Ludwig

Privacy Policy

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It applies to the Ludwig website (https://ludwig.guru/) and all related sites and subdomains, applications, services regardless of how you access or use them. We kindly ask you to read and pay particular attention to this privacy policy. If you wish, below you find an index that will allow you to jump straight to the sections that most interest you. Jump to section 1 Introduction, General Provisions and Definitions 2 Changes and modifications in this Privacy Policy 3 Information we collect 4 How we use your information 5 User’s rights 6 Children 7 Security 8 Links To Other Websites 9 Information about cookies and third-party data collection 10 Promotional emails and Communications 11 User Content 12 Unsubscribing and closing of the account 13 For how long do we store your data? 14 Payment 15 English Version Controls 16 Contacts 1 Introduction, General Provisions and Definitions 1.1 Owner and Data Controller Ludwig srls - Via Fiume 6 - 90133 - Palermo (Italy) VAT: IT06333200829 - Registration number: PA-314445 Owner/Data controller contact email: contact@ludwig.guru 1.2 Thank you for choosing Ludwig. Our Privacy Policy (“This Policy”, “The Policy”, “Our Policy”) explains what information Ludwig S.r.l.s., the Italian limited company which owns and operates the website https://ludwig.guru/ and all sub-domains thereof (collectively, the “Site”), and its subsidiaries and/or other affiliates (together, “Ludwig”, “The company”, “Our company”, “We” or “Us”) collect about you and why, what we may do with that information and how we handle your personal information and User Content. This legal documents sets out how we will handle your personal data and should be read in conjunction with our Terms and Conditions of Use (“Terms of Use”) which can be found by clicking the following link: Terms and Conditions. More specifically, this Privacy Policy forms part of our Terms of Use and is intended to: (1) explain you the way we use information that you share with us in order to improve our product and give you a great experience with it. (2) make sure that you understand which data and information we collect with your permission. (3) explain you how we use the information and data collected with your permission (4) Hold us accountable for protecting your rights and your privacy under this policy. With regards to the above-mentioned activities, Ludwig undertakes to protect Users’ privacy and to process their personal data in compliance with the principles of fairness, legality, transparency and confidentiality. More in particular, in accordance with the provisions set out in any applicable italian and EU’s laws, specifically with the provisions set out in the GDPR, with this Privacy Policy Ludwig intends to provide the Users with all necessary information about the processing of their personal data and the protection of their privacy while using its Services available on the Website or that can be downloaded on the Website. The terms and conditions set forth in this privacy notice apply to every website owned by Ludwig, unless otherwise specified in the registration forms provided by the Company to the Users or in different written agreements between the Users and the Company. This information notice shall not be considered valid for other websites that may be visited via links on the websites under the Ludwig’s domain name, which shall not be held liable under any circumstances for the websites of third parties. The data controller is Ludwig S.r.l.s., with registered offices in Via Fiume 6, 90133 Palermo (Pa), and registered in the Company Register of Palermo under VAT number: IT06333200829 - REA number: PA-314445, in the person of its legal representative. Exclusively for the purpose of satisfying organizational and operational needs, the company has recently appointed the following persons as subjects responsible for the processing of personal data, who are domiciled at the Company’s registered offices: √ Mr. Antonio Rotolo; √ Mr. Federico Papa; √ Miss Roberta Pellegrino; √ Mr. Francesco Giacalone; √ Mr. Francesco Aronica; √ Mr. Salvatore Monello. Personal data are collected and handled by the above mentioned persons which we have access to all of your requests sent via this email address: contact@ludwig.guru. All staff members of Ludwig S.rl.s. participating in any of the processing stages shall process and handle your data under strict care and confidentiality. Your data shall not be disclosed or communicated to a third party, unless required by legal provisions or the data subject has authorized otherwise. An updated list of any other person possibly in charge of processing personal data, may be requested by sending an email to: contact@ludwig.guru or by writing to: Ludwig S.r.l.s., Via Fiume 6, 90133 Palermo (Pa), Italy. All personal data, related to the Services provided by the Company, is processed at the above-mentioned registered offices of the Data Controller. Some data may be processed by third persons in order to ensure the maintenance of the technological elements of the websites owned by Ludwig. We will keep all the reasonably technical and organizational measures to minimize the risks associated to processing activities in order to ensuring You the best service as possible without endangering your privacy. 1.3 Information we collect. We minimize the information we collect to that which we reasonably believe is necessary to make Ludwig work. Specifically, we collect two types of information: <ol> <li> Personal Data. This is data that identifies you or can be used to identify or contact you and may include your name, address, e-mail address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised. Such information is only collected from you if you voluntarily submit it to us.</li> <li> Non-Personal Data (Usage Data). Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as: broad non- specific geographic location, which we derive from your IP address, demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and device you use and other anonymous statistical data involving the use of our website. 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. </li> </ol> When you agree to our Privacy Policy, you give us the right to collect this information and use it for the purposes described in this Policy. 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 Google, 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 partners. More specifically, if you use Facebook, Google 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 those accounts. When you create your Ludwig account, and authenticate with a third-party service (Facebook or Google) we collect, store, and periodically update information associated with that third-party account, such as your: full name and email address. We will have no access and we will not user and store any other information from these social platforms except those that have been specified above. Moreover, we will never publish through your third-party account without your explicit permission. 1.5 How do we collect information on our Users? There are two main methods we use: <ol> <li>We collect information through your entry and use of the Site. In other words, when you access or use the Site, we are aware of your usage of Site, and may gather, collect and store the information relating to such usage, either independently or through the help of third-party service providers as detailed below.</li> <li>We collect information which you provide us voluntarily. We collect Personal Information when you complete the contact form and/or send us a feedback through our website. We may gather, collect and store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.</li> </ol> 1.6 What are the purposes of the collection of information? Non-personal Information is collected in order to: <ul> <li>Enhance the User’s experience on the Site.</li> <li>Use it for statistical and research purposes and for customization and improvement of our Site’s interface.</li> <li>Learn about the preferences of Users and general trends relating to the Site.</li> </ul> Personal Information is collected in order to: <ul> <li>Provide you with Ludwig’s services.</li> <li>Allow us to contact you (in accordance with applicable law) with tailored information regarding new services and features, enhancements, special offers and/or upgrade opportunities,. </li> <li>Be able to contact Users for the purpose of providing them with technical assistance and support</li> <li>Be able to contact Users who have send us a feedback, a request of information </li> </ul> 1.7 The data controller of your personal information is Ludwig S.r.l.s., which also provides the service to you. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request. 1.8 This Policy is incorporated into Ludwig’s Terms of Use and License Agreement located at: https://ludwig.guru/terms ( “Terms of Use”), and applies to the information obtained by us through your use of our website (https://ludwig.guru), the Software and the Services, (together, “Services”) and/or all the others Ludwig services and products. Capitalized terms used in this Policy and not otherwise defined shall have the meanings provided for those terms in our Terms of Use. 1.9 This article contains a list of definitions that allows to better understand the contractual clauses contained in both this Privacy policy and in the Terms of Use. <ul> <li> 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.</li> <li> 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.</li> <li> Data Processor (or Data Processor). The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with applicable laws and this privacy policy.</li> <li> Data Subject. The natural person a personal data relates to.</li> <li> 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.</li> <li> Cookies. A cookie is a small file stored in your computer’s browser when you visit a website that uses cookies. Our website makes use of cookies. You can have more information about our Cookie Policy in section 9 of this Policy.</li> </ul> 1.10 Legal basis for processing any personal data: <ol> <li>The voluntary, unambiguous and explicit consent of the data subject;</li> <li>To meet Ludwig’s contractual obligations with regards to its users;</li> <li>To comply with legal obligations.</li> </ol> In any case, it is always possible to ask the Data Processor to clarify the effective legal basis of each treatment and in particular to specify whether the treatment is based on the law, on a contract or necessary to conclude a contract. 1.11 Consent. Through agreeing to this privacy notice you are consenting to Ludwig processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing at: contact@ludwig.guru or writing to us, see last section for full contact details. 1.12 Ludwig’s platform has, in principle, an indefinite duration. However, Ludwig S.r.l.s. is authorized to terminate or suspend the platform at any time. Where reasonably possible, We will advise about about the termination or suspension of the platform. 1.13 If you have general questions about this Privacy Policy, our use of your personal information, cookies or similar technologies, please contact us by sending an email at: contact@ludwig.guru 2 Changes and modifications in this Privacy Policy 2.1 Occasionally, in our discretion, we may need to update this Policy to keep pace with changes in our Service, our business and laws applicable to us and you. we will, however, always maintain our commitment to respect your privacy. We will communicate such changes by posting any revisions to this Policy, along with their effective date, in an easy to find area of the Site. In some cases we will also email you (to your most recently provided email address). In any case, we recommend you to periodically check back here to stay informed of any changes may occurred to our Privacy Policy. If required by any applicable law we will ask for your consent to such changes. Please note that if you continue to use Ludwig after any change, your use means that you agree with, and consent to be bound by, the new Privacy Policy. Please 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. 2.2 By using Ludwig, you consent to the collection and use of Your information as set forth in this Privacy Policy. If We decide to change this Privacy Policy, which We may do at any time without notice to You, We will post those changes on this page. By continuing to use the Service after We have posted the changes, you agree to and accept such changes. As already said, We encourage you to periodically check our website for changes to this Privacy Policy. 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: <ol> <li>Your full name, email address, and occupation. This lets us create your account, provide you with convenient and personalized access to your account and deliver and support our Services. This information also helps us communicate with you about your use of our Services, product announcements and software updates, as well as respond to your requests for assistance (including providing account verification support if you are having difficulty accessing your account). In addition, we may use your Personal Information to send you information on Ludwig’s new features and special offers. For more information, please see the section 10 below entitled “Promotional emails and Communications”.</li> </ol> <li>For paying users, your payment information is required to start the free trial and/or complete a commercial transaction on the Site. Ludwig does not collect, use and store your payment information. The whole payment operation is managed by Stripe and/or Paypal. Stripe and Paypal therefore are the sole entities of manage the payment of our Services to enable and fulfill your transactions. Both Paypal and Stripe may ask you to provide further information including credit or debit card details and billing address. This information is retained by Stripe and Paypal and will not be passed on to us. We do not collect and store credit or debit card details. </li> <li>The broad 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 Ludwig’s Services.</li> <li>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.</li> <li>Any User Content (as defined in the Terms and Conditions of Use ) added while users interact with our Services, including but not limited to: de-identified user queries and Feedbacks (as defined in the Terms and Conditions of Use ) and any message users send and/or receive via the Service. Records of your correspondence (if any) with us.</li> <li>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;</li> <li>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.</li> 3.2 You may also choose to voluntarily add other information to your profile by adding new and additional information on “Your Account” page. By doing this you authorize Us to use, collect and store such information in accordance to this policy. 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. Ludwig may use and release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website or services. Ludwig also collects information like Internet Protocol (IP) addresses. Ludwig does not use such information to identify its visitors and users. 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 website and use our Services, 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 information may be collected and stored by Stripe (https://stripe.com). Ludwig does not store credit card details and/or any financial information and instead relies on Stripe for this. Rather, all such information is provided directly to Stripe, whose use of your personal information is governed by their privacy policy. With regards to your payments, we only collect and store an alphanumeric code which these payment methods assign to any paying user. Through this alphanumeric code we may access some limited information about Ludwig’s premium users, such as: transaction history, card’s type, expiration date, and the last four digits of card number. 3.8 BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE LUDWIG TO USE AND SHARE WITH OTHER COMPANIES IN THE LUDWIG GROUP, AS WELL AS CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING ONLY COUNTRIES WHICH PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO LUDWIG, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROVISION OF THE LUDWIG SERVICE AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO LUDWIG, ANY COMPANY IN THE LUDWIG GROUP, AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH LUDWIG. 3.9 From time to time, we may offer you the opportunity to participate in promotions such as, contests, offers, and/or surveys (“Special Promotions”or “Promo Offers”) through the Service. A Special Promotion may be governed by specific terms and conditions that are additional to, or separate from,the general Terms and Conditions of Use. If the provisions of the Special Promotion terms and conditions conflict with the general Terms and Conditions of Use, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy. 3.10 We may also receive information about you from our service providers and partners, which we use to personalize your Ludwig experience, to send you communications 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”. 3.11 We may obtain additional information about you from third parties and combine it with information that we collect from or about you. If you connect to a third party network, platform, app, or service through our Services, you are authorizing us to collect, store, and use in accordance with this Privacy Policy. 3.12 Ludwig collects and aggregates pseudonymized data (data that has been stripped of any user identifiable information) and metrics about overall usage. This may include pages you visit, the time of access, the device, browser that you used and various other metrics necessary in order to maintain and improve user experience. This data is used by Ludwig in order to optimize user experience and to develop new services and features. 3.13 The data requested is appropriate, pertinent and strictly necessary, and, in no circumstance, is the data subject obliged to provide such data, but, lack of such communication may affect the objective of the service or imply the inability of its execution. 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. Specifically, the tracking we do at Ludwig is to make our service work as well as possible. In order to give you the best possible experience using Ludwig, we use your information to: <ul> <li>Provide, test, improve, promote and personalize Ludwig Services;</li> <li>Fight spam and other forms of abuse;</li> <li>Generate aggregate, non-identifying information about how people use our Services.</li> </ul> 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 non-exhaustive list of third-party services that are used by Ludwig can be consulted in the table in par. 9.11 of this information. 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: contact@ludwig.guru. 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: access, rectificate 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: <ul> <li>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;</li> <li>to communicate with you for Service-related or research purposes including via emails, notifications, or other messages, which you agree to receive;</li> <li>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;</li> <li>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;</li> <li>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;</li> <li>to prevent or detect fraud and to provide you with billing information;</li> <li>to enforce this Privacy Policy, the Terms and Conditions of Use, and any other terms that you have agreed to, including to protect the rights, property, or safety of Ludwig, its users, or any other person, or the copyright-protected content of our Services;</li> <li>to provide you with features, information, advertising, or other content which is influenced by your location;</li> <li>to allow a merger, acquisition, or sale of all or a portion of our assets. If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we’ll notify you in advance so you can opt out of any such new policy by deleting your account before transfer.</li> <li>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;</li> <li>to provide academic researchers with data for research purposes including statistical analysis and academic study, but only in a de-identified format;</li> <li>to publish de-identified or aggregate information about the use of the Ludwig Service;</li> <li>to allow other companies in the Ludwig group to use your information as specified in this Privacy Policy. and</li> <li>as otherwise stated in this Privacy Policy.</li> </ul> 4.6 We may from time to time share your information with service providers to perform functions and process user data and help provide our Services, consistent with this Privacy Policy. Where a third party processes user data on our behalf (e.g., a hosting service provider), it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law. Where a third party processes user data on its own behalf, its processing is subject to its own Privacy Policy and applicable law. 4.7 We may de-identify the information collected through your use of our Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose (such as advertising purposes). If we do combine such information with personal information, the combined information will be treated as personal information for as long as it remains combined. 4.8 We may use Personal information, Pseudonymized 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. 4.9 We share your information for the purposes listed above with our affiliates, partners and other trusted businesses and individuals that provide us services (such as payment processing and to assist in other business activities), or to which we provide a variety of services, developers and service providers who process such information for us, so they can help us provide and improve our Services. If you choose to download or install third party apps or features, we may share your information with such third party apps to assist in providing our Services. We may also share your information with third parties whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, protect your safety or the safety of others, as well as to investigate or prevent any fraud, security or technical issues. 4.10 information disclosure. Ludwig won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you. We may share your account information with third parties in some circumstances, including: (1) with your consent. (2) to a service provider or partner who meets our data protection standards. (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization. (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process. (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others. We will object to requests for information about users of our services that we believe are improper. 5 User’s rights 5.1 If you are a Ludwig Services User in the European Economic Area (EEA) and Switzerland you benefit from certain rights granted by applicable law but subject to limitations therein. These rights include the right of access, rectification, restriction, opposition, erasure and portability, and the right not to be subjected to automated decision-making. If you want to exercise those rights or find out more, please contact us at: contact@ludwig.guru. The following articles provide an in-depth clarification of some of the rights Ludwig grants you. 5.2 Right to access. You can ask us at any time to view and get information on the data we keep about you. If you want to access the data we keep about you, please contact us at contact@ludwig.guru. 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. 5.3 Right to representation. You have the right to correct any inaccurate information that we keep about you. This includes the right to have incomplete personal data completed. We are very keen to ensure the data we hold is accurate and up to date. 5.4 Right to erasure. The right to erasure (also known as the right to be forgotten) require Ludwig, as data controller, to cancel the data we keep about you when we no longer needs your data. Moreover, you can withdraw at any moment your consent. And upon the withdrawal of their consent, the controller has to delete all of their information. Specifically, we are obligated to erase the data we keep about you if one of the following criteria applies: <ul> <li> data are no longer necessary in relation to the purposes for which they were processed.</li> <li>If you withdraws your consent and no other legal ground for the processing exists.</li> <li>If you objects to the data processing and we not have compelling reasons for the processing which supersedes your objection.</li> <li>If the processing is unlawful.</li> <li>If the erasure is statutory.</li> </ul> 5.5 Right to restrict processing. Thank to this right you can ask us at any time to stop processing your data. 5.6 Right to lodge a complaint with a supervisory authority . Users in the European Economic Area (EEA) and Switzerland have the right to lodge a complaint with the Supervisory Authority for data protection in their country, should they find that we did not appropriately address their question or concern. A detailed list of supervisor authorities can be found by clicking the following link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 5.7 Right to opt-out. You can always ask us not to share your Information with non-essential third parties, or not to send you newsletters, emails, or other communications by emailing us at: contact@ludwig.guru. Moreover, you may opt-out of third party cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and following opt-out instructions. 5.8 Right to data portability. You have the right to receive your data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it. 5.9 If their data are processed for direct marketing purposes, users can oppose the processing without providing any reasons. To learn more about how to object to the processing of data for direct marketing purposes, Users may consult section 10 of this privacy policy entitled “Promotional emails and Communications”. 5.10 As already said, before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us identify you and respond to your request. We will respond to any request within a reasonable period of time without delay and at the latest within a month. 6 Children 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 contact@ludwig.guru and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights. 7 Security 7.1 Ludwig is committed to protecting the security of your information and uses commercially reasonable and industry standard security measures to protect your Information. We also use up to 256-bit SSL (secure sockets layer) encryption to transmit sensitive information. 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. Notice of Data Breaches will be provided to affected individuals and/or governmental agencies in accordance with applicable contractual and legal requirements. If the breach is likely to result in a high risk of adversely affecting individuals' rights and freedoms, Ludwig will notify via email affected parties as soon as possible but not later than 72 hours of reasonable suspicion of a Data Breach. 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 8.1 Our Services may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and carefully read at the Privacy Policy applicable to any website you visit. 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 9.1 Cookies consist of portions of code installed in the browser that assist the Owner of a given service in providing the Service according to the purposes described. Some of the purposes of installation of cookies may also require the consent of the User. When the installation of Cookies is based on consent, this consent can be freely revoked at any time by following the instructions contained in this document.We use cookies to improve the quality of our service and make the service easier to use for our users and clients. We do this by storing user preferences in cookies and by tracking user trends (for example, we may use cookies to allow you to automatically log in to the service after the first user session). Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Be aware, however, that some parts of Ludwig may not function properly if you refuse cookies. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. As already said, most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. 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. Please note that if you choose to block cookies, doing so may impair the Ludwig Service or prevent certain elements of it from functioning. 9.3 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 (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. 9.4 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. 9.5 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. 9.6 We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to You when You access our websites, based on Data relating to Your access to and use of our websites on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see. If You would like more information about this practice, and to learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies in desktop and mobile browsers on the particular device on which You are accessing this Privacy Policy, please visit the Network Advertising Initiative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that You have visited our website or seen one of our advertisements, and we may provide that Data to one or more third party advertising networks. The Data we provide may include the time and date of Your visit to our website, pages viewed, links clicked and other information that does not disclose Your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with Your visit to our website when You visit other websites on which they serve advertising, and they may make decisions about the advertisements You see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage You to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies. To learn more about the cookies that may be served through our Services, and how You can control our use of cookies, please see our Cookie Policy. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them 9.7 Cookie Policy. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and statistical analysis. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences and personalize content and other information. For the same reason, we may obtain information about your general internet usage by using cookies. A cookie is a small file which is stored on the hard drive of your computer. They help us to improve the Site and to deliver a better and more personalised service. We use the following cookies: <ul> <li>Strictly necessary cookies . These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.</li> <li>Analytical/performance cookies . They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.</li> <li>Functionality cookies . These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language currency, or region).</li> <li>Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.</li> </ul> 9.8 The cookies our site uses. The cookies used by the Site do not include any personal information about you.Ludwig doesn’t track you across the Internet. We track only your interactions within the Ludwig network (which encompasses https://ludwig.guru/ and custom domains hosted by Ludwig). Some third-party services that we use to provide the Ludwig Service, such as Google Analytics, may place their own cookies in your browser. Most of the cookies we use are known as “session cookies”. They are deleted after the end of you visit. Other cookies (“persistent cookies”) are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser. You can object in principle to the use of cookies through your browser settings. Specifically, the cookies we use allow us to perform the following activities: <ul> <li> Activity strictly necessary for the functioning of the service. Ludwig uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of the same, for example in relation to the distribution of traffic.</li> <li> Activity regarding the saving of preferences, optimization, and statistics. Ludwig uses Cookies to save browsing preferences and to optimize the User's browsing experience. Among these Cookies are, for example, those to set the language and the currency or for the management of first party statistics employed directly by the Owner of the site.</li> </ul> In addition we also use analytics and targeting cookies which are placed by or on behalf of independent advertisers who are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site. They are anonymous – they cannot identify individuals. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once. They might also allow the advertiser to tailor advertising to you when you visit other websites. We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies have their own strict privacy policies. Among others, on our website we use the marketing and remarketing services of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. “Google”). These services allow us to display advertisements in a more targeted manner in order to present advertisements of interest to users. Through remarketing ads and products are displayed to users relating to an interest established by activity on other websites within the Google Network. For these purposes, a code is used by Google when our website is accessed and what are referred to as (re)marketing tags are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may also be used instead of cookies). This file records which apps users have visited, which content they are interested in and which offers have been used. In addition, technical information about the browser and operating system, referring websites, the length of the visit as well as any additional data about the use of the online products and services are stored. The IP address of users is also recorded, although we would like inform you that within the framework of Google Analytics, IP addresses within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area are truncated. All user data will only be processed as pseudonymous data. Google does not store any names or e-mail addresses. All displayed ads are therefore not displayed specifically for a person, but for the owner of the cookie. This information is collected by Google and transmitted to and stored by servers in the USA. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google: http://www.google.com/ads/preferences . The following chart shows the different types of cookies we use and for which purposes: Company Service Type Purpose Link information and management preferences Ludwig cookie preference strictly necessary, first party This Website uses Cookies to: 1) Save the User's session and to carry out other activities that are strictly necessary for the operation of the same: recognize user session and user category (guest user, registered user or premium user). These cookies are necessary to allow us to operate the Ludwig Service as you have requested. 2) Save browsing preferences and to optimize the User's browsing experience. Among these Cookies are, for example, those to set the language. Google Analytics and social login Analytical, third party These cookies are used to: 1) allow users to login to Ludwig through their Google account 2) We use Google Analytics to collect aggregated data on the usage of our website and to analyze how Ludwigs Services are accessed, used, or performing. We use this information to maintain, operate, innovate and improve our Services. This is an analytical / performance cookie. The Site uses Google Analytics to help analyse how users use the Site, collecting standard internet log information and visitor behaviour information in an anonymised form from which no user is identifiable. This information is transmitted to Google and processed to compile statistical reports on activity on the Site. These reports allow us to optimise our user experience. Google provide a browser add-on for users who wish to prevent their data from being used by Google Analytics. Further information is available at: https://tools.google.com/dlpage/gaoptout/. Google Technologies Cookies Google provides an opt-out plug-in for most common website browsers here: Facebook social login functionality third-party These cookies allows interaction with social networks or other external platforms directly from the pages of this Website. The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network. Basically, these cookies allow users to login to Ludwig directly through their Facebook accounts. Facebook Cookie Policy facebook Advertising, Content Serving and Web Targeting, third-party This cookies allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/ . You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads . Doubleclick Advertising, Content Serving and Web Analytics Technology Targeting, third-party These 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. Doubleclick Technologies Cookies Stripe Operational strictly necessary/functionality third-party The chosen payments solution provider (Stripe) uses cookies for the purposes of user authentication, fraud detection, fraud prevention, certain services on its Web site, monitoring of its services and support of its advertising strategies. The Stripe cookies are an essential part of the payment operations and Ludwig cannot offer any service that depends on payments if these cookies are disabled by the user. A full disclosure of Stripes use of cookies, including persistent cookies, is documented online at https://stripe.com/cookies-policy/legal. Paypal Operational strictly necessary/functionality third-party The Paypal cookies are an essential part of the payment operations and Ludwig cannot offer any service that depends on payments if these cookies are disabled by the user. Paypal uses cookies to help you through the payment process. You can view Paypal's Privacy Policy here. Braintree Operational strictly necessary/functionality third-party The chosen payments solution provider (Braintree) uses cookies for the purposes of user authentication, fraud detection, fraud prevention, certain services on its Web site, monitoring of its services and support of its advertising strategies. The Braintree cookies are an essential part of the payment operations and Ludwig cannot offer any service that depends on payments if these cookies are disabled by the user. https://www.braintreepayments.com/ 9.9 Some of the services listed below collect statistics in aggregate form and may not require the consent of the User or be managed directly by Ludwig, depending on how they are described, without the help of third parties. If the services managed by third parties are listed among the tools below, these can be used to track the browsing habits of Users, in addition to the information specified here and without the knowledge of the Owner. Please refer to the privacy policy of the services listed for detailed information. 9.10 The information you provide us is stored by Contabo in data centers located within the EU (Germany). Deferred and secondary data may be stored with any of our service providers listed below. By using o Services, you consent to your information being transferred to the facilities of the third parties with whom we share it as described in our Privacy Policy. Please keep in mind that this Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible, downloaded, or otherwise distributed through our Services. You should always review their privacy practices carefully before providing personal information to such third parties. 9.11 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 Us to provide You to use Ludwig. The list below allow you understand which cookies third-party tools that might use. Specifically, the third-party services we use includes the following: Company and data processing activities Service provided Links Google Analytics Place of processing: USA Personal Data collected: Aggregate and anonymous site usage data and cookies Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Google Analytics allow us to collect aggregated and anonymous data on the usage of our website and to analyze how Ludwigs Services are accessed, used, or performing. We use this information to maintain, operate, innovate and improve our Services. (https://www.google.com/analytics/terms/us.html); https://tools.google.com/dlpage/gaoptout?hl=it Google AdWords conversion tracking (Google Inc.) Place of processing: USA Personal Data collected: Usage data and cookies Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on Ludwig. https://policies.google.com/privacy?hl=en Google Tag Manager (Google Inc.) Place of processing: USA Personal Data collected: Usage data and cookies Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Google Tag Manager is an analytics service provided by Google Inc. https://policies.google.com/privacy?hl=en Contabo GMBH Place of processing: UE (Germany) Personal Data collected:all the data categories mentioned in this privacy policy. This type of service has the purpose of hosting data and files that enable Ludwig to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Ludwig. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data is stored. https://contabo.com/data_privacy.html Sendinblue Place of processing: UE (France) Personal Data collected: email and contact information SendinBlue is an email address management and message sending service provided by SendinBlue SAS.This service makes it possible to manage a database of email contacts to communicate with the User. These service may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. (https://www.sendinblue.com/legal/termsofuse/) Stripe Place of processing: USA Personal Data collected: email and contact information Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Stripe is one of the payment gateways we use to sell our products and services to you. When you purchase from Ludwig, Stripe stores your credit card data and payment information.Your data is stored through Stripe's data storage, databases and the general Stripe application. Stripe stores your data on a secure server behind a firewall. (https://stripe.com/payment-terms/legal) Braintree Place of processing: USA Personal Data collected: email and contact information Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Braintree is one of the payment gateways we use to sell our products and services to you. When you purchase from Ludwig, Braintree stores your credit card data and payment information.Your data is stored through Braintree's data storage, databases and the general Braintree application. Braintree stores your data on a secure server behind a firewall. https://www.braintreepayments.com/ Paypal Place of processing: USA Personal Data collected: email and contact information Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Paypal is one of the payment gateways we use to sell our products and services to you. When you purchase from Ludwig, Paypal stores your paypal account, credit card data and payment information.Your data is stored through Paypal's data storage, databases and the general Paypal application. Stripe stores your data on a secure server behind a firewall. https://www.paypal.com/us/webapps/mpp/ua/useragreement-full Facebook Place of processing: USA Personal Data collected: Cookies and Usage Data Compliant with the EU-U.S. and the Swiss-U.S. Privacy Shield framework Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Ludwig. https://www.facebook.com/about/privacy/ Some of the services listed above collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner - depending on how they are described - without the help of third parties. If any third party operated services are listed among the tools above, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information. 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. 9.12 If you do not want your Personal Information to be archived by any of the services mentioned above, you should not provide us with the information, which in turn may mean that we can not offer you our service. 9.13 We also use mobile device identifiers to recognize your device when you return to the Ludwig app or otherwise use the Ludwig Services. 9.14 Please note that even if you disable the mechanisms described in the previous articles of this section, advertisements will still be visible on the Ludwig site when using the service. It is also specified that, by accepting this privacy policy, you consent to the use of cookies and other technologies described above. 9.15 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. 9.16 In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them. Through the browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that might possibly have saved the consent for the installation of Cookies by this website. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. Users can find information about how to manage Cookies in their browser at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer. In the case of services provided by third parties, Users can exercise their right to withdraw from the tracking activity by utilizing the information provided in the third party’s privacy policy, by clicking the opt-out link – if provided – or by contacting the third party. Notwithstanding the above, Ludwig informs that Users may take advantage of: Your Online Choices. This service allows Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of this resource in addition to the information provided in this document. 9.17 Since the installation of third-party Cookies and other tracking systems through the services used within Ludwig Services cannot be technically controlled by Us, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, consult the privacy policy for the respective third-party services listed in this document. Given the objective complexity linked to the identification of technologies based on Cookies and their very close integration with the operation of the web, Users are encouraged to contact us at: contact@ludwig.guru to receive any further information on the use of Cookies themselves and any possible use of them - for example, by a third party - carried out through this site. 10 Promotional emails and Communications 1 0.1 In the case you signed-up our newsletter, from time to time, we may contact you with information about services announcements, software updates and special offers (“Communications”).To the extent permitted under applicable law, you hereby agree that we may use your contact details for the purpose of informing you regarding products, services and new features which may interest you, and to send to you other material, transmitted to the e-mail address you have provided. at any time you may opt-out and withdraw your consent by sending a written notice to Ludwig by e-mail to the following address: contact@ludwig.guru or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you. 10.2 Our email marketing is powered by Seindiblue and so when you subscribe to our emails your details are held securely by them and far more safely then we could ourselves. As a respected service provider they won’t share your information with any third parties or contact you directly at any time. Their full Privacy Policy is available to read here: https://www.sendinblue.com/legal/privacypolicy/ 10.3 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. 10.4 You will continue to receive essential account-related information, even if you unsubscribe from promotional emails. 11 User Content 11.1 Once you register to Ludwig we firstly ask to confirm your email. The registration will only be effective when you have clicked on the link in the confirmation email. When you start using our services your personal information are pseudonymized and we assign you a numeric code which is stored separately from your personal information. Moreover, these two datasets (the one with pseudonymised information and the one with personal identifiable information) are stored and saved in different servers located in different physical locations within the EU. As a rule, Ludwig employees do not monitor or view your Personal Information or User Content stored in or transferred through our services, 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. Anyway, any of the user content provided by the user are stored separately from their personal information. This means that anytime We access any user content we will not associate it to any of our users. This ensure the full protection and respect of Ludwig’s users privacy. 12 Unsubscribing and closing of the account 1 2.1 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. 12.2 If Ludwig closes your account due to your violation of the Terms of Use, then you may contact us to request deletion of your data, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations. 13 For how long do we store your data? 13.1 We will retain your Personal Information for the period necessary to fulfil the purposes for which your Personal Information has been collected. Specifically, Data shall be preserved over the period of time to supply the service appropriately, as well as to answer any possible legal requirements. Specifically: <ul> <li>Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of the contract is completed.</li> <li>Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.</li> </ul> 13.2 When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or an order of an authority. 13.3 At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised. 13.4 With regards to Newsletter opt-ins, the information will be retained until you unsubscribe at which point your information will be retained on a suppression list in order to ensure that we comply with your request. 14 Payment 14.1 We accept certain online payment methods, such as Braintree, Stripe and PayPal (“Online Payment Services“) which enable Users to purchase Ludwig’s services securely online using a credit card or bank account. Ludwig is not affiliated with the providers of such Online Payment Services, as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Services is at the User’s discretion and sole liability. It is the User’s responsibility to abide by all the terms specified by the Online Payment Services’ providers in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. 14.2 By purchasing Ludwig’s services made available through Ludwig, you represent that you are 18 years of age or older, or that you have the permission of a legal guardian (e.g., a parent), and that you will comply with all specified processes and procedures for redeeming your purchase. If you choose to use Braintree, PayPal or Stripe to make purchases through the Site, you will be directed to the Braintree, PayPal or to the Stripe website and provide your payment information directly to Braintree, PayPal and Stripe. Braintree, PayPal and Stripe privacy policies applies to the information you provide on their website. Ludwig reserve the right at its sole discretion to replace its third-party payment processing services without notice to you. By making use of some or all of these payment services on the App, you agree to be bound by Stripe terms and conditions (available at: https://www.stripe.com/payment-terms/legal) along with its privacy policy (available at: https://www.stripe.com/privacy,) and/or by Paypal terms and conditions and (available at: https://www.paypal.com/us/webapps/mpp/ua/useragreement-full) and privacy policy https://www.paypal.com/us/webapps/mpp/ua/privacy-full) and/or by Braintree terms and conditions and privacy policy (availables at: https://www.braintreepayments.com). Moreover, hereby you consent and authorize Ludwig to delegate the authorizations and share the information you provide to Ludwig with Stripe, Braintree and Paypal to the extent required to provide the payment services to you. Stripe, may also be contacted directly for payments support by email at: support@stripe.com. By using Ludwig and purchasing Ludwig’s services through Paypal and Stripe you declare that You agreeing to their Terms and Conditions of Use Service and Privacy policies. 14.3 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 Braintree, Stripe and/or Paypal. You agree that Ludwig shall not be liable for any issues regarding, privacy, data protection, data breach, financial and monetary transactions between You and any other party, including Paypal and Stripe. 14.4 You are responsible for all transactions (one-time, recurring, and refunds) processed through braintree, Stripe and/or Paypal. If You process a transaction, it is Your responsibility to verify that the transaction was successfully processed. 14.5 You understand that Ludwig uses the Braintree API, the Stripe API and the Paypal API to run the Service and that these APIs are 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 effects that actions (whether intentional or unintentional) on the part of Braintree, Stripe and/or Paypal may cause to You, Your Business and/or Your Ludwig’s account. 14.6 In some countries, PayPal or other payment methods may not be available. If PayPal is available, you'll be able to select it as you payment option and log in to your PayPal account. If you aren’t able to select PayPal, you’ll need to select a different payment method. 14.7 Privacy Shield Certification. The online Payment Services we collaborate with comply with applicable laws to provide an adequate level of data protection for the transfer of Personal Data. Stripe is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework. For more, see Stripe’s Privacy Shield Policy. 15 English Version Controls 15.1 Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls. 16 Contacts 16.1 Thank you for reading our Privacy Policy. We hope you will enjoy Ludwig! You may contact us with any questions relating to this Privacy Policy by sending an email at: contact@ludwig.guru or by postal mail at: Ludwig S.r.l.s. Via Fiume 6, 90133 Palermo, Italy Data Controller Ludwig S.r.l.s. Via Fiume 6, 90133 Palermo Italy VAT: IT06333200829 - Registration number: PA-314445 Privacy Policy Modification Date May 17th, 2018 Effective until May 24th, 2018 Prior version of Ludwig’s Privacy Policy, link logoTld loginOutline Sign in downloadOutline Download App Explore Library Premium Business LIA Covid-19 Learn How To Use Blogwig FAQs Contact Us Follow us Keep Ludwig handy on your smartphone, download the app! In-App purchases Terms Privacy Cookies .css-1uvqhj2{box-sizing:border-box;-webkit-appearance:none;}ItalianEnglishPortugueseTurkishRussianChinese chevronDownOutline © 2014-2021 Ludwig S.R.L.S. P.IVA 06333200829 REA PA-314445 Ludwig è finanziato dall'Unione Europea con il fondo europeo per lo Sviluppo Regionale (FESR) Ludwig - Fondo Europeo Sviluppo Regionale.pdf Descrizione: Ludwig è un motore di ricerca linguistico pensato per consentire a chiunque di scrivere in un perfetto inglese. È un sistema di supporto alla scrittura basato sull'imitazione di testi provenienti da fonti affidabili (giornali, pubblicazioni scientifiche, etc,). Finalità e obiettivi: Servizio di supporto alla scrittura in lingua inglese basata sul confronto di frasi inglese/inglese By clicking "I Accept" or "X" on this banner, or using our site, you accept our cookie and privacy policy. I Accept