LUDENIO LABS LTD

PRIVACY POLICY

LUDENIO LABS LTD (“Ludenio Labs”) operates games in multiple territories worldwide. Depending upon the services you choose and the platform concerned, you may enter into a relationship with our company. These Privacy Policy (i) apply to Ludenio Labs’s online games and related services (the "Services"), and (ii) govern the relationship between you and Ludenio Labs. If you are using our Services through a social network, platform or applications provider (“Third Party Service”) (e.g., Facebook, Steam, iTunes, Google Play, etc.), any activities provided by such third party beyond Ludenio Labs’s Services are governed by that Third Party Service’s policies. If at any point you do not agree to any portion of the then-current version of our Terms of Service or another policies of Ludenio Labs, you must cease using the Services and your license to use the Services shall terminate.

AGREEMENT TO PRIVACY POLICY

By accessing any of Ludenio Labs’s Services, you agree to the terms of this Privacy Policy (and any updates thereto). By so agreeing, you authorize us to collect and use your information as outlined below. In the event you do not agree with this Privacy Policy (and any amendments which may be adopted by us), your only recourse is to cease use of our Services.

Please be aware that if you are using our Services through a social network, platform or applications provider (“Third Party Service”) (e.g., Facebook, Steam, iTunes, Google Play, etc.), any activities provided by such third party beyond Ludenio Labs’s Services are governed by that Third Party Service’s policies. We consider it a best practice for you to review the privacy policy of each website you frequent (as well as the privacy policies of any partners we may work with including advertisers) in order to be an informed consumer and to fully understand how your Personal Data is being handled.

PERSONAL DATA DEFINED

"Personal Data" is information that identifies you or that can be used to contact you (online or offline). Personal Data can include your name, email address, physical address, telephone number, gender, birthdate, etc.

COLLECTION OF PERSONAL DATA AND PURPOSES

We collect Personal Data in a variety of ways in order to provide you with the best possible experience using our Services. Sources of information include:

AGGREGATED DATA; NON-PERSONAL DATA GATHERING AND ANALYTICS

In addition to Personal Data, we collect a variety of data that is not used to specifically identify or contact you. This type of data is used to analyze and enhance our Services. Examples of such information include:

USER GENERATED CONTENT

User generated content includes various types of content which is publicly available and is produced by end users. For example, wall posts, messages, and actions with other end users would fall under this definition. It is possible that the user generated content you choose to provide may contain Personal Data. Please be aware that we cannot guarantee protection for information you make available publicly through comments, information sharing mechanisms, wall posts, etc. Any user generated content you share while using our Services on a social network, will very likely be disseminated broadly through the social network. Also, any Personal Data that is publicly shared by the user could be harvested by third parties (including by other users of the social network) with access to it and we cannot control those third parties' use of such information. Please bear these factors in mind before sharing any content with us.

WHAT WE DO NOT DO WITH YOUR INFORMATION

WHAT WE MAY DO WITH INFORMATION WE COLLECT

Here are some of the things we may do with the Personal Data and non-Personal Data that we collect. If we determine there are additional things we would like to do, we will amend this Privacy Policy and notify you.

Legal Requirements and Safety Issues.

Please be aware, we will disclose information, including Personal Data, to the extent it may be necessary due to the applicable legislation (required by law). We may disclose information pursuant to subpoenas, court orders, or other requests if such an action required by law.

Protection basic rules.

You are have full extent of rights as a subject ofPersonal Data in accordance with the applicable legislation, including General Data Protection Regulation (Directive 95/46/EC). It means you have the right:

To exercise any of your rights and ask any questions regarding aforementioned provisions, you may use the following link: privacy@luden.io.

TRANSFER IN THE EVENT OF SALE OR CHANGE OF CONTROL

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the services we provide you can continue to operate. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Policy. In the event that we no longer operate a specific game through our Services, we may work with the subsequent game operator to offer you the ability to continue to play the game with the new game operator. This might involve inviting you to create a new user name and password in order to continue playing the game with the new game operator. If material changes to Ludenio Labs's privacy practices will occur as a result of a business transition, we will notify you and other users of the business transition prior to transferring your Personal Data as set forth below under Changes to Privacy Policy.

SECURITY OF OUR SERVICES

We use encryption and authentication tools to protect the security of the information that you share with us. Once we receive your transmission, we will do our best to protect its security on our systems. For example, all Personal Data we gather in connection with our Services is maintained on a secured server behind a firewall. Unfortunately, while we strive to protect your Personal Data, no data transmission over the Internet can be guaranteed to be 100% secure and we caution you that any information you transmit to or from our Services is at your own risk. Accordingly, we disclaim liability for any theft, loss, or interception of or any unauthorized access or damage to any data or communications. By using the Services, you acknowledge that you understand and agree to assume these risks.

OPTING OUT

You may review, update, correct or delete Personal Data we receive from a Third Party Service by updating that information on your profile. If you elect to register with us and you would like to review, update, correct or delete that Personal Data, you may do so by removing and unsubscribing yourself in our email notifications. If you have any difficulties implementing any such changes on a Ludenio Labs Service, please contact our Customer Service team for the applicable Service and/or write to privacy@luden.io.

LINKS

If you access our Services through a Third Party Service such as Facebook, links may appear in the same window or on screens before you commence playing. Any links you see adjacent to our Services may link you to parties completely unrelated to Ludenio Labs. Because we cannot control the activities of third parties, we cannot accept responsibility for your use of their services or for any use of your Personal Data by such third parties and we cannot guarantee that they will adhere to the same privacy and security practices as ourselves. The presence of a third party link within the Services does not represent an endorsement of the content of that third party's link and Ludenio Labs disclaims all liability arising from such content.

INTERNATIONAL

Personal data provided to Ludenio Labs will be collected, processed and stored by Ludenio Labs in the European Union. As part of our international operations, our Affiliates have access to such personal identifiable information data for our legitimate business purposes. To operate and distribute the Services, our Affiliates provide certain services to Ludenio Labs. The data we hold may also be processed by employees who work for us or one of our Affiliates. For example, such parties may be involved in payment processing or provide support services for our games. To the extent that any of our Affiliates have access to personal identifiable information derived from the Services, such Affiliate will adhere to applicable laws.

OTHER JURISDICTIONS; RIGHT TO ACCESS PERSONAL DATA AND OPT-OUT RIGHTS

If you are resident in a jurisdiction which grants you the right to access the Personal Data that we maintain concerning you and/or any disclosures we may have made concerning such information, your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to privacy@luden.io. If you are resident in a jurisdiction where we are required to notify you that you may choose to opt out of Ludenio Labs’s disclosure of Personal Data to third parties for direct marketing purposes, your right to opt out can be exercised by writing to privacy@luden.io.

CHILDREN AND PRIVACY

Our Services are not directed to children under 16 years old. By using our Services, you represent and warrant that you are at least 16 years old. If we become aware that a user under the age of 16 has registered without prior verifiable parental consent, we will remove that user's Personal Data. If you are using our Services through a Third Party Service, please be advised that under most Third Party Service’s terms of service and privacy policies (e.g., Facebook’s Terms of Service and Facebook’s Privacy Policy), children under age 16 are prohibited from accessing and using such social networks. If you believe that we might have collected any information from a child under age 16, please contact us at privacy@luden.io so that we can investigate and remove the information.

DO NOT TRACK

Some web browsers allow the setting of a “Do Not Track” feature that communicates to websites that you do not want to have your online activity tracked. However, the communication of the Do Not Track signal is not yet uniform across the web. To find out more about "Do Not Track," you may wish to visit www.allaboutdnt.com.

CHANGES TO PRIVACY POLICY

In the event Ludenio Labs makes any changes to its Privacy Policy, it will post the updated policy on its Services. You may also be given additional notice, such as an e-mail message or through a notice which appears within one of our games or on our Services. You will be deemed to have accepted such changes by continuing to access the Services. Except as otherwise stated, all amended terms shall automatically be effective 30 days after they are initially posted. Ludenio Labs may also revise other policies, codes or rules at any time, and the new versions will be available on www.luden.io or from within the applicable game.

INQUIRIES

If you have any questions or concerns, please email us at privacy@luden.io