How we handle data

1. Who we are and what this covers

Playgent Inc., a Delaware corporation with offices at 108 W. 13th Street, Suite 100, Wilmington, DE 19801 (“Playgent,” “we,” “us” or “our”), makes Playgent Studio, a service for creating, publishing and running puzzles and games on websites and apps (the “Service”).

This Policy applies to our website at playgent.com, Playgent Studio at studio.playgent.com, our documentation at docs.playgent.com, our MCP server for AI assistants, and the games our customers publish with Studio, whether they are embedded on a customer’s own site or opened from a share link.

It covers three groups of people, and our role is different for each:

• Customers and their team members: the people and organizations that use Studio, and anyone invited to a workspace. We are the controller of this data.
• Website visitors: people who browse playgent.com or our documentation, or who contact us. We are the controller of this data.
• Players: people who play a game that a customer has published. We act as a processor on behalf of that customer, who is the controller. The customer is responsible for the lawful basis for processing player data, including any notices and consents its own site or app needs.

If you played a game on someone else’s site or app, or from a link they shared, they are the controller of your data, so please read their privacy notice. If you write to us, we will forward a verified request to them where we can.

2. Information we collect

We keep collection to what we need to provide, secure and improve the Service.

From customers and team members

• Account details: your name, your email address and how you sign in. We never store passwords in readable form. If you sign in with an account from another provider, see section 14.
• Workspace details: workspace names, members and their roles, invitations (including the email addresses you invite), the sites you allow to show your games, and settings such as your results webhook address.
• Your content: the games you make, your messages in the Studio chat, the requests that AI assistants you connect send for you, puzzles and schedules, pictures you upload, find through search or copy from a link, font files you upload, and the brand details we read from a website you name. Pictures are re-encoded when they are added, which removes hidden details such as a photo’s location.
• Keys and secrets: model and search keys you add, access keys for AI assistants, and the signing and webhook secrets Studio makes for you. We store them securely. A model key is never shown again once saved, and an access key is shown only once, when it is made.
• Billing details: your plan, its status and invoices, top-ups, your workspace’s balance, and a record of what used the balance, such as the tokens a chat used or how many searches ran. Card details are collected directly by our payment processor. We never receive or store full card numbers.
• How you use Studio: the pages and features you use, clicks and similar interactions, device and browser type, and approximate location derived from your IP address, collected with analytics and session-insight tools as described in section 13. In Studio, these tools may link that activity to your account.
• How you found us: when you sign up, we keep where your first and latest visits to our sites came from, such as the referring site, campaign tags, the page you landed on and whether you arrived from an ad (never the ad’s click identifier), together with the analytics identifier of your browser, where your cookie choices allow it.
• Communications: support requests, messages you send with Talk to us in Studio or on our website, and emails you exchange with us.
• Technical and security data: IP address, browser and device details, timestamps and similar request data, used to run, secure and protect the Service.

From website visitors

• Analytics and session insights: pages viewed, clicks, scrolling, device and browser type, approximate location and how you arrived, collected with cookies where your choices allow it (see section 13).
• Contact requests: when you ask to talk to our team, your name, work email address, company, job title and message, where you plan to show games, how you found us and your approximate country.

From players

Players never sign up with Playgent, and we never ask them for a name, email address, phone number or anything else about them. Games set no cookies and don’t track players from site to site. When someone plays a published game:

• Progress stays on the device. Saves, streaks, settings and the made-up guest name are kept in the browser’s storage for the game, never in an account.
• Analytics are anonymous counts. The game reports events such as shown, started, hint used, finished and shared, with the game’s own numbers (such as the time taken, hints used and whether it was solved), the puzzle’s day and level, the customer’s placement label, the country and the kind of device (phone, tablet or computer). Analytics keep no names, email addresses, cookies or IP addresses, and nothing in them can point to a person.
• Leaderboards and results, when the customer turns them on. A guest’s result is kept with a random identifier made on their device and a made-up name, such as Rustic Raven 62. A signed-in reader’s result is kept with the customer’s own identifier for that reader and the display name the customer passes in. Customers may never use an email address or phone number as that identifier. To keep boards fair, we may also keep a short coded tag derived from the player’s network address, which is different on every board so it cannot follow a player from one board to another, and we check that a puzzle was played on its day using the time zone of the player’s network location. Names on a leaderboard are public.
• Results sent to the customer. On the Team plan, a signed-in reader’s first result for each puzzle can be sent to the customer’s own server through the results webhook.
• Delivering the game. Like any website, our servers receive the player’s IP address and browser details when a game loads. We use them to deliver the game, keep the Service secure and limit abuse. We don’t keep them in game analytics.
• Fonts the customer chooses. If a customer styles a game with a font from a third-party font library, the player’s browser loads the font from that library, which receives the details browsers send with any request, such as the IP address.
• The customer’s own tools. A customer can pass game events to its own page or analytics tools. That data is handled under the customer’s own privacy notice.

3. How we use information

• Provide, operate, secure and improve the Service, including Playgent Forge, searches and the games our customers publish.
• Create and secure accounts, sign in people and connected AI assistants, enforce our terms, and detect abuse, fraud and bot activity.
• Show customers the analytics, leaderboards and results of their own games.
• Bill customers, keep each workspace’s balance and its usage record, send receipts and meet accounting and tax obligations.
• Send service messages, such as sign-in links, invitations, security and billing notices, reminders about your trial and plan, and notices when work you started in Studio has finished. With your consent, or where the law allows, we may also send product news, which you can unsubscribe from at any time.
• Answer support and sales requests, and understand how people find and use our sites so we can improve them.
• Comply with legal obligations, enforce our agreements, and protect the rights and safety of users and the public.
• Produce de-identified or aggregate statistics about the Service. We do not re-identify, sell or rent these statistics, and we do not use them for advertising.

4. Legal bases (GDPR and UK GDPR)

Where the GDPR or UK GDPR applies, we rely on these legal bases:

• Contract: to provide the Service to customers who have accepted our Terms of Service.
• Legitimate interests: to secure and improve the Service, prevent abuse, send service messages, understand how people find us, and run analytics that do not override your rights and freedoms.
• Legal obligation: tax, accounting, anti-fraud and lawful requests.
• Consent: for analytics and session-insight cookies where the law requires consent, for marketing messages, and wherever else local law requires it. You can withdraw consent at any time.

5. AI features

Studio includes AI features that help customers make games and puzzles. When they are used:

• Playgent Forge is our proprietary agent, optimized for building puzzles and games. When you chat with it, fill a schedule with puzzles, or ask a connected assistant to make or change a game, your request and the related game content are processed by third-party AI model providers that power it. We only use providers whose data policies do not allow them to keep that content after serving the request or to use it to train their models.
• Web and picture searches send your search terms, or the search terms the chat chooses, to third-party search providers. When the chat reads a page you point it to, or researches a topic, we fetch the public pages involved.
• Your own model keys. If you add a key from another AI provider, requests made with it go to that provider under your own agreement with them, and their terms and privacy policy apply.
• AI assistants you connect. An assistant connected through our MCP server acts as you, within your role: it can read and change your workspace’s games and read its analytics, leaderboards and balance. What the assistant does with that data is governed by your agreement with its provider. You can remove a connection at any time in Studio.
• We do not use customer prompts, customer content or player data to train general-purpose AI models.
• AI output is probabilistic. Customers are responsible for reviewing generated content before they publish it.

6. How we share information

We do not sell personal data. We share it only as follows:

• With service providers we engage to run the Service (our “subprocessors”), such as hosting and content delivery, databases and storage, sign-in, payment processing, email delivery, AI model and search providers, and analytics. Each is bound by written confidentiality and security obligations and may use personal data only to provide its service to us.
• Within your workspace. Members see each other’s names, email addresses and roles, the workspace’s games and their chats, and who connected each assistant or key.
• With customers, for the player data they control: their own analytics, leaderboards and the results their webhook receives. Customers cannot see another customer’s data.
• Publicly, when a customer publishes. Published games, share links and the names on leaderboards can be seen by anyone who opens them.
• With services you choose to connect, such as an AI assistant, your own model or search provider, or your own server through a webhook.
• With professional advisors, such as lawyers, auditors and insurers, under confidentiality.
• For corporate transactions: in connection with a merger, acquisition, financing or sale of assets, with successors required to honor this Policy.
• To comply with law or respond to valid legal process. Where lawful and appropriate, we will challenge overbroad requests and notify affected customers before disclosure.
• To protect rights and safety: to investigate fraud or abuse, enforce our agreements, or protect users or the public.

7. Subprocessors

We engage a small number of vetted service providers to host and operate the Service. Each is bound by written terms that require confidentiality, appropriate technical and organizational security measures, and the use of personal data only for the purposes we direct.

An up-to-date list of our subprocessors is available on request. Email support@playgent.com and we will send it.

8. International transfers

Playgent is based in the United States, and personal data may be processed in the United States, the European Union, the United Kingdom or other places where we or our service providers operate. Where we transfer personal data from the European Economic Area, the United Kingdom or Switzerland to a country without an adequacy decision, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses (with the UK Addendum or Swiss annex where relevant), supplemented by technical and organizational measures suited to the destination.

9. Retention and deletion

We keep personal data only as long as we need it to provide the Service, meet our legal obligations, resolve disputes and enforce our agreements.

• Accounts and workspaces are kept while they exist. A workspace without a plan keeps its games, so they can come back when a plan is picked again.
• Deleting a workspace (Owners can do this in Studio) deletes its games, folders, fonts and settings and takes its live games offline. Deleting your account removes you from every workspace and deletes the workspaces where you are the only member, with their games. We then remove the data from active systems within a reasonable period. Backups may persist on a rolling basis and are overwritten in the ordinary course.
• Billing records are kept for as long as accounting and tax law require.
• Leaderboard results are deleted after 90 days. A customer can delete one reader’s results at any time, and they leave every board within an hour.
• Game analytics are anonymous counts. Studio shows the last 90 days, and we may keep the counts in aggregate form for longer.
• Player progress stays on the player’s device until the player clears the browser’s storage for the game.
• Contact requests and support messages are kept as long as we need them to answer you and to keep a record of our relationship.
• Security and operational logs are kept for short periods that match their purpose.

You can ask us to delete your data at any time by writing to privacy@playgent.com. We will verify your identity before acting on the request and respond within the time applicable law requires.

10. Security

We use technical, administrative and physical safeguards designed to protect personal data, including encryption in transit and at rest for production data, least-privilege access controls, code and dependency review, and ongoing monitoring. Keys and secrets you give us are stored securely, assistant connections and access keys can be removed at any time, and results webhooks are signed so customers can check they came from us. Our personnel access customer content only as needed to provide and support the Service, investigate security or abuse, or comply with law.

No system is perfectly secure. If we experience a security incident that affects personal data, we will notify affected customers without undue delay and within the time applicable law requires.

If you find a vulnerability, please report it to security@playgent.com.

11. Your rights

Subject to applicable law, you have these rights over the personal data we process about you:

• Access. Ask for a copy of the personal data we hold about you.
• Rectification. Correct data that is inaccurate or incomplete.
• Erasure. Ask us to delete it, subject to legal retention obligations.
• Restriction. Restrict processing while a dispute about accuracy or lawfulness is resolved.
• Portability. Receive your data in a portable, machine-readable format.
• Objection. Object to processing based on legitimate interests or for direct marketing.
• Withdraw consent. Where processing is based on consent, withdraw it at any time.
• Non-discrimination. We will not penalize you for exercising a privacy right.
• Complaint. Lodge a complaint with a competent supervisory authority.

Customers and team members can change their name and password and delete their account in Studio, under Settings, Account, or write to privacy@playgent.com.

Players should contact the site or app where they played, which controls their data and can delete a signed-in reader’s leaderboard results. Players can remove their saved progress by clearing the browser’s storage for the game. If the site cannot be reached, write to us and we will forward your request and help within the limits of our processor role.

12. U.S. state privacy rights

If you live in a U.S. state that grants comparable privacy rights (including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana), the rights in section 11 apply. In addition:

• No sale, no sharing for cross-context behavioral advertising. In the past 12 months we have not sold personal data, and we have not shared it for cross-context behavioral advertising.
• Sensitive personal information. We do not use sensitive personal information for purposes that would require an opt-out.
• Authorized agents. You may name an authorized agent to make requests for you. We will verify both your identity and the agent’s authority.
• Appeals. If we deny a request, you may appeal within 60 days by replying to our decision.

13. Cookies and similar technologies

On playgent.com, our documentation and Studio, we use:

• Strictly necessary cookies and storage that keep you signed in, protect your account, and remember your cookie choice and preferences, such as Studio’s theme.
• Analytics and session-insight cookies that show how our sites are used: pages viewed, clicks, scrolling and how visitors move through a page. They help us find problems and improve the sites.
• Source cookies that remember where your first and latest visits came from, so that if you sign up we know how you found us.

Where the law requires consent, including for visitors in the European Economic Area, the United Kingdom and Switzerland, analytics, session-insight and source cookies stay off until you accept them. Anyone can change their choice at any time with Cookie settings at the bottom of our website. We do not use advertising cookies, share device identifiers with ad networks, or run cross-site tracking pixels.

Published games set no cookies. They keep progress in the browser’s storage for the game, on the player’s device. Customers are responsible for any cookie notice or consent flow on their own sites and apps, including for game events they send to their own analytics.

14. Signing in with another account

If you sign in to Studio with an account from another provider, such as a work, social or developer account, that provider shares a limited set of profile details with us, as you authorize on its consent screen: typically your account identifier, email address, name and profile picture. We do not ask for access to your email, files, calendar, contacts or any other data in that account.

We use these details only to create and secure your Studio account, recognize you when you sign in, show your name to your workspace, and send you account, security and billing notices. We do not sell them, use them for advertising, or use them to develop, improve or train general-purpose AI models. Only the service providers that run Studio for us handle them, under the obligations in sections 6, 7 and 10, and our personnel access them only to investigate security, fraud or abuse, to comply with law, or with your permission.

We keep these details for as long as you have a Studio account. You can revoke our access at any time in your settings with that provider. To delete your Studio account and these details, use Settings, Account in Studio or write to privacy@playgent.com. We delete them from active systems within 30 days, and backups are overwritten in the ordinary course.

15. Children’s privacy

Studio is not directed to children, and you must be an adult to have an account. We do not knowingly collect personal data from children. Customers may not publish games in products directed to children under 13 (or the equivalent minimum age in their jurisdiction), or knowingly to such children, without first implementing age-gating, obtaining verifiable parental consent under COPPA, the GDPR and other applicable laws, and notifying us in writing.

If you believe a child has given us personal data, contact privacy@playgent.com and we will delete it promptly.

16. Automated decisions and profiling

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Leaderboards apply automatic fairness checks, for example not ranking a result that is faster than a person can play, and they replace names that look like links, phone numbers or insults with a made-up name. Anti-fraud and abuse-detection systems may flag activity for human review. They do not close accounts on their own.

17. Do Not Track

Because there is no industry consensus on how to read a browser’s Do Not Track signal, the Service does not respond to it. Where applicable law requires us to honor a recognized opt-out preference signal, we do.

18. Changes to this Policy

We may update this Policy as the Service changes or as the law requires. When we make material changes, we will update the “Last updated” date and give additional notice as required, for example in Studio or by email. Continued use of the Service after an update takes effect means you accept the updated Policy.

19. Contact us

For privacy questions, requests or complaints, write to:

Residents of the EU and UK may also contact us by post at the address above. If you are in the EU and we cannot resolve your concern, you have the right to lodge a complaint with your local supervisory authority. UK residents may complain to the Information Commissioner’s Office at ico.org.uk.

For the terms that govern use of the Service, see the Terms of Service and, for customers’ player data, the Data Processing Addendum.