Privacy Policy

Last Updated: 15.12.2025 

This Privacy Policy describes how Puzzle Besties S.à.r.l.-s.  ("we", "us", or "our") collects, uses, and discloses your personal information when you visit https://www.puzzlebesties.eu/ (the "Site") or otherwise use our products and services (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Site and the Services.

By accessing the Site or using our Services, you agree to this Privacy Policy. If you do not agree, please discontinue use of the Site and our Services.

1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for operational, legal, or regulatory reasons. Updates will be posted on this page with a revised “Last Updated” date. Continued use of the Services after updates constitutes your acknowledgment and acceptance of the changes. 

2. What Information We Collect and How We Collect It

The information we collect about you depends on how you interact with our Site and use our Services. In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

2.1 Information We Collect Directly from You

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Under the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you, such as:

  • Name, email address, phone number

  • Order details (your name, billing address, shipping address, payment confirmation, email address, phone number)

  • Account information (username, password, security questions)

  • Shopping information (items you view, put in your cart or add to your wish list)

  • Customer support information (information you choose to include in communications with us)

  1.  Information We Collect through Cookies

We also collect certain information about your interaction with the Site and Services ("Usage Data") through cookies and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, such as:.

  • Browser type, IP address, and device identifiers

  • Referring and exit pages, pages viewed, and time spent on site

  • General location data and interaction information

We only set non-essential cookies (such as Performance and Analytics or Advertising cookies) after obtaining your prior consent through cookie banner. You may withdraw this consent anytime via the Cookie Preference link in the website footer.

For more information see Section 5 Cookies and Tracking Technologies.

  1.  Information We Obtain from Third Parties

We may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as: 

  • vendors who support our Site and Services,

  • payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you

  • advertising partners

  • analytics providers.

When we receive personal data from third parties, we ensure that these third parties are entitled to share the data with us and we process such data in accordance with this Privacy Policy and Article 14 of General Data Protection Regulation (GDPR). We are not responsible or liable for the accuracy of the information provided to us by third parties and for any third party's policies or practices. For more information, please see the Section 8 Third Party Websites of this policy.

3. How We Use Your Personal Information

We process your personal data only when we have a valid legal basis under Article 6 of GDPR. The legal basis depends on the context of the processing. Where we rely on our legitimate interests, we balance those interests against your rights and freedoms.

We use your personal information to:

  • Provide our Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to fulfill your orders, process your payments, send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges. The legal basis for these data processing activities is Contract performance according to (Art. 6(1)(b)) GDPR.

  • Communicate with you about your account, orders, or support requests. The legal basis for these data processing activities is Legitimate interest according to (Art. 6(1)(f)) GDPR.

  • Send newsletters, marketing communications and promotional offers (with your consent). Where we send you newsletters or personalized marketing or where advertising partners use cookies or similar tracking technologies, we rely on your consent (Art. 6(1)(a) GDPR). You may withdraw this consent at any time.

  • Improve our Site, Services, and customer experience. The legal basis for these data processing activities is Legitimate interest according to (Art. 6(1)(f)) GDPR.

  • Detect and prevent fraud or illegal activity. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. Do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. The legal basis for these data processing activities is Legitimate interest according to (Art. 6(1)(f)) GDPR.

  • Comply with accounting, tax, and legal obligations. The legal basis for these data processing activities is Legal obligation according to (Art. 6(1)(c)) GDPR.

Our legitimate interests include operating, securing and improving our Services, preventing fraud, and ensuring the proper functioning of our business. You have the right to object to processing based on legitimate interest at any time. See Section 12 Your Rights.

4. Updating Your Information

You may update or correct your personal information at any time through your account on our Site or by contacting us at 📧 info@puzzlebesties.eu

5. Cookies and Tracking Technologies

We use Cookies to provide and improve our Services, to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). The legal basis for processing necessary cookies and server-log data is our legitimate interest in providing the core functionality, security and performance of the Site (Art. 6(1)(f) GDPR). The legal basis for analytics and marketing cookies is your consent (Art. 6(1)(a) GDPR). We only use analytics or advertising Cookies with your prior consent. These Cookies will not be set unless and until you provide consent through our cookies banner. Specific information about the Cookies that we use to operate our store with Squarespace are listed in the Table below. The Table reflects the cookies that are active on our website based on regular scans. Because Squarespace and our third-party providers may update their cookies from time to time, we ensure this list is kept accurate and up to date.

Table - Cookies

Necessary and required cookies

Name - Purpose - Duration

CookieConsent - Stores the user’s cookie consent state for current domain - One year

Crumb - Prevents cross-site request forgery - Two weeks

rc::a - Used to distinguish between humans and bots. - Persistent

rc::c - Used to distinguish between humans and bots. - Session

Test - Investigates if the browser supports cookies and prevents errors - Session

Non-essential cookies - Performance and analytics

Name - Purpose - Duration

ss_cvisit - Identifies unique visitors and tracks a visitor’s sessions on a site. - 30 minutes

SS_lastvisit - Identifies unique visitors and tracks a visitor’s sessions on a site. Used for internal analytics by the website operator. - Session

SS_MATTR - Registers data on visitors' website-behaviour. This is used for internal analysis and website optimization. - Session

SS_MID - Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. - Session

Non-essential cookies - Advertising

Name - Purpose - Duration

ss_cid - Identifies unique visitors and tracks a visitor’s sessions on a site. - Two years

Ss_cpvisit - Identifies unique visitors and tracks a visitor’s sessions on a site. - Two years

ss_cvr - Identifies unique visitors and tracks a visitor’s sessions on a site. - Two years

ss_cvt - Identifies unique visitors and tracks a visitor’s sessions on a site. - 30 minutes

You can control or delete cookies via your browser settings, though some features may not function properly without them. Please note that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

6. Release and Disclosure of Information

We may disclose your personal information to third parties for legitimate purposes when necessary and in accordance with GDPR, as follows:

  • With vendors or other third parties who perform services on our behalf such as payment processing, fulfillment, and shipping.

  • With business and marketing partners to provide services and advertise to you (display personalized content and offers)

  • With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.

  • To comply with legal obligations such as responding to court orders, or governmental requests

  • During a business transfer such as a merger, acquisition or asset sale 

  • When you direct, request us or otherwise consent to disclose certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.

Where we use service providers that process personal data on our behalf, we enter into data processing agreements that meet the requirements of Article 28 of GDPR. Please note our service providers and marketing partners will use your information in accordance with their own privacy policies.

We have, in the past 12 months disclosed the following categories of personal information about users for the purposes set out above in Section 2 What Information We Collect and How We Collect It, Section 3 How We Use Your Personal Information and Section 6 Release and Disclosure of Information:

Category: Identifiers such as basic contact details and certain order and account information

Categories of Recipients: Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers)

Category: Commercial information such as order information, shopping information and customer support information

Categories of Recipients: Business and marketing partners

Category: Internet or other similar network activity, such as Usage Data

Categories of Recipients: Affiliates

We do not use or disclose personal information for the purposes of inferring characteristics about you. With your consent we share personal information for the purpose of engaging in advertising and marketing activities.

7. Use of Analytics

We use Squarespace Analytics to help understand how users interact with our Site. These analytics cookies are non-essential and will only be activated if you consent via our cookie banner. You can opt out by declining non-essential (Performance and Analytics) cookies when selecting your Cookies Preferences via cookie banner. You can revisit and manage your preferences via Cookies Preferences in the website footer at any time.

8. Third-Party Websites

Our Site may contain links to third-party websites or applications. We are not responsible for the privacy practices or content of such third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions.

9. Children

Our Site and Services are intended for adults 18 years of age or older. Only adults who can purchase with a credit card or other permitted payment method may purchase our Services. Any use of the Site by a minor must be under the strict supervision of the child’s parent, legal guardian, or other adult. We reserve the right to refuse service, terminate accounts, terminate your rights to use our Services, remove or edit content, or cancel orders in our sole discretion.

We do not knowingly collect, use, or disclose information from minors under 18. If you believe we have done so, please contact us. 

10. Security and Data Retention

We implement reasonable administrative, technical, and physical safeguards to protect your personal data. However, no transmission or storage system can be guaranteed to be completely secure. Any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate confidential information to us.

We retain different categories of your data for the following periods:

Data category: Order and transaction records (billing information)

Retention period: 10 years in accordance with Luxembourg Commercial Code

Data category: Account information

Retention period: Until you delete your account or after 24 months of inactivity

Data category: Customer services communications

Retention period: 24 months

Data category: Cookies and analytics data

Retention period: Retained according to the durations listed in the Table - Cookies (see Section 5 Cookies and Tracking Technologies)

We retain data only for as long as necessary for the purposes described in this Policy or required by law.

11. Your Rights

Depending on your location, you may have some or all rights under data protection laws in relation to your personal information, such as:

  • Accessing or requesting a copy of your personal information that we hold about you

  • Requesting correction or deletion of personal information we hold about you

  • Objecting to processing. You may have the right to limit how we process your data.

  • Withdrawing consent. Where we rely on consent to process your personal information, you may have the right to withdraw this consent without affecting prior processing.

  • Data portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

  • Appealing. You may have a right to appeal our decision if we decline to process your request.

  • Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made. You can do so by replying directly to our denial.

You may exercise these rights by contacting us at the Puzzle Besties email stated in Contact information below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provides proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law. You will not be charged unless requests are manifestly unfounded or excessive.

12. Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD), Luxembourg:

📍 15 Boulevard du Jazz, L-4370 Belvaux

🌐 www.cnpd.lu

13. International Users

Your personal information may be transferred, stored and processed outside the country you live in. Your personal information is also processed by staff and third-party service providers in these countries, such as Squarespace, our website hosting provider (United States). If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

14. Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal or significant effects on you.

15. Company Information

Puzzle Besties S.à.r.l.-s.

Registered office: 14, Rue St Laurent, 7370 Lorentzweiler, Luxembourg

R.C.S. Luxembourg: B297638

VAT ID: LU36703701

Email: info@puzzlebesties.eu

Website: https://www.puzzlebesties.eu/

Puzzle Besties S.à.r.l.-s. is a Société à responsabilité limitée simplifiée registered in Luxembourg and subject to Luxembourg consumer and data protection laws. For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.

16. Contact

If you have any questions, please contact us at:

Email: info@puzzlebesties.eu

Address

Puzzle Besties S.à.r.l.-s.

14 Rue St Laurent

7370 Lorentzweiler

Luxembourg