Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to the treatment of personally identifiable information submitted by, or otherwise obtained from, you in connection with the associated application (“Application”). The Application is provided by Ludum LLC aka Koolbros (“Ludum”) and may be provided by Ludum on behalf of a Ludum licensor or partner (“Application Partner”). By using or otherwise accessing the Application, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

WHAT PERSONAL INFORMATION DOES LUDUM COLLECT?

We collect the following types of information from our users:

Personal Information You Provide to Us:

Upon your explicit approval, we may receive and store any information you submit to the Application (or otherwise authorize us to obtain – such as, from for example your Facebook account). The types of personal information collected include your full name, email address, Facebook user ID, and list of Facebook friends necessary for us to provide the Application services.

Personal Information Collected Automatically:

We receive and store certain types of usage related information whenever you interact with Application. For example, Ludum may automatically receive and record information regarding your IP address, OS version, device brand and model, Facebook user ID, actions taken inside the application and third-party service IDs (e.g., deltaDNA, Appsflyer, Facebook, Apple, Google). For example, we may collect and share the advertising identifier associated with your device (such as the Apple IDFA and Android Advertising ID) with advertisers. An advertising identifier is an alphanumeric string that can be used to identify your device so that advertisers can serve relevant ads to you, and in certain territories (such as the EU) may be considered personal information. We use the Apple IDFA only as permitted by Apple, and we use the Android Advertising ID only as permitted by Google. An advertising identifier is assigned, and ad tracking is turned on, by default on your mobile device. You may limit the use of or reset your advertising device ID using the privacy settings on your mobile device; in some cases you may need to reset the operating system to reset the advertising device ID. We do not associate any of your other personal information with your advertising device ID without your consent. Such information may be shared in aggregate (non-personally identifiable) form with our partners.

HOW DOES LUDUM USE THE INFORMATION IT COLLECTS?

Ludum uses the information described in this Privacy Policy (i) internally, to provide customer support and analyze, develop and improve its products and services,  (ii) as set forth below in the “Will Ludum Share any of the personal information it Collects” section below.

APPLICATION PARTNER TREATMENT OF PERSONAL INFORMATION.

Ludum may provide personal information to the applicable Application Partner. The Application Partner’s use of your personal information is subject to the Application Partner’s separate privacy policy – and not this Privacy Policy. The Application Partner’s privacy policy is linked to from within the Partner’s Facebook application.

WILL LUDUM SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

Personal information about our users is an integral part of our business. We neither rent nor sell your personal information to anyone (with the exception of sharing your information with an applicable Application Partner – see the “Application Partner Treatment” section above). We share your personal information only as described below.

Application Partners: We will share your personal information with an applicable Application Partner (see the “Application Partner Treatment” section above).

Agents: We may employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, Ludum’s agents do not have any right to use personal information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information for the above purposes.

Third Parties: While we may use third parties to collect and process personal and other data on our behalf and according to our instructions in the course of providing our Application’s services, we do not actually control third-party data collection and use. You acknowledge and agree that your access to and use of the Application may be subject to terms and conditions of third parties, whether or not they are acting on our behalf. These third parties include mobile device manufacturers, operating system and browser developers, social network services, analytics providers, companies delivering advertisements in or for our Application, and online and mobile network communications providers, any of whom may utilize cookies and other technologies for analytics, monitoring and other purposes, including for other products and services you may be receiving from them. Please refer to the privacy policies and terms and conditions applied by such third parties. 

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if Ludum, or substantially all of its assets were acquired, or in the unlikely event that Ludum goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Ludum may continue to use your personal information as set forth in this policy.

Protection of Ludum and Others: We may release personal information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Ludum, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent: Except as set forth above, you will be notified when your personal information may be shared with third parties, and will be able to prevent the sharing of this information.

THIRD PARTY APPLICATIONS/WEBSITES.

The Application may permit you to link to other applications or websites. Such third party applications/websites are not under Ludum’s control, and such links do not constitute an endorsement by Ludum of those other applications/websites or the services offered through them. The privacy and security practices of such third party applications/websites linked to the Application are not covered by this Privacy Policy, and Ludum is not responsible for the privacy or security practices or the content of such websites.

CHILDREN UNDER 13 YEARS OF AGE

We do not knowingly collect personal information from children under 13 years of age. If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will take reasonable measures to promptly delete such information from our records. Some of our applications are intended for use only by a mature public and are restricted to users of age 17+.

USERS OUTSIDE THE US

If you are located outside the United States, you acknowledge and consent to the processing of such data in the country in which it was collected as well as in other countries where it may be transferred, including the United States, where regulations regarding processing of personal information may be less stringent than regulations in your country.

CHANGING OR DELETING YOUR INFORMATION

You have the right to request a copy of the personal information we hold about you.  We first require you to prove your identity with additional pieces of approved identification.  We will supply, correct or delete personal information about you on our files.  In addition, you may request rectification or erasure of personal information as well as the restriction of processing of your personal information. We will comply with your requests in accordance with the applicable law. You can exercise your right at any time by contacting us via the applicable Service (e.g., using customer care tools in app) or at privacy@ludum.io.

CHANGES TO THIS PRIVACY POLICY.

Ludum may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. Please bookmark and visit this page periodically to review the current Privacy Policy and to understand what information we gather and how we may use it. Users are bound by any changes to the Privacy Policy when he or she uses or otherwise accesses the Application after such changes have been first posted.

QUESTIONS OR CONCERNS.

If you have any questions or concerns regarding privacy on our Website, please send us a detailed message at privacy@ludum.io . We will make every effort to resolve your concerns.

(v1.2 09/14/2022)