Puzzel is committed to safeguarding the privacy of all our business processes; this policy sets out how we will treat your personal information.
Scope and acceptance
This Privacy Statement applies to all business processes in Puzzel and to all Puzzel websites, domains, mobile solutions, cloud services and communities as well as Puzzel- branded websites and third party social networks (e.g. Facebook) (Puzzel Sites). Any specific appendices for our cloud services will be found in the Terms of Service or equivalent for the service in question.
The Statement provides information about data processing carried out by Puzzel when Puzzel determines the purpose and means of the processing (Puzzel as data controller), and data processing we do on behalf of our Customers based on their instructions (the Customer as data controller and Puzzel as data processor).
Personal data is information that can identify you as a person, such as an email address, street address or phone number. Processing your personal data is necessary for us to serve you or our Customers. By providing us with your personal data, you accept the practices and terms described in this Privacy Statement. Please do not use Puzzel Sites or provide your personal data if you do not agree.
Whose data we process
Puzzel process data about contact persons and software users among our Customers, including persons representing potentially new Customers that approach us via Puzzel Sites or other channels. Our statement in these regards is to be found in the data controller section.
We also process data about our Customers’ employees and other persons’ data of which the Customer controls. Our statement in these regards is to be found in the data processor section.
In this Statement data subjects may also be referred to as persons or you.
Puzzel as a data controller
When Puzzel determines the purpose and means of processing your data we act as data controller. Puzzel controls personal data that we collect in the context of you being a employed by a Customer that has or may have a business relation to Puzzel, or you declare that you want to receive information from us based on your own or your employer’s interests. When you represent a Customer of Puzzel, your rights are the same as if you were a private person only representing yourself.
Why we process your personal data
To manage our Customer relations in general and to meet our Customer commitments, Puzzel requires some information about you in your role as Customer contact person or user of a service. Our aims with this are:
a) Provide offers services that Customers or prospective customers have requested.
b) Inform about and present service offers that are closely related to the services the Customer already uses.
c) Perform deliveries in accordance with a customer agreement
d) Offer support to users of our services
e) Improve the quality of our services and Puzzel Sites
f) Detect and prevent security threats and perform maintenance and debugging
g) Prevent abuse of our software and services
h) Communicate information that is relevant for our deliveries and our customer relations in general
i) Process orders, invoicing, payments and other financial follow up of Customers
j) Payment of services purchased through Puzzel Sites
Processing according to the above listed purposes (a to j) is necessary for us to manage our customer relations. Therefore, Puzzel does not, as additional ground ask for your consent to process your personal data. We do not consider that the processing disadvantages you in any way.
In addition, we will also collect information about you as a contact person or user of a service, for the following purposes:
k) To manage your access to our web-based services (cloud services)
l) To promote new products and services
The basis for Puzzel’s processing of personal data for the above purposes (k to l) is based on your voluntary consent. Your consent may be given freely on Puzzel Sites when applicable. Please note that the collection of individual personal data is required to gain user access to many of our programs and services and to access the information you have requested.
To protect your security and ours we will also store information about you when you visit our premises. You will be informed of your rights in this context when you register in our electronic visitor system.
How we collect your personal data
In general, Puzzel collects data directly from you or other persons linked to the Customer company where you are employed. These persons may be a manager or colleague. If the Customer you work for purchases Puzzel services via a Puzzel partner company, we may collect information about you from the partner company.
In some cases, we may also collect information about you from other legitimate sources if you have given your consent that the party collecting the personal data may share this with others. These sources may be third party data aggregators, Puzzel’s marketing partners, public sources or third party social networks. Puzzel will be able to combine personal data about you obtained from one source with data obtained from another source. This gives us a more complete picture of you as contact person, which also gives us the possibility of serving you in a more relevant way with a greater degree of personalisation.
Automatic data collection tools
Puzzel uses a variety of technologies to collect information about your movements on the web as well as interest and preferences you freely have made available.
Cookies are small text files that contain a string of characters and uniquely identify a browser. They are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies. You may be, however, able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. If you would like to know more about cookies and how they work, please visit www.allaboutcookies.org.
Marketing Automation Tools
Google Analytics: This cookie allows us to see information on user Website activities including, but not limited to page views, source and time spent on a Website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our Website, and strive to give you more of the things you enjoy reading and watching.
Google Analytics Remarketing: Places cookies on your computer which means that after you leave our website, Google can show you advertisements about Puzzel that you might be interested in, based on your previous behavior on our website. This information is not personally identifiable.
Google AdWords: By using Google AdWords code, we can see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget. This information is not personally identifiable.
Google Adwords Remarketing: Places cookies on your computer which means that after you leave our website Google can show you advertisements about Puzzel that you might be interested in, based on your previous behavior on our website. This information is not personally identifiable.
You can prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser. This Add-on is available at http://tools.google.com/dlpage/gaoptout.
What personal data we process
The type of data that Puzzel processes about you may be:
- Your own and the Customer’s contact details such as name, address, telephone number and email.
- Information about date of birth, age and gender
- Employment information about you at the customer company such as job title, position including preferences and interests in professional context
- Feedback, comments or questions about Puzzel as a supplier, or concerning our services
- Photos or video of you recorded at our premises
- Content you have uploaded such as photos and video
- Unique user information such as login ID, username, password and security question
- Financial information such as credit card information
- Traffic information as provided by your web browser such as browser type, language and the address of the website from which you arrived and other traffic information such as IP address
- Clickstream behavior such as which links you click and when
- Other personal data contained in your profile on third party social networks (Facebook etc.)
- Call Data Records
We may also in some cases compare a collected IP address with a geographic map service to derive your general location.
If you make a post, comment or similar on any public forum or Puzzel Site, such information can be read and used by anyone with access to site and used for purposes over which neither Puzzel nor you have control. Puzzel is not responsible for any information you submit on such forums or Puzzel Sites. Puzzel will not post any comment, testimonial or similar made by you without your prior consent.
How we share your personal data
- Puzzel shares your personal data within the organization to better be able to serve you as a customer or interested party of us.
- Puzzel does not share your personal data with third parties who intend to use the data for marketing purposes if you have not given your consent to this.
- Puzzel may share your personal data with third parties for other purposes but only in the following contexts:
Puzzel may share your personal information with our partners in the event this is legitimate from a business perspective. For example, if you purchase a service on behalf of your employer that we provide through one of our certified partners.
The police and other authorities may demand the handover of personal information from Puzzel. In these cases, Puzzel will only hand over the data if there is a court order to do so.
In connection with mergers, acquisitions or divestiture of all or parts of Puzzel’s business, the acquiring entity as well as its consultants will obtain access to data managed by Puzzel. The acquiring entity and its consultants will enter into a NDA with Puzzel, which will also cover potential disclosure of personal data.
Right to opt-out of marketing communications
You have the right to opt-out of receiving marketing communications from Puzzel and can do so by:
(a) Following the instructions for opt-out in the relevant marketing communication, or
(c) Contacting us via e-mail at email@example.com
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from Puzzel, such as order confirmations and notifications about your activities (e.g. account confirmations and password changes).
Access and rectification
You have the right to request a copy of your personal data. You may send us a request for this.
You also have the right to request that Puzzel corrects any inaccuracies in your personal data. If you have an account with Puzzel for a Puzzel Site, this can usually be done through the appropriate “your account” or “your profile” section(s) on the Puzzel Site (if available) or inside your Puzzel cloud service. To manage subscription settings for Puzzel Newsletters, please click the “Manage my subscription” link at the bottom of the emails you receive. Alternatively, you can send us a request to rectify your data.
Data security and retention
How we keep your personal data secure
Puzzel takes the trust you place in us seriously. Puzzel is committed to prevent unauthorized access, disclosure or other deviant processing of your data. Further, Puzzel is committed to ensure proper use of the information, to maintain data integrity and to secure data availability. As part of our commitment, we utilize reasonable and appropriate physical, technical, and administrative procedures and measures to safeguard the information we collect and process. Puzzel has implemented a number of security measures, including:
- Secure operating environments – Puzzel stores your data in secure operating environments that are only accessible to Puzzel employees and subcontractors on a need-to-know basis. Puzzel also follows generally accepted industry standards in this respect.
- Encryption of payment information – Puzzel uses industry-standard encryption to provide protection for sensitive financial information, such as credit card information, sent over the Internet (e.g., when you make payments through Puzzel’s services).
- Prior authentication for account access – Puzzel requires its registered users to verify their identity (e.g. login ID and password) before they can access or make changes to their account to prevent unauthorized access.
Please note that these protections do not apply to the personal data that you choose to share in public areas such as community websites.
How long we store your personal data
Puzzel will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required in this way, we destroy or delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
Puzzel as a data processor
Puzzel provides different services to our Customers. These services involve processing of the Customers’ data and may include processing of personal data. The purposes of this processing are determined by our Customers and not by Puzzel. The Customer is then the data controller for the data subject’s data. Puzzel does in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. When acting as data processor, Puzzel is in accordance with the requirements in applicable data protection legislation always committed to enter into a data processing agreement (DPA) with the Customer. The Customer has agreed and guaranteed that:
- The Customer is the owner of or otherwise has the right to transfer the data to Puzzel for processing and that he has the responsibility for the accuracy, integrity, content, reliability and legality of the personal data
- It is the Customer’s duty as data controller to notify, to the extent required by applicable law, the relevant supervisory authorities and/or the data subject in the event of any breach or unauthorized disclosure of personal data
When acting as data processor, Puzzel is responsible for providing technical and organizational security measures to safeguard your privacy on behalf of our Customer – the data controller.
As data processor, Puzzel will not process personal data in any other manner or for any other purpose than as authorized in the agreement with the data controller. Data subjects having questions, comments, claims or any other issues regarding their personal data that Puzzel is data processor for, must submit these to the data controller. As data processor, Puzzel will not give any data subjects access to their personal data without instructions given by the data controller to do so. If governmental authorities or the police request disclosure of personal data, Puzzel will promptly notify the data controller and we will disclose such data only to comply with a court order.
Puzzel will provide non-public information about internal systems and routines for data processing to Customers and collaboration partners upon request and NDA.
Subcontractors and export of personal data
In some cases, Puzzel will use subcontractors to process personal data, and we may export your or our Customers data outside the EU. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, Puzzel will always enter into a data processing agreement (DPA) in order to safeguard your privacy rights and/or to fulfil our obligations towards our Customers.
If the processing of data is performed outside of the EU, we will make sure that the DPA is based on the EU Standard Contractual Clauses or that the data importer is certified according to the EU/US Privacy Shield framework, if located in the US. In such cases, we will also inform our Customers about the export of data. Puzzel is not responsible for providing such information to data subjects whose data is controlled by our Customers.
Changes to this Statement
If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.
The last update of this Privacy Statement was March 13th 2017.
How to contact us
We value your opinion. If you have any comments or questions about our Privacy Statement, please send them to firstname.lastname@example.org. You can also send it in writing to Puzzel AS, Brynsveien 13, N-0667 Oslo, Norway.
We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.