Privacy Policy

1. Data Controller

The data controller responsible for your personal data is LUDOCCA OÜ, a company registered in Estonia. For questions about data processing, contact us at privacy@ludocca.com.

2. Data We Collect

We collect the following personal data:

• Account information: email address, username, and date of birth (required for registration)
• Profile data: gender, country, city, and birth year (optional)
• Gameplay data: game history, scores, rankings, and tournament participation
• Communications: chat messages, direct messages, and friend requests
• Technical data: IP address, browser type, and device information for security and service operation
• Virtual credits: transaction history for credits earned through surveys, tournaments, and administrative grants

3. Legal Basis for Processing

We process your personal data on the following legal bases under GDPR Article 6:

• Contract performance (Art. 6.1.b): Processing necessary to provide our gaming services, manage your account, and enable gameplay features
• Consent (Art. 6.1.a): For optional profile information such as gender and location
• Legitimate interest (Art. 6.1.f): For platform security, fraud prevention, content moderation, and service improvement
• Legal obligation (Art. 6.1.c): For age verification and compliance with applicable laws

4. Data Retention

We retain your personal data for as long as your account is active. Guest accounts are automatically deleted after 7 days of inactivity. Upon account deletion, your personal data is removed, with chat messages being soft-deleted to maintain conversation integrity. Game history may be retained in anonymized form for statistical purposes.

5. Your Rights

Under the GDPR, you have the following rights:

• Right of access (Art. 15): Request a copy of your personal data
• Right of rectification (Art. 16): Correct inaccurate personal data via your profile settings
• Right of erasure (Art. 17): Delete your account and all associated data
• Right to data portability (Art. 20): Export your data in a machine-readable format from your profile
• Right to restriction (Art. 18): Request restriction of processing in certain circumstances
• Right to object (Art. 21): Object to processing based on legitimate interests

To exercise these rights, visit your profile settings or contact us at privacy@ludocca.com.

6. Cookies

We only use strictly necessary cookies for authentication (session management via Supabase) and language preferences. We do not use tracking, marketing, or analytics cookies. These essential cookies are exempt from consent requirements under the ePrivacy Directive.

7. Children's Privacy

Our platform requires users to be at least 13 years of age. We implement age-based communication restrictions to protect minors: users under 18 can only communicate with others within a 2-year age range. We do not knowingly collect data from children under 13.

8. International Data Transfers

Your data is stored and processed within the European Economic Area (EEA). We use infrastructure providers based in the EU to ensure your data remains protected under European data protection standards.

9. Data Security

We implement appropriate technical and organizational measures to protect your data, including encrypted connections (HTTPS/TLS), row-level security in our database, rate limiting, CAPTCHA protection, and regular security reviews.

10. Contact & Complaints

For questions about this privacy policy or to exercise your rights, contact us at privacy@ludocca.com. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee.