PRIVACY NOTICE

Effective Date: January 16, 2025

This Privacy Notice together with our Terms of Use (“Terms”) (collectively, the “Agreement”) contain the binding terms and conditions between you and Ludex LLC (“Ludex,” “we,” “our,” or “us”), applicable to your access to and use of our Website, located at https://www.ludex.com, TCG Scanner, mobile app, mobile device, and any other application, website, product or tool (collectively, the “Services”) this Privacy Notice is linked or affixed.

Topics:

Why do we collect data?
What data do we collect?
How do we collect your data?
How will we use your data?
What are your data protection rights?
Change to our Privacy Notice
How to Contact us
How to contact the appropriate authorities

Why do we collect data?

At Ludex, we honor the tradition of card collecting while pushing the boundaries of technology to elevate the Hobby and empower our community through trust and transparency. Central to this mission is our commitment to being transparent about the data we collect about you, how it is used in furtherance of our mission, and with whom it is shared.

What data do we collect data?

Ludex recognizes the following categories of personal information referenced in the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, the “California Privacy Laws”) that a business may collect about a consumer. Ludex has collected the following categories of personal information from consumers within the last 12 months:

Categories of Personal Information	The Information We Collect from this Category
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar information.
Commercial Information	Information related to your activities within the Services, including eBay sales activity, collectible behaviors, card collections data, and preferences and behaviors when engaging with our Services.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	Physical location or movements.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Please note that we may not collect each of these categories about every user.

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information otherwise excluded from the California Privacy Laws’ scope.

Ludex has obtained the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, the information we obtain in the course of providing our services to you, or from observing your actions on our website.
From third-party business partners such as social media sites, ad networks, and analytics providers.

How do we collect your data?

You directly provide Ludex with most of the data we collect. We collect data and process data when you:

Register online for a subscription or engage with our products or services on our platform
Voluntarily complete a customer survey or provide feedback on any of our message boards or via email
Participate in our online community discussions
Use the app or view our platform via cookies or log files
Interact with our Customer Experience Representatives through our help and support functions
We also reserve the right to collect personal data from other sources such as credit agencies or bureaus and data providers.
Other

How will we use your data?

Ludex collects your data for various purposes and based on several different legal bases that allow this processing.

Email you with special opportunities which may include opportunities for in person or virtual social interaction
Provide notification of certain collectible items which may be available for a short time on our platform
Provide customer service
Provide you with personalized advertising and marketing communications
Detect, prevent, mitigate and investigate fraudulent or illegal activity
In order to fulfill our contract with you under the Terms and, if applicable, the Payments Terms of Use.
To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
Provide you with a personalized user experience on this website
Provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.

Who we disclose your information to?

We may disclose your personal information to a third party for a commercial business purpose. When we disclose personal information for a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The following sets for the categories of recipients we may share your personal information and why, underlying that not every one of the following may apply to your personal information:

Service Providers: We may share your personal information with third-party companies and individuals that provides services on our behalf or help us operate our Sites and Services (such as payment, customer support, hosting, analytics, email delivery, marketing, shipping and fulfillment, database management, and research services). These third-party service providers are given the information that they need to perform their designated functions and may only use your information as directed or authorized by us and in a manner consistent with this Privacy Notice, and we do not authorize them to use or disclose your personal information for their own or any others’ marketing purposes.

Advertising Partners: We may enable advertising partners to procure information regarding our users for targeted marketing purposes. Third-Party Platforms and Social Media Networks: If you have enabled features or functionality that connect the Services to a third-party platform or social media network, we may disclose the personal information that you authorized us to share. We do not control the third-party’s use of your personal information.

Compliance, Fraud Prevention and Safety: On rare occasions, we may also be required to disclose your information as is required by law pursuant to lawful requests, such as subpoenas, court or agency orders, or as we may reasonably determine to be necessary to protect our rights or the rights of others, to avert harm to persons or property, to enforce this Privacy Notice or the terms governing our Services, and to protect investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

The sale or sharing of your personal information

The California Privacy Laws define a “sale” of information as essentially any exchange of consumers’ information for essentially anything of value. Thus, while Ludex is not in the business of selling your Personal Information, we may sell or rent your personal information within the California Privacy Laws’ broad definition of the term.

In the preceding twelve (12) months, we have not sold any personal information.

The California Privacy Laws define “sharing” information as doing so for the purpose of cross-behavioral advertising. We do not share the information we collect about you for this purpose.

User-Generated Content

You may share personal data with us when you submit user-generated content to the Services, including photographs. We urge you to be very careful when deciding to post sensitive photographs to our Services.

Children’s Privacy

Our Services are not directed to and only available for those over the age of 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers. If you are under 13, do not provide any personal information through the services.

International Users

Our data is maintained in the United States. All information we collect is gathered, stored, used, and otherwise processed in the United States, including information from individuals outside the United States. By accessing our Services, you consent to the transfer to and use of your information in the United States in accordance with this notice and applicable law.

We may transfer the personal information we collect about you when providing you with Services, to recipients in countries other than the country in which the information was originally collected, including to the United States, where we are headquartered. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g., via a program specific privacy notice provided to you at sign up, and from time to time). You understand and agree that while in the United States or foreign jurisdictions, your personal information may be accessible to law enforcement or other governmental authorities or bodies.

What are your data protection rights?

Ludex would like to make sure you are fully aware of all of your data protection rights. California residents are entitled to the following and as to the extent we become subject to any other state consumer-facing data privacy laws, residents in those states will also have the following rights, subject to the specific protections or requirements of those specific state laws:

The right to access and data portability

You have the right to request Ludex for copies of your personal data. Unless prohibited by applicable law, we may charge you a small fee for this service. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each
- category of recipient obtained.

Under certain circumstances and to the extent technically feasible, you have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity. When you make a request to know specific pieces of information, the report we will provide will be in a structured, commonly used, and machine-readable format.

The right to erasure

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which We collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to correct

Subject to some exceptions, you have the right to request the correction of personal information we have collected about you.

Right against Discrimination

You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising any of your data privacy rights. Unless permitted by applicable law, we will not:

Deny you goods or services
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you with a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to opt out of the sale of your information.

As noted above, we may disclose your information to third parties for their direct marketing purposes.

If you would like to opt-out of such disclosures, please contact us at Support@ludex.com or call (312) 569-0810.

Exemptions

Before responding to any request Ludex will check whether there are any exemptions under applicable law that may apply to the personal information that are the subject of the request. Exemptions may apply under applicable law where it is necessary and proportionate not to comply with the requests including:

national security;
defense;
public security;
the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
the protection of judicial independence and judicial proceedings;
the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in a. to e. and g. above;
the protection of the data subject or the rights and freedoms of others; or
the enforcement of civil law claims.

How to exercise your rights

To exercise your rights contact us at Support@ludex.com or call (312) 569-0810.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom We collected personal information or an authorized representative, which may include:
- Proving an ability to access the relevant password-protected account or the email address we have on file for the account.
- A designation of you as an authorized representative by the person about whom we have collected personal information, or other proof that you are their authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will make commercially reasonable efforts to identify your personal information that we collect, process, store, disclose and otherwise use, and to respond to your requests. We reserve the right to charge a reasonable fee, or decline to act upon a request, if it is excessive or overly burdensome. If we deny your request, we will explain the reasons in our response.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Authorized agents

If you are a registered agent and want to submit a request on behalf of a California consumer with a registered eBay account in good standing, you should work with the user to submit an access request directly through his or her account.

You will need to provide Proof of Identity (POI) and Proof of Address (POA) for the consumer on whose behalf you are submitting the request and proof that you are authorized to act on their behalf. Only after verifying both your authorization to act and proof of the requestor’s identity will we fulfill the request.

If the name, address, or email address you provide us for the consumer on whose behalf you are submitting the request does not match what is in our records, we will not be able to process the request.

Canadian Users – Opt Out

If you are a Canadian resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes by contacting us by phone at (312) 569-0810; e-mailing us at: Support@ludex.com; or writing us at the address provided in the “Contact Us” section below. Canadian residents can opt out of secondary marketing uses of your personal information by Ludex or our business partners by contacting us at the address provided.

Data retention

The time we retain personal information may vary depending on the Services we provide, and our legal obligations under applicable law. The following factors typically affect the retention period:

Necessity for the provision of our Services: This includes things such as executing the Terms, maintaining and improving the performance of our Services, keeping our systems secure, and maintaining appropriate business and financial records. Most retention periods are determined on the basis of this general rule.
Consent-based processing of personal information: If we process personal information on the basis of consent (including consent to the extended storage), we store the information for as long as necessary in order to process it according to your consent.
Statutory, contractual or other similar obligations: We may be required to retain information for certain periods of time pursuant to applicable laws or official orders (e.g. for legal compliance, tax, accounting or auditing purposes), or to detect and prevent fraudulent or illegal activity on eBay. We may also retain personal information relating to pending or future legal disputes. Personal information contained in contracts, notifications and business letters may be subject to statutory storage obligations. We store the data for as long as necessary to comply with these obligations.

California Practice Law Metrics

The California Privacy Laws require us to track and publish the below metrics for the previous calendar year. The below metrics are our calculations from January 1, 2024 through January 1, 2025, and include requests from all individuals in the U.S.

Metric	Number
Number of Access requests (“Requests to Know”) received	1
Number of Access requests complied with in whole or in part	1
Number of Access requests denied	0
Mean or Median number of days to substantively respond to Access requests	1
Number of Deletion requests received	8
Number of Deletion requests complied with in whole or in part	8
Number of Deletion requests denied	0
Mean or Median number of days to substantively respond to Deletion requests	1
Number of Opt-out requests received	0
Number of Opt-out requests complied with in whole or in part	0
Number of Opt-out requests denied	0
Mean or Median number of days to substantively respond to Opt-out requests	0

Do Not Track

Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to do no track (“DNT”) signals respond to them at this time.

California’s Shine the Light Law

If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.

Cookies

When you use our Services, we and authorized third-party providers make use of cookies and similar technologies (which we will refer to collectively as “cookies”). We make use of two main types of cookies: those which will not be saved on your device or which will only be saved on your device for as long as your browser is active (called session cookies); and those which will be saved on your device for a longer period (called persistent cookies). We take appropriate security measures to prevent unauthorized access to our cookies.

The cookies used in connection with the Services have various functions:

They may be (technically) necessary for the provision of our Services
They help us to technically enhance our Services (e.g. monitoring of error messages and loading times)
They help us to recognize you so we can improve your user experience (e.g. by saving the font size and data entered into webforms)
They enable us to show you more relevant ads.

Your choice options for the use of cookies relating to our Services will depend on the purposes for which we use these technologies.

Consent to Sharing Information with Pixel Providers

Our Services use pixels, which are tools provided by various platforms, to help us measure the effectiveness of our advertising and understand user interactions with our Services. These tools allow us to collect and share certain information about your use of the Services, including device information, IP address, browsing behavior, and other online identifiers with those third-party pixel providers.

By using our Services, including interacting with our Website, scanner, or mobile app, you agree and otherwise consent to the sharing of this information with the third-party pixel providers for the purposes of improving a targeting and analytics. Those third-party pixel providers may combine that information with other data it may hold about you to serve targeted advertisements based on your online activities. For more details on how Meta processes your data, please refer to Meta’s Data Policy.

We encourage you to manage your browser-based cookies by adjusting your device browser settings (e.g., Chrome, Edge, Firefox, Internet Explorer, or Safari). You can choose whether you want to consent or not consent to the use of pixels by managing your preferences on our Website www.Ludex.com.

Data Security

We protect your personal information through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration. To this end we use network security services and data encryption, for example, as well as physical access restrictions for our data centers and logical access controls for data and systems access. However, given that our Services are via the Internet, we cannot guarantee that your personal information will remain protected as nefarious acts of third parties can interfere with our protection measures.

Consent to Receive Electronic Notifications

Electronic communication is the most effective and timely way to provide the users of the Website and Services with any optional or required notifications and disclosures. In some circumstances, however, applicable laws may require us to send you disclosures or communications in paper format unless you have affirmatively consented to receiving electronic notifications only in advance of the notification. Through this Privacy Notice, pursuant to 15 U.S.C. § 7001, you hereby affirmatively consent to receive electronic notifications and disclosures from us only (without requiring a paper copy) and you represent that, to date, you have not withdrawn such consent. You have the right to change your mind and withdraw your consent at any time. If you would like to withdraw your consent to receive electronic notifications and/or would like to request paper copies of any required notifications you receive electronically, you may contact us. To receive electronic records, you will need access to a smartphone, tablet, laptop or computer with internet access and an email account.

In the event you receive marketing email communications from us and no longer wish to, you can click the “Unsubscribe” link at the bottom of any marketing email to opt out of further marketing communications. Please note that this opting out is only effective for marketing communications as we will still communicate with you via email regarding transactional issues, such as to confirm a purchase or to provide you information about a purchase.

Change to our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, We will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

How to Contact us

Should you have any questions about Ludex’s Privacy Notice, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. Our Data Protection Officer is Ryan Fischer, and he can be reached at the following:

By email: Support@ludex.com

By visiting this page on our website: https://www.ludex.com

By mail: 223 W. Erie St. Suite 6E Chicago, IL 60657, United States