Privacy Policy

Last updated: January 24, 2026

Thank you for choosing to be part of our community at Comet Sprouts / Comet Sprouts Academy (“Company,” “we,” “us,” or “our“). We operate the websites cometsprouts.com and cometsproutsacademy.com. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at support@cometsprouts.com.

This privacy notice describes how we might use your information if you:

• Visit our websites at cometsprouts.com or cometsproutsacademy.com
• Engage with us in other related ways ― including any sales, marketing, or events

In this privacy notice, if we refer to:

• “Website,” we are referring to any website of ours that references or links to this policy.
• “Services,” we are referring to our Websites, member portal, and other related services, including any sales, marketing, puzzles/worksheets distribution, or events.

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Websites (such as entering giveaways or downloading puzzle resources), or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Websites, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Personal Information Provided by You: We collect names, phone numbers, email addresses, mailing addresses, billing addresses, debit/credit card numbers, and other similar information.
• Payment Data: We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored securely by our third-party payment processors or membership management platforms (such as Stripe or MemberSpace).

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Websites for a variety of business purposes described below. We use the information we collect or receive:

• To facilitate account creation and logon process. (e.g., via MemberSpace).
• To post testimonials. We post testimonials on our Websites that may contain personal information with prior consent.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Websites and puzzle resources.
• To manage user accounts. We use your information to maintain your account in working order.
• Fulfill and manage your orders. We use your information to fulfill and manage your memberships, digital puzzle purchases, and payments made through the Websites.
• Administer prize draws and competitions. We use your information to administer monthly giveaways and competitions when you elect to participate.
• To deliver and facilitate delivery of services. We use your information to provide access to your purchased logic puzzles, brain teasers, and educational worksheets.
• To respond to user inquiries / offer support. We use your information to respond to your inquiries and solve potential issues.
• To send you marketing and promotional communications. If in accordance with your preferences, we may use your information for marketing purposes (such as new puzzle releases or updates). You can opt-out at any time.
• Deliver targeted advertising. We may use your information to develop and display personalized content and advertising tailored to your interests.

3. Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data based on the following legal bases: Consent, Legitimate Interests, Performance of a Contract, Legal Obligations, and Vital Interests. More specifically, we may need to share your data with service providers (such as payment processors and membership hosting platforms) under strict written contracts to deliver our Services to you, or in connection with business transfers (such as a merger or asset sale).

4. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax or accounting requirements). No purpose in this notice will require us keeping your personal information longer than 6 months past account closure, unless legally mandated.

5. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Transmission of personal information to and from our Websites is at your own risk.

6. What Are Your Privacy Rights?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time. If you are a resident in the EEA or UK, you have rights to request access, rectification, erasure, restriction of processing, or data portability. You may also withdraw consent at any time by contacting us at support@cometsprouts.com.

7. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. At this stage, no uniform technology standard for recognizing DNT signals has been finalized, so we do not currently respond to DNT browser signals.

8. Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information under the CCPA and California Civil Code Section 1798.83.

Comet Sprouts / Comet Sprouts Academy has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months, and will not sell personal information in the future. California residents can request deletion, know what categories of data are collected, and exercise non-discrimination rights by emailing support@cometsprouts.com.

9. Do We Make Updates To This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this notice.

10. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at support@cometsprouts.com or visit our contact page on cometsprouts.com / cometsproutsacademy.com.

11. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may request access to, changes to, or deletion of the personal information we collect from you. To make a request, please email us at support@cometsprouts.com.