Privacy Policy

Last updated: 26 October 2026

This is an English translation provided for convenience. The binding version is the German Datenschutzerklärung; in case of any differences, the German version applies.

Summary

• This website sets no cookies and stores nothing in your browser. There are no user accounts and no advertising.
• For reach measurement we use Umami on our own server, without cookies and without recognising you from one day to the next.
• When you visit, our server processes your IP address as technically necessary. Access logs are kept for at most 14 days.
• The server is located in the EU (Frankfurt am Main). No external scripts or fonts are loaded.

Preamble

With the following privacy policy we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for which purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us in connection with our offering “Puzzle Hub” at puzzlesolver.net (hereinafter “online offering”).

The terms used are not gender-specific.

Table of contents

• Preamble
• Controller
• Overview of processing
• Relevant legal bases
• Security measures
• Transfer of personal data
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Provision of the online offering and web hosting
• Cookies and storage in the browser
• Contact and enquiry management
• Reach measurement
• Definitions of terms

Controller

Rahul Dharamdasani
c/o flexdienst – #22111
Kurt-Schumacher-Straße 74
67663 Kaiserslautern
Deutschland

Email address: contact@dharamgames.com

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or establishment. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

• Performance of a contract and pre-contractual requests (Art. 6 (1) sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6 (1) sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases including profiling. Furthermore, the data protection laws of the individual federal states may apply. For access to information on your device (e.g. cookies), the Telecommunications Digital Services Data Protection Act (TDDDG) also applies.

Note on the applicability of the GDPR and the Swiss DPA: This privacy notice serves to provide information under both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that, owing to their broader geographical application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DSG, “Bearbeitung” (processing) of “Personendaten” (personal data), “überwiegendes Interesse” (overriding interest) and “besonders schützenswerte Personendaten” (particularly sensitive personal data), the terms used in the GDPR, “processing” of “personal data” as well as “legitimate interest” and “special categories of data”, are used. However, within the scope of the Swiss DSG, the legal meaning of the terms continues to be determined by the Swiss DSG.

Overview of processing

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of data subjects

• Users.
• Communication partners.

Purposes of processing

• Communication.
• Security measures.
• Organisational and administrative procedures.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Reach measurement.

Security measures

In accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

The measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, disclosure, securing of availability and separation of the data concerned. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data and responses to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through privacy-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect users' data transmitted via our online services from unauthorised access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and encrypted.

Transfer of personal data

In the course of our processing of personal data, it happens that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

International data transfers

Our server is located in a data centre within the European Union (Frankfurt am Main). However, the service providers we use, DigitalOcean (hosting), Cloudflare (email forwarding) and Google (email mailbox), have their registered office or parent company in the USA, so that access from the USA cannot be completely ruled out. For the USA, there is an adequacy decision of the EU Commission for companies certified under the EU-US Data Privacy Framework (DPF). Where a provider is not certified, the transfer takes place on the basis of the EU Commission's standard contractual clauses (Art. 46 (2) lit. c) GDPR). Where required, data processing agreements (Art. 28 GDPR) are in place with the service providers.

General information on data storage and deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consents are withdrawn or no further legal bases for the processing exist. This concerns cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

Where there are several statements on the retention period or deletion periods for an item of data, the longest period always applies. Data that is no longer retained for the originally intended purpose but on the basis of legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to access to this data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without delay or, alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged in particular with a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement.

For all requests, an email to contact@dharamgames.com is sufficient.

Provision of the online offering and web hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

• Types of data processed: Usage data (e.g. page views, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers); log data (e.g. access and error logs).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and deletion: see “Log files” and “Request limiting” below.
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a “web host”); Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
• DigitalOcean: Our server (website and database) is operated by DigitalOcean, LLC (USA) in its Frankfurt am Main data centre, as is the server for our reach measurement; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Privacy policy: https://www.digitalocean.com/legal/privacy-policy.
• Log files: Our web server logs every page request with the IP address, date and time, requested page, status code, amount of data transferred, previously visited page (referrer) and browser and operating system. These access logs are rotated daily and automatically deleted after 14 days at the latest. In addition, the application writes a technical log (including IP address, requested page, status code) whose size is limited to approximately 30 MB and which is continuously and automatically overwritten. The logs serve exclusively the security and stability of operation (e.g. defending against abuse, analysing errors) and are not combined with other data; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
• Request limiting (rate limiting): To protect against overload and automated mass retrieval, we count the requests per IP address within one minute for certain functions. These counters are held only in the server's memory and expire at the end of the time window; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
• No external content: All scripts, stylesheets and graphics are delivered from our own server. No content from third-party providers (e.g. CDNs, font services, social media or video embeds) is loaded. The reach measurement script is also delivered via our own domain.

Cookies and storage in the browser

This website sets no cookies and stores no information in your browser (e.g. in local storage). Nor does it access information already stored on your device. Consent under Section 25 TDDDG is therefore not required, and there is no cookie banner.

Contact and enquiry management

When contacting us (e.g. by post or email), the information provided by the enquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.

• Types of data processed: Contact data (e.g. name and email address); content data (e.g. text messages and the information relating to them, such as the time of creation). Meta, communication and procedural data (e.g. time information, persons involved).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; organisational and administrative procedures.
• Retention and deletion: Enquiries are deleted as soon as they have been finally dealt with, provided there are no statutory retention obligations (see “General information on data storage and deletion”).
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual requests (Art. 6 (1) sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

• Transmission and mailbox: Emails to contact@dharamgames.com are forwarded by Cloudflare (Cloudflare Email Routing, Cloudflare, Inc., USA) to our mailbox at Google (Gmail, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and stored there. Please note that emails on the internet are generally encrypted in transit but not end-to-end encrypted; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).

Reach measurement

For reach measurement we use Umami, software that we operate ourselves on our own server at DigitalOcean (Frankfurt am Main). Umami sets no cookies and stores nothing on your device. Visits are only counted as anonymous totals (e.g. pages viewed, referring page, country, device type and the number of hints viewed per game). Your IP address is only used to determine the country and is not stored; the anonymous visitor identifier changes daily, so you are not recognised from one day to the next. No data is passed on to third parties.

• Types of data processed: Usage data (e.g. page views, interactions with content and functions, device types and operating systems used).
• Data subjects: Users (e.g. website visitors).
• Purposes of processing and legitimate interests: Reach measurement; improving our offering.
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR) in data-minimising reach measurement.

Definitions of terms

In this section you will find an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.
• Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission routes. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, as well as audit logs used for tracking and reviewing operations.
• Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data comprises a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they take through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible problem areas within digital offerings.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
• Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or erasure.

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