Until they would have expired anyway — minutes, not days
Encrypted backups	Up to 35 days, after which they roll off

We are a small operation, so we lean on strong defaults rather than on process:

• Encrypted in transit. Everything the app and the website send travels over HTTPS, and the live connection that tells you a picture is ready is encrypted the same way. Our file storage refuses any connection that is not encrypted, and a plain HTTP request for one of our image addresses is redirected to HTTPS before anything is served.
• Encrypted at rest. Our database, our file storage and our backups are encrypted.
• Storage that is closed and scoped to you. Our file storage has every form of public access blocked. Your photos and pictures are kept in a folder tied to your account, and the app reaches them only through signed links that we issue on demand and that expire. A link issued to you opens files in your own folder and nowhere else.
• Kept only as long as it is needed. A reference photo is used only to make the picture you asked for. Our generation provider is instructed to delete its copy after 24 hours, and our own copy, together with any result you did not save, is deleted automatically 30 days after it was uploaded. The only pictures we keep longer are the ones you choose to save, and they stay until you delete them or your account.
• Sign-in uses tokens we issue ourselves and sign with a modern elliptic-curve algorithm. Tokens are short-lived, tied to the device that obtained them, and can be revoked immediately — which is what happens when you log out or delete your account.
• A guest account is protected by a key pair generated on your device. The private half never leaves the device — we hold only the public half — and requests to delete an account or change a session must be signed with it.
• Our logs keep no prompts, pictures, support messages or email addresses. They do record the internet address your request came from, your account number, and technical identifiers such as your device's identifier and the identifier your sign-in provider uses for you. They are deleted after 14 days, and nobody outside the people who run Puzzitive can read them.
• Card details never reach us. Apple and Google process payments.

No system is perfectly secure. If a breach ever puts your rights at risk, we will notify you and the relevant authority as the law requires.

Two things happen automatically and can affect you:

• Safety filtering. Descriptions and generated pictures are checked automatically for content we prohibit. A request that fails is refused and no picture is produced. Nothing is deleted from your account and no penalty follows from a single refusal.
• Reward verification. When you watch an ad for credits, an automated check confirms it before crediting you.

Neither produces legal effects or anything similarly significant. If you believe a refusal was wrong, write to us and a person will look at it.

Wherever you live, you can ask us to:

• give you a copy of the personal data we hold about you;
• correct it if it is wrong;
• delete it;
• give it to you in a portable form, or send it to someone else;
• object to a use we base on our own legitimate interest, including usage analytics and profiling for advertising. If you object to direct marketing, or to profiling connected with it, we stop without asking why;
• restrict how we use it while a question about it is being sorted out;
• withdraw a consent you gave, without affecting what we did before you withdrew it.

Two of these you can do yourself, immediately: Settings → your name → Delete Account in the app, and Settings → Manage Privacy Choices for advertising and analytics.

For anything else, write to draw.without.borders@gmail.com. We answer within one month, and we will tell you if we need longer because the request is complex. We do not charge for this and we will not treat you differently for asking.

We may ask you to confirm something only you would know about the account, so that we do not hand your data to somebody else.

If you think we have handled your data badly, you can complain to your data protection authority. In Poland that is the President of the Personal Data Protection Office (UODO), ul. Stanisława Moniuszki 1A, 00-014 Warsaw.

You can delete your account in two ways:

• in the app, at Settings → your name → Delete Account;
• on the web, at puzzitive.com/account, without installing anything.

Deleting removes your profile, your sign-in links, your sessions, your saved pictures and albums, your balance and its history, your support conversations and your usage totals.

Some records survive, and here is why:

• Records of purchase notifications from Apple and Google, for up to 180 days, so we can investigate fraud and billing disputes;
• A record that a purchase from the App Store was claimed by your account, which keeps Apple's transaction number and your internal account number, for about a week while Apple can still resend the notification, so the same purchase cannot be credited twice;
• A marker on the store's subscription record showing that the account holding it was deleted. It keeps the store's subscription identifier, your internal account number, which subscription it was, when we first recorded it, when its last paid period ended, when the account was deleted and an internal reference to the purchase request, so that nobody else can claim a subscription that was yours. If somebody else later buys the same subscription, your account number stays on that record as its previous holder;
• Accounting records of purchases, for as long as tax law requires;
• Encrypted backups, until they roll off within 35 days;
• Diagnostic reports, until their own retention period ends;
• Server logs, which record your internal account number and the internet address your request came from, for 14 days;
• Messages still waiting in our internal processing queues, including ones that could not be processed and that carry the description you typed, for up to 14 days;
• Records of generations that failed, which carry your account number, for 30 days — they are filed by date rather than by person, so they lapse rather than being searched for and removed.

Deleting your account does not cancel a subscription. Subscriptions are billed by Apple or Google, and you must cancel yours in the App Store or Google Play, otherwise billing continues. Do that before deleting.

Puzzitive is for people aged 13 and over, or older where your country requires a higher age for us to rely on your consent. It is not designed for or directed at children, and we do not knowingly collect personal data from anyone under that age. If you believe a child has given us personal data, write to us and we will delete it.

European Economic Area, United Kingdom and Switzerland

The legal bases we rely on are named beside each purpose above. Where we rely on a legitimate interest, we have weighed it against your rights and you may object at any time. You may complain to your national supervisory authority; ours is the Polish UODO. A representative is something a company appoints where it has no establishment of its own. We are established in Poland, inside the European Economic Area, so we appoint none there.

United States

Depending on your state, you may have the right to know, delete, correct and port your personal data, to opt out of "sale" or "sharing" for targeted advertising, and to be free from discrimination for exercising those rights. The categories we collect, our purposes and the recipients are listed above; the sources are you, your device, and the sign-in and store providers you choose. In practice targeted advertising is on until you opt out. Basic usage analytics is always collected, and you can separately stop it being linked to your account in the same place. Puzzitive is for people aged 13 and over and we do not ask your age, so we cannot tell which of our users are teenagers. We do not knowingly sell or share the personal data of anyone under 16, and some states draw that line at 18; if you tell us you are under that age, we will stop. Use Manage Privacy Choices to opt out, or write to us. If an authorised agent acts for you, we will ask for proof.

Canada, including Quebec

We follow the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25.

Person in charge of the protection of personal information: draw.without.borders@gmail.com

Off until you turn it on. Two things in the app can identify you or build a profile of you: linking usage analytics and crash reports to your account, and personalised advertising. In Canada both start off. On first launch the app asks whether you want either of them, with nothing pre-selected, and you can change your answer at any time in Settings → Manage Privacy Choices. Basic usage records are still collected, as described under "Usage and diagnostics", but while the link is off they are not tied to your account and they never carry your advertising identifier. The app recognises Canada from the region set on your device, and applies these defaults across the whole country, not only in Quebec.

How we look after your information. We run Puzzitive ourselves, so the person in charge named above is responsible for your information at every stage, from collection to deletion. What we keep and for how long is in "How long we keep things", how it is protected is in "How we protect your data", and what happens when you leave is in "Deleting your account". Your information is stored and processed outside Quebec and Canada, mainly in the United States, as "Sending data outside your country" explains.

Questions and complaints. Write to the address above and we will answer within 30 days. If you are not satisfied, you can complain to the Commission d'accès à l'information du Québec or to the Office of the Privacy Commissioner of Canada.

This policy is available in French.

Australia

We handle your personal information under the Australian Privacy Principles. The rights described above are available to you. Your information is stored and processed overseas, mainly in the United States, and also in the European Union for our website visit statistics, as "Sending data outside your country" explains. Write to us first if you are unhappy about something; if our answer does not satisfy you, you can complain to the Office of the Australian Information Commissioner.

Japan

The purposes for which we use your personal information are the ones named beside each purpose above. Your information is transferred to and stored in the United States, and in the European Union for our website visit statistics; we tell you this so that you know your information leaves Japan, and the safeguards are described in "Sending data outside your country". You may contact the Personal Information Protection Commission if you are unhappy with our answer.

Everywhere else

The rights described above are available to you wherever you live, and you may contact your national data protection authority if you are unhappy with our answer.

When we change how we handle your data, we publish a new version of this policy. If the change is significant, the app asks you to read and accept the new version before you continue. Each published version carries its own number and date, and older versions remain available on request.

We may change our providers or how our systems work; what matters for you is what this document says we do with your data, and that is what we keep accurate.

We publish this policy in several languages. The translations are made from the English text, and a translation can still read differently from the original. The English version is the one we wrote and the one that governs, except where the law where you live requires otherwise; in Quebec, the French version is the one that binds you. If a translation gives you more protection than the English version does, that is what you get. If any of it reads wrongly or unclearly in your language, write to us and we will correct it.

[[PUBLISHER_LEGAL_NAME]] — individual entrepreneur registered in Poland (CEIDG)

• [[PUBLISHER_POSTAL_ADDRESS]]
• NIP [[PUBLISHER_NIP]] · EU VAT [[PUBLISHER_VAT_EU]] · REGON [[PUBLISHER_REGON]]
• Email: draw.without.borders@gmail.com

This address is also our point of contact for users and authorities, and for data protection questions in every country where the app is available. You can write to us in English or Polish.