PRIVACY NOTICE

Effective Date: May 5, 2025

This Privacy Notice, together with our Terms of Use (“Terms”) (collectively, the “Agreement”), outlines the binding terms and conditions between you and Ludex LLC (“Ludex,” “we,” “our,” or “us”) regarding your access to and use of our Website (https://www.ludex.com), TCG Scanner, mobile app, mobile devices, and any other applications, websites, products, or tools (collectively, the “Services”) to which this Privacy Notice is linked or affixed.

Why Do We Collect Data?

At Ludex, we honor the tradition of card collecting while leveraging technology to enhance the hobby and empower our community through trust and transparency. Central to this mission is our commitment to being transparent about the data we collect about you, how it is used to further our mission, and with whom it is shared.

What Data Do We Collect?

Ludex recognizes the following categories of personal information referenced in the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, the “California Privacy Laws”), that a business may collect about a consumer. Ludex has collected the following categories of personal information from consumers within the last 12 months:

Please note that we may not collect each of these categories about every user.

How Do We Collect Your Data?

You directly provide Ludex with most of the data we collect. We collect data and process data when you:

• Register online for a subscription or engage with our products or services on our platform.
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
• Participate in our online community discussions.
• Use the app or view our platform via cookies or log files.
• Interact with our Customer Experience Representatives through our help and support functions.

We may also collect personal data from other sources such as credit agencies or bureaus and data providers.

How Will We Use Your Data?

Ludex collects your data for various purposes, including:

• Emailing you with special opportunities, which may include opportunities for in-person or virtual social interaction.
• Providing notifications of certain collectible items which may be available for a short time on our platform.
• Providing customer service.
• Providing you with personalized advertising and marketing communications.
• Detecting, preventing, mitigating, and investigating fraudulent or illegal activity.
• Fulfilling our contract with you under the Terms and, if applicable, the Payments Terms of Use.
• Maintaining the safety, security, and integrity of our Services, databases, and other technology assets, and business.
• Providing you with a personalized user experience on this website.
• Providing you with email alerts, event registrations, and other notices concerning our products or services or that of our partners, or events or news, that may be of interest to you.
• Conducting testing, research, analysis, and product development.
• Protecting the rights, property, or safety of us, our clients, or others.
• Carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collections.
• Improving our website and presenting its contents to you.

Who Do We Disclose Your Information To?

We may disclose your personal information to third parties for various business purposes. When we disclose personal information for a business purpose, we enter into contracts that describe the purpose and require the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The categories of recipients we may share your personal information with include:

• Service Providers: Third-party companies and individuals that provide services on our behalf or help us operate our Sites and Services (such as payment processing, customer support, hosting, analytics, email delivery, marketing, shipping and fulfillment, database management, and research services).
• Advertising Partners: We may enable advertising partners to collect information regarding our users for targeted marketing purposes.
• 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 may disclose the personal information that you authorized us to share.
• Business Partners and Data Aggregators: We may share user data with strategic partners, including data aggregators, to jointly develop aggregated, anonymized, or pseudonymized data products. These products may be licensed or sold to third parties, such as sports teams, marketing platforms, or enterprise partners, to better understand trends, behavior, and interests in the collectibles space. Shared data is either de-identified or used in accordance with contractual and legal obligations to prevent misuse and protect individual privacy.
• Compliance, Fraud Prevention, and Safety: We may disclose your information as required by law pursuant to lawful requests, such as subpoenas, court or agency orders, or as we may reasonably determine to be necessary to protect our rights or the rights of others, to avert harm to persons or property, to enforce this Privacy Notice or the terms governing our Services, and to protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

The Sale or Sharing of Your Personal Information

Under the California Privacy Laws, a “sale” is defined broadly to include any exchange of consumers’ information for value. While Ludex does not sell individual user profiles for direct marketing purposes, we may share data (including aggregated or de-identified data) with partners and third-party data aggregators to create market insights or to support joint commercial efforts. In the preceding twelve (12) months, we have conducted campaigns and may have received compensation related to email marketing or insights derived from user activity, which may qualify as a “sale” under the law.

You have the right to opt out of such data sharing by clicking “Do Not Sell or Share My Personal Information” or contacting us at Support@ludex.com.

User-Generated Content

You may share personal data with us when you submit user-generated content to the Services, including photographs. We urge you to be very careful when deciding to post sensitive photographs to our Services.

Children’s Privacy

Our Services are not directed to and only available for those over the age of 13. We do not knowingly collect, use, or disclose personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers. If you are under 13, do not provide any personal information through the Services.

International Users

Our data is maintained in the United States. All information we collect is gathered, stored, used, and otherwise processed in the United States, including information from individuals outside the United States. By accessing our Services, you consent to the transfer to and use of your information in the United States in accordance with this notice and applicable law.

We may transfer the personal information we collect about you when providing you with Services, to recipients in countries other than the country in which the information was originally collected, including to the United States, where we are headquartered. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g., via a program specific privacy notice provided to you at sign up, and from time to time). You understand and agree that while in the United States or foreign jurisdictions, your personal information may be accessible to law enforcement or other governmental authorities or bodies.

California Practice Law Metrics

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

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

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; e-mailing us at: Support@ludex.com; or writing us at the address provided in the “Contact Us” section below. Canadian residents can opt out of secondary marketing uses of your personal information by Ludex or our business partners by contacting us at the address provided.

Data retention

The time we retain personal information may vary depending on the Services we provide, and our legal obligations under applicable law. The following factors typically affect the retention period:

• Necessity for the provision of our Services: This includes things such as executing the Terms, maintaining and improving the performance of our Services, keeping our systems secure, and maintaining appropriate business and financial records. Most retention periods are determined on the basis of this general rule.
• Consent-based processing of personal information: If we process personal information on the basis of consent (including consent to the extended storage), we store the information for as long as necessary in order to process it according to your consent.
• Statutory, contractual or other similar obligations: We may be required to retain information for certain periods of time pursuant to applicable laws or official orders (e.g. for legal compliance, tax, accounting or auditing purposes), or to detect and prevent fraudulent or illegal activity on eBay. We may also retain personal information relating to pending or future legal disputes. Personal information contained in contracts, notifications and business letters may be subject to statutory storage obligations. We store the data for as long as necessary to comply with these obligations.

If you are located in the European Economic Area or United Kingdom, we process your personal information based on legal grounds such as your consent, fulfillment of a contract, legal obligations, or our legitimate interests (e.g., to improve our services).

Your Data Protection Rights

Ludex would like to make sure you are fully aware of all of your data protection rights. California residents are entitled to the following rights under the California Privacy Laws, and residents in other states may have similar rights under their respective state laws:

• The Right to Access and Data Portability: You have the right to request copies of your personal data. We may charge you a small fee for this service where permitted by law.
• The Right to Erasure: You have the right to request that we delete your personal information, subject to certain exceptions.
• The Right to Correct: You have the right to request the correction of personal information we have collected about you.
• The Right to Opt-Out of the Sale or Sharing of Your Information: As noted above, we may disclose your information to third parties for their direct marketing purposes. If you would like to opt out of such disclosures, please contact us at Support@ludex.com or call (312) 569-0810.
• If you use our mobile app, you can exercise this right by visiting our website and clicking ‘Do Not Sell or Share My Personal Information’ in the footer, or by contacting us directly.
• Right Against Discrimination: You have the right not to be discriminated against for exercising any of your data privacy rights.

How to Exercise Your Rights

To exercise your rights, contact us at Support@ludex.com or call (312) 569-0810. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it appropriately.