PRIVACY NOTICE
Last updated November 20, 2021
Thank you for choosing to be part of our community at Alexey Khripkov ("Company,"
"we," "us," or "our"). We are committed to protecting your personal information and
your right to privacy. If you have any questions or concerns about this privacy notice
or our practices with regard to your personal information, please contact us at
crosswordshop@gmail.com.
This privacy notice describes how we might use your information if you:
Download and use our mobile application — Puzzle Book: Daily Pages
Engage with us in other related ways ― including any sales, marketing, or
events
In this privacy notice, if we refer to:
"App," we are referring to any application of ours that references or links to
this policy, including any listed above
"Services," we are referring to our App, and other related services, including
any sales, marketing, or events
The purpose of this privacy notice is to explain to you in the clearest way possible
what information we collect, how we use it, and what rights you have in relation to it.
If there are any terms in this privacy notice that you do not agree with, please
discontinue use of our Services immediately.
Please read this privacy notice carefully, as it will help you understand what we
do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT
FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register
on the App, express an interest in obtaining information about us or our products and
Services, when you participate in activities on the App (such as by posting messages
in our online forums or entering competitions, contests or giveaways) or otherwise
when you contact us.
The personal information that we collect depends on the context of your interactions
with us and the App, the choices you make and the products and features you use.
The personal information we collect may include the following:
Personal Information Provided by You. We collect names; email addresses; and
other similar information.
Social Media Login Data. We may provide you with the option to register with us
using your existing social media account details, like your Facebook, Twitter or other
social media account. If you choose to register in this way, we will collect the
information described in the section called "HOW DO WE HANDLE YOUR SOCIAL
LOGINS?" below.
All personal information that you provide to us must be true, complete and accurate,
and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
App.
We automatically collect certain information when you visit, use or navigate the App.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences,
referring URLs, device name, country, location, information about how and when you
use our App and other technical information. This information is primarily needed to
maintain the security and operation of our App, and for our internal analytics and
reporting purposes.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage
and performance information our servers automatically collect when you
access or use our App and which we record in log files. Depending on how you
interact with us, this log data may include your IP address, device information,
browser type and settings and information about your activity in the App (such
as the date/time stamps associated with your usage, pages and files viewed,
searches and other actions you take such as which features you use), device
event information (such as system activity, error reports (sometimes called
'crash dumps') and hardware settings).
Device Data. We collect device data such as information about your computer,
phone, tablet or other device you use to access the App. Depending on the
device used, this device data may include information such as your IP address
(or proxy server), device and application identification numbers, location,
browser type, hardware model Internet service provider and/or mobile carrier,
operating system and system configuration information.
Location Data. We collect location data such as information about your
device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use
to access the App. For example, we may use GPS and other technologies to
collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your Location setting on your
device. Note however, if you choose to opt out, you may not be able to use
certain aspects of the Services.
Information collected through our App
In Short: We collect information regarding your geolocation, mobile device, push
notifications, when you use our App.
If you use our App, we also collect the following information:
Geolocation Information. We may request access or permission to and track
location-based information from your mobile device, either continuously or
while you are using our App, to provide certain location-based services. If you
wish to change our access or permissions, you may do so in your device's
settings.
Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model and manufacturer), operating system, version
information and system configuration information, device and application
identification numbers, browser type and version, hardware model, Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server). If you are using our App, we may also collect information about
the phone network associated with your mobile device, your mobile device’s
operating system or platform, the type of mobile device you use, your mobile
device’s unique device ID and information about the features of our App you
accessed.
Push Notifications. We may request to send you push notifications regarding
your account or certain features of the App. If you wish to opt-out from
receiving these types of communications, you may turn them off in your
device's settings.
This information is primarily needed to maintain the security and operation of our
App, for troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our legal
obligations, and/or your consent.
We use personal information collected via our App for a variety of business purposes
described below. We process your personal information for these purposes in
reliance on our legitimate business interests, in order to enter into or perform a
contract with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose listed
below.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook
account), we use the information you allowed us to collect from those third
parties to facilitate account creation and logon process for the performance of
the contract. See the section below headed "HOW DO WE HANDLE YOUR
SOCIAL LOGINS?" for further information.
To post testimonials. We post testimonials on our App that may contain
personal information. Prior to posting a testimonial, we will obtain your consent
to use your name and the content of the testimonial. If you wish to update, or
delete your testimonial, please contact us at crosswhordshop@gmail.com and
be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to
contact you about your use of our App.
To enable user-to-user communications. We may use your information in
order to enable user-to-user communications with each user's consent.
To manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.
To send administrative information to you. We may use your personal
information to send you product, service and new feature information and/or
information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts
to keep our App safe and secure (for example, for fraud monitoring and
prevention).
To enforce our terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in connection with our
contract.
To respond to legal requests and prevent harm. If we receive a subpoena
or other legal request, we may need to inspect the data we hold to determine
how to respond.
Fulfill and manage your orders. We may use your information to fulfill and
manage your orders, payments, returns, and exchanges made through the
App.
Administer prize draws and competitions. We may use your information to
administer prize draws and competitions when you elect to participate in our
competitions.
To deliver and facilitate delivery of services to the user. We may use your
information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential issues you
might have with the use of our Services.
To send you marketing and promotional communications. We and/or our
third-party marketing partners may use the personal information you send to
us for our marketing purposes, if this is in accordance with your marketing
preferences. For example, when expressing an interest in obtaining
information about us or our App, subscribing to marketing or otherwise
contacting us, we will collect personal information from you. You can opt-out of
our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY
RIGHTS?" below).
Deliver targeted advertising to you. We may use your information to develop
and display personalized content and advertising (and work with third parties
who do so) tailored to your interests and/or location and to measure its
effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?
In Short: We only share information with your consent, to comply with laws, to
provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to
use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably
necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you,
we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal process, such as in
response to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential violations
of our policies, suspected fraud, situations involving potential threats to the
safety of any person and illegal activities, or as evidence in litigation in which
we are involved.
More specifically, we may need to process your data or share your personal
information in the following situations:
Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing,
or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business
partners to offer you certain products, services or promotions.
Other Users. When you share personal information or otherwise interact with
public areas of the App, such personal information may be viewed by all users
and may be publicly made available outside the App in perpetuity. If you
interact with other users of our App and register for our App through a social
network (such as Facebook), your contacts on the social network will see your
name, profile photo, and descriptions of your activity. Similarly, other users will
be able to view descriptions of your activity, communicate with you within our
App, and view your profile.
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our App offers you the ability to register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do this,
we will receive certain profile information about you from your social media provider.
The profile information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends list, profile picture
as well as other information you choose to make public on such social media
platform.
We will use the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant App. Please
note that we do not control, and are not responsible for, other uses of your personal
information by your third-party social media provider. We recommend that you review
their privacy notice to understand how they collect, use and share your personal
information, and how you can set your privacy preferences on their sites and apps.
5. IS YOUR INFORMATION TRANSFERRED
INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other
than your own.
Our servers are located in Russia. If you are accessing our App from outside Russia,
please be aware that your information may be transferred to, stored, and processed
by us in our facilities and by those third parties with whom we may share your
personal information (see "WILL YOUR INFORMATION BE SHARED WITH
ANYONE?" above), in the United States, and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK),
then these countries may not necessarily have data protection laws or other similar
laws as comprehensive as those in your country. We will however take all necessary
measures to protect your personal information in accordance with this privacy notice
and applicable law.
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share
with third-party providers who advertise, but are not affiliated with, our Website.
The App may contain advertisements from third parties that are not affiliated with us
and which may link to other websites, online services or mobile applications. We
cannot guarantee the safety and privacy of data you provide to any third parties. Any
data collected by third parties is not covered by this privacy notice. We are not
responsible for the content or privacy and security practices and policies of any third
parties, including other websites, services or applications that may be linked to or
from the App. You should review the policies of such third parties and contact them
directly to respond to your questions.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements). No purpose in
this notice will require us keeping your personal information for longer than the period
of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal information to and
from our App is at your own risk. You should only access the App within a secure
environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18
years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the App, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the App. If
we learn that personal information from users less than 18 years of age has been
collected, we will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at
crosswhordshop@gmail.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United
Kingdom (UK), you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any
time.
In some regions (like the EEA and UK), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy
of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing of your
personal information. To make such a request, please use the contact details
provided below. We will consider and act upon any request in accordance with
applicable data protection laws.
If we are relying on your consent to process your personal information, you have the
right to withdraw your consent at any time. Please note however that this will not
affect the lawfulness of the processing before its withdrawal, nor will it affect the
processing of your personal information conducted in reliance on lawful processing
grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection
authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email us at
crosswordshop@gmail.com.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your
account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with applicable legal
requirements.
Opting out of email marketing: You can unsubscribe from our marketing email list
at any time by clicking on the unsubscribe link in the emails that we send or by
contacting us using the details provided below. You will then be removed from the
marketing email list — however, we may still communicate with you, for example to
send you service-related emails that are necessary for the administration and use of
your account, to respond to service requests, or for other non-marketing purposes.
To otherwise opt-out, you may:
Contact us using the contact information provided.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law,
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with the App, you have the right to request removal of unwanted data that you
publicly post on the App. To request removal of such data, please contact us using
the contact information provided below, and include the email address associated
with your account and a statement that you reside in California. We will make sure
the data is not publicly displayed on the App, but please be aware that the data may
not be completely or comprehensively removed from all our systems (e.g. backups,
etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias,
postal address, telephone or mobile
contact number, unique personal identifier,
online identifier, Internet Protocol address,
email address and account name
YES
B. Personal information
categories listed in the
California Customer
Records statute
Name, contact information, education,
employment, employment history and
financial information
YES
C. Protected classification
characteristics under
California or federal law
Gender and date of birth YES
D. Commercial information
Transaction information, purchase history,
financial details and payment information
YES
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar
network activity
Browsing history, search history, online
behavior, interest data, and interactions
with our and other websites, applications,
systems and advertisements
NO
G. Geolocation data Device location YES
H. Audio, electronic, visual,
thermal, olfactory, or similar
information
Images and audio, video or call recordings
created in connection with our business
activities
NO
I. Professional or
employment-related
information
Business contact details in order to
provide you our services at a business
level, job title as well as work history and
professional qualifications if you apply for
a job with us
NO
J. Education Information Student records and directory information NO
K. Inferences drawn from
other personal information
Inferences drawn from any of the collected
personal information listed above to create
a profile or summary about, for example,
an individual’s preferences and
characteristics
NO
We may also collect other personal information outside of these categories instances
where you interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this
privacy notice.
You may contact us by email at crosswordshop@gmail.com, or by referring to the
contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a
request if the authorized agent does not submit proof that they have been validly
authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Each service provider is a for_profit entity that
processes the information on our behalf.
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to be "selling" of your personal data.
Alexey Khripkov has not disclosed or sold any personal information to third parties for
a business or commercial purpose in the preceding 12 months. Alexey Khripkov will
not sell personal information in the future belonging to website visitors, users and
other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation or any processing that may be required
to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business
purpose;
the categories of third parties to whom the personal information was sold or
disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal
information.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to re_identify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g. phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. If, however, we
cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying your
identity, and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data.
you may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the data.
you can designate an authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
you may request to opt-out from future selling of your personal information to
third parties. Upon receiving a request to opt-out, we will act upon the request
as soon as feasibly possible, but no later than 15 days from the date of the
request submission.
To exercise these rights, you can contact us by email at crosswordshop@gmail.com,
or by referring to the contact details at the bottom of this document. If you have a
complaint about how we handle your data, we would like to hear from you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with
relevant laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
crosswhordshop@gmail.com or by post to:
Alexey Khripkov
Stavropolskiy proezd 17 app 81
Moscow 109380
Russia
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it in some circumstances. To request to review, update, or delete your
personal information, please submit a request form to crosswordshop@gmail.com.
