PRIVACY POLICY for edu-games.org

Last Updated: 10 December 2025

Effective Date: 10 December 2025

📢 IMPORTANT NOTE ON CONTACT INFORMATION (GDPR Transparency)

As a highly mobile Sole Proprietor operating outside the European Economic Area (EEA), we understand the GDPR requirement for a stable postal address. Due to the continuous and unpredictable relocation required by our professional life, we cannot guarantee the reliability of any single fixed mailing address.

Therefore, to ensure compliance with the **Right to Contact** and guarantee that we receive and respond to your official privacy requests, the dedicated email below is the **only reliable, effective, and guaranteed channel** for exercising your data subject rights.

1. WHO WE ARE (DATA CONTROLLER)

The website edu-games.org ("The Site") is an educational resource operated by Johannes Verhoef (the "Data Controller," "we," "us," or "our"). We provide tools primarily for teachers and educational professionals.

Data Controller Name: Johannes Verhoef (Sole Proprietor)
Address for Legal Correspondence: **NOT PROVIDED.** Please use the email below for all official communications.
Contact Email for Privacy: privacy@edu-games.org (Please use this email for all data subject requests.)

2. THE DATA WE COLLECT AND WHY (LAWFUL BASIS)

We collect and process the following categories of personal data based on specific legal grounds defined by the GDPR:

Category of Data	What We Collect	Purpose of Processing	Lawful Basis (GDPR Art. 6)
Account Data	Email Address, Hashed Password.	To provide access to the member service and authenticate the user.	Contractual Necessity (Art. 6(1)(b))
User Preferences	Settings for receiving emails/notifications, Paper size preference (A4/Letter).	To customize and deliver the service features you request.	Contractual Necessity (Art. 6(1)(b))
System/Usage Data	IP Address, Browser/Device Type, Pages Viewed.	To secure the website, diagnose errors, and prevent malicious activity.	Legitimate Interest (Art. 6(1)(f))
User-Created Content	Puzzles created on the website (words and clues).	To publish, share, and utilize as educational content on the Site, as agreed to in the Terms of Use.	Contractual Necessity / Legitimate Interest (Art. 6(1)(b), (f))
Advertising/Analytics Data	Data collected via non-essential Cookies (e.g., Google identifiers).	To measure site performance and fund the site through advertising (based on consent).	Consent (Art. 6(1)(a))

3. THIRD-PARTY SERVICES AND DATA SHARING

We use third-party services for essential website functions. We are responsible for implementing technical controls (like the consent banner) to respect your choices, but these services process data according to their own policies.

Google Analytics: Used to measure site traffic. This is only activated if you provide consent.
Google AdSense: Used to display advertisements and fund the service. This is only activated if you provide consent.
Hosting Provider: Inmotion Hosting (Located in: US).

You should consult the privacy policies of Google LLC for information on how they process data they collect through our site.

4. COOKIES AND YOUR CONSENT

We use cookies to ensure basic functionality and for advertising/analytics purposes only with your permission.

Strictly Necessary Cookies: We use these to remember your language preference and record your Cookie Consent choice. These are essential for the site to function and do not require your permission.
Non-Essential Cookies: These are used by Google for analytics and personalized advertising. They are not set until you actively click the "Aceptar" (Accept) button on our consent banner.

You can withdraw your consent at any time by clearing your browser's cookies and local storage.

5. DATA RETENTION

We retain your data based on necessity, distinguishing between identifying information and content.

Account Data (Email, Password, Preferences): Retained as long as your account is active. If you close your account, all personal data linked to your identity will be securely deleted within 7 days of your request.
User-Created Content (Puzzles): Puzzles created and saved on the website are not deleted upon account closure. This retention is necessary for the performance of the contract (Terms of Use) where you grant us ownership and permission to publish the content. We will **sever the link** between your deleted account identity and the puzzle content, and the puzzle will remain as anonymous, aggregated content on the website.
System/Usage Data (IPs/Logs): Retained for a maximum of **90 days** for security and error tracking purposes.

6. YOUR DATA PROTECTION RIGHTS (GDPR)

Under the GDPR, you have the following rights regarding the personal data we hold about you. To exercise any of these rights, please contact us at privacy@edu-games.org.

You have the right to:

Access: Request a copy of your personal data.
Rectification: Request correction of inaccurate or incomplete data.
Erasure ('Right to be Forgotten'): Request the deletion of your personal data (excluding the puzzle content, which is retained anonymously).
Restrict Processing: Request that we limit the way we use your personal data.
Object to Processing: Object to processing based on our Legitimate Interest.
Data Portability: Request that we transfer your data to you or another organization.
Withdraw Consent: You can withdraw your consent for future processing (e.g., for advertising cookies).

If you have a concern about our data handling, you have the right to lodge a complaint with a supervisory authority in your country of residence.

7. CHANGES TO THIS POLICY

We will update this policy as necessary to reflect changes in our data processing practices or legal requirements. The latest version will always be posted here. We will notify registered members of any material changes via the email address associated with your account.