PRIVACY POLICY FOR THE LUDUS AI SERVICES
Last updated: 19th April 2025
1. INTRODUCTION
1.1. Ludus AI P.S.A. ("Company", "we", "us", "our") is committed to protecting the privacy and security of personal data. This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect personal data in connection with our website and services (collectively, the "Services").
1.2. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with this Policy, please do not use the Services.
1.3. We process personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.
2. INFORMATION WE COLLECT
2.1. We may collect the following types of personal data:
a. Device and browser information, including IP address, cookie data, operating system, device type, and unique identifiers;
b. Personal data provided during registration, such as name, email address, company name, address, phone number, and location;
c. Information about your visits to and use of the Services, including geographical location, browser type, referral source, length of visit, page views, and navigation paths;
d. Information provided when subscribing to email notifications or newsletters;
e. Information contained in communications sent to us through the Services;
f. Information necessary for the recruitment process;
g. Any other personal data you choose to send us.
2.2. If you provide personal data of another person, you must obtain that person's consent to both the disclosure and the processing of their personal data in accordance with this Policy.
3. PURPOSE OF DATA COLLECTION
3.1. We collect personal data for the following purposes:
a. To fulfill your requests, process business inquiries, and handle job applications;
b. To send email notifications about new content, blog articles, or other relevant information;
c. To pursue our legitimate interests, provided that the processing does not override your rights and freedoms;
d. To share your data with third parties (partners and providers) for contact purposes, subject to your consent;
e. To personalize the Services, send invoices and payment reminders, and maintain the security of the Services.
f. To process User Prompts via third-party AI Partners (as defined below) in order to generate Outputs and deliver the core functionality of the Services.
3.2. We will only collect personal data that is necessary for the purposes outlined above.
3.3. You may opt out of receiving marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.
3A. USE OF DATA FOR SERVICE IMPROVEMENT AND AI MODEL TRAINING
3A.1. In accordance with the license granted by you in our Terms of Service, we may use User Prompts and Outputs to improve the Services and to train and fine-tune the proprietary AI models developed by the Company.
3A.2. When using data for these improvement and training purposes, we implement measures to protect your privacy, such as using data in an aggregated and/or anonymized form where feasible, removing identifiable information, and restricting access to such data.
3A.3. We do not use your Prompts or Outputs to specifically target advertising to you.
3A.4. Our third-party AI Partners' use of data is governed by our agreements with them, as described in Section 4.1.f.
4. DATA SHARING AND DISCLOSURE
4.1. We may disclose personal data and other data (including User Prompts) to the following categories of recipients:
a. Service providers who facilitate our business operations, including but not limited to infrastructure hosting, analytics and performance monitoring, payment processing, error tracking, security services, and customer relationship management; b. Legal and regulatory authorities, where required by applicable law or regulation, or when necessary to establish, exercise, or defend our legal rights or protect the vital interests of any person; c. Third parties in connection with a prospective or actual merger, acquisition, or sale of any part of our business assets, provided that the recipient agrees to handle the personal data in accordance with standards comparable to this Policy; d. Our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors, insofar as reasonably necessary for the purposes articulated in this Policy. e. Specific third-party service providers whose platforms we utilize for infrastructure, security, communication, error tracking, and analytics include, but are not limited to: Cloudflare, Inc., Google LLC (encompassing Google Analytics, Google Cloud Platform), Microsoft Corporation (encompassing Azure, Microsoft 365, Clarity), and Functional Software, Inc. (dba Sentry). Utilization of these platforms may involve the processing of personal data for service provision and analytical insights. f. AI Partners: Third-party providers of artificial intelligence models (such as Anthropic AI, DeepSeek AI, and others we may engage) with whom we share User Prompts solely for the purpose of generating the Outputs requested by you through the Services. Your Prompts are processed by these AI Partners according to our instructions and contractual agreements which include confidentiality and security obligations. Please be reminded, as per our Terms of Service, not to include personal or sensitive data within your Prompts. Our AI Partners are contractually prohibited from using your Prompts for training their own models or for any purpose other than generating Outputs for the Ludus AI Services.
4.2. We shall not disclose your personal data to any third party for their independent marketing purposes without your explicit prior consent. Disclosure beyond the scope defined herein (including sharing Prompts with AI Partners for Output generation) will only occur as legally required or permitted, or as necessary for the provision, security, analysis, and improvement of the Services.
5. DATA RETENTION
5.1. We will retain personal data for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements.
5.2. For paid services, we are required under Polish tax law to retain basic personal data (name, address, contact details) for a minimum of 5 years.
5.3. Personal data used for marketing purposes will be retained until you notify us that you no longer wish to receive such information.
6. YOUR RIGHTS
6.1. You have the following rights regarding your personal data:
a. The right to access, rectify, erase, restrict processing, object to processing, and data portability;
b. The right to withdraw consent at any time (where processing is based on consent);
c. The right to lodge a complaint with a supervisory authority.
6.2. To exercise your rights, please contact us using the information provided in Section 10.
6.3. If you are not satisfied with our response or believe we are processing your personal data unlawfully, you may lodge a complaint with the Polish data protection authority (UODO) at https://www.uodo.gov.pl.
7. COOKIES, ANALYTICS, AND THIRD-PARTY PROCESSING
7.1. Cookies: We employ cookies and analogous tracking technologies (such as web beacons and pixels) to operate, personalize, and enhance the Services. Cookies constitute small text files stored on your computing device.
a. Essential Cookies: Certain cookies are strictly necessary for the technical operation of the Services and the provision of functionalities explicitly requested by you (e.g., session management). The deployment of these cookies does not require prior consent due to their essential nature for service delivery.
b. Non-Essential Cookies (Analytics & Performance): Subject to your explicit consent, we may deploy cookies and similar technologies to gather information regarding your interaction with the Services. This encompasses technical data such as IP address, browser specifications, operating system details, device identifiers, visited pages, and interaction patterns. Such data facilitates performance analysis, user experience optimization, and comprehension of usage trends, leveraging analytics capabilities from integrated third-party services where applicable.
7.2. Consent: For the deployment of non-essential cookies and associated data collection for analytical purposes, we shall solicit your explicit consent prior to such activities. You retain the right to manage your cookie preferences and withdraw consent at any time via browser settings or designated cookie management tools within our Services. Be advised that disabling certain cookies may impair the functionality of the Services.
7.3. Analytics Services: We utilize analytics capabilities provided by third-party services, including but not limited to Google Analytics (provided by Google LLC), to gain insights into the usage patterns of our Services. These services may employ cookies and other tracking mechanisms, consistent with section 7.1.b, to collect relevant information. The generated data is aggregated into reports aiding service improvement. The use and sharing of information collected by Google Analytics are governed by the Google Analytics Terms of Use and the Google Privacy Policy. Other integrated platforms (as listed in 7.4) may also contribute to our analytics understanding.
7.4. Other Third-Party Services: The Services integrate various third-party platforms essential for functionality, security, performance, analytics, and core AI processing. These include, without limitation: a. Cloudflare, Inc.: For network security, content delivery, and associated analytics. b. Google LLC (Google Cloud Platform / Google Workspace): For infrastructure hosting, communication tools, and related operational analytics. c. Microsoft Corporation (Microsoft Azure / Microsoft 365): For infrastructure hosting, communication tools, and related operational analytics. d. Functional Software, Inc. (dba Sentry): For error tracking, application performance monitoring, and associated diagnostic analytics. e. AI Partners: As detailed in Section 4.1.f, providers such as Anthropic AI and DeepSeek AI process User Prompts to generate Outputs. f. Other Providers: Additional specialized service providers may be engaged for functions such as payment processing, customer support, etc., which might involve associated data processing.
7.5. Data Processing by Third Parties: These third-party service providers, including AI Partners, may process your personal data and User Prompts acting as data processors on our behalf or, in some instances, as independent data controllers, subject to their respective privacy policies and terms of service. Processing of User Prompts by AI Partners is strictly limited to the purpose of generating Outputs as requested via the Services, governed by our contractual agreements. We endeavor to select providers adhering to high data protection standards. We recommend consulting the privacy documentation of these third parties for comprehensive details regarding their data processing practices. Disclosure to and processing by these third parties occurs as reasonably necessary for the provision, security, analysis, and improvement of the Services, and as further delineated in Section 4.
8. CHANGES TO THIS POLICY
8.1. We may update this Policy from time to time. Any changes will be posted on this page with an updated revision date.
8.2. We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect personal data. Significant changes may also be communicated via email or through the Services.
9. SECURITY
9.1. We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
9.2. However, no method of transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee absolute security of personal data. You are also responsible for maintaining the security of your account credentials.
10. CONTACT INFORMATION
10.1. The data controller is Ludus AI P.S.A., with its registered office at Okrężna 8, 44-100 Gliwice, Poland, registered under NIP number 6312724828.
10.2. If you have any questions, concerns, or requests regarding this Policy or the processing of your personal data, please contact us at:
- Email: hello@ludusengine.com
- Address: Okrężna 8, 44-100 Gliwice, Poland