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Privacy Policy

Last updated: October 21st, 2025

1. Introduction

1.1 This Privacy Policy (“Policy”) describes how LUDENS S.A. (“we”, “us”, “our”) collects, uses, stores, transfers, and discloses information, including personal data, in connection with your access to and use of our advertising campaign-management platform (the “Platform”) and related services (the “Services”).

1.2 This Policy applies to information we collect from or about:

(a) Clients, advertisers, and agencies using our Platform (“Clients” or “you”);

(b) End users or individuals exposed to campaigns delivered through the Platform (“End Users”).

1.3 By accessing or using the Platform or Services, you agree that we will collect, use, and disclose your information as set out in this Policy. If you do not agree, you must not use the Platform.

1.4 We may update this Policy from time to time (see Section 14). The “Last updated” date above indicates when this Policy was last revised.

2. Who We Are

Company name: LUDENS S.A.

Registered address: Dr. Luis Bonavita 1294 Of. 214, Montevideo, Uruguay

Registration number: 219746610010

We are a digital advertising company providing a Platform that allows Clients to create, manage, and monitor campaigns across multiple advertising networks.

3. Definitions

“Ad-Network” means any third-party digital advertising platform or publishing network (e.g., Meta, Google, Taboola).

“Client Data” means data, information, or materials you provide to us (or that we collect on your behalf) in connection with your use of the Platform, including campaign content, targeting criteria, budgets, analytics, and performance metrics.

“End User Data” means any information about individual persons (e.g., device identifiers, IP addresses, cookie data, behavioural data) collected through campaigns, the Platform, or Ad-Networks.

“Personal Data” means any information relating to an identified or identifiable individual as defined under applicable law.

4. Information We Collect

We collect different types of information in connection with your use of the Platform and Services.

4.1 Information you provide directly

– Account registration details (name, company, billing contact, email)

– Campaign content and creative assets

– Targeting criteria, budgets, placements, ad formats

– Other information you voluntarily provide when contacting us.

4.2 Information collected automatically

– Log data (IP address, device type, OS, browser, timestamp, actions performed)

– Usage analytics and performance data

– Cookies and tracking technologies (see Section 7).

4.3 Information from third parties

– Performance data from Ad-Networks (impressions, clicks, conversions)

– Information from analytics or measurement partners you or we engage.

4.4 End User Data from campaign delivery

When your campaigns run via Ad-Networks, End User Data (e.g., device IDs, cookies, IP addresses, demographic segments) may be collected by those Ad-Networks. Their policies govern such collection. We may receive aggregated or anonymised performance data derived from these campaigns.

5. How We Use Information

We use the information collected to:

– Provide, operate, and improve our Platform and Services;

– Set up, monitor, and report on campaigns;

– Bill and process payments;

– Maintain security and prevent fraud;

– Comply with legal obligations;

– Generate aggregated, anonymised analytics and benchmarks;

– Communicate with you regarding the Services.

6. Disclosure of Information

We may share information:

(a) With Ad-Networks, analytics vendors, and subcontractors necessary to provide the Services;

(b) With legal authorities if required by law;

(c) As part of a business transfer (e.g., merger or acquisition);

(d) In aggregate or de-identified form for statistical or marketing purposes.

All such recipients are required to maintain confidentiality and apply appropriate data-protection measures.

7. Cookies and Tracking Technologies

7.1 We and our partners use cookies, pixels, tags, and similar technologies on the Platform to:

– Enable basic functionality (e.g., login, user-session management);

– Store preferences and customize the user experience;

– Measure performance and usage patterns;

– Support analytics and marketing operations.

7.2 Cookies are small text files stored on your device. They may be “session” cookies (deleted when you close your browser) or “persistent” cookies (stored for a defined period).

7.3 We categorise cookies as:

- Essential cookies: necessary for operation of the Platform.

- Analytics cookies: help us understand usage to improve performance.

- Advertising cookies: enable measurement of campaign results and retargeting through Ad-Networks.

7.4 You can manage or disable cookies in your browser settings. However, disabling certain cookies may limit functionality.

7.5 Where required by law, we will obtain your consent for non-essential cookies.

8. Data Retention

We retain your information only as long as necessary to fulfil the purposes described in this Policy and to comply with legal or contractual obligations. Campaign data and related analytics are typically retained for 30 days after the campaign ends unless required longer by law or you request deletion.

9. Data Security

We implement reasonable technical and organizational measures to protect the data we hold against unauthorized access, alteration, disclosure, or destruction. While we strive to safeguard your information, no system is completely secure; we cannot guarantee absolute security.

10. GDPR Compliance and International Data Protection

10.1 Legal Basis for Processing (EU/EEA Users)

When the General Data Protection Regulation (“GDPR”) applies, we process Personal Data under one or more of the following legal bases:

(a) Legal Basis for Processing (EU/EEA Users) – to provide and manage the Services you request.

(b) Legitimate interests – to operate, improve, and secure our Platform, except where such interests are overridden by your rights.

(c) Legal obligation - to comply with laws, regulations, or court orders.

(d) Consent – where required (for example, non-essential cookies or marketing).

10.2 Controller / Processor Roles

For Client account information and billing data, LUDENS S.A. acts as a Data Controller.

For campaign execution and analytics processed on behalf of Clients, LUDENS S.A. acts as a Data Processor, processing such data only under the Client’s instructions and applicable data-processing agreements.

10.3 Data Subject Rights

EU and EEA individuals have the rights described in Section 12 (access, correction, erasure, restriction, portability, objection, withdrawal of consent).

10.4 International Transfers

If Personal Data is transferred outside the European Economic Area (EEA), we implement safeguards such as the EU Standard Contractual Clauses or rely on adequacy decisions as permitted under Articles 44–49 of the GDPR.

10.5 Supervisory Authority

If you are located in the EEA, you have the right to lodge a complaint with your local data-protection authority concerning our processing of your Personal Data.

10.6 Contact for GDPR Matters

Any inquiries or requests regarding GDPR compliance may be sent to:

📩 info@ludens.com.uy

11. Children’s Privacy

Our Platform and Services are not directed to individuals under 18 years of age.

We do not knowingly collect Personal Data from anyone under 18. If we become aware that we have collected such data, we will promptly delete it.

12. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

(a) Access the Personal Data we hold about you;

(b) Request correction of inaccurate data;

(c) Request deletion of Personal Data (subject to legal retention requirements);

(d) Restrict or object to processing;

(e) Request data portability;

(f) Withdraw consent where processing is based on consent.

To exercise these rights, contact us using the details below. We may verify your identity before responding. You may also lodge a complaint with your local data-protection authority.

13. Third-Party Links and Ad-Networks

Our Platform integrates with third-party Ad-Networks (e.g., Meta, Google, Taboola).

We do not control their privacy practices and encourage you to review their respective policies.

Our role is limited to facilitating access to these networks; we are not responsible for their use of data.

14. Amendments to this Policy

We reserve the right to update this Policy at any time.

If you continue to use the Services after the update becomes effective, you will be deemed to have accepted the changes.

We will provide at least 30 days’ prior notice before material changes take effect.

15. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:

LUDENS S.A.

Dr. Luis Bonavita 1294 Of. 214, Montevideo, Uruguay

Registration Number: 219746610010

Email: info@ludenssa.com

End of Privacy Policy