Ludeo LTD - Privacy Policy
This Privacy Policy (the “Privacy Policy”) is designed to inform you as to how Ludeo Ltd. (referred to as “Ludeo”, “we”, “us” or “our” in this Privacy Policy) handles your Personal Data in connection with your use of the Ludeo Services (as defined below) and to notify you about your privacy rights and how the law protects such rights.
“Personal Data” means any information about an individual from which that person can be identified.
The term “Ludeo Services” includes the following services offered by Ludeo:
a) the “Platform” – Ludeo’s proprietary playable social media platform, which is developed, managed and made available by Ludeo as a web-based platform service via the internet (available at beta.ludeo.com and its subdomains), which allows its users to create, play, and share gameplay moments (“Ludeos”) and engage with other users;
b) the “Ludeo SDK” – a software development kit offered by Ludeo to game studios and embedded in their games; and
c) the “Ludeo Cloud” – a cloud-based software-as-a-service offered by Ludeo using a third-party provider, that provides users the ability to experience some of the services offered on the Platform.
This Privacy Policy supplements other policies we may provide as part of our interactions with you or policies you may have received from other controllers and is not intended to override such policies.
This Privacy Policy is provided in a layered format below.
The Data We Collect About You
How We Collect Your Data
How We Use Your Data
Sharing Your Data with Third Parties
International Transfers
Data Security
Data Retention
Your Rights
Accessibility
Contact Details
Changes to this Privacy Policy
1. The Data We Collect About You
The following table explains what types of Personal Data we may collect in each of the Ludeo Services:
| Type of Data | Platform | Ludeo SDK | Ludeo Cloud |
|---|---|---|---|
| User Data includes a user ID that you used for registering to the Ludeo Services, or that we received from a game studio that uses the Ludeo SDK. In case that you used a third-party authentication service (e.g., Steam, Apple, Google) to log into the Ludeo Services or a game that uses the Ludeo SDK, User Data may also include additional details from that authentication service. For example, if you log into Ludeo or a game that uses the Ludeo SDK using your Steam Account, we will receive your Steam ID, Steam nickname and Steam profile picture. If you log into Ludeo using Apple or Google account, we will receive your Apple ID or Google ID and additional information that you chose to share with us through your Apple or Google settings (e.g., your name and Contact Data). | ✓ when logged-in |
✓ | ✓ when logged-in |
| Contact Data includes your email address. | upon registration | upon registration | upon registration |
| Activity Data includes information about how you use or interact with the Ludeo Services (such as, when you entered a Ludeo Service, how long you stayed in the Ludeo Service and/or a specific game or video in the Ludeo Service, impressions, mouse clicks and hovers). When you use the Platform, this also includes data regarding your activity on the Platform, such as comments that you made, Ludeos that you played, challenges in which you participated, and the scores you achieved. | ✓ | ✓ | ✓ |
| Gameplay Data includes game events, such as shots, runs, jumps, character’s health, etc. | ✓ | ✓ | |
| Gameplay Recording includes a recording of your game screen. Such recording is stored locally in the game disposal memory for a short period of time when you play games that contain the Ludeo SDK, and is not uploaded to Ludeo unless you choose to “capture” it. The Gameplay Recording does not capture any other apps or items on your screen, other than the game you are playing and does not capture your screen outside of the game. | ✓ | ||
| Technical Data includes information on your internet connection (such as your IP address and internet service provider name), on the device and software that you are using to access the Ludeo Service (e.g., your web browser type and device operating system and language), and on your device hardware (e.g., CPU, memory). | ✓ | ✓ | ✓ |
| Device Performance Data includes information regarding the performance of the device that you are using, such as game FPS (frames per second), CPU utilization etc. | ✓ | ✓ | |
| Additional Inquiry Data includes additional information that you may provide when you use the Platform (e.g., through chat or posting comments), contact us through the Platform or when you sign up for any of our services. | ✓ |
We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered Personal Data. For example, we may aggregate your Activity Data to calculate the percentage of users accessing a specific feature available through the Ludeo Services.
Protecting the Privacy Rights of Third Parties
If you provide to us any Personal Data relating to others, you must make sure that you have permission to do so.
2. How We Collect Your Data
We use different methods to collect data from and about you including through:
Direct interactions. When you register to use the Ludeo Services, contact us through our Platform, or otherwise provide your Personal Data directly to us, you will be asked to provide us with your User Data and Contact Data so that we can provide our services to you, respond to your questions or requests, or otherwise contact you. You may also provide Additional Inquiry Data when you contact us, and you will share with us your Gameplay Recording when you choose to “capture” it, as explained above.
Automated technologies or interactions. As you interact with the Ludeo Services, we automatically collect the applicable Technical Data, Device Performance Data, Activity Data, and Gameplay Data, as detailed above. We collect this data by using cookies, server logs, and other similar technologies
Third parties or publicly available sources. We may receive Technical Data, Activity Data and Gameplay Data about you from third parties, such as data that we may receive from studios whose games use the Ludeo SDK, analytics providers, and from advertising and marketing partners. Additionally, if you register to the Ludeo Services with any of the third-party authentication services (e.g., Steam, Google, or Apple), we may receive your User Data and Contact Data from them.
You are not legally obligated to provide any Personal Data to Ludeo. Any Personal Data that you choose to provide to Ludeo, is provided at your own free will.
3. How We Use Your Data
We will only use your Personal Data when permitted by law. We will commonly use your Personal Data in the following circumstances:
Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.
Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate interest means our interest in managing and conducting our business.
Where the processing is necessary for compliance with a legal or regulatory obligation.
Where you have provided your consent for such processing. Such consent can be revoked at any time.
Purposes for Which We Use Your Data
Below is a description of the ways we use your Personal Data. To the extent that the GDPR and UK GDPR apply, we have mentioned the legal bases we rely on to use your Personal Data, and identified what our legitimate interests are where appropriate:
We use your User Data and Contact Data to enter into or fulfill a contract with you. We use your Activity Data, Technical Data, Device Performance Data, Gameplay Data, and Gameplay Recording for the performance of a contract with you (to provide the Ludeo Services to you).
We use your Contact Data and Additional Inquiry Data to respond to your requests or questions and to manage our relationship with you. We do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests.
We use your Activity Data, Gameplay Data, Gameplay Recording, Technical Data, Device Performance Data, and Contact Data for marketing purposes, to deliver relevant and personalized content to you and to deliver special offers to you, as well as service messages (for example, for security purposes) including via email and to measure or understand the effectiveness of our marketing efforts. We do so where it is necessary for our legitimate interests (to grow our business, to inform our marketing strategy and to maintain and secure the services); or if we have obtained your prior consent (where laws require consent for such communications).
We allow other users to access and follow your Activity Data and Gameplay Data (which are associated with your Account, Steam ID, Steam nickname and Steam profile picture) including by publishing your Steam nickname and applicable score in the leaderboard, as well as Gameplay Recordings you choose to “capture” and comments that you post to the Ludeo Services. We do so for our legitimate interest – to promote interactions within the Ludeo Services and to enhance user experience.
We use your Activity Data, Gameplay Data, Technical Data, Device Performance Data, and Gameplay Recording to provide the Ludeo Services to you, to improve our services, marketing, customer relationships and experiences, including by personalizing and customizing our content, and may include such data in our marketing material. We do so where it is necessary for our legitimate interests (to keep the Ludeo Services updated and relevant, to develop our business and to inform our marketing strategy).
In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), we may use your Personal Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights).
We may also use your Personal Data as: (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms of use, to maintain security of the Ludeo Services and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates. We do so based on our legitimate interest (to defend and enforce our legal rights and to protect and ensure the continuous operation of the Ludeo Services).
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.
Promotional Offers
You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving marketing communications.
If you wish to stop receiving marketing communications from us, or if you wish to change you contact preferences, you can do so at any time by sending us an email with your request to: privacy@ludeo.com
Cookies and Other Tracking Technologies
The Ludeo Services use cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.
Types of cookies:
Strictly Necessary Cookies. These cookies are necessary for proper functioning of the Ludeo Services, such as displaying content, logging in, validating your session, responding to your request for services, and other functions.
Performance Cookies. These cookies collect information about the use of the Ludeo Services, such as pages visited, traffic sources, users’ interests, content management, and other measurements.
Functional Cookies. These cookies enable the Ludeo Services to remember a user’s choices – such as their language, user name, and other personal choices – while using the Ludeo Services. They can also be used to deliver services, such as letting a user post a review or a comment, watch a Ludeo or create a Ludeo on the Platform or the Ludeo Cloud.
Media Cookies. These cookies can be used to improve the performance of the Ludeo Services and provide special features and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies. These cookies can be used by Ludeo to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
Session Cookies. These cookies allow us to link the actions of a user during a browser session. Session cookies permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long-term.
Persistent Cookies. These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on the Ludeo Services correctly or at all. Further details on how to disable cookies in different web browsers can be found here:
Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer#w_cookie-settings
Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
Microsoft Edge: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
Opera: https://help.opera.com/en/latest/web-preferences/
We may share personal information such as your email address and your user activity with certain services providers, such as Mixpanel and Tableau. For more information on how Mixpanel uses and shares Personal Data, please see the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy. For more information on how Tableau uses and shares Personal Data, please see Tableau’s EULA, available at https://www.tableau.com/en-gb/legal/eula, and Tableau’s Privacy Policy, available at https://www.salesforce.com/company/privacy/.
We may also use a technology called web beacons to collect general information about your use of our Platform and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.
Third parties may use cookies, web beacons, and other storage technologies to collect or receive information from the Ludeo Services and elsewhere on the Internet, and use that information to provide measurement services and target ads.
Third-Party Links
The Ludeo Services may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy policy of every website you visit.
4. Sharing Your Data with Third Parties
We share Personal Data with third-party service providers that provide us services in connection with the purposes listed above. For example, we use cloud storage providers for hosting the Ludeo Services, third-party analytical tools to analyze traffic and user engagement and to improve the Ludeo Services, , authentication services (e.g., for two-factor authentication), and additional external services for moderation, comments, operation, maintenance, optimization. and support of the Ludeo Services, etc.
For example, we may share your applicable User Data, Contact Data, Activity Data, Technical Data, Device Performance Data, and Activity Data with web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Ludeo Services. For additional information, please see the description above in the section titled Cookies and Other Tracking Technologies.
We may also share your Personal Data with legal and regulatory authorities to the extent required by applicable law our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services to us; and third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire.
5. International Transfers
We may transfer your Personal Data to countries outside of the country in which you reside (including outside of the European Economic Area (EEA) or the United Kingdom (UK)), that do not necessarily provide the same level of data protection as the country in which you reside and are not recognized by the European Commission and/or the applicable UK authority as providing an adequate level of data protection.
Our transfers of Personal Data outside of the EEA or the UK are done for the performance of a contract or implementation of pre-contractual relations with you, based on your consent, or subject to safeguards that ensure the protection of your Personal Data, such as standard contractual clauses approved by the European Commission and/or the applicable UK authority.
6. Data Security
We have put in place security measures to prevent your Personal Data from accidental or unlawful loss, use, alteration or disclosure. We also maintain technical and physical safeguards to protect your Personal Data.
Unfortunately, we cannot guarantee against the loss or misuse of your Personal Data or secure data transmission over the Internet because of its nature.
7. Data Retention
We retain your Personal Data for as long as necessary to fulfill the purposes we collected it for.
In order to determine the appropriate retention period for Personal Data, we consider the following criteria: the volume, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we collect and process Personal Data, the time frame during which we may require such Personal Data in connection with potential litigation, and applicable legal requirements.
8. Your Rights
Certain privacy laws, including the GDPR and UK GDPR, provide users with rights related to their Personal Data. To the extent that such laws apply to your Personal Data, you may have the following rights:
Request access. This means that you may receive a copy of the Personal Data we hold about you.
Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.
Request erasure. This means that you may ask us to delete or remove Personal Data that we hold about you. If we are unable to comply with such a request, we will notify you of the specific legal reasons for our decision.
Object to processing. This means that you may object to the processing of your Personal Data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
Data Portability. This means that you may request that we transfer your Personal Data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Data based on your consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details below.
What We May Need From You
When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.
Time Limit to Respond
We try to respond to all legitimate requests within one month or less, if required by law. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.
9. Accessibility
If you have a disability and would like to access this policy in an alternative format, please contact us via our contact details listed below.
10. Contact Details
If you have any questions or concerns, please contact us at privacy@ludeo.com.
You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.
11. Changes to this Privacy Policy
We reserve the right to change this Privacy Policy at any time. If we do so, we will post an updated version of this Privacy Policy so that our users are aware of what information we collect, use, and disclose. Your continued use of the Ludeo Services after any change to this Privacy Policy will constitute your acceptance of such change.
This version was last updated on March [6], 2024