Privacy Policy

1. Data Controller Identity

The data controller responsible for the collection, handling, and processing of personal data on this website is:

Corporate Entity: MIDNIGHT GAMES S.R.L.

Brand Name: tracetwistpuzzle

Registration Number (CUI): 44653826

Registered Office Address: Sos. Moara De Foc 33, Bl. IV, Et. 1, Ap. 10, Iași 700520, Romania

Official Email Contact: letter@tracetwistpuzzle.com

Official Telephone Contact: +40 740016539

2. Age Eligibility and Capacity Threshold

This website and its web-based interactive puzzle games are strictly intended for individuals who are at least 18 years of age. By accessing this website, creating an account, or initiating any transaction, you represent and warrant that you have reached the age of majority and possess full legal capacity to enter into binding agreements.

The Company does not knowingly collect personal data from individuals under the age of 18. Any transaction executed via our checkout process is legally deemed to have been executed by an adult with full authorization and financial capacity.

3. Payment Processing and Data Transfers

To facilitate financial transactions for our digital interactive content, this website utilizes Stripe (Stripe Payments Europe, Ltd.) as our external third-party payment processing partner.

When you execute a payment, your financial credentials, credit card details, and transactional information are collected, handled, and processed directly by Stripe on their own systems in accordance with their corporate privacy standards. MIDNIGHT GAMES S.R.L. does not store, retain, or have visibility of your raw payment credentials or full credit card numbers. Data transmission during the checkout process is managed using industry-standard cryptographic protocols appropriate for commercial web transactions.

4. Data Retention Periods

In strict compliance with Romanian and European Union regulations, the Company retains personal data only for the precise duration necessary to fulfill legal, fiscal, and operational mandates:

Transactional and Accounting Records: Pursuant to Romanian financial law (including Law no. 82/1991 on Accounting), all data and supporting documentation connected to commercial transactions, invoicing, and completed payments must be archived and retained for a mandatory statutory period of 10 years.

Contractual and Service Data: Personal data collected to facilitate ongoing access to the interactive puzzle content is retained for the duration of the service provision and an additional 3 years following the conclusion of the transaction, in accordance with the general statutory limitation period under the Romanian Civil Code.

5. Instant Supply of Digital Content & Statutory Right of Withdrawal Waiver

The items available on this website consist exclusively of digital, browser-based interactive entertainment. Access to the purchased items is rendered instantaneously upon successful confirmation of the transaction. No physical shipment or postal tracking documentation is required or issued.

Mandatory Consumer Notice

In accordance with Article 16(m) of the European Union Consumer Rights Directive (2011/83/EU) and Romanian national consumer legislation (Emergency Ordinance no. OUG 34/2014), the statutory 14-day right of withdrawal (cooling-off period) is not applicable to the supply of digital content not delivered on a tangible medium if the performance has begun.

By completing your transaction and accessing the interactive puzzle content, you provide your explicit prior consent for the immediate supply of this digital service. You explicitly acknowledge and agree that once the digital delivery commences or access to the online game is granted, you forfeit your 14-day right of withdrawal, and the transaction is final and non-refundable.

6. User Rights Under GDPR

As a resident of the European Union, you possess specific statutory rights regarding your personal data under the General Data Protection Regulation (GDPR). These include the right to request access to, rectification of, or erasure of your personal data, as well as the right to restrict or object to certain processing activities. To submit a formal inquiry regarding your data rights, please contact the Company via our official email address: letter@tracetwistpuzzle.com.