Privacy Policy - Puzzle Chase

PuzzleChase.games Privacy Policy

Last updated: [03 January 2022]

1. Your privacy

We care about protecting and respecting your privacy. In order to serve you better and provide you with the best customer experience, we need to collect some personal data about you. This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with, and how you can control the way your personal data is collected and used by us.

If you access or use our website (www.puzzlechase.games) (which we will refer to as “Site” in this Privacy Policy) or mobile application ("App"), or register to join as a member of the Site or App ("Membership"), then this Privacy Policy is deemed to be agreed by you and will apply to you. If you do not agree with this Privacy Policy, please stop using our Site or App, and do not apply for a Membership.

Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt out of such uses.

2. About us

Puzzlechase.games is a platform (“PuzzleChase”) that enables members to earn and redeem PuzzleChase puzzles (“Puzzles”) in return for products, discounts, services, or vouchers (“Rewards”) from participating businesses (“Partners”). PuzzleChase is owned and operated by Kowloon E-Stadium (“KES”, "we", "us", “our”), the data controller, and an affiliate of Innotainment Group Limited and REES AG Limited ("Related Companies"). Personal data we collect about you will be used in line with this Privacy Policy.

3. How do we collect data?

Your personal data will either be provided by you, or will be collected by us, Related Companies, or any affiliates of the Related Companies (the “Group”) or our Partners, or captured automatically. For example, we collect your personal data when you complete your Membership application, when you transact with a Partner and accumulate Puzzles on your Membership account ("Account"), when you redeem a Reward, when you send us emails or when you browse our Site or App.

4. Are you over 18?

Our Site, App and PuzzleChase are only intended for people over the age of 18. However, if you are under the age of 18, you may only use our Site or App, or apply for a Membership if this has been authorized by your parent or legal guardian and you have obtained their consent to use our site or App, or become a PuzzleChase Member, on the basis of this Privacy Policy.

5. What information do we collect about you?

It may be necessary for you to provide us with certain personal data in order for you to receive the benefits of PuzzleChase, our Site or App. We will let you know when such data is essential for Membership. All other personal data is up to you to provide or not, as you prefer.

(a) Your Membership

If you are a PuzzleChase member ("Member"), some of the personal data we may collect about you includes but not limited to:

your full name, month and year of birth, email address, telephone number, postal address, username, and password;
your Membership number ("PuzzleChase ID"), points balance, Account status and activities relating to your Account;
your transaction history or payment details when you purchase anything from our Partners and you use your Membership to accumulate Puzzles (including the product or service purchased, the date of purchase, where you made your purchase, the cardholder's name, credit card number, expiry date and billing information);
information about the Rewards you redeem; and
your shopping preferences, including brand preferences and the types of products and services you may be interested in.

(b) When you visit our Site or App

We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

your visits to our Site or App, such as your browsing history, how long you stay on our Site or App, and how often you visit;
your location information as provided by your mobile or other device when you interact with our Site or App, including your IP address and general geographic location; and the device that you use to browse our Site or App (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.

(c) Other information

We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).

6. How do we use your information?

We will only use your personal data for the purposes set out below.

(a) Account administration

To help administer and maintain your Account, including:

creating and updating your Account;
verifying your identity;
creating a single profile about you, including combining your information with any other personal data already held by us or any members of the Group;
processing Puzzles issuance and Reward redemptions;
completing transactions, including processing or facilitating payments;
sending you updates about new features and benefits relating to PuzzleChase; and
enabling features that allow you to personalize your Account on our Site or App, such as bookmarking your favourite Partners.

(b) Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(c) Marketing

To provide you with marketing and promotional materials ("Marketing Communications"), if you choose to receive them. Please see the section on Direct Marketing below for more information.

(d) Personalization

To create personalized Marketing Communications tailored to your interests and preferences, and to provide you with the best possible customer experience in relation to our Site, App and your Membership. We may also use data analytics tools to determine whether our or any Group members' offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customize the content and types of offers, products, services and Rewards that we present to you.

(e) Optimization and improvements

We may use your personal data to understand and improve our Site, App or PuzzleChase operations, or our Partners' or Group members' operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Partners and our Group members to enhance services or products, develop new features and benefits, and amend business, marketing and strategic operations and plans.

(f) Legal and administration purposes

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

7. Who do we share your information with?

To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymized or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your personal data) with third parties who may or may not be located overseas, as detailed in this section. By using our Site or App, or applying for a Membership, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.

(a) Partners

If you are a Member, your personal data may be shared with our Partners to facilitate the processing of Puzzles issuance, Puzzles redemption and related transactions, as well as for data analytics purposes in order to improve their operations, services or products.

Please be aware that our Partners may themselves directly collect personal data from you if you give it to them when you purchase any goods or services at their store, or if you register with them as a customer. The handling of your data collected by our Partners will be governed by the relevant Partner's separate privacy policy (and not this Privacy Policy), and we are not involved or responsible for the collection and handling of such data.

(b) The Group

Your personal data may be transferred to any Group members for any of the purposes we have set out above. However, we will not provide your personal data to any Group member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.

(c) Service providers

Your personal data may be shared with our or any Group members' service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate PuzzleChase, our Site and our App, to conduct data analytics, to help aggregate and anonymize the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our Group members, for any of the purposes set out above.

We only use trustworthy service providers, who are under an obligation to only use your personal data in accordance with this Privacy Policy.

(d) Professional advisors and assignees

When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.

(e) Government and regulatory authorities

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy, shall be subject to the exclusive jurisdiction of the courts of Hong Kong.

8. Aggregated and anonymized data

Aggregated or anonymized data that does not include any personally identifiable information, may be used by us, our Partners, our Group members or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.

9. Direct Marketing

If you have opted to receive offers and promotions from us, we may use your personal data to:

send you direct marketing communications in connection with the latest news, events, updates, offers, contests and promotions in relation to PuzzleChase;
send you direct marketing communications in connection with the latest news, events, updates, contests, promotions, offers, products, services and Rewards offered by our Partners or Group members, which relate to retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications;
analyze your preferences, online behaviour and transactional history in order to gain insights, so that we can customize the content and types of news, events, updates, contests, promotions, offers, products, services and Rewards that we present to you via our Site, our App, our direct marketing communications, social media or other communication means; and
in conjunction with any seasonal events, lucky draws and contests or other promotional activities.

We may send you direct marketing communications and market research invitations by email, through your online Membership user account or in-app notifications on your mobile device, when you access the Site or App, or through online banner advertisements, post, telephone or SMS.

Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time not to receive any direct marketing communications from us. Please see the section on Your rights below.

10. Can our Partners or affiliates send you marketing materials?

We will not provide your personal data to our Partners or our Group members for them to send you marketing materials, unless you allow this.

If any of our Partners or Group members wish to directly send you any marketing materials regarding their own products and services directly, then they must obtain your separate consent for this. We are not involved in any marketing done directly by our Partners or Group members that is unrelated to PuzzleChase. However, we may send Marketing Communications to you on behalf of our Partners or Group members, subject to your consent and in accordance with the Direct Marketing section above. If you agree to receive any marketing materials directly from our Partners or Group members, then please carefully read our respective Partners' own privacy policies.

11. How do we keep your information secure?

We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorized disclosure, use and modification. All transactions under the terms and conditions of this Privacy Policy are based on the encryption of data exchanged between you and us on our secure Site and App.

12. How long do we keep your data for?

We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymize or securely delete it on our servers.

13. Your rights

(a) Access and correction

You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at [email protected]

In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.

(b) Opt-out of direct marketing

At any time, you can ask us to stop using your personal data to send you direct Marketing Communications, or you can customize how you would like to receive direct Marketing Communications from us. You can exercise your rights to do this by:

changing your settings on your online Membership user account or in the Site; or
following the unsubscribe instructions in the Marketing Communications we send to you.

We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.

We are not involved or responsible for any marketing materials sent directly by our Partners or Group members that are unrelated to PuzzleChase. If you would like to stop receiving any marketing materials from our Partners or Group members, please contact them directly in order to unsubscribe from their mailing lists.

14. Online tracking technology

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.

We use cookies and other similar identification technologies such as web beacons and pixel tags on our Site, App, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our Site or App; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimizing the operation of our Site and App; tracking and measuring the effectiveness of our advertising campaigns; and analyzing traffic on our Site, our App and the websites of our Partners or Group members.

You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalized experience.

15. Links to other sites

Our Site and App may contain links to other third party websites and applications, including those of our Partners or Group members (“Third Party Sites”). We do not own or control, and are not responsible for the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our Site or App, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.

16. How do we manage updates to this policy?

From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our Site.

17. How to contact us

If you have any questions or comments concerning this Privacy Policy, you can contact our Data Protection Officer at [email protected]