LUDEX PRIVACY NOTICE

Effective Date: October 22nd, 2025

Last Updated: November 12, 2025

This Privacy Notice explains how Ludex LLC (“Ludex,” “we,” “our,” or “us”) collects, uses, and discloses information about you when you use our website, mobile application, and related online services (collectively, the “Services”). Please read this Privacy Notice carefully. By accessing or using the Services, you agree to the practices described here. If you do not agree, please stop using the Services. In some regions, you may have additional rights or be asked for specific consent before certain types of information are collected or used. 

For details on how to manage your preferences, see Section 10 Your Rights and Choices. This Privacy Notice applies globally to all users of the Services and should be read together with any region-specific notices that apply to you.

Table of Contents

1. Key Terms
2. Changes to This Privacy Notice
3. How We Collect Information 

3.1 Information You Provide 

3.2 Information Collected Automatically 

3.2.1 Device and Usage Data

3.2.2 Cookies and Similar Technologies 

3.2.3 Inferences from Usage Data 

3.3 Information from Third-Party Sources

4. How We Use Information
5. How We Disclose Information
6. Children’s and Teen Privacy
7. Third-Party Services, Features, and Links
8. Advertising and Analytics Services Provided by Others
9. Data Retention
10. Your Rights and Choices 

10.1 Rights Available to All Users 

10.2 Additional Rights by Region 

10.3 Sale and Sharing of Personal Information

 10.4 California Sale/Share and Disclosure Table (Past 12 Months) 

10.5 How to Exercise Your Rights

10.6 Appeals

10.7 Targeted Advertising Profiling

10.8 California “Shine the Light” Disclosure

11. Managing Your Preferences
12. Categories of Information We Collect
13. International Data Transfers
14. California Privacy Metrics
15. Contact Us

1. Key Terms

For clarity in this Privacy Notice:

• “information” means any data we collect about you or your device when you use the Services. This includes both personal Information (as defined below) and other information that may not, on its own, identify you.
• “personal information” (sometimes called personal data under applicable law) means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual or household. This includes obvious details like your name and contact information, as well as less direct identifiers such as device IDs, online activity, location data, and inferences drawn from other information. For clarity, this term includes “personal data” as defined under the EU and UK General Data Protection Regulation (GDPR), “personal information” under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), “personal information” under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and similar concepts under other applicable privacy and data protection laws worldwide.
• “service providers” means entities that process information on our behalf and are contractually bound to use it only for the purposes we specify.
• “affiliates” means companies that are owned or controlled by Ludex LLC, or that own or control us.
• “advertising partners” means third parties that help deliver targeted advertising or measure ad performance.
• “data aggregator partners” means third parties that compile information from various sources for analytics, marketing, or other purposes.

2. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make changes, we will post the updated version on the Services with a revised “Last Updated” date. If we make material changes, we will also provide additional notice, such as by email or within the Services, if and as required by applicable law. Your continued use of the Services after the updated Privacy Notice is posted constitutes your acceptance of the changes.

3. How We Collect Information

When you interact with the Services, we collect information to operate, improve, and protect the Services. This includes information (a) you provide directly, (b) information collected automatically, and (c) information we receive from other sources.

3.1 Information You Provide

We collect information you submit directly through the Services, which may include the following:

• Contact Information: Name, address, phone number, email address.
• Order Details: Billing and shipping address, payment confirmation, order history.
• Account Credentials: Username, password, security questions, and other information used for account security purposes.
• Customer Support: Information you choose to include in communications with us, for example when sending a message through the Services.

Some features may require you to provide specific information. If you choose not to provide it, certain functionalities may be limited.

3.2 Information Collected Automatically

3.2.1 Device and Usage Data

We automatically collect certain information about your interactions with the Services to help us understand usage patterns, improve performance, and enhance your experience. This data is collected through cookies, log files, and similar technologies, and may include:

• Device and Browser Information: Type of device, operating system, browser type, and version.
• IP Address and Network Details: Your IP address, general location derived from IP, and internet service provider.
• Site Usage and Activity Logs: Pages visited, features used, time spent on the Services, navigation paths, and other behavioral metrics.
• Performance and Diagnostic Data: Error reports, load times, and technical data used to monitor and improve service reliability.

This data is often collected in aggregate form and does not directly identify you unless linked to your account or other personal information.

3.2.2 Cookies and Similar Technologies 

We use cookies and similar technologies to collect usage data, personalize content, and improve the functionality of our Services. Cookies are small data files stored on your device that help us recognize repeat visitors, track usage trends, and deliver relevant content.

You can manage your cookie preferences through your browser settings. Most browsers are set to accept cookies by default, but you may choose to remove or reject cookies. Disabling cookies may impact the availability and functionality of certain features within the Services.

For more information about the types of cookies we use, the purposes they serve, and how to manage them, please see our Cookie Policy.

3.2.3 Inferences from Usage Data

 In some cases, we use the usage data we collect to make inferences about your preferences, interests, or behavior. These inferences help us:

• Personalize your experience on the Services.
• Recommend content or features that may be relevant to you.
• Improve our understanding of user needs and expectations.
• Deliver more relevant marketing or promotional communications where permitted.

These inferences are generated using automated systems and are based primarily on your interactions with the Services. You may be able to opt-out of certain personalization features or targeted communications by adjusting your account settings or contacting us directly. For more information, see the Section 10 Your Rights and Choices below.

3.3 Information from Third Party Sources

We may also receive information about you from third party sources, including:

• Service Providers: Vendors who support our Services, for example Shopify, may share data related to your interactions with the Services.
• Payment Processors: To fulfill orders and provide requested products or services, our payment partners may collect and share payment related information, including billing address and credit or debit card details.
• Marketing and Advertising Partners: We may receive data about your engagement with our ads or communications, such as whether you opened an email or clicked on a link.
• Data Providers and Credit Agencies: Where permitted by law, we may obtain additional information from external sources to verify identity, assess risk, or enhance our services.
• Data Aggregator Partners: We may receive limited information about users or aggregated audience segments from authorized partners to help us understand collector trends, improve our analytics, and support our affiliated business products. These partners provide data under data license agreements in accordance with privacy laws. This information is handled in accordance with this Privacy Notice.

Any information we obtain from third parties is handled in accordance with this Privacy Notice. For more details on how third-party websites and links are treated, see Section 7 Third-Party Services, Features, and Links below.

4. How We Use Information

We use the information we collect to provide, maintain, and improve the Services. This includes fulfilling our contractual obligations, enhancing your experience, and supporting business operations. Specifically, we may use your information to:

Provide and Maintain the Services

• Process transactions, including payments, orders, and returns.
• Manage your account and preferences.
• Arrange shipping, returns, and exchanges.
• Enable account features and functionalities.
• Support integrations with third party platforms such as Shopify.

Communicate with You

• Send service-related communications, including updates to your account, purchases, returns, or exchanges.
• Notify you of changes to our policies or terms.
• Respond to inquiries and provide customer support.

Marketing and Promotional Communications

• Send promotional messages, newsletters, or special offers.
• Alert you to products, services, or events that may be of interest.
• Personalize marketing content based on your preferences and interactions. (See Section 10 Your Rights and Choices for information on opting out).

Personalization and Advertising

• Customize your experience on the Services and third-party platforms.
• Tailor advertisements based on your interests, browsing behavior, and purchase history.
• Evaluate advertising performance, including impression counts and placement quality.

Improve the Services

• Monitor and improve the performance, accessibility, and usability of the Services.
• Conduct research, testing, and development.

Analyze Usage and Trends

• Track user behavior and engagement across the Services.
• Generate insights to inform business decisions and improve experiences.

Ensure Security and Prevent Fraud

• Detect, investigate, and help prevent fraudulent, illegal, or malicious activity.
• Protect the rights, property, and safety of Ludex, users, and others.
• Maintain the integrity of our systems and infrastructure.

Comply with Legal Obligations

• Comply with legal and regulatory requirements.
• Resolve disputes or enforce our agreements.
• Respond to lawful requests and investigations.

Other Purposes

• Use information for purposes disclosed at the time of collection.
• Carry out any other use with your consent.

We may also de-identify or aggregate your information so that it no longer identifies you. This data may be used for analytics or other purposes consistent with this Privacy Notice.

5. How We Disclose Information

We may disclose your information to third parties in the ways described in this Privacy Notice, including to provide and improve the Services, comply with legal obligations, and protect our rights. We disclose your information only as described below and in accordance with applicable law.

Service Providers: We disclose your information to third party companies and individuals that provide services on our behalf or help us operate the Services, including payment processing, customer support, hosting, analytics, email delivery, marketing, shipping and fulfillment, database management, and research services. These service providers are contractually required to use your information only as necessary to provide the requested services to us.

Affiliates: We disclose your information to our affiliates for purposes consistent with this Privacy Notice, including to operate and improve the Services, provide customer support, and offer relevant products and services.

Advertising Partners: We disclose certain personal information to advertising partners to deliver targeted advertising, measure ad performance, and improve relevance. Some of these disclosures may be considered a “sale” or “sharing” under applicable privacy laws. See Section 10 Your Rights and Choices below for details.

Business Partners: We disclose your information to business partners with whom we jointly offer products or services, or whose offerings may be integrated with our Services. We disclose only the information necessary for these partners to provide or improve their offerings.

Data Aggregator Partners: We disclose your information to data aggregator partners for analytics, market research, or other lawful purposes. Where required by law, we will obtain your consent before making such disclosures.

Third Party Platforms and Social Media Networks: If you have enabled features or functionality that connect the Services to a third-party platform or social media network, we disclose the information that you authorize us to share.

Legal and Compliance: We may disclose your information if we believe it is necessary to:

• Comply with applicable laws, regulations, or legal processes.
• Respond to lawful requests from public authorities.
• Enforce our agreements, policies, and terms of service.
• Protect the rights, property, or safety of Ludex, our users, or others.

Corporate Transactions: If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be disclosed as part of that transaction, subject to applicable law.

With Your Consent: We may disclose your information for any other purpose disclosed to you at the time of collection, or with your consent.

Note: Certain disclosures described above may be considered a sale or sharing of personal information under U S state privacy laws. For more information, including how to exercise your rights, see Section 10 Your Rights and Choices below.

6. Children’s and Teen Privacy

Our Services are intended for individuals age 16 and over. We do not knowingly collect, use, sell, or share personal information from anyone under the age of 16. Because our Services currently do not include an age-verification feature, it is possible that information from younger users could be submitted without our knowledge.

If you are a parent or guardian and believe that your child under 16 has provided us with personal information, please contact us at [email protected]. If we become aware that we have collected personal information from anyone under 16 without verified parental consent, we will take steps to delete that information.

If you are between the ages of 13 and 15, certain U.S. state privacy laws, including the California Privacy Rights Act, require that we obtain your affirmative opt-in consent before “selling” or “sharing” your personal information for targeted advertising or marketing purposes. Until we implement an in-Service consent mechanism, we do not knowingly sell or share personal information of users under 16 in a manner that constitutes “sale” or “sharing” under applicable law.

7. Third Party Services, Features, and Links

The Services may include social sharing features and other integrated tools, such as the Facebook “Like” button and embedded content such as videos or interactive media. Using these features could allow you to share certain information with your contacts or the public, subject to the privacy settings you maintain with the third-party provider.

For more information about how these third parties handle the information they collect, please review their privacy policies. Additional details about cookies or  similar technologies associated with these integrations can be found in our Cookie Policy.

The Services may also include links to or integrations with third party websites. We have no control over the information that is collected, stored, or used by third party websites, and we are not responsible for their information handling or privacy practices. Your use of these third-party websites is subject to each provider’s privacy policy, so we encourage you to read these policies carefully.

8. Advertising and Analytics Services Provided by Others

We may allow third parties to provide analytics services in connection with our Services, and we may include third party content or integrations that use cookies or similar technologies. These entities may collect information technical and usage information from your device and activity across the Services and other websites over time.

This information may be used by us and by others to, among other purposes, analyze usage trends, measure the effectiveness of content, deliver or personalize advertising (including interest-based advertising), and improve the functionality of the Services. Where required by law, these technologies are used only with your consent.

To learn more about the specific cookies and technologies we use, and how you can manage your choices, including opting out of certain interest-based advertising, please see our Cookie Policy.

9. Data Retention

We keep information for as long as needed to provide the Services and for other essential purposes, such as complying with legal obligations, resolving disputes, and enforcing our agreements. The length of time we retain information depends on factors such as the type of information, the reasons it was collected, and applicable legal or operational requirements.

Once information is no longer needed for the purposes for which it was collected, or for other legally permissible business need, we will use commercially reasonable measures to delete it or de-identify it, unless we are required or permitted by law to keep it for longer.

10. Your Rights and Choices

We respect your privacy rights and provide various ways for you to manage your information. Some rights apply to all users, while others apply only in certain jurisdictions.

10.1 Rights Available to All Users

Regardless of where you live, you may have the right to:

• Access: Request a copy of the information we hold about you.
• Correction: Ask us to correct inaccurate or incomplete information.
• Deletion: Request deletion of information, subject to legal or operational requirements and our legitimate business needs.
• Restriction: Ask us to limit certain processing of your information.
• Portability: Request a portable copy of your information in a commonly used format if technically feasible.
• Objection: Object to certain processing, including for direct marketing.
• Withdraw consent: Withdraw consent where we rely on it for processing.

You may exercise these rights as described in Section 10.5 (How to Exercise Your Rights).

10.2 Additional Rights by Region

EU/EEA, Switzerland, and UK: If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have certain rights under the GDPR or UK GDPR. In this section, we use the term personal data as it appears in those laws. In Section 1 Key Terms, personal information has the same meaning as personal data for these purposes. You may have the right to:

• Access, rectify, or erase your personal data.
• Restrict or object to processing.
• Receive your personal data in a portable format.
• Withdraw consent at any time.
• Lodge a complaint with your local data protection authority.

We process your personal data only when we have a lawful basis to do so. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

Canada: You have rights under PIPEDA, including the right to challenge our compliance and to be informed of transfers outside Canada. You may withdraw consent at any time, subject to legal or contractual restrictions. You may also request written information about our policies and practices relating to the management of personal information by contacting us using the details in Section 15 Contact Us below.

Canadian Users Opt-Out 

If you are a Canadian resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes by contacting us by phone at (312) 569-0810, emailing us at [email protected], or writing to us at the address provided in Section 15 Contact Us below. Canadian residents may also opt-out of secondary marketing uses of personal information by us or our business partners by using these contact methods.

Certain U.S. States: Residents of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have the following rights, subject to exceptions:

• Access/Know: The categories and specific pieces of Personal information we collect, use, disclose, sell, or share.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of personal information.
• Opt-out: Opt-out of the sale or sharing of personal information (see Section 10.3 Sale and Sharing of Information).
• Limit: If applicable, limit the use and disclosure of sensitive personal information. Note: We do not collect sensitive personal information as defined under California law.
• Appeal: Appeal our decision if we decline your request. (see Section 10.6 Appeals).

We will not discriminate against you for exercising these rights.

10.3 Sale and Sharing of Information

As defined under applicable U.S. state privacy laws, we may sell or share certain categories of personal information in the past 12 months for purposes including advertising, marketing, analytics, and data licensing. These categories are described in Section 12 Categories of Personal Information We Collect below.

Examples include:

• Advertising and cookies: We permit certain third-party advertising partners, such as YouTube through embedded videos and cookies, to collect information about your interactions with the Services for targeted advertising, measurement, and analytics.
• Data licensing and commercialization: We disclose personal information to our affiliate, Collectors Data Store, LLC (CDS), a wholly owned subsidiary. CDS licenses and commercializes datasets that include personal information derived in part from Ludex-collected information in conjunction with data aggregator partners. Because this disclosure involves an exchange of value, it may be deemed a “sale” or “sharing” under state privacy laws such as the CCPA and CPRA.

You may opt-out of these sale and sharing activities as described in Section 10.2 Additional Rights by Region above and Section 10.5 How to Exercise Your Rights below. We do not knowingly sell or share personal information of children under 13. For users aged 13 to 15, we will not sell or share your personal information without affirmative opt-in consent as required by applicable law. Until we implement an in-Service consent mechanism, we do not knowingly sell or share personal information of users under 16. For more information about how we handle children’s and teen personal information, see  6 Children’s and Teen Privacy above.

10.4 California Sale/Share and Disclosure Table (Past 12 Months)

Category of Personal Information	Sold or Shared?	Categories of Third Parties (Sale/Share)	Disclosed for a Business Purpose?	Categories of Third Parties (Business Purpose)
Identifiers	Yes (sold/shared)	Advertising networks, analytics providers	Yes	Payment processors, customer support providers, fraud prevention partners
Account & Transaction Data	Yes (sold/shared)	N/A	Yes	Payment processors, shipping providers, customer support providers
Commercial Information	Yes (sold/shared)	Advertising networks, analytics providers, data licensing partners	Yes	Fulfillment providers, analytics providers
Internet or Network Activity	Yes (sold/shared)	Advertising networks, analytics providers	Yes	Security partners, analytics providers
Geolocation Data	Yes (sold/shared)	Advertising networks, analytics providers	Yes	Fraud prevention partners, analytics providers
Inferences	Yes (sold/shared)	Advertising networks, analytics providers, data licensing partners	Yes	Analytics providers, marketing partners

Notes:

• “Sold” means the disclosure of personal information for monetary or other valuable consideration.
• “Shared” means the disclosure of personal information for cross-context behavioral advertising.
• We do not knowingly sell or share personal information of children under 16. 

10.5 How to Exercise Your Rights

You can exercise your privacy rights by submitting a request through our Your Privacy Choices / Do Not Sell or Share My Personal Information link, by emailing us at [email protected] , or by mail to the address in Section 15. We will verify your identity before processing your request and respond within the timeframes required by applicable law.

For California-resident requests, we will confirm receipt within 10 business days of a request for access/know, to delete or to correct and provide information and cease selling/sharing within 15 business days of your opt-out and notify relevant third parties as required. If you choose to have someone act on your behalf, please review the following requirements.

Authorized Agents: California residents may also exercise their rights through an authorized agent. To do so, the agent must provide proof of their authorization, such as a signed written permission from you or a valid power of attorney. We may also require you to verify your identity directly with us and confirm that you have authorized the agent to act on your behalf, as permitted by California law. 

Nevada Residents. To opt out of the sale of your personal information, submit a verified request to our designated request address [email protected] , subject line “Nevada Do Not Sell”.

10.6 Appeals

If we deny your request, you may appeal by emailing us at [email protected] with the subject line “Appeal of Privacy Request.”

If you are in Colorado, Oregon, or New Jersey, we will decide your appeal within 45 days from our receipt of your request. If you are in Connecticut, Nebraska, New Hampshire, Maryland, Texas, or Virginia we will decide your appeal within 60 days from our receipt of your request.

For all responses, we will include reasons and how to contact your state Attorney General if you remain unsatisfied.

10.7 Targeted Advertising and Profiling

In states where applicable, you may opt out of targeted advertising and, where provided by law, opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

10.8 California “Shine the Light” Disclosure

California residents may request information about our disclosures of personal information to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please contact us by email at [email protected] or by writing to the address provided in Section 15 Contact Us below.

11. Managing Your Preferences

You can control certain types of information we collect and how we communicate with you.

Account Information: Update, correct, or delete certain account details by contacting us at [email protected]. If you request deletion or deactivation, we may retain information as required by law or for legitimate business purposes.

Location Information: If our mobile application collects precise location information, you will be asked to consent when you first use the app. You can withdraw consent in your device settings or by uninstalling the app. Disabling location services may affect certain features.

Cookies and Similar Technologies: Manage cookies through your browser settings. For details on our use of cookies and related technologies, see our Cookie Policy. Disabling cookies may affect the availability and functionality of our Services.

Promotional Communications: Opt-out of promotional emails or texts by following the instructions in those messages or contacting us. We may still send non-promotional messages related to your account or our ongoing business relationship.

Push Notifications: With your consent, we may send push notifications to your device. You can disable these in your device settings.

12. Categories of Information We Collect

Category	Examples	Purposes	Legal Bases*
Identifiers	Name, postal address, email, phone, username, IP address, device ID	Provide and maintain services; account management; personalization; marketing; security; legal compliance	Contract performance; legitimate interests; consent (where required); legal obligation
Account & Transaction Data	Contact details, billing/shipping address, payment confirmation, order history	Same as above, plus payment processing and order fulfillment	Contract performance; legitimate interests; legal obligation
Commercial Information	Purchase history, order details, preferences	Fulfill orders; personalize services; marketing; analytics; product improvement; targeted advertising	Contract performance; legitimate interests; consent (where required)
Internet or Network Activity	Browsing history, search history, pages visited, features used, interactions with ads or emails	Service functionality; analytics; personalization; targeted advertising; security	Legitimate interests; consent (where required)
Geolocation Data	Approximate location from IP address or precise location if you have granted device-level permission	Personalization; fraud prevention; targeted advertising; analytics	Legitimate interests; consent (where required)
Inferences	Profiles reflecting preferences, characteristics, behaviors, interests	Personalization; marketing; analytics; product improvement	Legitimate interests; consent (where required)

*Legal bases apply to jurisdictions that require them (e.g., GDPR/UK GDPR).

13. International Data Transfers

Our Services are operated in the United States, and your information may be transferred to, stored in, and processed in the United States and other countries. These countries may not provide the same level of data protection as your home country.

• EU/EEA and UK Users: We rely on legal bases permitted under GDPR and UK GDPR and take steps to provide appropriate safeguards, such as contractual terms with service providers and affiliates. While in the U.S., your information may be accessible to courts, law enforcement, and national security authorities.
• Canadian Users: By using the Services, you understand your information may be transferred to the U.S. and other jurisdictions, where it may be subject to lawful access by foreign authorities. We use contractual and organizational measures intended to protect your information in accordance with this Privacy Notice.

14. California Privacy Metrics

The California Privacy Laws require us to track and publish the following metrics for the previous calendar year. The metrics below reflect our calculations from January 1, 2024 through January 1, 2025, and include requests from all individuals in the United States.

Metric	Number
Number of Access requests (“Requests to Know”) received	1
Number of Access requests complied with in whole or in part	1
Number of Access requests denied	0
Mean or Median number of days to substantively respond to Access requests	1
Number of Deletion requests received	8
Number of Deletion requests complied with in whole or in part	8
Number of Deletion requests denied	0
Mean or Median number of days to substantively respond to Deletion requests	1
Number of Opt-out requests received	0
Number of Opt-out requests complied with in whole or in part	0
Number of Opt-out requests denied	0
Mean or Median number of days to substantively respond to Opt-out requests	0

15. Contact Us

For more information about our privacy practices, or if you have any questions, inquiries, or complaints about the collection or use of your information, please contact us by e-mail at [email protected] or by mail using the details provided below: 

Ludex, LLC

223 W. Erie, Suite 6E

Chicago, IL 60654

USA