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Privacy Policy

Table of Contents

Website: ludis.app
Last updated: April 08, 2025

This Privacy Policy explains what data ludis.app collects and processes, for what purposes, on what legal basis, and how we protect your rights. Please read it carefully.

1. Who We Are

Ludis.app is an independent editorial platform publishing reviews of mobile applications. We are the data controller for personal data processed in connection with the operation of the Website.

Privacy contact: [email protected]

2. What Data We Collect and Why

We follow the principle of data minimisation: we collect only what is genuinely necessary for the Website to function. Below is the complete list.

2.1. Telegram Login

The Website uses the official Telegram Login Widget. This is the only way to create an account and submit a review on the Website.

When you log in via Telegram, we receive the following data from Telegram:

  • your numeric Telegram identifier (Telegram ID);
  • the first and/or last name set in your Telegram profile;
  • your Telegram username, if one is set in your profile;
  • the URL of your Telegram profile photo, if one is set and publicly available.

We do not receive access to your phone number, message history, contacts, or any other data from your Telegram account.

Purpose: user identification, enabling review submission and content moderation.
Legal basis (GDPR): performance of a contract (Art. 6(1)(b) GDPR) — you are requesting a service (login and review submission), and processing is necessary to provide it.

2.2. Reviews and Comments

If you submit a review for an application, we store:

  • the text of your review;
  • your rating, if applicable;
  • the date and time of submission;
  • a link to your Telegram account (Telegram ID).

Purpose: publishing user-generated content, operating the reviews section, moderation.
Legal basis (GDPR): performance of a contract (Art. 6(1)(b) GDPR).

2.3. Cloudflare Turnstile Technical Data

The Website uses Cloudflare Turnstile — a tool that protects against automated bots and spam. Turnstile analyses browser and device signals (behavioural patterns, environment characteristics) to determine whether a user is human. This processing is carried out on Cloudflare's side.

We do not receive or store the results of this analysis in any identifiable form — we receive only a final verification token (pass/fail).

Purpose: protection against spam and abuse.
Legal basis (GDPR): legitimate interests (Art. 6(1)(f) GDPR) — ensuring the security and integrity of the Website.

For more information on Cloudflare's data processing: cloudflare.com/privacypolicy

2.4. Data We Do NOT Collect

For complete clarity, the following data is not collected or processed by us:

  • first-party cookies;
  • web analytics data (we do not use Google Analytics, Yandex Metrica, or similar services);
  • advertising identifiers or tracking pixels;
  • payment data;
  • geolocation data;
  • device data in any identifiable form.

3. Cookies and Similar Technologies

We do not use first-party cookies.

However, the Telegram Login Widget and Cloudflare Turnstile may set their own cookies or use browser local storage in accordance with their respective privacy policies. These technologies are outside our control.

4. Third Parties and Data Transfers

4.1. Telegram

Telegram acts as an independent data controller with respect to its own platform and login widget. When you click the Telegram login button, your browser establishes a connection with Telegram's servers, and data is transferred under Telegram's rules. We recommend reviewing Telegram's Privacy Policy at the link above.

4.2. Cloudflare

Cloudflare acts as our data processor for the Turnstile service. Cloudflare processes technical signals in accordance with its own privacy policy and data processing agreements (DPA) that comply with GDPR requirements.

4.3. Other Third Parties

We do not sell, transfer, or disclose your personal data to third parties for commercial purposes. Data may be disclosed only in the following circumstances:

  • when required by law or a competent government authority;
  • to protect our legitimate rights and interests or those of third parties;
  • in the event of a business reorganisation, merger, or sale — with prior notice to users.

5. Data Retention

Authentication data (Telegram ID, name, username, profile photo URL) is retained for as long as your account exists on the Website, or until you request its deletion.

Review content is retained until your account is deleted or until you submit a request to remove a specific review. Publicly published reviews may be removed at your request even after account deactivation.

We do not retain data for longer than is necessary for the stated purposes.

6. Your Rights

Depending on your jurisdiction, you have the following rights with respect to your personal data:

6.1. For Users in the European Economic Area (GDPR)

  • Right of access — you may request a copy of the data we hold about you.
  • Right to rectification — you may request correction of inaccurate data.
  • Right to erasure ("right to be forgotten") — you may request deletion of your data where there is no lawful basis for retaining it.
  • Right to restriction of processing — you may request that we restrict the processing of your data in certain circumstances.
  • Right to data portability — you may request that your data be provided to you in a machine-readable format.
  • Right to object — you may object to processing based on legitimate interests.
  • Right to lodge a complaint — you have the right to contact the data protection supervisory authority in your country.

6.2. For California Residents (CCPA)

  • Right to know — what personal data we collect and how we use it.
  • Right to deletion — you may request deletion of your personal data.
  • Right to opt out of sale — we do not sell personal data.
  • Right to non-discrimination — we will not provide a lesser level of service for exercising your rights.

6.3. How to Exercise Your Rights

To exercise any of the rights listed above, please send a request to [email protected]. We will respond within 30 days of receiving your request. For complex requests, this period may be extended by a further 60 days, with mandatory prior notification.

7. Data Security

We implement reasonable technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. However, no system of internet data transmission or storage can be guaranteed to be 100% secure. By using the Website, you acknowledge this inherent risk.

8. Children

The Website is not intended for children under the age of 13. We do not knowingly collect personal data from individuals below this age. If you become aware that a child has provided us with their data without parental consent, please notify us at [email protected] — we will delete the relevant data without undue delay.

9. International Data Transfers

As our technical partners (Telegram and Cloudflare) are global companies, your data may be processed outside the European Economic Area. Cloudflare ensures that data transfers comply with GDPR requirements through Standard Contractual Clauses (SCCs). For full details, please refer to the privacy policies of the respective partners.

10. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. The current version is always available at ludis.app/privacy-policy. For material changes, we will update the date at the top of this document. Your continued use of the Website following the publication of an updated Policy constitutes your acceptance of the changes.

11. Contact Information

For all questions relating to privacy and the processing of personal data, please contact us:

Email: [email protected]
Website: ludis.app

We aim to respond to all requests within 30 days.

© 2025 Ludis.app. All rights reserved.