PRIVACY POLICY FOR THE LUDUS AI SERVICES
Last updated: 14th August 2026
1. INTRODUCTION
1.1. Ludus AI P.S.A. ("Company", "we", "us", "our") provides an AI assistant for Unreal Engine development. This Privacy Policy ("Policy") explains what personal data we process in connection with our websites, applications, plugin and services (collectively, the "Services"), why we process it, on what legal basis, for how long, and what rights you have.
1.2. This Policy is an information notice under Articles 12–14 of the General Data Protection Regulation (GDPR) (EU) 2016/679; where we rely on your consent, we ask for it separately and you can withdraw it at any time.
1.3. We process personal data in accordance with the GDPR, the Polish Electronic Communications Law and other applicable data protection laws.
1.4. Products covered by this Policy. This Policy applies to all of the following, which together form the Services:
a. the Ludus web application at app.ludusengine.com, including billing, account settings and project insight views;
b. the Ludus marketing site (ludusengine.com) and Ludus Academy (our learning site);
c. the Ludus AI plugin for Unreal Engine, a program that you install into your own Unreal Editor and which reads parts of your project and transmits them to us as described in Section 2A, including the chat interface embedded in the editor;
d. the Ludus API. You may authorise third-party tools (for example IDE integrations or MCP clients) to access your Ludus account through the API; those tools are not our products, and this Policy covers the data we receive through the API and the authorisation records we keep (including the registration IP address and browser agent — see Section 5), not the third-party tool's own processing. Check that tool's own privacy documentation before authorising it;
e. the Ludus backend services that process your prompts and project content and route them to the AI providers referred to in Section 4.
Where a section of this Policy applies to only one of the above, it says so.
1.5. Enterprise self-hosted deployments. Enterprise customers may operate the Services on their own infrastructure under a separate agreement. In such deployments the content processed within the customer's infrastructure does not reach us, and the processing of that content is governed by the separate Enterprise agreement, not by this Policy. This Policy continues to apply to the account, billing and support data we hold about Enterprise contacts.
2. INFORMATION WE COLLECT
2.1. Account and contact data. Name, e-mail address, and the account identifier and profile picture supplied by your chosen sign-in provider. For paid plans: billing name, address, country, tax identifiers, invoice records and a payment-provider customer identifier. We do not receive or store your full card number.
2.2. Account preferences and product state. Role, engine version last used, language and time zone, theme, notification preferences, onboarding and feature flags, credit balance and credit usage records, and your consent and objection choices (see Section 3.5).
2.3. Device and connection data. IP address, browser type and version, operating system, device type, referral source, pages viewed and navigation paths, and — where you have consented — cookie identifiers and analytics events. See Section 7.
2.4. Identifiers we generate or derive. Technical identifiers created or derived by the Services: device and installation identifiers generated by the Ludus plugin, a machine login identifier reported by your operating system, a browser fingerprint and a hashed form of your e-mail address (used only for the fraud- and abuse-prevention purpose in Section 3B), and a diagnostic reference attached to requests and error reports that lets us link a report to your account for support purposes.
2.5. Conversation data. The prompts you send, the files and images you attach, the outputs generated for you, the tool calls made by the assistant and their results, your feedback and reactions, and the state of each conversation, retained as described in Section 5.
2.6. Communications. The contents of communications you send us, and the information you provide when subscribing to our newsletter.
2A. PROJECT CONTENT COLLECTED BY THE LUDUS PLUGIN
The Ludus plugin runs inside your Unreal Editor. To answer your questions and carry out the actions you ask for, it reads parts of your project and transmits them to us. Depending on what you ask for, this may include:
a. the names of assets currently open in the editor and the name of the current level, transmitted with every message you send, together with your engine version;
b. project metadata: project name, engine version, installed plugins and modules, and the absolute file paths of your project, engine installation, plugins and modules — on most systems these paths contain your operating-system user name;
c. the full contents of source files in your project's Source directory;
d. the full contents of Blueprint graphs, including nodes, pins, variables and default values;
e. the asset registry and project tree of your Content directory;
f. screenshots — when you or the assistant request a screenshot, the plugin may capture either the 3D viewport or the entire Unreal Editor window; anything else visible in that window at that moment is captured with it;
g. the output of scripts the assistant runs inside your editor at your request.
2A.1. Project Insights. If you start a Project Insights analysis, the plugin builds a database of your project on your machine and uploads it to our cloud storage. In addition to (b)–(e) above, that database contains the complete text of the configuration files (.ini) in your project's Config directory and an inventory of every actor in every level. We recommend reviewing your configuration files before running an analysis and removing anything you do not want to transmit. Project Insights never runs automatically; it runs only when you start it.
2A.2. Server-side storage and indexing. To provide the Services efficiently, project content we receive may be stored and indexed on our servers — including searchable and vector (embedding) representations of your project — and associated with your account, for the periods stated in Section 5. This is what lets the assistant answer questions about your project without re-reading it each time.
3. PURPOSES AND LEGAL BASES
3.1. We process personal data only for the purposes below, on the legal basis stated for each.
3.2. Legal-basis table.
| # | Purpose | Main data categories | Legal basis | Consent control |
|---|---|---|---|---|
| 1 | Service delivery — operating your account; authentication and session management; licence and entitlement checks; generating Outputs from your Prompts and project content; storing and indexing project content to provide the Services (Section 2A.2); storing your chat history for you; plugin-to-server synchronisation; billing, invoicing and payment collection | Sections 2.1, 2.2, 2.4(a)–(b), 2.5, 2A | Contract — Art. 6(1)(b); legal obligation — Art. 6(1)(c) for tax and accounting records. Strictly-necessary device storage under Art. 399(3)(b) of the Polish Electronic Communications Law | None — always on |
| 2 | Reliability, security and content safety — detecting and diagnosing faults; crash and error reporting (Section 7A.1); technical performance monitoring (Section 7A.2); protecting the Services against attacks and abuse (including Section 3B); automated content-safety screening of images submitted to or generated by the Services and, where applied, automated misuse checks on conversations (see Terms of Use, Section 2.6); rate limiting | Sections 2.3, 2.4, technical telemetry scrubbed of content as described in Section 7A | Legitimate interests — Art. 6(1)(f): keeping the Services working and secure. A documented balancing test is on file | You may object at any time (Art. 21(1)) — see Section 3.5; crash reporting and plugin technical telemetry have off switches in the plugin's settings |
| 3 | Product analytics and session replay — understanding how our websites and the signed-in product are used; measuring website interaction and feature usage; masked session replay on the web application | Section 2.3, usage and interaction events (pseudonymous; keyed to your user identifier when you are signed in) | Consent — Art. 6(1)(a), with Art. 399 of the Polish Electronic Communications Law for device storage and access | Product analytics consent (Section 3.5) — runs only if you enable it |
| 4 | Marketing and advertising measurement — measuring visits to and conversions from our marketing site and campaigns; campaign attribution | Section 2.3, campaign identifiers, conversion events | Consent — Art. 6(1)(a) + Art. 399 of the Polish Electronic Communications Law | Marketing consent (Section 3.5) — runs only if you enable it |
| 5 | Model improvement — using your prompts, outputs and project context to evaluate, tune and train the Company's own AI models and to improve our algorithms and the Services, including collection into a dedicated dataset before any training takes place | Sections 2.5 and 2A, scrubbed as described in Section 3A | Consent — Art. 6(1)(a) | Model improvement consent (Section 3.5) — runs only if you enable it. See Section 3A |
| 6 | Marketing e-mail and newsletters | E-mail address, subscription status | Consent — Art. 6(1)(a) | Unsubscribe link in every e-mail; retained until you unsubscribe |
| 7 | Enquiries and support | Section 2.6 | Art. 6(1)(b) (steps at your request) and Art. 6(1)(f) | — |
| 8 | Legal compliance and claims — responding to lawful requests; establishing, exercising or defending legal claims | As required | Art. 6(1)(c) and Art. 6(1)(f) | — |
3.3. You may opt out of marketing communications at any time via the unsubscribe link or by contacting us. Objection to direct marketing is unconditional (Art. 21(2) GDPR).
3.4. We do not carry out any processing for purposes incompatible with those above. If we intend to process your data for a new purpose, we will inform you first and, where required, ask for your consent.
3.5. Your consent and objection controls. Your privacy settings contain consent controls for Product analytics, Marketing and Model improvement (nothing consent-based runs unless you enable it), objection controls for Crash reports and Plugin technical telemetry (on by default under our legitimate interest in keeping the Services reliable), and access to your cookie choices for our websites, which govern the websites only. All of these can be changed at any time. We record your choices with a timestamp and the policy version so that we can demonstrate them. Withdrawing consent does not affect the lawfulness of processing before withdrawal, nor your use of the Services or your price.
3.6. What happens when you withdraw a consent, or object.
a. Withdrawal stops collection immediately. When you turn a consent toggle off, nothing further covered by that toggle is collected, and anything queued on your device but not yet sent is discarded rather than transmitted.
b. We then dispose of what we collected under that consent. Within 30 days we delete the records collected under the withdrawn consent or reduce them to aggregated, irreversibly anonymous statistics; from the moment you withdraw, records awaiting disposal are excluded from any use. Withdrawal does not affect data we hold to provide the Services under our contract with you (Section 3.2 row 1), aggregated anonymous statistics already derived, or records we keep independently of the consent — principally billing and accounting records, the record of your consent choices, and a non-reversible suppression note that prevents deleted data reappearing from a backup. Section 5 states the retention of each.
c. Model improvement is different in one respect (Section 3A.2): withdrawal removes your content from our datasets and from all future training runs, but content already incorporated into a trained model cannot be extracted from that model.
d. Objection to crash reports or plugin technical telemetry (Section 3.5) stops that collection immediately. Records already collected are kept only until the end of their normal retention period stated in Section 5, are not extended, and are not used for any other purpose. If you want them erased sooner, write to privacy@ludusengine.com and we will treat that as an erasure request under Section 6.
e. We never link backwards. If you enable a consent after a period without it, we do not retroactively connect data collected before that point to you or to your account. Consent works forward from the moment you give it.
3A. USE OF YOUR CONTENT TO IMPROVE THE SERVICES AND TRAIN OUR MODELS
3A.1. Only where you have enabled the Model improvement toggle, we may use your Prompts, Outputs and the project content described in Section 2A to evaluate, tune and train AI models developed by us and to improve our algorithms and the Services. We may collect and hold that content in a dedicated, access-restricted dataset before any training run takes place: enabling the toggle covers both that collection and the later use, and Section 3.6 governs what happens if you change your mind.
3A.2. This is optional. The Model improvement setting is off by default and can be changed at any time in your privacy settings; declining or withdrawing does not affect your use of the Services or your price. Withdrawal stops use of your content in any future training run, but content already incorporated into a trained model cannot be extracted from that model.
3A.3. Enterprise self-hosted deployments are governed by the separate Enterprise agreement; content processed within the customer's own infrastructure does not reach us and is not used for model improvement.
3A.4. Scrubbing. Before content enters an evaluation or training dataset we apply filtering intended to remove user identifiers, e-mail addresses, machine paths (such as C:\Users\<name>\...), credentials and keys, and project and asset names where feasible. Filtering is not perfect, which is why Section 2A.1 recommends reviewing configuration files before submitting them. Access to these datasets is restricted and logged.
3A.5. We do not use your Prompts, Outputs or project content to target advertising to you, and we do not sell them.
3B. PREVENTING FRAUD AND ABUSE OF FREE TRIALS
3B.1. To detect repeated sign-ups that abuse free trials and free allowances, we operate an automated check that compares new and existing accounts using the identifiers described in Section 2.4 (browser fingerprint, plugin device identifiers, hashed e-mail address) and non-reversible payment-instrument references from our payment processor. These signals are used only for this purpose, not for analytics, profiling or marketing.
3B.2. Automated decisions. Where the check concludes that a free trial is being taken more than once, it automatically cancels the trial subscription and flags the account, and we e-mail you the ground for the decision. This is automated decision-making within the meaning of Article 22 GDPR: you have the right to human review, to explain your circumstances and to contest the decision, by writing to privacy@ludusengine.com or the Contact Point stated in the Terms of Use; your case will be reviewed by a member of staff not involved in the automated decision and answered within 14 days. No account is permanently closed or deleted on an automated signal alone.
3B.3. Legal basis and retention. This processing is based on our legitimate interest in preventing abuse of the Services (Art. 6(1)(f) GDPR). The related identifiers are retained for 12 months from last use or until account erasure. You may object under Article 21(1) GDPR; if you do, we may be unable to offer you a free trial.
4. DATA SHARING AND DISCLOSURE
4.1. We disclose personal data only to the following categories of recipients, and only as necessary:
a. service providers who process data on our behalf for infrastructure and hosting, storage, payment processing, e-mail delivery, error monitoring, analytics, content safety and AI model inference;
b. legal and regulatory authorities, where required by law or necessary to establish, exercise or defend legal rights or protect the vital interests of any person;
c. successors in connection with a prospective or actual merger, acquisition or sale of business assets, provided the recipient is bound to standards comparable to this Policy;
d. our professional advisers, insurers, agents and subcontractors, insofar as reasonably necessary for the purposes in this Policy.
4.2. Provider list. We maintain a current, dated list of our sub-processors and AI providers — stating what each receives, the country of processing and the transfer safeguard — at https://trust.ludusengine.com, which forms part of this Policy. We update that page when providers change; provider changes that materially affect your use of the Services are notified as described in the Terms of Use.
4.3. AI providers. To generate Outputs and analyse project content, we send your Prompts, attachments and the project content described in Section 2A to third-party providers of AI models. Each provider is engaged under contractual terms that limit processing to providing the Services and prohibit use of your content to train that provider's own models, except where we state otherwise for a specific provider on the provider list. We do not permit these providers to use your content for their own advertising or profiling. Please avoid deliberately including personal data of third parties, or credentials and secrets, in your Prompts (see Terms of Use, Section 5.2(e)).
4.4. We do not disclose your personal data to any third party for that party's independent marketing purposes, and we do not sell personal data.
4A. INTERNATIONAL TRANSFERS
4A.1. Our production infrastructure is hosted in the European Union, and our primary product-analytics platform is hosted in the EU.
4A.2. Some providers we use process data outside the European Economic Area, including in the United States. This applies in particular to certain AI model providers, our error-monitoring provider, and certain search, embedding and content-safety providers.
4A.3. Where we transfer personal data outside the EEA we rely on: an adequacy decision of the European Commission (including the EU–US Data Privacy Framework, where the recipient is certified); the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914); or, exceptionally, a derogation under Article 49 GDPR.
4A.4. The provider list at https://trust.ludusengine.com states, for each recipient, the country of processing and the safeguard relied on. You may request a copy of the relevant safeguards (for example, the Standard Contractual Clauses concluded with a provider) by writing to us (Section 10).
5. HOW LONG WE KEEP DATA
5.1. We keep personal data only as long as needed for the purposes in Section 3, then delete it or irreversibly anonymise it. Retention periods:
| Category | Retention |
|---|---|
| Account record (name, e-mail, sign-in identifier, preferences) | Life of the account, then 30 days after deletion, then erased |
| Conversations, prompts, outputs, attachments and tool results | Until you delete the conversation, then 30 days in a recoverable state, then erased. Conversations you do not delete are kept for 24 months from last activity, then erased |
| Project content transmitted by the plugin, held in server-side caches | 7 days |
| Search and vector (embedding) indexes of project content (Section 2A.2) | Life of the account; refreshed as your project changes; removed when the underlying content is deleted and erased with your account |
| Project Insights analyses (your project database, index and report) | For the life of your account; erased when you delete your analyses (a delete control is available in the product) or your account |
| Generated assets (images, sounds, animations, 3D models) | Life of the account, or until you delete them |
| Billing and accounting records | 5 years from the end of the tax year, as required by Polish law |
| Fingerprints, installation identifiers and normalised e-mail hashes (Section 3B) | 12 months from last use, or until account erasure, whichever is sooner |
| OAuth client registrations (including registration IP and browser agent) | 90 days after the client becomes inactive |
| Error reports and diagnostic logs | 90 days |
| Technical performance telemetry (spans and metrics) | 90 days |
| Diagnostic reports you send via the bug icon (Section 7A.4) | 90 days |
| Data collected under a consent you later withdraw | Excluded from use at withdrawal; deleted or irreversibly anonymised within 30 days (Section 3.6) |
| Withdrawal and erasure suppression notes (non-reversible references only) | For as long as needed to keep the deletion effective |
| Product analytics events (consent-based) | 12 months |
| Session replay recordings (consent-based) | 90 days |
| Evaluation and training datasets (Section 3A) | While your Model improvement toggle is enabled; on withdrawal or account deletion, removed within 30 days (Section 3.6) |
| Consent and refusal records | For as long as the related processing continues, plus the limitation period for legal claims |
| Marketing contact data | Until you unsubscribe or object |
| Backups | 35 days rolling; deleted data may persist in a backup until it is overwritten and is not restored into live systems |
5.2. When you delete your account we erase or irreversibly anonymise your data on the schedule above, except records we must keep to comply with a legal obligation (principally accounting records) or to establish, exercise or defend legal claims. Where we retain identifiable records (such as invoices), we will tell you what we have kept and why if you ask; data that has been irreversibly anonymised can no longer be linked to you.
6. YOUR RIGHTS
6.1. You have the right to access, rectify and erase your personal data, to restrict processing, to object to processing, and to data portability; the right to withdraw any consent at any time without affecting prior processing; and the right to lodge a complaint with a supervisory authority.
6.2. To exercise any right, write to privacy@ludusengine.com or use the tools in your account settings. We respond within one month; for complex requests we may extend by up to two further months and will tell you within the first month if so.
6.3. If you are not satisfied with our response, you may lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw — https://www.uodo.gov.pl.
6.4. Access and portability. On request we provide a copy of your account record, conversation history, billing history and credit usage in a structured, commonly used, machine-readable format.
6.5. Deletion. You can delete your account at any time from Settings. We then cancel any active subscription and begin the process described in Section 5: your personal data is erased or, in defined cases (such as usage statistics), irreversibly anonymised so it can no longer be linked to you, across our systems — including analytics, error-monitoring and tracing stores. Records we are legally required to keep (principally accounting records) are retained for their statutory period.
6.6. Objection. Where we process on the basis of legitimate interests — principally reliability telemetry and abuse prevention (Sections 3.2 row 2 and 3B) — you may object at any time under Article 21(1) GDPR. Objection to direct marketing under Article 21(2) is unconditional and always honoured.
7. COOKIES, CONSENT AND WEBSITE ANALYTICS
7.1. What we use. We use cookies and similar technologies (local storage, session storage, pixels) in three groups:
a. Strictly necessary — signing you in, keeping you signed in, security (including CSRF protection), remembering your consent choice and theme. No consent required.
b. Product analytics and session replay — understanding how our websites and the signed-in application are used. Consent required (Section 3.5).
c. Marketing and advertising measurement — advertising tags, campaign attribution and conversion measurement. Consent required (Section 3.5).
7.2. Your choice. Cookies in groups (b) and (c) are used only with your consent, which you can give, change or withdraw at any time in the cookie settings; if you decline or make no choice, no analytics or marketing data is collected or sent.
7.3. Marketing site. Until you consent, our marketing site runs strictly-necessary functions only: the session cookie, our content-delivery and security provider, and server-side error monitoring with IP truncation. The cookie settings on the site offer both toggles from Section 7.1:
a. Product analytics — if you enable it, we measure how you interact with the website: pages viewed, navigation paths, clicks on site elements and similar interaction events, using our first-party analytics tooling;
b. Marketing — if you enable it, we additionally measure campaign attribution (including advertising click identifiers) and conversions, and our advertising and marketing measurement tags operate. The specific providers behind these tags are listed at https://trust.ludusengine.com and may change over time. Conversion measurement in the signed-in web application is governed by the Marketing toggle in your privacy settings (Section 3.5), which we ask for separately.
A choice you make on the website governs the website (and Ludus Academy, below) and is not carried into your account, where we ask for your product choices separately (Section 3.5).
Ludus Academy carries the same cookie settings as our marketing site: until you consent, it runs strictly-necessary functions only, and the Product analytics and Marketing toggles described in Section 7.1 govern everything else. A choice made on either site applies to both.
7.4. Signed-in application. If you enable Product analytics, we collect usage events keyed to your user identifier (pages and features used, feature timings, coarse country-level location) in the web application and in the chat interface embedded in the Unreal Editor, and masked session replay as described in Section 7B. If you do not, no product-analytics events are sent from either surface and no analytics identifiers are stored on your device.
7.5. Cookies we set.
| Name | Purpose | Group | Lifetime |
|---|---|---|---|
ludus:session | Keeps you signed in | Necessary | 30 days |
cookieChoice | Stores your consent choice | Necessary | 12 months |
csrf_token | Protects forms against cross-site request forgery | Necessary | 10 minutes |
lastUsedProvider | Remembers which sign-in button you used | Necessary | 12 months |
ludus-theme | Remembers light or dark mode | Necessary | 12 months |
authRedirectTarget | Returns you to the page you came from after sign-in | Necessary | Session |
| Product-analytics cookies | Product analytics (Section 7.4) | Analytics | Up to 12 months |
| Advertising and marketing measurement cookies | Marketing and conversion measurement (Section 7.3) | Marketing | Up to 24 months |
The specific third-party cookies in the last two rows depend on the providers we currently use, listed at https://trust.ludusengine.com.
7A. RELIABILITY TELEMETRY, ERROR REPORTS AND TRACING
7A.1. Error monitoring and diagnostics. We use an error-monitoring provider to detect and diagnose faults in the web application, the backend and the Ludus plugin. Error reports contain your pseudonymous user identifier, the diagnostic reference described in Section 2.4(e), and the technical context of the error. Content payloads — prompts, file contents, paths, asset and project names — are scrubbed or replaced with non-reversing references before transmission. Our current error-monitoring provider processes this data in the United States; see Section 4A and the provider list.
7A.2. Technical performance telemetry. Our backend and the Ludus plugin emit technical spans and metrics (timings, error classes, resource usage) to our observability tooling. These are keyed to pseudonymous identifiers and do not carry your content. You can turn plugin technical telemetry off in the plugin's settings (Section 3.5).
7A.3. AI request tracing. To operate and bill the Services we record your credit usage in our billing systems (Section 3.2 row 1). Where you have enabled the corresponding toggle (Section 3.5), our analytics and tracing tooling additionally records, for each AI request, metadata such as model, token counts, cost, latency and outcome. The content of your prompts and the model's responses is not retained in our analytics or tracing stores unless you have enabled the Model improvement toggle (Section 3A). Your chat history itself is stored for you as part of the Service (Section 3.2 row 1) and is visible to you in the product.
7A.4. Diagnostic reports you send us (the bug icon). If you report a problem from the plugin, the report contains what you write, a screenshot of your Unreal Editor at that moment, technical logs from the minutes preceding the report, and your setup details (engine and plugin version, project name, active asset). Your recent chat messages are included only if you tick that option in the report form. Because a report cannot be produced or processed without them, the Crash reports and Plugin technical telemetry switches (Section 3.5) must be on to submit one — the product will tell you if they are not. Your Product analytics, Marketing and Model improvement choices make no difference to whether you can report a problem and are never a condition of receiving support. Diagnostic reports are retained for 90 days (Section 5.1) and are not used for model training, regardless of your Model improvement setting.
7B. SESSION REPLAY
7B.1. Where you have enabled the Product analytics toggle, we record masked replays of your use of the web application and of the Ludus chat interface embedded in the Unreal Editor, to understand usability problems. Replays are sampled (not every session is recorded); all typed input and on-screen text is masked by default and replaced with non-reversible placeholders before it leaves your device; account, billing and admin pages are never recorded; and console output is not captured.
7B.2. Replay never captures your Unreal Editor or your project. The recording covers only the Ludus interface itself — the embedded chat panel — and cannot see the surrounding editor window, your viewport, your assets or any other part of your project workspace. Screenshots that you or the assistant deliberately request (Section 2A(f)) belong to the Service and diagnostic flows, not to analytics, and are never attached to replays.
7B.3. Replays are retained for 90 days (Section 5.1), access to them is restricted (Section 9A), and you can withdraw consent at any time, which stops further recording.
8. CHANGES TO THIS POLICY
8.1. Updates to this Policy are posted on this page with an updated revision date; earlier versions are available from us on request.
8.2. We will notify users with an active account, by e-mail or through the Services, in advance of any change that materially reduces your rights or expands our use of your content. A new processing purpose is handled under Section 3.4, and an update to this Policy does not reset your existing consent choices.
9. SECURITY
9.1. We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, EU hosting of our core infrastructure, least-privilege access controls, and client-side scrubbing of content before it reaches diagnostic tooling.
9.2. No method of transmission or storage is completely secure; we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
9.3. Personal data breaches. If a breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, and we will notify the President of the Personal Data Protection Office within 72 hours where required.
9A. ACCESS BY OUR STAFF
9A.1. A limited number of our staff can access customer accounts, conversations and project analyses where necessary to investigate faults you report, respond to support requests, detect abuse, or comply with legal obligations.
9A.2. Access is restricted to named personnel on a least-privilege basis, subject to written confidentiality obligations, and a record is kept of who accessed which customer's data.
9A.3. We do not read your conversations for any other purpose.
9B. DATA THE PLUGIN STORES ON YOUR COMPUTER
9B.1. The Ludus plugin stores the following on your machine: (a) your conversation history, in your project's Saved/ChatHistories folder; (b) caches used to speed up the assistant, in Saved/LudusCache; (c) screenshots and generated assets you have requested; (d) a queue of pending diagnostic reports; (e) if you have run Project Insights, a database of your project in your user settings folder; and (f) your sign-in token and device identifiers, in an encrypted store in your application data folder.
9B.2. Files in your project's Saved folder travel with your project if you copy, zip or commit it. Do not share that folder if you do not want your conversation history to travel with it.
9B.3. You can remove items (a)–(e) at any time using Settings → Clear local data in the plugin. Signing out clears your sign-in token but does not remove the files above.
9C. TEAMS
9C.1. If your account is part of a Team (available on team-capable plans), the Team's Admins and Managers can see your name, e-mail address and your usage of the Services within that Team (such as credit consumption), for the purpose of managing the Team and its billing. They do not gain access to the content of your conversations or your projects through the Team feature.
9C.1a. Your privacy choices are yours. All choices under Section 3.5 — including the Model improvement toggle — are individual to each member's account. Team Admins and Managers cannot make, see or change them on a member's behalf, and no Team plan alters the consent model described in this Policy.
9C.2. When you join a Team, your subscription and billing are managed at Team level as described in the Terms of Use, Section 3A.
10. CONTACT
10.1. The data controller is Ludus AI P.S.A., Wincentego Pola 27/1-10, 44-100 Gliwice, Poland, NIP 6312724828.
10.2. Privacy questions and requests: privacy@ludusengine.com. General contact: hello@ludusengine.com, or by post to the address above.
10.3. We have not appointed a Data Protection Officer; privacy matters are handled by the Security Officer's team at the address above.
10.4. The Services are not intended for anyone under 18. We do not knowingly collect data from children; if you believe a child has provided us with personal data, write to privacy@ludusengine.com and we will delete it.
11. AI TRANSPARENCY
11.1. The Services are an artificial-intelligence system within the meaning of Regulation (EU) 2024/1689. When you use the chat, you are interacting with an AI system, not a natural person, and the product says so in the interface.
11.2. Content generated through the Services — including images, sounds, animations and 3D assets — is artificially generated, in whole or in part by the AI models of our providers. Together with those providers and where technically feasible, we are implementing machine-readable marking of generated image, audio and 3D asset files identifying them as AI-generated, in accordance with Article 50(2) of that Regulation. Such marking may already be present for some categories of generated files and is being extended to the remaining ones; we will complete this roll-out no later than the date from which that obligation applies to the Services.
11.3. If you publish or distribute AI-generated content produced through the Services, you may have your own disclosure obligations under Article 50 of that Regulation — in particular for content that resembles real persons, places or events, or that informs the public on matters of public interest. You are responsible for complying with those obligations when you publish.