1 Introduction, General Provisions and Definitions
1.2 There are two categories of information we collect:
1) Information that we need to make Ludwig work.. This category includes: Registration information including but not limited to full name, birth date, address, and other information you may provide when you sign up for Ludwig; broad, non- specific location, which we derive from your IP address. This also enables us to provide you suggestions and/or make suggestions based on your general location; technical information necessary to operate Ludwig’s Services. This includes the type of browser and device you use.
2) information that we can use to provide additional features and improved experiences if you choose to share that information. This second category includes information that enables us to offer you additional features. We never receive any of the following information unless you expressly choose to share it with us. Here are some examples of the information included in this category: your specific location (We will never gather or use your specific device location without first getting your explicit permission); and your contacts (We will never scan or import your contacts unless you ask us to).
1.4 In some contexts, we will share certain information. For example, like most services, if you sign up for Ludwig through a third party like Facebook or a mobile provider, we share some information with them and they share some information with us in order to enable your account. We are also allowed to share information with our technical and marketing partners. More specifically, if you use Facebook or other social platforms to create your account, or if you connect your user account with such￼social platforms' accounts, you give us the permission to access basic information from that account, as well as information you made available on your account.
- Personal Information (or Data). Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
- Usage information (or Data). Information collected automatically from Ludwig (or third party services employed in our Services ), including but not limited to: the IP addresses or domain names of the computers utilized by the Users who use our Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within our Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
- Data Controller. The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Ludwig’s Services. The Data Controller, unless otherwise specified, is the Owner of this Service.
2.2 Please therefore make sure you read any such notice carefully. If you disagree with any changes in this Policy and do not wish your information to be subject to the revised Policy, you will need to STOP using our services and close your Ludwig account.
3 Information we collect
3.1 When you use or interact with our Services, we may use a variety of technologies that allow us to collect information about how the Service is accessed and used. Specifically, we collect and store such information:
- Your full name, email address, and username. This lets us create your account, provide you with convenient and personalized access to your account and deliver and support our Products. This information also helps us communicate with you about your use of our Products, product announcements and software updates, as well as respond to your requests for assistance (including providing account verification support ifyou’re having difficultly accessing your account). In addition, we may use your Personal Information to send you direct marketing emails and special offers. For more information, please see the section 10 below entitled “Promotional emails and Communications”.
- The geographic area where you use your computer and mobile devices (as indicated by an IP address or similar identifier), and the language you select when interacting with our Services. We collect this information in order to help us deliver and support our Services, including by localizing your experience. This information also helps us improve our understanding of how our users use the Services.
- The Ludwig services you use. This information helps us deliver and support our Services and respond to your requests for assistance. We also collect this information to improve our understanding of how our users use our Services.
- Any User Content (as defined in the Terms and Conditions of Use ) you add while interacting with our Services, including but not limited to: the details of the queries you make and the date and time of your request, your Feedback (as defined in the Terms and Conditions of Use ) and any message you send and/or receive via the Service;
- information about your type of subscription and your interactions with the Service, Third Party Applications, and advertising, products, and services which are offered, linked to, or made available on or through the Service;
- Unique device identifier for devices that are using Ludwig software. We use this information to (1) calculate aggregate statistics on the number of unique devices using our Services, and (2) detect and prevent misuse of our Services. Our third-party fraud detection partner also uses device identifiers for the detection and prevention of fraud and malicious use of our Services.
3.2 You may also choose to voluntarily add other information to your profile by adding new and additional information on “Your Account” page.
3.3 We don’t use this information for any purpose other than to provide the Services, make sure it is available to you when you use our Products and improve our algorithms underlying our Products.
3.4 The Site and the Software also collect and receive information from your computer or mobile device, including the activities you perform within your account, the type of hardware and software you are using (for example, your operating system, word processing or other productivity software and browser type) and information obtained from cookies. When you access the Software, that application will request access to certain information on your computing device.
3.5 We use a third party services and/or applications and to gather information about how you and others use the Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to better understand and optimize the Site.
3.6 Gathering this kind of information helps us administer our Services and/or provide convenient and personalized user access and improve the features and usability of our Services.
3.7 If you sign up for a Trial (as defined in the Terms and Conditions of Use), purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use), or make other purchases through the Service, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by Stripe (https://stripe.com). We may also collect some limited information, such as your delivery address in case of physical goods being shipped and details of your transaction history, all of which are necessary to provide you with our Services. In addition, the payment processors may provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they have stored, and your card’s type, expiration date, and certain digits of your card number.
3.10 We may also receive information about you from our service providers and partners, which we use to personalize your Ludwig experience, to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you. We also use this information as explained in the section below “How we use your information”.
4 How we use your information
4.1 Ludwig processes the information of its users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
4.2 The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller/s, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties appointed (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies), if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
4.3 The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact us by sending an email at: firstname.lastname@example.org.
4.4 The Data is kept for the time necessary to provide the service requested by the user, or stated by the purposes outlined in this document, and the user can always request that the Data Controller suspend or remove the data.
4.5 Consistent with the permissions you give us to collect the information, we may use the information we collect, including your personal information:
- to ensure technical functionality of the Service, develop new products and services, and analyze your use of our Services, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Services;
- to communicate with you for Service-related or research purposes including via emails, notifications, or other messages, which you agree to receive;
- to provide, personalize, and improve your experience with our Services and advertising (including third party products and services) made available on or outside Ludwig’s Services (including on other sites that you visit), for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside our Services;
- to communicate with you, either directly or through one of our partners, for marketing and promotional purposes via emails, notifications, or other messages, consistent with any permissions you may have communicated to us. You can decide to opt out from receiving certain messages at any time;
- to enable and promote our Services and other services or products, either within or outside our Services, including features and content of the Services made available through Ludwig’s Services;
- to prevent or detect fraud and to provide you with billing information;
- to provide you with features, information, advertising, or other content which is influenced by your location;
- to allow a merger, acquisition, or sale of all or a portion of our assets;
- to respond to legal process (e.g., a court order or subpoena), if we believe in good faith that it is necessary to do so; to comply with requirements of mandatory applicable law; to protect the safety of any person; to protect the rights and property of Ludwig, including to enforce the Terms and Conditions of Use and any other terms that you have agreed to; and to address fraud, security, or technical issues;
- to academic researchers for purposes including statistical analysis and academic study, but only in a de-identified format;
- to publish de-identified or aggregate information about the use of the Ludwig Service;
4.7 We may use Personal Information or Anonymous Information in connection with our online advertising activity. Online advertisements may be in the form of banner ads, splash ads, or other formats. These advertisements may appear at our Website, and we may contract with third party advertising companies to promote our Services and serve related advertisements on websites and mobile applications that are owned or operated by parties not affiliated with us.
5 Accessing and updating user information
5.2 We will respond to your request within a reasonable period of time upon verification of your identity in accordance with local laws. We recommend you include documents that prove your identity and a clear and precise description of the information which you request access to.
6.1 The Ludwig Service is not directed to children under the age of 13. (In some countries, stricter age limits may apply. See our Terms and Conditions of Use) We do not knowingly collect personal information from children under 13 or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, do not use the Service and do not provide any personal information to us. If you are a parent of a child under the Age Limit and become aware that your child has provided personal information to Ludwig, please contact us at email@example.com and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights.
7.1 Ludwig is committed to protecting the security of your information and takes reasonable precautions to protect it. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be totally secure, and as a result, we cannot ensure the security of information you transmit to us, including Personal Information and User Content. Accordingly, you acknowledge that you provide us with your personal information and data at your own risk.
7.2 If Ludwig learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.
7.3 Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used our Services. While we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information.
7.4 In the event we share information with third party service providers or joint marketers, we restrict the ability of such parties to use or disclose the information we furnish. We also require such parties to apply appropriate security measures to protect information. Unfortunately, no data transmission or storage system can be guaranteed to be absolutely secure, and we disclaim any representation or warranty that our information security systems or those of our service providers and joint marketers are absolutely invulnerable to breach or compromise.
8 Links To Other Websites
8.2 We may display advertisements from third parties and other content that links to third party websites. We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your personal information.
9 Information about cookies and third-party data collection
9.2 To disable cookies you will need to change your browser privacy settings. The action required to do this will vary according to the operating system and browser you use. You can find out how to manage cookies, and to make the changes to your browser that we refer to above at this site: http://www.allaboutcookies.org/manage-cookies.
9.4 There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. You may visit aboutads.info to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt out of having your data used for online behavioral advertising by Digital Advertising Alliance (DAA) participating companies. Canadian users can also visit youradchoices.ca. European users can also visit youronlinechoices.com to learn how to opt out of having their data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies. Another available tool is the Network Advertising Initiative’s (NAI) Opt-Out Tool at networkadvertising.org/choices. This allows you to opt out from the use of information about your online activities for online behavioral advertising by NAI member companies.
9.5 On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.
9.6 We work with advertising partners to serve advertisements on the Ludwig Service. One of the services we use to track activity related to the Service, e.g., by placing cookies, is Google Analytics by Google (Google, Inc. a company headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). We may use vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our websites, including Google Analytics for Display Advertising. Google provides tools to manage the collection and use of certain information by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings at https://www.google.com/settings/ads.
9.7 We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We use the following types of cookies for the purposes explained in the following chart:
|Operational||These cookies are necessary to allow us to operate the Ludwig Service as you have requested.|
|Analytics||We use these cookies to analyze how Ludwigs Services are accessed, used, or performing. We use this information to maintain, operate, innovate and improve our Services. We may also obtain information from our email newsletters, including whether you opened or forwarded a newsletter or clicked on any of its content. This information helps us ensure that we're delivering information that you find interesting.|
|Functional||These cookies let us operate certain functions of our Services in line with the choices you make. These cookies mean that when you continue to use or come back to our Service, we can provide you with our services as you have asked for them to be provided (Eg. knowing your username, reminding you of content you have enjoyed).|
|Targeting||We use these cookies to: serve you with advertisements that may be interesting and relevant to you; help us regulate the advertisements you receive; measure advertisement effectiveness.|
|Ludwig Ads||We work with web publishers, advertising networks, and service providers to deliver Ludwig ads on other web sites and services. Cookies may be used to serve you with advertisements that may be relevant to you and your interests on other web sites and services and to regulate the advertisements you receive and measure their effectiveness.|
9.8 We also use mobile device identifiers to recognize your device when you return to the Ludwig app or otherwise use the Ludwig Services.
9.9 Please note that even if you opt out using the mechanisms described in the previous articles of this section, you may still receive advertisements when using the Ludwig Service. You hereby consent to the use of the cookies and other technologies described above.
10 Promotional emails and Communications
10.1 From time to time, we may want to contact you with information about services announcements, software updates and special offers (“Communications”). We also may want to contact you with information about services from our business partners.
10.2 We consider your acceptance of this Policy as your acceptance of our offer to send you these emails. You may opt out of such communications at any time by changing your preferences.
10.3 You will continue to receive essential account-related information, even if you unsubscribe from promotional emails.
11 User Content
11.1 As a rule, Ludwig employees do not monitor or view your Personal Information or User Content stored in or transferred through our Products, but it may be viewed if we believe the Terms of Service have been violated and confirmation is required, if we need to do so in order to respond to your requests for user support, if we otherwise determine that we have an obligation to review it as described in the Terms of Service, or to improve our algorithms as described in the User Content section of our Terms of Service. In addition, our employees may also read your User Content in connection with our provision of proofreading/translation services. Finally, your Personal Information may be viewed where necessary to protect the rights, property or personal safety of Ludwig and its users, or in order to comply with our legal obligations, such as responding to warrants, court orders or other legal process.
12 Unsubscribing and closing of the account
12.1 You can stop using our Services at any time. Residual copies of your Personal Information and deleted User Content may continue to exist on Ludwig’s back-up and archiving systems for up to one year due to the nature of those systems’ operations.
13 Where do we store the information?
13.2 In the event we do have to share your personal information with third-parties, we only do it to deliver a consistently great service to our users. We only share information to ensure that third party services and applications can provide a service to us that benefits our customers. Below you can find a list with the main third party services that are required to provide us their services in order to allow you use Ludwig. These third party services includes but are not limited to the following:
- Google Analytics;
- Microsoft Azure;
13.3 If you do not want to have your Personal Information stored with any of the above mentioned services, you should not provide us with the information, which in turn may mean that we cannot deliver our service to you.
14 Payment information and Payment Processor: Stripe
14.1 Ludwig uses the third party payment platform, Stripe, the Stripe API, and in conjunction, your Stripe account to process credit and debit card transactions for your Ludwig’s account. By using Ludwig and agreeing to the Ludwig Terms and Conditions of Use Service, You also agree to be bound by Stripe’s Terms of Service.
14.2 You expressly understand and agree that Ludwig shall not be liable for any payments and monetary transactions that occur through Your use of the Service. You expressly understand and agree that all payments and monetary transactions are handled by Stripe. You agree that Ludwig shall not be liable for any issues regarding financial and monetary transactions between You and any other party, including Stripe.
14.3 You are responsible for all transactions (one-time, recurring, and refunds) processed through Stripe. If You process a transaction, it is Your responsibility to verify that the transaction was successfully processed.
14.4 You understand that Ludwig uses the Stripe API to run the Service and that the Stripe API is subject to change at any time and such changes may adversely affect the Service. You understand and agree to not hold Ludwig liable for any adverse affects that actions (whether intentional or unintentional) on the part of Stripe may cause to You, Your Business and/or Your Ludwig’s account.
Via Fiume 6, 90133 Palermo
Contacting Entity and Data Controller
Via Fiume 6, 90133 Palermo
Last Updated: 14 October 2017