Effective Date: September 14, 2026
Last Updated: February 5, 2026
This Privacy Notice explains how Ludex Inc ("Ludex," "we," "our," or "us") collects, uses, and discloses information about you when you use our website, mobile application, and related online services (collectively, the "Services"). Please read this Privacy Notice carefully. This Privacy Notice describes our information practices and does not by itself constitute consent where explicit and/or affirmative consent is otherwise legally required. Where applicable law requires explicit and/or affirmative consent, we will request it separately; otherwise, this Privacy Notice constitutes consent.
For details on how to manage your preferences, see Section 10, Your Rights and Choices. This Privacy Notice applies globally to all users of the Services and should be read together with any region-specific notices that apply to you. The data-licensing activities described in Sections 4, 5, and 10 are currently limited to personal information relating to individuals in the United States and approved U.S. business customers, unless we provide additional notice or obtain any consent required by applicable law.
For clarity in this Privacy Notice:
We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make changes, we will post the updated version on the Services with a revised "Last Updated" date. If we make material changes, we will also provide additional notice, such as by email or within the Services, if and as required by applicable law. Your continued use of the Services after the updated Privacy Notice is posted constitutes your acceptance of the changes unless where applicable law requires explicit and/or affirmative consent, in which case we will obtain such consent.
When you interact with the Services, we collect information to operate, improve, and protect the Services. This includes information (a) you provide directly, (b) information collected automatically, and (c) information we receive from other sources.
We collect information you submit directly through the Services, which may include the following:
Some features may require you to provide specific information. If you choose not to provide it, certain functionalities may be limited.
We automatically collect certain information about your interactions with the Services to help us understand usage patterns, improve performance, and enhance your experience. This data is collected through cookies, log files, and similar technologies, and may include:
This data is often collected in aggregate form and does not directly identify you unless linked to your account or other personal information.
We use cookies and similar technologies to collect usage data, personalize content, and improve the functionality of our Services. Cookies are small data files stored on your device that help us recognize repeat visitors, track usage trends, and deliver relevant content.
You can manage your cookie preferences through your browser settings. Most browsers are set to accept cookies by default, but you may choose to remove or reject cookies. Disabling cookies may impact the availability and functionality of certain features within the Services.
For more information about the types of cookies we use, the purposes they serve, and how to manage them, please see our Cookie Policy.
In some cases, we use the usage data we collect to make inferences about your preferences, interests, or behavior. These inferences help us:
These inferences are generated using automated systems and are based primarily on your interactions with the Services. You may be able to opt-out of certain personalization features, targeted advertising, data licensing or promotional communications by adjusting your account settings, using our Your Privacy Choices link, or contacting us directly. For more information, see Section 10, Your Rights and Choices, below.
We may also receive information about you from third party sources, including:
Any information we obtain from third parties is handled in accordance with this Privacy Notice. For more details on how third-party websites and links are treated, see Section 7, Third-Party Services, Features, and Links below.
We use the information we collect to provide, maintain, and improve the Services. This includes fulfilling our contractual obligations, enhancing your experience, and supporting business operations. Specifically, we may use your information to:
We may also de-identify or aggregate your information so that it no longer identifies you. This data may be used for analytics or other purposes consistent with this Privacy Notice.
We may disclose your information to third parties in the ways described in this Privacy Notice, including to provide and improve the Services, comply with legal obligations, and protect our rights. We disclose your information only as described below and in accordance with applicable law.
Service Providers: We disclose your information to third-party companies and individuals that provide services on our behalf or help us operate the Services, including payment processing, customer support, hosting, analytics, email delivery, marketing, shipping and fulfillment, database management, security, and research services. These service providers are contractually required to use your information only as necessary to provide the requested services to us.
Affiliates: We disclose your information to our affiliates for purposes consistent with this Privacy Notice, including to operate and improve the Services, provide customer support, and offer relevant products and services, and develop and license data products. This includes disclosure to CDS as describes below.
Advertising Partners: We disclose certain personal information to advertising partners to deliver targeted advertising, measure ad performance, and improve relevance. Some of these disclosures may be considered a "sale" or "sharing" under applicable privacy laws. See Section 10, Your Rights and Choices below for details.
Business Partners: We disclose your information to business partners with whom we jointly offer products or services, or whose offerings may be integrated with our Services. We disclose only the information necessary for these partners to provide or improve their offerings.
Data Licensing Partners and Customers: We disclose identifiers, including email addresses, commercial information, internet or network activity, and inferences to CDS for data licensing and commercialization. CDS may license those categories to select, verified business customers and their approved email service providers or activation providers for specifically approved purposes. Email addresses may be provided in hashed form or, for select approved customers that cannot use hashed identifiers, in directly readable form. Written agreements restrict the customer's purpose, retention, security, onward disclosure, resale, and use; require the customer to honor deletion, opt-out, and suppression instructions; and prohibit the use of licensed data as evidence of consent to send email, texts, or telephone calls. We do not include known minors or sensitive personal information in data-licensing products.
Data Aggregator and Data Provider Partners: We may disclose your information to authorized data aggregator and data provider partners for source matching, quality assurance, analytics, market research, suppression, and other lawful purposes described in this Privacy Notice. Where required by applicable law requires consent, we will obtain it before making the disclosure.
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 disclose the information that you authorize us to share.
Legal and Compliance: We may disclose your information if we believe it is necessary to:
Corporate Transactions: If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be disclosed as part of that transaction, subject to applicable law.
With Your Consent: We may disclose your information for any other purpose disclosed to you at the time of collection, or with your consent.
Note: Certain disclosures described above may be considered a sale or sharing of personal information under U S state privacy laws. For more information, including how to exercise your rights, see Section 10, Your Rights and Choices below.
Our Services are intended for individuals age 16 and over. We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent, and we do not knowingly sell or share the personal information of any consumer under 16 unless the affirmative authorization required by applicable law has been obtained. Because our Services currently do not include an age-verification feature, it is possible that information from younger users could be submitted without our knowledge.
If you are a parent or guardian and believe that your child under 16 has provided us with personal information in a manner not permitted by law, please contact us at support@ludex.com. We will take appropriate steps, including deletion where required.
Separate from applicable legal opt-in thresholds, our data-licensing program is designed to exclude personal information of individuals we know or reasonably should know are under 18. We do not knowingly provide directly readable email addresses or other licensed identifiers of minors to CDS, data licensing customers, or their approved providers.
The Services may include social sharing features and other integrated tools, such as the Facebook "Like" button and embedded content such as videos or interactive media. Using these features could allow you to share certain information with your contacts or the public, subject to the privacy settings you maintain with the third-party provider.
For more information about how these third parties handle the information they collect, please review their privacy policies. Additional details about cookies or similar technologies associated with these integrations can be found in our Cookie Policy.
The Services may also include links to or integrations with third party websites. We have no control over the information that is collected, stored, or used by third party websites, and we are not responsible for their information handling or privacy practices. Your use of these third-party websites is subject to each provider's privacy policy, so we encourage you to read these policies carefully.
We may allow third parties to provide analytics services in connection with our Services, and we may include third party content or integrations that use cookies or similar technologies. These entities may collect technical and usage information from your device and activity across the Services and other websites over time.
This information may be used by us and by others to, among other purposes, analyze usage trends, measure the effectiveness of content, deliver or personalize advertising (including interest-based advertising), and improve the functionality of the Services. Where required by law, these technologies are used only with your consent.
To learn more about the specific cookies and technologies we use, and how you can manage your choices, including opting out of certain interest-based advertising, please see our Cookie Policy.
We keep information for as long as needed to provide the Services and for other essential purposes, such as complying with legal obligations, resolving disputes, and enforcing our agreements. The length of time we retain information depends on factors such as the type of information, the reasons it was collected, and applicable legal or operational requirements.
Once information is no longer needed for the purposes for which it was collected, or for another legally permissible business need, we will use commercially reasonable measures to delete it or de-identify it, unless we are required or permitted by law to keep it for longer.
For data-licensing products, approved customers receive time-limited rights and are required to delete or render inaccessible the licensed personal information at the end of the approved usage period, subject to limited backup exceptions. Ludex, CDS, customers, and approved providers may retain restricted suppression information solely to honor privacy rights, email unsubscribes, and do-not-contact instructions and to prevent an identifier from being reintroduced or used again. We may also retain records of disclosures, requests, and compliance actions as required by law or for audit and enforcement purposes.
We respect your privacy rights and provide various ways for you to manage your information. Some rights apply to all users, while others apply only in certain jurisdictions.
Regardless of where you live, you may have the right to:
You may exercise these rights as described in Section 10.5 (How to Exercise Your Rights).
EU/EEA, Switzerland, and UK: If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have certain rights under the GDPR or UK GDPR. In this section, we use the term personal data as it appears in those laws. In Section 1, Key Terms, personal information has the same meaning as personal data for these purposes. You may have the right to:
We process your personal data only when we have a lawful basis to do so. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.
Canada: You have rights under PIPEDA, including the right to challenge our compliance and to be informed of transfers outside Canada. You may withdraw consent at any time, subject to legal or contractual restrictions. You may also request written information about our policies and practices relating to the management of personal information by contacting us using the details in Section 15, Contact Us below.
Canadian Users Opt-Out: If you are a Canadian resident, you may ask us to refrain from sharing your personal information with certain affiliates and other third parties for their marketing purposes by contacting us by phone at (312) 569-0810, emailing us at support@ludex.com, or writing to us at the address provided in Section 15, Contact Us below. Canadian residents may also opt-out of secondary marketing uses of personal information by us or our business partners by using these contact methods.
Certain U.S. States: Residents of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have the following rights, subject to exceptions:
We will not discriminate against you for exercising these rights.
An opt-out sale or sharing applies to email addresses and other identifiers regardless of whether the identifier is maintained or disclosed in hashed or directly readable form.
As defined under applicable U.S. state privacy laws, we may have sold or shared certain categories of personal information during the preceding 12 months for purposes including advertising, marketing, analytics, and data licensing. These categories are described in Section 12, Categories of Personal Information We Collect below.
Examples include:
You may opt-out of these sale and sharing activities as described in Section 10.2, Additional Rights by Region, and Section 10.5, How to Exercise Your Rights. An applicable opt-out or deletion request is applied to directly readable and hashed forms of the identifier and associated consumer-level records and is communicated to CDS and participating data licensing customers or approved providers as required by law. We may retain limited suppression information solely to prevent the information from being reintroduced or used again.
We do not knowingly sell or share the personal information of consumers under 16 without the affirmative authorization required by applicable law, and our data-licensing program is designed to exclude individuals we know or reasonably should know are under 18. For more information, see Section 6, Children's and Teen Privacy, above.
| Category of Personal Information | Sold or Shared? | Categories of Third Parties (Sale/Share) | Disclosed for a Business Purpose? | Categories of Third Parties (Business Purpose) |
|---|---|---|---|---|
| Identifiers | Yes (sold/shared) | Advertising networks; analytics providers; Collectors Datastore LLC; select data licensing customers; and approved email service providers or activation providers acting for those customers | Yes | Payment processors; customer support providers; fraud prevention partners; hosting and security providers; email delivery providers |
| Account Credential and Payment Data | No | N/A | Yes | Payment processors; fraud prevention and security providers; hosting and account-administration providers; customer service providers |
| Commercial Information | Yes (sold/shared) | Advertising networks; analytics providers; Collectors Datastore LLC; select data licensing customers; and approved providers acting for those customers | Yes | Fulfillment providers; analytics providers; customer support providers |
| Internet or Network Activity | Yes (sold/shared) | Advertising networks; analytics providers; Collectors Datastore LLC; selected data licensing customers; and approved providers for those customers | Yes | Security partners; analytics providers; customer support providers |
| Geolocation Data | Yes (limited to approximate geolocation; we do not sell or licens precise geolocation) | Advertising networks and analytics providers | Yes | Fraud prevention partners; analytics providers; location-service providers |
| Inferences | Yes (sold/shared) | Advertising networks; analytics providers; Collectors Datastore LLC; select data licensing customers; and approved providers acting for those customers | Yes | Analytics providers; marketing partners; product-development providers |
| Sensitive Personal Information | No | N/A | Yes, only as necessary for permitted operational purposes | Security and fraud-prevention providers; payment processors; account-administration providers; location-service providers, as applicable |
Notes:
You can exercise your privacy rights by submitting a request through our Your Privacy Choices / Do Not Sell or Share My Personal Information link, by emailing us at support@ludex.com, or by mail to the address in Section 15. We recognize applicable universal opt-out preference signals, where required by law. We will verify your identity when required before processing your request and respond within the timeframes required by applicable law.
For California-resident requests, we will confirm receipt within 10 business days of a request for access/know, to delete, or to correct and we will process an opt-out of sale/sharing as soon as feasibly possible, but no later than 15 business days after receipt. We will notify relevant third parties as required by law or contract. If you choose to have someone act on your behalf, please review the following requirements.
Authorized Agents: California residents may also exercise their rights through an authorized agent. To do so, the agent must provide proof of their authorization, such as a signed written permission from you or a valid power of attorney. We may also require you to verify your identity directly with us and confirm that you have authorized the agent to act on your behalf, as permitted by California law.
Nevada Residents. To opt out of the sale of your personal information, submit a verified request to our designated request address support@ludex.com, subject line "Nevada Do Not Sell".
When an applicable request concerns personal information disclosed for data licensing, we will apply the request to directly readable and hashed forms of the identifier and associated records and will communicate the request to CDS and participating customers or approved providers as required by law.
If we deny your request, you may appeal by emailing us at support@ludex.com with the subject line "Appeal of Privacy Request."
If you are in Colorado, Oregon, or New Jersey, we will decide your appeal within 45 days after receiving it. If you are in Connecticut, Nebraska, New Hampshire, Maryland, Texas, or Virginia, we will decide your appeal within 60 days after receiving it.
For all appeal responses, we will explain our decision and how to contact your state Attorney General if you remain unsatisfied.
In states where applicable, you may opt out of targeted advertising and, where provided by law, opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
California residents may request information about our disclosures of personal information to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please contact us by email at support@ludex.com or by writing to the address provided in Section 15, Contact Us below.
You can control certain types of information we collect and how we communicate with you.
Account Information: Update, correct, or delete certain account details by contacting us at support@ludex.com. If you request deletion or deactivation, we may retain information as required by law or for legitimate business purposes.
Location Information: If our mobile application collects precise location information, you will be asked to consent when you first use the app. You can withdraw consent in your device settings or by uninstalling the app. Disabling location services may affect certain features.
Cookies and Similar Technologies: Manage cookies through your browser settings. For details on our use of cookies and related technologies, see our Cookie Policy. Disabling cookies may affect the availability and functionality of our Services.
Promotional Communications: Opt-out of promotional emails or texts from Ludex by following the instructions in those messages or contacting us. We may still send non-promotional messages related to your account or our ongoing business relationship. Unsubscribing from Ludex promotional communications does not by itself opt you out of the sale or sharing of personal information; use the Your Privacy Choices link for that purpose. If you receive a commercial email from a data licensing customer, you may use the unsubscribe method in that message and may separately use our Your Privacy Choices link to prevent future data-licensing disclosures, subject to applicable law.
Push Notifications: With your consent, we may send push notifications to your device. You can disable these in your device settings.
| Category | Examples | Purposes | Legal Bases* |
|---|---|---|---|
| Identifiers | Name, postal address, email address in hashed or directly readable form, phone number, username, IP address, device ID | Provide and maintain services; account management; personalization; marketing; security; legal compliance; audience matching; analytics; data licensing; and, for select approved customers, direct email marketing of the customer's own products or services | Contract performance; legitimate interests; consent (where required); legal obligation |
| Account Credentials and Payment Data | Username, password, other account credentials; billing/shipping address; payment confirmation; payment-card information handled by payment processors | Account administration; authentication; security payment processing; or fulfillment; fraud prevention | Contract performance; legitimate interests; legal obligation; consent (where required) |
| Commercial Information | Purchase and order history, ownership or collection activity, product interactions, preferences | Fulfill orders; personalize services; marketing; analytics; product improvement; targeted advertising; audience segmentation; data licensing | Contract performance; legitimate interests; consent (where required) |
| Internet or Network Activity | Browsing and search history, pages visited, features used, interactions with ads or emails, device and usage activity | Service functionality; analytics; personalization; targeted advertising; security; audience segmentation; data licensing | Legitimate interests; consent (where required) |
| Geolocation Data | Approximate location from IP address or precise location if you have granted device-level permission | Personalization; fraud prevention; targeted advertising; analytics. We do not include precise geolocation is data-licensing products. | Legitimate interests; consent (where required) |
| Inferences | Profiles reflecting preferences, characteristics, behaviors, and interests | Personalization; marketing; analytics; product improvement; audience segmentation; data licensing | Legitimate interests; consent (where required) |
| Sensitive Personal Information | Account log-in credentials; precise geolocation if enabled; contents of communications when Ludex is the intended recipient; other sensitive information you choose to provide | Account security; fraud prevention; location-enabled features; customer support; legal compliance. We do not sell or license sensitive personal information in data products | Contract performance; legal obligation; legitimate interest; consent (where required) |
*Legal bases apply to jurisdictions that require them (e.g., GDPR and UK GDPR). The data-licensing program described in this Privacy Notice excludes sensitive personal information and known minors and limits directly readable email to approved U.S. uses and customers.
Our Services are operated in the United States, and your information may be transferred to, stored in, and processed in the United States and other countries. These countries may not provide the same level of data protection as your home country.
The directly readable email data-licensing activities described in this Privacy Notice are currently limited to U.S. personal information, approved U.S. business customers, and U.S.-approved access locations. We do not authorize access to directly readable email from outside the United States unless the proposed transfer has received a separate legal and security review and any required notice or consent has been provided.
The California Privacy Laws require us to track and publish the following metrics for the previous calendar year. The metrics below reflect our calculations from January 1, 2024 through January 1, 2025, and include requests from all individuals in the United States.
| 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 |
For more information about our privacy practices, or if you have any questions, inquiries, or complaints about the collection or use of your information, please contact us by e-mail at support@ludex.com or by mail using the details provided below:
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