Privacy Policy

PRIVACY POLICY 

In this document, Ludus Materials Ltd. (“the Company”), wishes to provide its policy regarding the privacy of users of the Ludus App.
This privacy policy reflects our practices regarding the collection, use, and sharing of personal and other information compiled on Ludus. It enables you to learn how the Company uses the information provided by Ludus users or compiled during use of Ludus. We recommend that you carefully read this privacy policy before using Ludus and specifically, prior to the submission of personal information.
By nature, a privacy policy is a dynamic document.  The Company may change it from time to time.  For example, as Ludus acquires new contents and/or services, they may also impact this policy. In such cases, the policy shall be updated to ensure proper adjustments. We therefore recommend that you review the policy from time to time.
By using Ludus, you express your consent to the Company’s privacy policy set forth in this document, as well as your consent to act in compliance thereto. Therefore, if you do not agree to any term or provision of this document, please refrain from using Ludus.
This document relates equally to both genders and use of the masculine form is derived of convenience purposes only. The terms appearing in this document, which were not specifically defined therein, shall be construed in accordance with the definitions attached thereto in the Ludus [Terms of Service|terms_and_conditions]. The provisions of this document comprise an integral part of the Terms of Service, complement them and shall be construed together with them.

User Age

We will not request personally identifiable information from anyone under the age of 18 without requesting parental consent. If we learn that we have collected Personal Information of a child under 18, without parental consent we will take steps to delete such information from our files as soon as possible. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the App without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please contact us, at info@ludus-materials.com  and we will endeavor to delete that information from our databases.

Children’s Data

You must be at least 18 years old to create a Ludus account. However, if you are a parent or guardian, you may create accounts (or confirm the creation of an account initiated by your child) under your account for your children aged 7 to 18 to access Ludus App and some of its services. If you do so, we will process your child’s data in accordance with this Privacy Policy.
Ludus may collect and store personal information about children if this information is submitted by a child with prior parental consent or by the parent or guardian of the child. If a service is directed to children under COPPA  (https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule), Ludus may ask users to verify their dates of birth before collecting any personal information from them. Those users that indicate they are children are either blocked from the activity or taken through a parental consent process.

Parental Access

A parent who has already given Ludus permission to collect and use his or her child’s personal information can, at any time, do the following: (1) review, correct, or delete the child’s personal information; and/or (2) discontinue further collection or use of the child’s personal information. To do so, please refer to the confirmation email provided to you when you gave consent or contact Ludus. Please be sure to include your child’s name and email address, your name and email address. Alternatively, you may contact us at:
info@ludus-materials.com 

What Information Do We Collect? 

We collect the following types of information from our users.
Information You Provide When You Register to Ludus
The Ludus registration form requires that you provide personal information, such as: full name, gender, e-mail address and password. Further information may be required upon registration to certain services. This is information that you provide knowingly upon registering to Ludus and/or the services thereby provided. The mandatory fields shall be explicitly marked. If you do not provide the details defined as “mandatory”, you will be unable to operate within Ludus and/or register to the services or applications requiring registration.
The user name and/or password you create are intended for your use only and you are required to maintain their confidentiality. In any event, the Company shall not be liable for any violation of your privacy, or any other damage, caused by unauthorized use of your personal username and password.

Information You Provide When Using Ludus

Ludus contains and enables you to upload information of any kind, including verbal, visual, audio, audiovisual, graphic, images, documents, clips, links, and the like.
When you contact, share or upload information to Ludus or when you take any other action within the Ludus App, you must assume that the mere contact and sharing, as well as contents thereof, are public, and that any person may have access to such information and contents.
While using your personal profile account, you may be able to conduct private discussions, i.e. participate in closed discussions or sharing groups, or by way of a chat. Information disclosed in such arenas shall be exposed to the members of the relevant group or to other members of the chat. However, regarding this information as well, you must assume that it may be exposed to the public and will not remain within the group or chat. Third parties may be exposed to this information. For instance, the chat or discussion group members publish the information on Ludus or other platforms by copying or sharing it with others. Other than in the framework of private discussions, as mentioned above, information uploaded by you, whether in your personal profile account or other areas of the network, personal profile accounts of others, public chats or posts, are public information.

Information Collected through Other Social Media 

Information collected through your other social media account(s), if you choose to link such information, including, if applicable, but not limited to information from your Facebook account (i.e. name, e-mail address, number of friends, and followers), your Twitter account (i.e. name, number of followers), and your LinkedIn account (i.e. name, industry, job title, current position). We may also collect information through Instagram (e.g. name, e-mail, number of followers, and hash-tags and photos related to the properties we feature on Ludus), and Google+ (e.g. name, e-mail address, and number of friends in your circles). We do not collect or store your social media account(s) username(s) or password(s). The social media website(s) processes your username and password directly through their website(s) and network(s), and as such, if you choose to connect your social media account(s) with Ludus such connection is controlled by the terms of use of each individual social media website(s). Additionally, we will have access to the following information through your social media accounts, but will not store this information: Facebook –profile picture, age range, gender, language, country, other public information (e.g. likes); LinkedIn –photo, headline, current positions; Twitter –tweets from timeline, who or what you follow; Instagram –your profile, photos and followers; Google+ –photos, your posts, and friends in your circles.

Information We Collect About Your Use

Ludus systems contain additional information relating to your Ludus use. This includes: information about the groups with which you are affiliated; the chats that you take part in; requests addressed to you or by you to other users or your coach; the accounts that you created or in which you are involved; Ludus services that you used; searches that you conducted; and other information about your use of Ludus. 
We also collect information about the advertisements you read or clicked on; pages viewed; pages and topics that interest you; the time spent on Ludus; the IP address from which you accessed Ludus; the browser you used; the operating system you used; and other information about your visit to and use of Ludus.
In addition, when you use your personal computer or mobile phone, we may also receive location based information.  Thus, when you upload an image or clip, we may obtain information regarding where and when the photo was shot, and other information concerning your location while using Ludus.
We may process this information within the Ludus systems, combine various Ludus data, cross reference or aggregate them. 
The Company may employ various companies or contractors that provide it with statistical analyses relating to Ludus usage.  Such companies compile and analyze information regarding the scope of Ludus usage, frequency, user access points, and other statistical use information.  Such information is statistical in nature, it does not identify you personally and is intended only for purposes of analysis, research and to make improvements to Ludus and our services and features.

Smart training tool and other devices

When you register Ludus wristband to your account the wristband will automatically connect to the coach who registers all wristbands of users in Ludus App. Each time you use a Ludus smart training tool or a Ludus wristband on a Ludus App or other devices, we may automatically access and store information about your use of that device and it will be connected to your coach account, this data includes, but is not limited to, your name. gender, age, weight, height, level, belt, performance data, etc. Your coach account will be connected to the organization in which your coach is a member and you agree that we will share your information with such third party organization. In addition, if you sign into your account we may combine it with other data we have for that account.
The data that we access from and store on your devices may include:
Device identifiers such as your smart training tool, wristband, coach App, mobile device IDs, cookie IDs
Network identifiers such as your IP address  Account authentication tokens that avoid you having to log in repeatedly
Content and ads downloaded to your device for the online services that you access
Your current and recent locations if you choose to share this with us
Trophies, scores and rankings achieved online and offline
Some device type and setting details and error reporting
Information about which features and services you are accessing from your device or app and when 
Information about the device you are using and how you have configured it and any connected peripherals, such as model and serial number and device settings
Information about how you use the software installed on your device (including offline), such as date and time of use, what games you play, what content you browse, share or download, what services you access and for how long, including how often you use chat and other communication applications

What actions you take within a game or app

Software errors and load times details
If your device or app crashes, you may be asked to provide detailed information about the crash, including screenshots and video captured before the crash 

Where Do We Store Your Information?

The personal information, including details that you provide on the registration form, will be kept in duly registered Company database. You are not required, by law, to disclose the personal information and disclosure depends solely on your desire. However, without such information, the Company will be unable to permit you to use Ludus. When providing your personal information, you agree to the inclusion of this information in the Company database and that the Company shall be permitted to make use thereof, pursuant to this Privacy Policy and in accordance with applicable law, as defined under the [Terms of Service|terms_and_conditions]. You hereby waive in advance and will be prevented from raising any argument, claim or request against the Company in connection with the saving of said information in the Company’s database.

How Do We Use Your Information?

We use your information for the following purposes:
To enable you to use the Ludus App;
To properly operate and, develop Ludus App and its related devices;
To enrich the Ludus activity as a network and generate increased sharing among its users;
To improve and enrich the services and contents offered by Ludus, as well as the user experience, including the creation of new services and contents that meet Ludus user demands and expectations and the cancellation of existing contents and services;
To provide you with advertisement that may be of interest to you, based on pages viewed by you when visiting Ludus and other websites. 
To contact you or analyze and submit statistical information to third parties, including advertisers.
To send e-mail or text messages to you.  For example, we may contact you to provide information on Ludus updates and/or improvements regarding services, content and proposals that may interest you, as well as marketing and promotional material – whether it is information that the Company and/or anyone on its behalf will publish or whether it is information received from other advertisers. You may, at all times, through written request to the Company, discontinue receipt of advertising information;
To comply with any other objective defined by law and/or specified in this Privacy Policy or the Terms of Service, including the terms of service relating to relevant Ludus services.

Use of Information – Search Engines

Ludus may enable users to perform various searches within Ludus website, whether or not for a fee. Using various search words or definitions, a user may encounter information that you uploaded to Ludus, even if he is not a “member” of the page.
Users can also perform various searches of the personal profile accounts, posts and other public information within or outside of Ludus (excluding information or arenas defined as private).

How Do We Share Your Information?

Ludus may share your information with its third party service providers, vendors, organizations in which your coach is a member, and/or suppliers in order to enable Ludus to provide functionality of Ludus services to you. 
Where you take part in content activities of a third party or activities jointly conducted by the Company and the third party, as presented on Ludus. In such cases, the relevant third party will receive the information required for conducting the relevant activity and for creating or maintaining contact with you.
To enable users to use the search engine and search services within Ludus; 
With third parties for the purpose of academic, historic, competitions or other research;

With third party advertisers and ad-networks;

With other users, unless designated as private;
In the event that you violate or attempt to violate the Terms of Service relating to Ludus or any of the service provided by the Company or if you execute or attempt to execute, directly or through others, actions that are considered illegal;
Where the Company receives a judicial order instructing it to disclose your details or information about you to a third party;
In any legal argument, suit, claim or proceeding, if any, between you and the Company and/or anyone on its behalf;
Where the Company believes that the disclosure of such information is necessary in order to prevent severe injury or damage to you or to other third party/ies;
Where there is legal permission and/or duty to disclose the information;
Where Ludus activities are organized within a different incorporation or where the Company merges with another entity or merges the Ludus activity with a third party activity (“the New Corporation) – the Company shall be entitled to provide the New Corporation with the information compiled about you in Ludus or any other statistical information compiled by the Company.

Publications and Advertising, Direct Mailing

From time to time, the Company wishes to send you, by electronic mail or any other medium, information relating to its services as well as marketing and promotional material – whether information that it publishes itself or information received for distribution from other advertisers. This information will only be sent to you if you have granted your prior consent, including upon registration to Ludus or at another time, and so long as you did not cancel your said consent and/or where the terms of law so permit.
In addition, the Company may use information provided to Ludus – and any other information – for the purpose of analyzing and providing third parties, including advertisers, with statistical data. 
You may change your commercial subscription directly from your account or notify the Company in writing that you do not wish to receive commercial advertisements.  Such notices can be sent through info@ludus-materials.com 

Third Party Services

Access to third party networks, websites and/or services may be provided through Ludus, in addition to use of third party plug-ins and widgets as described above. In such cases, the services are not provided or operated through Company computers only, but through those third parties. By accessing other third party websites through Ludus, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them. This includes your use of Facebook, Twitter, LinkedIn, Instagram, Google+ and/or any other social media that may be added to Ludus from time to time. The Company does not accept any responsibility for any additional third party websites that we may add in the future.

Information Security

The Company applies data security systems and procedures of standards customary in the industry.  Such systems and procedures are intended to reduce the risk of unauthorized access. However, they can never provide absolute security. Therefore, the Company does not guarantee that the Ludus services shall be absolutely resistant to unauthorized access to the information stored therein.

International Transfers

Your information may be processed, stored and transferred outside your country of residence and beyond the European Economic Area (EEA) for the purposes set out in this Privacy Policy. Data protection laws in these countries may not offer the same level of protection as in your country or the EEA and you may have fewer legal rights in relation to your information. We ensure there are adequate safeguards in place when transferring your data outside your country and the EEA, including by relying on Privacy Shield, Model Clauses or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law.

Right to Review Information

You are entitled to review the database information submitted by you and/or relating to you, under applicable law. A person who has reviewed the information relating to him/her and found it to be incorrect, incomplete, unclear or not up to date, may contact the database owner and request that the information be updated or deleted. You may send us such a request at info@ludus-materials.com 

Information Removal

Information that you uploaded to your personal profile account can be removed at any time by deleting it. Please note, deletion means removal from your personal profile account only and not that the information was fully removed from Ludus or that others do not have access thereto, assuming that some of it may have been uploaded by other users on Ludus or elsewhere.

Personal Profile Account Cancellation

You may, at any time, cancel your personal profile account that you created. In this case, the personal profile account will be cancelled and removed from Ludus completely. Please note, information amassed outside of the cancelled personal profile account will not be deleted from Ludus. To cancel the user personal profile account please contact customer service at info@ludus-materials.com 
Cancellation usually requires a period of approximately 14 working days.

Clarifications and Reporting

If you suspect or are aware of any violation of this Privacy Policy, please contact us immediately through Ludus at info@ludus-materials.com   If you have encountered information that conflicts with Ludus’s spirit, please notify us at the above address.
Please contact us with any questions or clarifications required in regards with this Privacy Policy, at info@ludus-materials.com 

Changes to the Privacy Policy

The Company Privacy Policy may change from time to time.  In the event of substantial change to the provisions, regarding use of the personal information that you provided, you will be appropriately notified.

This Privacy Policy is updated as of May 2023