Privacy Policy (Datenschutzerklärung)

Paradoxx UG (haftungsbeschränkt), Danksteder Straße 11, 26316 Varel, Germany, represented by the management (Geschäftsführung) Dr. Yuno Rolfes. For privacy questions, contact us at contact@keepsakeclues.com. Further details are in the Legal Notice.

This website consists of static files served by the Caddy web server on a server operated by Paradoxx UG (haftungsbeschränkt) in Germany. No external hosting provider is engaged for it. The certificates used for encrypted transport (HTTPS) are issued by Let’s Encrypt; no visitor data is transmitted to the certificate authority.

When you visit the site, the web server processes technically necessary connection data and writes access logs (date and time, IP address, requested address, status code, browser identification). Those logs are analysed automatically on the same server to detect and block attacks and abusive requests. The legal basis is Article 6(1)(f) GDPR; the legitimate interest is the secure and functional operation of the website. Log files are rotated automatically and deleted after 14 days at the latest. Attack detection uses the CrowdSec software; IP addresses from which attacks originate may be reported, together with the time and type of attack, to CrowdSec’s community blocklist service (CrowdSec SAS, France).

Visitor statistics from the same logs. Once a week, a program on the same server counts, from these access logs, page views, the ten most visited pages, the kind of referring site (search engine, social network, direct, other), error pages and visits to /create. To estimate how many different visitors came on a day, it forms a one-way checksum of IP address and browser identification with a random key that changes every day; key and checksums exist only in the program’s working memory and are discarded when it finishes, so visitors cannot be recognised across days. Only the resulting totals are kept; they contain no personal data. Nothing is stored on or read from your device for this. The legal basis is Article 6(1)(f) GDPR; our legitimate interest is knowing, in aggregate, which pages are used so that we can improve the site. You can object under section 13.

The guided crossword preview runs entirely in your browser. Anything you type there is used only to draw the puzzle on your own device. It is not transmitted to any server and not stored; it is discarded when you reload the page.

This website has no user accounts and no sign-in. It uses no analytics tools, no tracking pixels and no marketing cookies; the only statistics are the aggregate totals from the server logs described in section 2. Apart from the puzzle tool described in section 8, which sets one strictly necessary session cookie once you have unlocked your order, the site sets no cookies and uses neither local storage nor session storage. No consent under § 25 TDDDG is required for any of this.

All page content, including fonts, images and scripts, is served from this server. The site loads no content from third-party servers, so visiting it creates no connections to third parties.

If you write to us, we process your email address and the content of your message in order to handle your inquiry (Article 6(1)(b) GDPR where your inquiry relates to a contract or pre-contractual steps; otherwise Article 6(1)(f) GDPR). There is no contact form on this site — the contact links open your own email program. The mailbox for contact@keepsakeclues.com is operated on our behalf by united-domains AG (Germany). Messages are deleted once your inquiry has been dealt with, unless a statutory retention obligation applies: messages about an order are business correspondence, which German commercial and tax law requires us to keep for six years (§ 257 of the Commercial Code, HGB; § 147 of the Fiscal Code, AO); in that case the legal basis is Article 6(1)(c) GDPR.

Calls to our phone number go to a voicemail box around the clock; nobody answers live. If you leave a message, we process your phone number (if it is transmitted), the date, time and length of the call, the recording with everything you say in it, and an automatically created transcript.

Our telephone provider is fonial GmbH, Kaiser-Wilhelm-Ring 7–9, 50672 Köln, Germany. fonial records the message and emails it to a server in Germany that we administer ourselves. There the recording is turned into text automatically, using speech recognition installed on that server with no connection to the internet; we use no external service or third-party AI provider for this. The working copy of the recording is deleted straight afterwards. The recording and the transcript go to our service mailbox, and a short notice (phone number, time, transcript) to an internal notification channel on the same server. As a telecommunications provider, fonial processes the call data and keeps a copy of the message in our customer account; see fonial’s privacy notice (in German).

The legal basis is Article 6(1)(b) GDPR where your message relates to an order or pre-contractual steps, otherwise Article 6(1)(f) GDPR (our legitimate interest in receiving and answering phone enquiries). Leaving a message is up to you; without contact details we cannot reply. You can also email us (section 5).

The emails with the recording and the transcript are deleted automatically after 30 days, and the internal notice automatically after 30 days at the latest. fonial, as the telecommunications provider, keeps the copy of the message in our fonial customer account under its own terms (message storage under § 6 of the German TDDDG); we delete it there manually at regular intervals and will switch to automatic deletion as soon as fonial offers it. If your enquiry leads to an order, we keep what is needed for it for the statutory periods (section 5). Your rights and your right to object (sections 12 and 13 after renumbering) apply here too.

Crosswords are sold through our shop on Etsy. If you order there, the purchase, the checkout and the payment happen on Etsy’s platform under Etsy’s own privacy policy; we receive from Etsy the data we need to prepare and deliver your order, such as your order details, the personalisation details you supply, and the contact channel Etsy provides. We use those details only to produce and deliver the made-to-order crossword, to communicate about delivery or factual corrections, and to comply with statutory retention obligations. The legal basis is Article 6(1)(b) GDPR, and Article 6(1)(c) GDPR for retention duties.

For a made-to-order crossword, the names, the occasion and the memories we work from are the personalisation details you type into the Etsy listing; Etsy passes them to us together with the order. They are stored, with the order data Etsy provides and the files produced from them, in a protected directory on a computer in Germany that is administered by us and that only the management can read, and they are deleted 30 days after the order has been delivered.

Etsy is an independent controller for everything that happens on its platform; the order record we receive is the one Etsy makes available to sellers, and we keep only what the sections above describe. The 30-day deletion runs automatically once a week.

The clues for a made-to-order crossword are drafted with the help of a language model that runs on hardware administered by us in Germany; no third-party AI provider is involved, and your details are not used to train a model. A person reads every clue, corrects it where needed and approves the puzzle before it is delivered.

What we must keep for accounting is only the record of the sale itself — order number, date, amount and tax, as shown in Etsy’s statements — for the periods set by German commercial and tax law (§ 257 HGB, § 147 AO: currently eight years for accounting vouchers); it contains none of your personalisation details.

One of our Etsy listings is an instant download whose file points you to keepsakeclues.com/create, where you make the crossword yourself in your browser. This section describes that tool. It is free to use and sells nothing; you have already paid on Etsy.

What you enter. To unlock the tool: the order number from your Etsy receipt and the code printed in the file you downloaded from Etsy. To make the puzzle: the occasion, the recipient’s name and your own name, a tone, an optional title and dedication, and between 8 and 16 short memories of up to 400 characters each. You then edit the suggested answers and clues and confirm that you have read and approved every one of them. Your memories are often about other people, such as the recipient; please include only what you are comfortable sharing about them, and no sensitive details such as health information, religious beliefs or sexual orientation. The tool asks for no email address, no postal address and no payment details, and there is no account and no sign-in.

Purpose and legal basis. We process these details for one purpose only: to produce the crossword you bought. The legal basis is Article 6(1)(b) GDPR — performance of the contract you concluded on Etsy. The separate, unticked box before we draft your clues, by which you agree that we begin before the withdrawal period ends (see the Right of withdrawal page), is a declaration about your right of withdrawal under consumer law, not a data-protection consent; the processing does not rest on your consent. If you do not tick it, the tool does not draft or make your puzzle during the 14 days, and what you have already entered is deleted as described below.

Where the processing happens. On the server described in section 2, operated by us in Germany. The draft wording of the clues is written by a language model running on hardware administered by us, on our local network in Germany. Your memories are sent to that machine only while it is drafting; they exist there in working memory only, nothing is written to its disk, and no memory text reaches its logs. No third-party AI provider is involved, nothing you type leaves equipment administered by us, and none of it is used to train a model. If the model is unavailable, the tool simply lets you write the clues yourself.

What we store, and for how long.

• Your memories, the names, the title and the dedication: stored encrypted (AES-256-GCM, each field separately) and deleted 24 hours after your finished PDF is made. If you never finish, they are deleted 7 days after you last worked on the puzzle.
• The answers and clues you approved, the layout file and the finished PDF: kept 14 days so that you can download them again, then deleted from the database and from disk.
• The text sent to and returned by the language model: discarded as soon as the drafting job ends, and never written to a log.
• The record of the order itself — order number, listing code, the counters for the limits, the time of your approval, a checksum of the approved clue list, the time, wording version and checksum record of your start agreement, and the time we gave you its confirmation as a PDF file (our evidence for that confirmation, which page 3 of your PDF repeats; Article 6(1)(c) and (f) GDPR): kept 24 months for accounting and dispute purposes. It contains none of your puzzle text.
• Counters used to block guessing of order numbers: held as keyed checksums of the IP address and of the order number, never the values themselves, and removed after one to two days.

If Etsy reports your order as cancelled or refunded, we delete the memories and clues immediately, the files within 24 hours, and the link stops working.

Session token and re-download, no tracking. When you unlock your order we set one cookie, kc_session, which is HttpOnly and holds only a random token, and we show you a bookmarkable link containing a second such token that stays valid for the 14 days. The same session token is also held in your browser’s session storage for as long as the tab is open and is cleared once you have downloaded your puzzle. Both tokens exist only to keep you connected to your own order; they are strictly necessary for the service you requested (§ 25(2) TDDDG), so no consent is required. The pages of the tool contain no analytics, no advertising, no profiling and no content loaded from third parties.

Logs. The tool’s own log entries contain no request contents, no memories, no names and no clues. IP addresses appear only as a shortened network prefix, and the order number only as a keyed checksum. These logs are rotated automatically; the web server’s access logs are covered by section 2.

What Etsy sends us for this. To check your unlock we use a local copy of our own Etsy orders that contains only the order and transaction number, the listing number, the order status, the quantity and the time of payment. It contains no name, no address and no email address. We use it to establish that the order is paid, that it belongs to this listing, and that you receive as many puzzles as you bought.

Your rights. The rights described in section 12 apply to everything in this section, and you can also ask us to delete your memories before the periods above have run. Because of those periods there may be nothing left to give you once they have passed, so keep your own copy of the PDF.

The server’s data directory is copied every hour to a standby machine on the same network, also administered by us; that copy mirrors deletions, so the periods above apply to it with a delay of at most one hour. Once a day it is also copied to a backup machine at a second location, likewise administered by us; that copy mirrors deletions at its next daily run, so there the periods above apply with a delay of at most about one day.

The details described in sections 7 and 8 are needed to make your crossword; without them we cannot perform the contract. Everything else is optional. We make no decisions based solely on automated processing, including profiling, within the meaning of Article 22 GDPR: the language model only suggests wording, and a person — you at /create, or we for a made-to-order crossword — decides what is printed.

We do not operate a checkout on this website and we do not receive or store payment card data. Payment is handled by Etsy as part of the Etsy checkout.

Everything described above is processed by us, on equipment in Germany that we administer. The only recipients outside our company are: CrowdSec SAS (France), which receives the IP address, time and type of an attack from our attack detection (section 2); united-domains AG (Germany), which operates our mailbox on our behalf as a processor (section 5); fonial GmbH (Germany), our telephone provider, for calls to our voicemail (section 6); and Etsy, an independent controller, for everything you do and send on its platform (section 7). We use no third-party AI provider, no analytics provider and no content delivery network.

We do not transfer personal data to countries outside the European Union or the European Economic Area. Whether and how Etsy transfers data it holds about your order, for example to its parent company in the United States, is governed by Etsy’s own privacy policy.

Subject to the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, and objection to processing based on legitimate interests. You can withdraw consent at any time with effect for the future. You may also lodge a complaint with a data protection supervisory authority; for us that is generally the Landesbeauftragte für den Datenschutz Niedersachsen. To exercise your rights, please contact us using the address above.

Where we process your data on the basis of our legitimate interests (Article 6(1)(f) GDPR, for example the server logs in section 2), you may object at any time on grounds relating to your particular situation. We will then stop, unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.