Professor Puzzle Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.professorpuzzle.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our”means Professor Puzzle Ltd, a limited company registered in England under company number 04398865, whose registered address is THE PUZZLE ACADEMY, MESSOM MEWS, TWICKENHAM, MIDDLESEX, TW1 4DP.

2. Information About Us
2.2. Our Site is owned and operated by ‘Us’.
2.3. Our VAT number is 786-041-811.
2.4. Our Data Protection Manager is Zoe Mann, and can be contacted by email at privacy@professorpuzzle.com

3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights
4.1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1. The right to be informed about Our collection and use of personal data;
4.1.2. The right of access to the personal data We hold about you (see section 12);
4.1.3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5. The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7. The right to object to Us using your personal data for particular purposes; and
4.1.8. Rights with respect to automated decision making and profiling.

4.2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies, similar technologies and Our Cookie Policy);
5.1. Your name;
5.2. Business/company name;
5.3. Your job title;
5.4. Your contact information such as email addresses and telephone numbers;
5.5. Demographic information such as post code, preferences, and interests;
5.6. IP address;
5.7. Web browser type and version;
5.8. Operating system;
5.9. A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

6. How Do We Use Your Data?
6.1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and GDPR at all times. For more details on security see section 7, below.
6.2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1. Providing and managing your Account;
6.2.2. Providing and managing your access to Our Site;
6.2.3. Supplying Our products to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4. Replying to emails from you;
6.2.5. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the link at the bottom of the email);
6.2.6. Market research;
6.2.7. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4. Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases);
6.7. We retain data for as long as we feel comfortable it is accurate and can be relied upon.

7. How and Where Do We Store Your Data?
7.1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2. Your data will only be stored in the UK.
7.3. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4. Steps We take to secure and protect your data include:

7.4.1. All information you provide to us is stored on our secure servers.
7.4.2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.4.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. Do We Share Your Data?

8.1. Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?
9.1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10. How Can You Control Your Data?
10.1. In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.

11. Your Right to Withhold Information
11.1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11.2. You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy on Our website.

12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge.

13. Our Use of Cookies
13.1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.
13.2. Before Cookies are placed on your computer or device, you will be shown a ‘pop up’ requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

14. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at privacy@professorpuzzle.com by telephone on +44 (0)203 829 0844, or by post at THE PUZZLE ACADEMY, MESSOM MEWS, TWICKENHAM, MIDDLESEX, TW1 4DP, UK. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

15. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.