Privacy Policy

Last Updated: 12 July 2024

This Privacy Policy applies to information that we collect about you when you use our website, mobile application, and other products and services (collectively “Services").

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources.

Information You Provide to Us

Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Ludoly account to provide an email address and password, along with a username or name — and that's it. You may provide us with more information — like your address and other information you want to share — but we don't require that information.
Public profile information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Ludoly account, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me" description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For example, if you buy something from us we'll collect information to process those payments and contact you.
Communications with us: When you communicate with us via email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically

We also collect some information automatically:

Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system's permissions.
Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system's permissions. For example, if you give us permission to access the photographs on your mobile device's camera roll, our Services may access the photos stored on your device when you upload a profile image.
Information from cookies and other technologies: A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Ludoly uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may also get information about you from other sources. For example:

Third Party Login: If you create or log in to your Ludoly account through another service (like Google) we'll receive associated login information (e.g. a connection token, your username, your email address)

The information we receive depends on which services you use or authorise and what options are available.

Third-party services may also give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analysing how users interact with our Services so we can create new features that we think our users will enjoy.
To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analysing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Ludoly and others, which may result in us, for example, declining a transaction or terminating Services.
To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
To customise the user experience. For example, to personalise your experience by serving you relevant notifications and advertisements for our Services.
To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Ludoly. If you don't want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we'll still send you important updates relating to your account.)

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalise your experience; or

(5) You have given us your consent — for example before we place certain cookies on your device and access and analyse them later on, as described in our Cookie Policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called 'Ads and Analytics Services Provided by Others':

Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (such as payment providers that process your credit and debit card information, fraud prevention services that allow us to analyse fraudulent payment transactions, cloud storage services, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and those who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).
Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Ludoly, third parties, or the public at large.
Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Ludoly goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
With your consent: We may share and disclose information with your consent or at your direction.
Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customised ad campaigns on other platforms.
Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

How Long We Keep Information

We generally discard information about you when it's no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we're not legally required to keep it.

For example, we keep web server logs that record information about a visitor to Ludoly's website, like the visitor's IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyse traffic to Ludoly's website and investigate issues if something goes wrong.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorised access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information.
Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps.
Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
Set your browser to reject cookies: At this time, Ludoly does not respond to “do not track" signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Ludoly's website, with the drawback that certain features of Ludoly's website may not function properly without the aid of cookies.
Close your account: While we'd be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR"), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

Request access to your personal data;
Request correction or deletion of your personal data;
Object to our use and processing of your personal data;
Request that we limit our use and processing of your personal data; and
Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Laws in some US states require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You'll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).

In the last 12 months, we collected the following categories of personal information, depending on the Services used:

Identifiers (like your name, contact information, and device and online identifiers);
Commercial information (your billing information and purchase history, for example);
Internet or other electronic network activity information (such as your usage of our Services);
Geolocation data (such as your location based on your IP address);
Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the 'Information We Collect' section above.

We collect personal information for the business and commercial purposes described in the 'How and Why We Use Information' section. And we share this information with the categories of third parties described in the 'Sharing Information' section. We retain this information for the length of time described in our 'How Long We Keep Information' section.

In some US states you have additional rights subject to any exemptions provided by your state's respective law, including the right to:

Request a copy of the specific pieces of information we collect about you and, if you're in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
Request deletion of personal information we collect or maintain;
Request correction of personal information we collect or maintain;
Opt out of the sale or sharing of personal information;
Receive a copy of your information in a readily portable format; and
Not receive discriminatory treatment for exercising your rights.

Right to Opt Out

We never directly sell your personal information in the conventional sense (i.e., for money).

We may share your information as necessary with our third-party service providers to provide our services to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a “sale" or “share" in certain U.S. States, which you may have the right to opt out of.

You can learn more about this sharing and how to opt out by clicking the “Do Not Sell My Personal Information" link in the footer of our websites, or from the settings page within our apps. Note that in some instances this link will only display to individuals visiting our sites from within the relevant states.

Our opt-out is managed through cookies, so if you delete cookies, your browser is set to delete cookies automatically after a certain length of time, or if you visit sites in a different browser, you'll need to make this selection again.

We also respect the GPC browser signal and will treat it as a valid means of communicating your desire to opt out.

We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don't knowingly sell or share personal information of those under 16.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren't able to or you'd like to contact us about one of the other rights, scroll down to 'How to Reach Us'.

When you contact us about one of your rights under this section, we'll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorised agent to make a request on your behalf by giving us written authorisation. We may still require you to verify your identity with us.

Appeals Process for Rights Requests Denials

In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.

In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing.

If your appeal is denied, in some US states you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the 'Your Rights' section above, please contact us via email.

Other Things You Should Know

Transferring Information

Because Ludoly's Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the 'How and Why We Use Information' section above.

When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include entering into European Commission approved standard contractual arrangements with entities based in countries outside the EEA.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Privacy Policy Changes

Although most changes are likely to be minor, Ludoly may change its Privacy Policy from time to time. Ludoly encourages visitors to frequently check this page for any changes to its Privacy Policy. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Translation

Our Privacy Policy was originally written in English. We may translate it into other languages.

In the event of a conflict between a translated version of our Privacy Policy and the English version, the English version will control.